In the position adopted on 25 February, Europaforum Northern Sweden (EFNS) welcomes the ambition of the EU Renewable Energy Directive (RED II Directive) and the upcoming revision in RED III to increase Europe's hydrogen production, but objects that some of the write-ups may contribute to the opposite effect and slow down the green transition. 

The proposal does not take into account northern Sweden’s large production of renewable electricity 

The European Commission is now working on a delegated act that will specify provisions from the adopted Renewable Energy Directive RED II of 2018 on provisions for energy sources such as hydrogen to be classified as sustainable. Hydrogen is highlighted as an important component in a future energy system, but since hydrogen production requires large amounts of electricity, the principle of "additionality" is introduced, which advocates that sustainable hydrogen should only be produced with electricity recently added to the electricity networks. This part of the proposal does not take into account regions, such as those in northern Sweden, which already have a large production of renewable electricity used for large-scale projects that have significant climate benefits for Sweden's and Europe's aggregated climate impact. 

Current writings risk to work against northern Sweden's large industrial projects that use hydrogen from renewable energy sources in production as well as the region's transition to sustainable transport where existing production of renewable energy is a production factor in renewable hydrogen as a fuel. 

Sweden is one of the countries in Europe with the highest share of renewable energy 

EFNS underlines that regions that have already made major investments in renewable electricity generation should be able to use it for the production of renewable hydrogen and thus be exempted from the requirements defined in the delegated act.  

Northern Sweden's major industrial projects use hydrogen from renewable energy sources in their productions. In order for these to be able to contribute to the green transition with great climate benefits for the whole of the EU, it is necessary to make it clear that the regulations put forward in the delegated act will not affect industrial applications of hydrogen production, now or in the future. Industrial application of hydrogen technology entails great needs but also a significant climate benefit that must be taken into account and cannot fall under the same regulations as renewable energy for the transport sector.  

- The principle of additionality should, as a whole, make clear exceptions for regions and Member States with predominantly renewable energy and with an excess of renewable energy in the electricity networks. 

- The European Commission should make it clear that the discussion on additionality does not concern the production of hydrogen for industrial application 

- The delegated act should not hinder northern Sweden's ability to produce renewable hydrogen with existing overcapacity of green electricity to enable the development and use of hydrogen-powered aircraft, trains and heavy transport. 

Read EFNS’ position on the Energy Directive and hydrogen here.