Position paper Hydrogen and Certification 

As a Hydrogen Industry Cluster, we (the “Waterstof Industrie Cluster”) unite 140 companies, based mainly in Belgium but also partly based in the Netherlands, which are already actively investing in hydrogen technology or are investigating how they can develop activities in this sector in the future.
It is widely recognised that hydrogen and hydrogen-derived energy carriers will play an important role in the energy transition, both as feedstock and as an energy vector. European legislation, which is currently being developed, is also increasingly providing the necessary impulses for this.
However, adequate and pragmatic renewable and low-carbon hydrogen certification must be
provided to develop a liquid market and utilisation of these gasses. Currently, the lack of a clear and well-organized hydrogen certification framework is hindering the development of the hydrogen market in Belgium -as in most other EU countries-, despite a growing demand and more interest from producers. The certification process is a complex matter to understand and follow, for both producers and suppliers. Thus, to foster the integration of renewable hydrogen in Belgium, it is crucial to set up a well-working certification framework, understandable for all participants and stakeholders. Building a solid framework right now will also help to foster the development of the hydrogen market.
In this position paper we will first explain the difference between Guarantees of Origin (GOs) and RFNBO certificates and some basic concepts like the difference between mass balance and book and claim systems (the two main operation systems used in certification). We will then give an overview of the existing European legislative framework, indicating what types of applications require certification. After this, we drop to the level of Belgium as a very complex member state, due to the different levels of competence for GOs and RFNBO certificates. Here, we will identify the roles that are needed in the certification process of renewable hydrogen, indicating what roles are still missing for Belgium and how and by whom these roles could be filled in. Once we have zoomed in on Belgium, it is time to look what best practices there are to learn from The Netherlands, since they are already relatively advanced in developing a certification system for renewable hydrogen. Lastly; this paper will try to, in an objective and neutral way, describe the different certification scenarios Belgium could take with all its
benefits and downsides. It is then up to the policy makers to decide what pathway to choose. We end our paper with some recommendations to help our governments to make a well-informed choice.
WaterstofNet, as coordinator of the Benelux Hydrogen Industry Cluster (WIC), calls on Belgium and all its legislative levels to urgently adopt a clear and uniform framework for the certification of green gas and in particular the certification of renewable and low carbon hydrogen.

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Hydrogen and Additionality
Position paper in relation to delegated act RED II Art. 27.3

WaterstofNet, as coordinator of the Benelux Hydrogen Industry Cluster (WIC), calls on the Commission to suspend all requirements laid out in this Delegated Act until an Impact Assessment has been made. To avoid slowing down the roll-out of pioneering electrolysers, we urge the Commission to exclude installations built before 2030 from the requirements for their entire lifetime, or, at least, to extend the grandfathering clause to the contents of the transitional clause (monthly temporal correlation) and to projects built before 2030 instead of 2027. A review of the Delegated Act by 2030 could then re-evaluate the need for and impact of the delegated act based on experiences from the first projects. Additionally, a general exception for small installations (e.g. up to 25 MW) for compliance with all rules should be considered, because the administrative burden would be disproportionately large for smaller projects, especially compared to the relatively small impact on the energy mix and its emissions.

In the paper, it is explained why the Delegated Act in its current form forms a significant burden to the roll-out of hydrogen production facilities in Belgium in particular. In addition, we are already formulating concrete recommendations to adjust various points in the case of an adapted proposal for the Delegated Act (after impact assessment) in order to achieve a workable implementation of additionality, taking into account the specific preconditions for renewable energy production in Belgium.

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