France Hydrogène stands for adopting a relevant average carbon content for the French electricity mix in the DA assessing greenhouse gas emissions of RFNBOs.

The French hydrogen industry is in the starting blocks to scale up. For now, a majority of electrolysis projects in the pipe is based upon an operation profile with a very high load factor (>7000h/p.a), thanks to the ability to use the decarbonized electricity of the national grid. Using the “electricity mix method” defined at the Article 4(1) of the DA from Article 27(3) of RED II should allow fuel producers to deliver 40% of RFNBOs and 60% of low carbon hydrogen, in France, by 2030.


However, the average carbon content value considered by the European Commission for France (70,56gCO2/kWh) in its last DA28(5) proposal (December 2022) will make ineligible French projects for using the “electricity mix method” method, while not justified by any physical reality. It would severely hinder the rollout of the French hydrogen industry.

Therefore, regarding the DA from Article 28(5) of RED II, France Hydrogène stands for adopting a relevant average carbon content for the French electricity mix. It can be done:

  • Either by making an exception for France, given its specificity with overseas territories, and considering only the annual average carbon content of the Metropolitan Area. Then the average carbon content for French electricity would be 51,93gCO2eq/kWh (2020).
  • Or by taking the bidding zone as a reference, and not the country, or by leaving at the discretion of Member States the possibility to refer to the country or to the bidding zone. The annual carbon content of the French bidding zone is 54,25gCO2eq/kWh (2020).

Furthermore, the French hydrogen industry calls the european Commission to add an alternative method for assessing the average carbon content of the electricity mix. The possibility should be left to use, when available, the data of TSO/DSOs on the average hourly carbon content of the electricity mix, what would pave the way for a consistent subsequent method to asses greenhouse gases emissions of low carbon hydrogen.