Assessment of Emission Rights of Green PtX Products

The import and domestic use of green hydrogen and Power-to-X products (PtX) in Germany and the European Union (EU) encounters a complex regulatory landscape in flux. At the EU level, the most relevant policy instruments are the EU Emissions Trading System (EU ETS), the Renewable Energy Directive (RED), and the newly introduced Carbon Border Adjustment Mechanism (CBAM). Both, the EU ETS and the CBAM directly target industry. RED primarily targets EU Member States but defines fundamental requirements regarding the “green” character of PtX that can also be transposed to industry players. In the German context, the national ETS (nETS) provides a regulative framework for PtX use in transport and the heating/building sector as well as smaller businesses not covered by the EU ETS. This study analyses the implications of this complex ruleset on the competitiveness of green hydrogen/PtX; differentiating between hydrogen use and production both for imported and domestically produced hydrogen to the extent possible. It also highlights upcoming changes to the policy framework and discusses their impact.