Bellona Europa welcomes the opportunity to provide feedback to the European Commission on their proposal for a draft delegated act specifying a methodology for assessing greenhouse gas emissions savings from low-carbon fuels. To achieve maximum decarbonisation potential in the long run, the EU should use the route of the production of Renewable Fuels of Non-Biological Origin (RFNBO), with the production of such fuels through additional renewable energy.

However, it is clear that in the upcoming decades, renewable electricity will remain a scarce resource needed to decarbonise the power sector and meet the growing demand driven by deep electrification. Given the limitations and the urgency imposed by climate breakdown, as well as the need to meet our climate neutrality targets by mid-century, it is crucial that no source of low-carbon hydrogen is neglected, making low-carbon hydrogen a necessary technology. The definition of this hydrogen must effectively contributes to the decarbonisation of targeted sectors and avoids becoming a greenwashing exercise for fossil fuels. 

We very much welcome the commitment to basing the emissions accounting methodology for low-carbon fuels on a complete life-cycle analysis, including, among other things, upstream methane emissions, actual carbon capture rates and indirect emissions. However, the devil of truly meeting the 70% threshold for emissions reductions compared to the fossil fuel comparator lies in the details.

Read our response below:

• Consultation Response (pdf)