Position papers
The German National Hydrogen Council has prepared and published the following position papers*:
2024
- RED III (Industry target)
- midstream
- Import Strategy
- Power Plant Strategy
- Taxation of hydrogen in mobility
2023
- Responsible approach to PFAS
- Hydrogen network planning
- Updated hydrogen strategy
- Hydrogen in transport
- Effects of the ban on PFAS
2022
- Inflation Reduction Act
- Certification Criteria
- Hydrogen Storage Roadmap
- Update on hydrogen strategy
- Russia’s war of aggression against Ukraine
- EU Gas Market Decarbonisation package
2021
- Fit for 55 II
- Fit for 55 I
- Sustainability criteria
- EU aid schemes for hydrogen
- Hydrogen Action Plan Germany 2021–2025
- Aviation
- Study on the heat market
2020
* Note: The NWR is an independent panel of experts. NWR publications do not necessarily reflect the opinion of the German government.
IMPLEMENTATION OF RED III INTO NATIONAL LAW: NWR IDENTIFIES BASIC REQUIREMENTS FOR MEETING THE INDUSTRY TARGET
The statement of the National Hydrogen Council (NWR) dated 1 March 2024, addresses the implementation of the Renewable Energy Directive (RED III) into national law, describes the associated challenges for the industry, and provides specific recommendations for action. The revised EU directive RED III introduces targets for the industry for the use of renewable fuels of non-biological origin (RFNBO), which includes green hydrogen and its derivatives. The RFNBO share of industrial hydrogen consumption is expected to reach 42 percent by 2030 and 60 percent by 2035. To facilitate the achievement of the intended RFNBO target, the NWR presents specific recommendations for the implementation of RED III into national law.
The statement is available for download here.
HYDROGEN SUPPLY: NWR PRESENTS RECOMMENDATIONS FOR THE EMERGENCE OF A FUNCTIONING HYDROGEN MARKET
The National Hydrogen Council (NWR) has released a new statement outlining approaches to accelerate the ramp-up of hydrogen and its derivatives. The foundation of the hydrogen economy is a self-sustaining market. Such a market requires specific key players to connect supply and demand commercially. The NWR identifies these key players as so-called midstreamers. Companies operating in the "midstream" undertake important functions such as maturity transformation, coordination, and product structuring. Until now, there has been little attention given to this crucial market role.
The complete statement "Hydrogen supply – maturity transformation, coordination and product structuring as essential elements of an ambitious and efficient hydrogen ramp-up" is available for download here.
NWR COMMENTS ON THE DEVELOPMENT OF A HYDROGEN IMPORT STRATEGY BY THE FEDERAL GOVERNMENT
The National Hydrogen Council (NWR) has published a new statement on 19 January 2024, addressing the development of the hydrogen import strategy and commenting on key areas of the strategy. Although hydrogen can be produced domestically, Germany will need to import large quantities of hydrogen and hydrogen derivatives in the future. Therefore, the NWR welcomes the development of an import strategy for hydrogen and hydrogen derivatives, emphasizing the importance of the import strategy for communication both domestically and internationally.
The statement is available for download here.
POWER PLANT STRATEGY OF THE FEDERAL GOVERNMENT: NWR SEES SIGNIFICANT ROLE OF HYDROGEN IN THE CLIMATE-NEUTRAL ELECTRICITY SYSTEM OF THE FUTURE
The planned power plant strategy of the federal government sets important framework conditions for a climate-neutral electricity supply in Germany. The National Hydrogen Council (NWR) sees a significant role of hydrogen in the climate-neutral electricity system of the future. The statement of the NWR, adopted on 19 January 2024, highlights the challenges that the power plant strategy should address.
The statement is available for download here.
NWR RECOMMENDS UNIFORM TAXATION OF HYDROGEN IN THE MOBILITY SECTOR
The statement of the National Hydrogen Council (NWR) dated 19 January 2024, recommends the uniform taxation of hydrogen for mobility applications. The differing taxation of hydrogen for vehicles with fuel cells and vehicles with hydrogen internal combustion engines should be discontinued.
The statement is available for download here.
A RESPONSIBLE AND DIFFERENTIATED APPROACH TO PFAS
The National Hydrogen Council (NWR) supports in principle the regulation of per- and polyfluoroalkyl substances (PFAS) as well as the efforts of a responsible approach to protect humans and the environment. Due to their unique physicochemical properties, PFAS are currently indispensable for many key technologies of the energy transition and thus essential for the emergence and ramp-up of a hydrogen economy. In its statement adopted on 15 September 2023, the NWR calls for a differentiated risk assessment and a classification of the relevant hydrogen and energy transition technologies as "essential use". It shows how a responsible and differentiated approach to PFASs can look.
The statement is available for download here.
NWR RECOMMENDS KEY POINTS FOR THE PROCEDURAL DEVELOPMENT OF HYDROGEN NETWORK PLANNING
The National Hydrogen Council (NWR) published a statement with key points for the further procedural development of hydrogen network planning. With the new regulations for a hydrogen core network (“Wasserstoff-Kernnetz”), the German government has taken the first important step towards creating an initial hydrogen network infrastructure. The next step is to regulate the transition to comprehensive and integrated network development planning for hydrogen and methane. The NWR has set out in its statement what is needed for this.
The "key points for the procedural further development of hydrogen network planning" are available for download here.
NWR welcomes updated national hydrogen strategy
The statement comments on the update of the National Hydrogen Strategy (Nationale Wasserstoffstrategie - NWS), which was adopted by the Cabinet on 26 July 2023. The NWR particularly welcomes the 2030 target (“Zielbild 2030”) formulated in the update of the NWS, which will ensure an accelerated market ramp-up for hydrogen and its derivatives. In its statement, the NWR identifies the strengths of the NWS update, but also points out where it sees a need for legislative action.
The NWR paper "Statement on Germany’s updated National Hydrogen Strategy" is available for download here.
NWR COMMENTS ON THE SUPPLY OF GREEN HYDROGEN AND ITS DERIVATIVES TO THE TRANSPORT SECTOR
The National Hydrogen Council (NWR) released a statement on February 1st, 2023, which deals with the supply of green hydrogen and its derivatives to the transport sector.
The statement is based on questions submitted to the NWR by the German Federal Ministry for Digital and Transport (BMDV). The questions of the BMDV relate to supply of the transport sector with green hydrogen and its derivatives, political measures to support hydrogen supply, the role of hydrogen derivatives and economic opportunities for Germany.
The NWR statement provides information on the application of hydrogen and hydrogen derivatives in shipping and aviation, as well as for rail and road. Depending on the mode of transport, different requirements for hydrogen and hydrogen derivatives arise. Commercial vehicles (and especially trucks that need to travel long distances) are expected to create high demand for hydrogen in the transportation sector.
The transport sector can serve as an initial sales market for the entire German hydrogen economy and decisively support the ramp-up of hydrogen production and use. The use of hydrogen in the transport sector will play an important role in the long term, alongside battery-electric drives.
The NWR paper "Supplying the transport sector with green hydrogen and its derivatives" is available for download here.
Effects of the ban on perfluorinated and polyfluorinated chemicals (PFAS)
Per- and polyfluoroalkyl substances comprise a class of thousands of synthetic industrial chemicals. PFASs exhibit unique chemical-physical properties. These make them indispensable both for use as key components for electrolyzers and fuel cells and in the field of lithium batteries. Here, the highest demands are placed on chemical and thermal resistance, which up to now can only be met with the help of PFAS.
Under the REACH restriction process, the EU Commission can restrict or ban the use of substances in various ways. For PFAS materials, there are currently no alternatives in use for the above mentioned areas, which is why it is requested that exemptions under the Montreal Protocol be created at this point until alternatives are available. In addition, research in the area of alternative materials must be intensified in order to be able to offer substitutes for PFAS.
The complete NWR statement "Effects of the ban on perfluorinated and polyfluorinated chemicals (PFAS)" is available for download here.
Inflation Reduction Act
In its statement, the National Hydrogen Council (NWR) dealt with the Inflation Reduction Act (IRA) in the USA and submitted corresponding recommendations to the federal government. In the statement, the NWR outlines the expected effects of the IRA on the ramp-up of renewable energies and the ramp-up of hydrogen in the USA against the background of the current economic situation. In a second step, the NWR classifies the instrument of the IRA and its mode of action and describes the effects on Germany and Europe. The complete statement of the NWR "Assessment on the Inflation Reduction Act" is available for download here.
CERTIFICATION CRITERIA
The National Hydrogen Council (NWR) published a new statement, which identifies concrete action requirements for the certification of green or low CO2 hydrogen.
A rapid ramp-up of the hydrogen economy is a key building block for successfully shaping the energy transition and meeting the climate targets under the Paris Agreement, respectively climate neutrality in Germany by 2045. For this, however, a European and internationally compatible legal framework must be created that regulates the certification of green and low CO2 hydrogen and its derivatives. The development of the necessary certification rules is highly time-critical, even though efforts at the international level will still take some time.
The complete NWR statement "The role and necessary design of the certification criteria to ensure a fast and effective ramp-up of the hydrogen economy" is available for download here.
Hydrogen Storage Roadmap
The National Hydrogen Council presents a coherent action plan for the transition from fossil natural gas storage to the hydrogen economy. Hydrogen can be stored in large quantities. Large-volume storage solutions are indispensable, especially with increasing hydrogen imports. Germany has the best starting conditions with a large capacity of existing cavern storage facilities that can be converted to hydrogen. The storage facilities are connected to the nationwide consumption centers via a supra-regional hydrogen network infrastructure. The roadmap underscores the need for political support measures now to stimulate investment in hydrogen storage. A hydrogen storage requirement of at least 5 TWh can already be expected by 2030, which will then increase significantly. With a view to the approval process and conversion period of at least five years, the time window for important investment decisions is already closing in the middle of this decade. Therefore, investment incentives and funding measures for the storage conversion must be initiated now.
The NWR position paper "Hydrogen Storage Roadmap 2030 for Germany" is available for download here.
Update on hydrogen strategy – German National Hydrogen Council drafts key issues paper
The Council has prepared five packages of measures for an ambitious ramp-up of the hydrogen economy – hydrogen seen as key to climate neutrality and security of supply by panel of experts
The German government presented their National Hydrogen Strategy in June 2020. We have witnessed a number of changes in the intervening years, which include the adoption of stricter climate targets, Russia’s war of aggression against Ukraine and rising energy prices. The German National Hydrogen Council has drafted a new key issues paper in order to adapt the National Hydrogen Strategy to come in line with the changed environment. The five packages of measures are intended to expedite the ramp-up of the hydrogen economy.
‘Key issues paper on revisions to the National Hydrogen Strategy’ can be downloaded by clicking the link below:
Key issues paper on revisions to the National Hydrogen Strategy (PDF, 141 KB)
NWR’s position on the impact of Russia’s war of aggression on Ukraine on the hydrogen ramp-up
The German National Hydrogen Council lays out its position at its meeting on 1 April 2022 in Duisburg on the possible impact of Russia’s war of aggression against Ukraine on the hydrogen economy.
The ‘NWR statement on Russia’s war of aggression against Ukraine – Possible impact on hydrogen ramp-up’ can be downloaded by clicking the link below:
Russia’s war of aggression against Ukraine – Possible impact on hydrogen ramp-up’ (PDF, 84 KB)
EU GAS MARKET DECARBONISATION PACKAGE NOT ENOUGH TO SUPPORT HYDROGEN RAMP-UP
The German National Hydrogen Council (NWR) laid out its position on the EU’s Hydrogen and Decarbonised Gas package at its meeting on 4 February 2022. The package was published as the second part of the ‘Fit for 55’ package in December. The aim is to align the European legal framework for the gas market to the goals of the Green Deal and lay the foundations for the hydrogen market. The NWR has determined, however, that the package will only partially meet the conditions necessary for the rapid development of a Europe-wide hydrogen grid, for cross-border hydrogen trading and transmission and in order to ensure modest fees and provide investment security.
The position paper on the European Commission’s Hydrogen and Decarbonised Gas package from 15 December 2021 can be downloaded by clicking the link below:
NWR WEIGHS IN ON FIT FOR 55 (II)
At its meeting on 15 December, the German National Hydrogen Council (NWR) once more took up the issue of the EU’s Fit for 55 package. In the follow-up session, the NWR laid out its opinion on the European Commission’s proposals to introduce a carbon border adjustment mechanism and on amendments to the EU’s Emissions Trading Directive and Germany’s Renewable Energies Directive.
NRW’s position paper ‘Proposal by the EU Commission regarding the introduction a carbon border adjustment mechanism (CBAM)’ can be downloaded by clicking the link below:
Fit for 55 package: CBAM (PDF, 119 KB)
The position paper ‘Proposal of the EU Commission to amend the European Union’s emissions trading system (EU ETS)’ is available for download by clicking the link below:
Fit for 55 package: EU ETS (PDF, 140 KB)
The position paper ‘Proposal of the EU Commission to amend the EU Renewable Energies Directive (RED)’ is available for download by clicking the link below:
NWR WEIGHS IN ON FIT FOR 55 (I): WE CAN – AND SHOULD – BE MORE AMBITIOUS
At its meeting on 29 October 2021, the National Hydrogen Council (NWR) once again took up the EU’s Fit for 55 package. The package contains proposals put forward by the European Commission for amendments or changes to directives and regulations in and around climate protection policy in order to implement the European Green Deal. The NWR has given its initial views on the EU’s hydrogen-related plans for an infrastructure for alternative fuels (Alternative Fuels Infrastructure Regulation (AFIR)) and the use of alternative fuels in aviation and maritime applications (ReFuel Aviation and FuelEU Maritime).
The position paper ‘EU Commission’s proposal on the deployment of alternative fuels infrastructure (Alternative Fuel Infrastructure Regulation, or AFIR)’ is available for download at the link below:
Fit for 55 package: AFIR (PDF, 128 KB)
The position paper ‘Proposal by the EU Commission on the regulation to guarantee equal competitive conditions for sustainable air transportation (Fit For 55 dossier/ReFuelEU aviation)’ is available for download at the link below:
Fit for 55 package: Aviation (PDF, 121 KB)
NWR’s position paper ‘Proposal by the EU Commission on the regulation on the use of renewable and low-carbon fuels in marine transportation and on a modification to Directive 2009/16/EC (Fit for 55 dossier/FuelEU maritime)’ can be downloaded by clicking the link below:
NWR appeals for sustainability in HYDROGEN imports
At its meeting on 29 October 2021, the German National Hydrogen Council (NWR) adopted sustainability criteria for projects to import renewable hydrogen and power-to-X products. NWR Chair Katherina Reiche stated that the rapid development of the global hydrogen economy is essential for meeting the climate goals.
NWR’s position paper ‘Sustainability criteria for projects to import renewable hydrogen and PtX products’ can be downloaded by clicking the link below:
Plea for sustainability in hydrogen imports (PDF, 207 KB)
NWR believes there is room for improvement with regard to EU aid schemes for hydrogen
A massive ramp-up of hydrogen technology is necessary in order to implement the European Green Deal and achieve the climate targets. To make the investments necessary to reach these two goals, the EU’s legal framework on state aid urgently needs to be amended. In its position paper adopted on 7 October, the German National Hydrogen Council (NWR) welcomes the EU Commission’s approach to revise and adapt the guidelines on state aid for energy as well as climate and environmental protection. However, the panel sees a need for improvement in several key areas.
The position paper ‘Revision of the Climate, Energy and Environmental Aid Guidelines (Draft CEEAG)’ can be downloaded by clicking the link below:
Room for improvement in EU aid schemes for hydrogen (PDF, 121 KB)
Hydrogen Action Plan Germany 2021–2025
To achieve the climate policy goals, Germany must take swift and ambitious steps to ramp up the hydrogen economy. The Hydrogen Action Plan Germany 2021–2025 contains 80 proposals by the German National Hydrogen Council for the next government of Germany. The 26 experts on the panel advising the German government submitted the action plan to the Head of the Federal Chancellery, Dr Helge Braun, today.
The ‘Hydrogen Action Plan Germany 2021-2025’ can be downloaded by clicking the link below:
Position paper ‘Hydrogen in aviation in Germany’
The German National Hydrogen Council published its position paper entitled ‘Hydrogen in aviation in Germany’ on 20 April 2021. In the position paper, the German National Hydrogen Council outlines concepts for climate-neutral aviation. In addition to revised aircraft and propulsion concepts, sustainable energy sources, such as synthetic fuels and hydrogen, modified flight routes and shifts in traffic also play an important role. The vision for the future of aviation is the zero-emission aircraft – an aircraft that emits no pollutants during both flight and ground operations.
The German National Hydrogen Council therefore recommends that a long-term, politically secured Europe-wide plan for the decarbonisation of air transport be developed. This should assess the potential of hydrogen while at the same time taking into account the complexity of aviation, its international interdependencies, the economic implications and the exceptionally high safety requirements.
For more information on the position of the National Hydrogen Council, please refer to the position paper ‘Hydrogen in aviation in Germany’.
Recommendation: Study on the heat market
The German National Hydrogen Council published a recommendation for a study on the heat market on 20 April 2021. To make progress in the required ‘decarbonisation of the heating sector’, the German National Hydrogen Council has recommended the commissioning of a study. The aim is to put the council in a position where it is able to make recommendations to the German government in spring 2022 on the specific basis of data and experience. These recommendations are designed to serve as a roadmap and demonstrate options for a decarbonised heating market in 2050. The German National Hydrogen Council calls on policymakers to refrain from any fundamental decisions for or against a heat market with green gases or hydrogen until such time.
For more information on the recommendation of the German National Hydrogen Council, please refer to 'Empfehlung einer Studie zum Wärmemarkt' - only available in German.
Statement on the NWS measure 20 (infrastructure)
The German National Hydrogen Council published a position paper on the implementation of NWS measure 20 (infrastructure) on 10 November 2020. The development of a competitive European market for hydrogen is closely linked to the building of a hydrogen infrastructure. The German National Hydrogen Council calls on the German government to create the necessary conditions for this to happen:
- The existing gas infrastructure is the cornerstone for the development of a hydrogen grid in Germany – quickly, at low cost and in an environmentally friendly way.
- The legal and regulatory conditions necessary for the transport of hydrogen in the existing gas infrastructure must be created during this legislative term.
- The hydrogen grid should be available to all customers on a non-discriminatory and technology-neutral basis.
- There must be a reliable way to fund measures to upgrade the grid.
- Hydrogen should be on an equal footing with natural gas in the process of developing the grid development plan to ensure efficient and transparent planning.
For more information on the position of the German National Hydrogen Council, please see ‘Fünf Handlungsempfehlungen zum Aufbau einer Wasserstoffinfrastruktur‘ - only available in German.
Fünf Handlungsempfehlungen zum Aufbau einer Wasserstoffinfrastruktur (PDF, 134 KB)
Position paper on the transposition of RED II into national law
The German National Hydrogen Council published a position paper on the implementation of RED II into national law on 6 November 2020. The Council gives its view on the draft bills of the Federal Ministry for the Environment and Consumer Protection (BMU), which implement the requirements of Article 25–28 of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources (Renewable Energy Directive, or RED II). Under these requirements, Member States are mandated to increase the share of renewable energy in transport and sustainable, advanced fuel options. The draft bill for the amendments to the Federal Emissions Control Act (BImSchG) and the Federal Emissions Control Ordinance (BImSchV) sets an important course for enhanced climate protection in transport. However, it falls short of the options made available by current technological progress, especially in the production and use of hydrogen. They also fail to implement the ambitious targets laid down in the National Hydrogen Strategy. The German National Hydrogen Council recommends a more ambition quota for greenhouse gas reductions (GHG quota), coupled with double counting of the energy content of renewable fuels of non-biological origin, electricity in road vehicles as well as advanced biofuels. This would ensure technology neutrality, put battery and hydrogen-powered vehicles on an equal footing and support the market ramp-up of fuel cell vehicles.
The NWR’s position paper ‘Transposition of RED II into national law (amending BImSchG/BImSchV)’ can be downloaded by clicking the link below:
Position paper on the further development of the German Renewable Energy Sources Act (EEG)
The German National Hydrogen Council published a position paper on the necessary further development of the German Renewable Energy Sources Act on 22 October 2020. The current system of taxes, levies and surcharges, which impose heavy fees on electricity, impedes its use in many electricity-based energy transition technologies at the moment. This also includes in particular the production of hydrogen at electrolysis plants. To promote a rapid market ramp-up, the use of electricity in water electrolysis plants should be exempted to the fullest extent possible from the EEG surcharge.
For more information on the position of the German National Hydrogen Council, please see ‘EEG weiterentwickeln: Stromeinsatz bei Elektrolyse von EEG-Umlage befreien (EEG)‘ - only available in German.
EEG weiterentwickeln: Stromeinsatz bei Elektrolyse von EEG-Umlage befreien (EEG) (PDF, 130 KB)
Position paper on the German EU Presidency
The German National Hydrogen Council published a position paper on the German EU Presidency on 6 November 2020. During Germany’s EU Council Presidency, the German National Hydrogen Council calls on the German government to pursue the following goals with equal intensity, in particular in relation to the European Green Deal. The NWR regards the period up to 2030 as the most critical phase in the development of the hydrogen economy:
- Goal: Pan-European strategy – The German and European hydrogen strategies represent a commitment to the central role of hydrogen in the successful implementation of the global climate change policy. With regards to hydrogen, Germany should strive to bring together as many Member States as possible and make use of the broad consensus that exists to ensure the consistent implementation at the European level during its EU Presidency.
- Goal: European internal market and uniform classification – Establishing a clearly defined framework is essential to ensuring timely private investment in hydrogen technologies, with the creation of a European internal market given top priority. Furthermore, classification as well as the technical rules and standards should be clearly defined and harmonised at a European level.
- Goal: Infrastructure development – It is necessary to start making the necessary changes to the required infrastructure early on in order to create large-scale hydrogen applications.
- Goal: Set in motion ramp-up in demand – It is necessary to create corresponding demand in order to achieve economies of scale over the short and medium term.
- Goal: Energy partnerships – To date, the European hydrogen strategy has taken a more cautious approach to international partnerships than the German hydrogen strategy has. Establishing international projects and energy partnerships should be actively promoted by the German government during its EU Council Presidency.
- Goal: Financing instruments – It is essential to develop financing instruments to ensure the successful implementation of the targets set out in the European hydrogen strategy.
- Goal: Funding of research on key technologies – Funding for research and development on technologies for hydrogen production and use should be further promoted in order to create a competitive hydrogen economy with marketable products in Europe.
For more information, please refer to ‘Sieben Ziele für die deutsche EU-Ratspräsidentschaft‘ - only available in German:
Sieben Ziele für die deutsche EU-Ratspräsidentschaft (PDF, 153 KB)
