France Hydrogène’s Position Paper on RED3 Industrial Targets
In 2023, the adopted revision of the Renewable Energy Directive (RED3) has set important milestones to ensure visibility for investors and structure demand for non-fossil hydrogen in the industry.
- article 22a sets a target for the use of renewable hydrogen of non-biological origin (RFNBO) in
industry of 42.5% by 2030 and 60% by 2035. - for Member States achieving between 77 and 80% non-fossil hydrogen consumption (low-carbon
electrolytic; biogenic) in industry by 2030 and 2035 respectively, the target for the use of RFNBO
may be reduced to 33.6% and 48% (Article 22b).
The framework set out in Articles 22a and b of RED3 is a decisive and unique tool globally to accelerate the decarbonisation of basic industries in the EU, which is essential for achieving our national and European climate objectives.
Now, finalising the structuring of a market for non-fossil hydrogen in industry requires transposing these two articles, through a set of concrete proposals giving the right price signal to carbon in the markets of basic industries.
France Hydrogène proposes the following measures declined in two pillars:
- to implement the obligations at the right level while anticipating the particularities
inherent in certain basic industrial sectors- reflect objectives at the company and capital group level in order to offer flexibility in the
strategy of the companies; - create sector-specific mechanisms to mitigate the risk of circumvention of targets by imports of fossil energy products;
- apply the same objectives for all sectors (except steel – adapted target) and develop a sectoral tool for exchanging certificates for exceeding non-fossil hydrogen consumption targets;
- adopt national and European financing measures to initiate the scale-up of low-carbon basic industries;
- reflect objectives at the company and capital group level in order to offer flexibility in the
- to create downstream outlets for carbon-free industrial products in order to avoid any phenomenon of carbon leakage and loss of competitiveness of companies
- define a list of finished or semi-finished products to which the maximum carbon content will apply, in connection with the identification of the economic actors in the value chain capable of bearing the cost of this measure
- apply the mechanism at the level of products put on sale on the European market (including those imported from third countries) and direct penalties to the EU’s own funds (e.g. Hydrogen Bank);
- determine a multi-year trajectory for reducing the maximum carbon content, consistent with the availability of decarbonisation solutions: the objective is not for distributors to pay the tax, but to encourage upstream investment in decarbonisation projects;
- create a system for the sectoral exchange (excluding refineries) of certificate allowing the actors concerned to financially value the achievement of preestablished targets.
- define a list of finished or semi-finished products to which the maximum carbon content will apply, in connection with the identification of the economic actors in the value chain capable of bearing the cost of this measure
Find the position paper below: