E‑fuels for maritime and aviation sectors, heavy and intensive road transport, and electrolysis capacities: the IRICC mechanism must be corrected

Decarbonising refining operations, maritime and aviation transport through a French e‑fuels production industry, alongside heavy and intensive road mobility, the government’s project is insufficient. France Hydrogène offers its recommendations.

France Hydrogène responded to the government’s consultation in May on the proposed Mechanism to Incentivise Reduction of Carbon Intensity in Fuels (IRICC).

By imposing obligations on conventional fuel distributors to lower the carbon intensity of the fuels they market, this mechanism forms the cornerstone of transport decarbonisation in France up to 2035. It is essential to achieving the threefold objectives set out in the National Hydrogen Strategy (SNH), published in April:

  1. Decarbonise refining activities, maritime and aviation transport by establishing a French e‑fuels manufacturing industry, and support heavy or intensive road mobility (i.e., uses for which battery solutions will not meet professional operational constraints).
  2. Deploy 4.5 GW of electrolysis capacity in France by 2030 and 8 GW by 2035, noting that the transport sectors included in IRICC (refining, aviation, maritime, road) account for over 50% of the hydrogen needs tied to these production targets. The use of hydrogen in transport is thus indispensable to creating a scaled, competitive production value chain that will serve industries vital to our sovereignty (steel, fertilisers, basic chemicals).
  3. The deployment of renewable and low‑carbon hydrogen production and applications in transport should stimulate a comprehensive national industrial ecosystem – supported strategically by the State during the first phase of the National Hydrogen Strategy (2020–April 2025), including electrolyser manufacturers and a fully integrated hydrogen mobility value chain.

These objectives present major socio‑economic returns: by 2035, the sector could create over 66,000 jobs, reduce France’s goods trade deficit by nearly 8%, and cut the external energy bill by about €6 billion (according to a BDO study). These targets align with transport sector needs and are realistic given the projects currently under development in France. They are achievable provided that appropriate economic regulatory tools, such as IRICC, are implemented in line with EU law.

However, the government’s current IRICC proposal falls far short of the state’s own targets set in April. In its current form, IRICC essentially represents a covert abandonment of hydrogen-sector deployment in France. France Hydrogène has therefore put forward a set of recommendations to rectify this: see the detailed response and summary, as well as a specific analysis on the maritime transport sector and the development of a French e‑fuels production industry.