European Commission adopts criteria defining low-carbon hydrogen

The European Commission has tabled a delegated Regulation^[1] and its annex^[2], introducing the exact criteria and methodology to define low-carbon hydrogen and fuels, including for maritime applications. This is a technical legislative act that further specifies certain provisions of  Directive (EU) 2024/1788^[3] on common rules for the internal markets for renewable gas, natural gas and hydrogen.

In an explanatory press release^[4], the European Commission recalls that low-carbon fuels “will support efforts to decarbonise sectors where electrification is currently not a viable option, such as aviation, shipping and certain industrial processes.” The Commission press release also refers back to the overarching rule, set by the above-mentioned Directive on renewable gas, natural gas and hydrogen from which the delegated Regulation derives: “To be considered low carbon, hydrogen and related fuels will need to reach a threshold of 70% greenhouse gas emission savings compared to the use of unabated fossil fuels. This means that low-carbon hydrogen can be produced in various ways, for instance using natural gas with carbon capture, utilisation and storage (CCUS) – a technology that prevents emissions from the process of producing hydrogen-, as well as from low-carbon electricity sources”, the European Commission writes.

The purpose of the delegated Regulation and the annex is to define how exactly a fuel can meet the low-carbon criteria. The delegated Regulation does this among others by setting different default values, depending whether hydrogen is produced from natural pipeline gas, LNG or other fossil fuels.

The delegated Regulation complements a delegated Regulation^[5] on renewable hydrogen and is thus considered to be an important addition to the EU’s rulebook on hydrogen, a fuel expected to contribute to the decarbonisation of hard-to abate sectors, in particular  shipping and aviation.  This regulatory development is not directly linked to the EU’s work at IMO level, but there is still a connection, since a comprehensive regulatory environment for the production of renewable and low-carbon hydrogen and its derivatives are also expected to contribute to the decarbonisation of international shipping.           

The delegated Regulation will formally enter into force at the latest on 10 November 2025, provided there is no veto by the European Parliament or the Council of the EU (EU Member States). However, such a veto is a very unlikely scenario.

It can be understood as being another important piece in the EU’s regulatory framework governing low-carbon hydrogen and fuels.

[1] https://energy.ec.europa.eu/document/download/3d3d0214-75f4-4e79-805e-3240526e2082_en?filename=C_2025_4674_1_EN_ACT_part1_v8.pdf

[2] https://energy.ec.europa.eu/document/download/7d6e84e5-a188-4573-b0f6-2d069fd04e85_en?filename=C_2025_4674_1_EN_annexe_acte_autonome_part1_v7.pdf

[3] https://eur-lex.europa.eu/eli/dir/2024/1788/oj/eng

[4] https://ec.europa.eu/commission/presscorner/detail/en/ip_25_1743

[5] https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2023.157.01.0011.01.ENG&toc=OJ%3AL%3A2023%3A157%3ATOC