The European Commission has officially adopted the Delegated Act establishing a clear definition and methodology for low‑carbon hydrogen, reinforcing the EU’s broader hydrogen strategy alongside frameworks like RED III and gas market rules .
70 % Greenhouse Gas Reduction Target
Under the new rules, low‑carbon hydrogen must reduce lifecycle greenhouse gas emissions by at least 70 % compared to conventional fossil fuels—equivalent to a maximum carbon intensity of 3.38 kg CO₂/kg H₂.
Production pathways include:
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Reforming natural gas with carbon capture (CCUS)
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Electrolysis powered by low‑carbon or nuclear electricity (nuclear inclusion conditional)
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Other non-renewable electrolysis methods meeting the emissions threshold
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Lifecycle Emissions & Methane Accounting
Emissions calculation spans:
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Direct production CO₂
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Upstream methane leaks
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Energy used for transport and compression
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Carbon capture efficiency
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The Commission has aligned upstream methane default values with scientific consensus, lowering defaults from 8.4 g CO₂/MJ to 4.9 g CO₂/MJ—with a commitment to refine these by 2028 regionally.
Nuclear Hydrogen Under Review
Hydrogen generated from nuclear-powered electricity is not yet recognized as low‑carbon. A public consultation will be held in 2026, with official consideration set for by mid-2028. This delay has agitated nuclear advocates in France, Poland, and Sweden, who argue it could disadvantage nuclear path projects
Stakeholder & Industry Response
Hydrogen Europe welcomed the final act, praising lowered methane defaults and recognition of carbon-storing by-products, while urging faster regulation.
Energy industry groups caution the act could slow down key hydrogen projects unless simplified.
Environmental NGOs warn that default values may still allow greenwashing without more stringent, project‑based assessments.
Strategic Implications & Next Steps
- Completes the EU hydrogen regulatory triad—renewable, low‑carbon, and gas/hydrogen market rules.
- Aligns with REPowerEU’s ambition targeting 10 Mt domestic and 10 Mt imported renewable hydrogen by 2030.
- Two-month scrutiny period, extendable by two months, for Council and Parliament before final entry into force.
Upcoming milestones:
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2026: Public consultation on nuclear pathway
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By July 2028: Review of nuclear inclusion and methane emissions methodology revisions
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