The European Commission’s consultation on the delegated regulation on low carbon fuels sets the scene for the adoption of a detailed methodology on how to define low carbon hydrogen and low carbon fuels (LCFs): it elaborates on how to calculate the 70% reduction in GHG emissions for LCFs compared to fossil equivalents.
In our response to the consultation:
We call authorities to use this opportunity to offer clear and consistent rules, including by using concrete examples, to avoid the need for future guidance and give economic operators the clarity required to invest promptly in hydrogen and Carbon Capture and Utilisation (CCU) technologies, helping accelerate Europe’s transition away from fossil fuels.
We also believe that further delays and legal uncertainties should be avoided by including specific timelines for reality checks and impact assessments to evaluate whether CCU fuel deployment rules are meeting the deadlines established in EU legislations (e.g. REDIII, ReFuelEU Aviation, and FuelEU Maritime).
We invite the European Commission to clarify its plans to extend the GHG comparator for RFNBOs in transport to include industrial sectors, as this directly affects the methodology for LCFs, which relies on the RFNBOs’ GHG comparator.
We advocate for EU authorities to use consistent terminology throughout its different pieces of legislation and avoid reintroducing obstacles to the deployment of CCU fuels.
Read our response to the public consultation on the delegated regulation on low carbon fuels here.
