Art 19.2 extends GOs to a uniform system for renewable hydrogen. In a similar vein to provisions in RED II, the flexibility not to issue GOs if financial support is provided to the producer is extended to hydrogen GOs.

“Art 19.2 To that end, Member States shall ensure that a guarantee of origin is issued in response to a request from a producer of energy from renewable sources 

including gaseous renewable fuels of non-biological origin such as hydrogen, unless Member States decide, for the purposes of accounting for the market value of the guarantee of origin, not to issue such a guarantee of origin to a producer that receives financial support from a support scheme

Art 19.2 allows national issuing bodies to issue sub-MWh GOs, facilitating 24/7 matching. This is especially relevant for the production of renewable hydrogen, as per the RFNBO Delegated Act that mandates timestamping at hourly granularity from 2030 onwards. Note, that 

“A guarantee of origin shall be of the standard size of 1 MWh. 

Where appropriate, such standard size may be divided to a fraction size, provided that the fraction is a multiple of 1 Wh.”

Art 19.4 now requires Member States to publish annual residual mix data. Up until now Member States that are AIB members already reported their residual mixes, however with the new paragraph inserted into RED, non-AIB countries such as Poland, will also have to report their residual mix. This shall improve data accuracy because currently the AIB relies on data from Eurostat, inter alia, to infer the non-AIB countries’ residual mixes. The AIB is expected to publish the residual mix for 2022 at the end of May/June.

“For the purposes of disclosure referred to in paragraphs 8 and 13, Member States shall ensure that energy companies cancel guarantees of origin at the latest six months after the end of the validity of the guarantee of origin. Furthermore, by ... [transposition deadline of this amending Directive], 

Member States shall ensure that the data on their residual mix is published on an annual basis

Art 19.7 pushes for but not obliges a GO to specify time stamping of GO production as accurately as possible, thereby facilitating 24/7 matching, necessary for renewable hydrogen production.

“A guarantee of origin shall specify at least:

the energy source from which the energy was produced and the start and end dates of production, which may be specified:

in case of renewable gas, including gaseous renewable fuels of non-biological origin, and renewable heating and cooling, at an hourly or subhourly interval;

for renewable electricity, in accordance with the imbalance settlement period as defined in Article 2, point (15) of Regulation (EU) 2019/943”.

As for the impact on GO prices, 24/7 tracking of electricity production and consumption could potentially cause seasonal and time price variations of EACs which currently are priced the same regardless of the time of day. For instance, the price of a renewable EAC would be potentially higher when generated at an hour where renewable energy production is low and vice versa when production is high.

Art 19.8 retains the right for Member State not to issue GOs to producers benefitting from support schemes and provides for an exception under which an electricity supplier does not have to use GOs to demonstrate the origin of energy if a Member State does not issue GOs to producers benefitting from support schemes as in RED II but relates it directly to gas suppliers.

“Where gases are supplied from a hydrogen or natural gas network, including gaseous renewable fuels of non-biological origin or biomethane, the supplier is required to demonstrate to final consumers the share or quantity of energy from renewable sources in its energy mix for the purposes of Annex I, section 5 of [proposal for a Directive on common rules for the internal markets in renewable and natural gases and in hydrogen COM(2021)0803]. The supplier shall do so by using guarantees of origin except:

(a) as regards the share of its energy mix corresponding to non-tracked commercial offers, if any, for which the supplier may use the residual mix.

(b) where a Member State decides not to issue guarantees of origin to a producer that receives financial support from a support scheme.”

Deadline set for the EU Green Label for Renewable Energy

Art 19.13 gives a deadline to the European Commission to establish an EU green label for renewable energy that further entrenches the additionality principle that promotes new renewable plants and names GOs as the default tool used to comply with the requirements of any EU label. It also signals the greater importance of GOs for the Commission since now the lawmaker will need to regularly monitor the market on an institutional level.

«By 31 December 2025 the Commission shall adopt a report assessing options to establish a Union-wide green label with a view to promoting the use of renewable energy coming from new installations. Suppliers shall use the information contained in guarantees of origin to demonstrate compliance with the requirements of such a label.

The Commission shall monitor the functioning of the guarantees of origin system and assess by 30 June 2025 the balance of supply-demand of guarantees of origin in the market and in the case of imbalances identify relevant factors affecting supply and demand”.

The interinstitutional negotiations concluded on 30 March 2023 with post-trialogue changes to the text of the RED following on 5 May 2023. A couple of last-minute changes are still to be expected, especially concerning biomass energy. A consolidated text is expected in the coming days ahead of a vote at the end of May in the Energy Committee in the Council (ITRE). The plenary vote in the European Parliament is scheduled for September. We therefore can expect the formal adoption and entry into force of the directive towards October.

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The Renewable Energy Directive positions hydrogen GOs and more granular GOs necessary to produce renewable hydrogen, bringing the legislative framework in line with the RFNBO Delegated Act, that mandates hourly timestamping for renewable hydrogen from 2030 onwards. The text also obliges Member States to publish their residual mix data, a move, that will primarily affect non-AIB members. 

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Leaked Renewable Energy Directive positions GOs for hydrogen production

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