India has published its definition of green hydrogen, setting an emissions threshold of 2kg of CO2 equivalent (CO2e) per kilogramme. But the definition leaves questions open, including the exact scope of greenhouse gas (GHG) emissions that is considered.
The definition states that "green hydrogen" will refer to hydrogen "produced using renewable energy including, but not limited to, production through electrolysis or conversion of biomass". For hydrogen to count as "green", the average "non-biogenic greenhouse gas emissions" over the previous 12 months cannot exceed 2kg CO2e/kg of hydrogen.
A government press release states that the threshold is for "well-to-gate emissions". This would mean that scope 1, 2 and 3 emissions are taken into account.
But the definition itself makes no specific reference to this. For the electrolysis process, it states that emissions for "water treatment, electrolysis, gas purification and drying and compression of hydrogen" will be factored in. And for biomass, it refers to "emissions arising from biomass processing, heat/steam generation, conversion of biomass to hydrogen, gas purification and drying and compression of hydrogen".
This could be interpreted as excluding GHG emissions associated with the electricity — or biomass — used in the process, according to consultancy Umagine's chief executive Santosh Gurunath. It would then refer to scope 1 emissions only and make it incomparable with carbon intensity standards set by other countries, Gurunath said. Most crucially, it could allow for hydrogen to count as "green" even if overall GHG emissions in the process are higher than for conventional hydrogen made from natural gas with unabated emissions, he said.
Other industry participants have similarly called for more clarity on the definition, which will be crucial in determining which projects can get support under India's production-linked incentive scheme to stimulate hydrogen production.
New Delhi notes that "a detailed methodology for measurement, reporting, monitoring, onsite verification and certification of green hydrogen and its derivatives" will be specified by the ministry of new and renewable energy. But it has not outlined a timeframe for this.
Assuming well-to-gate emissions are considered, India's standard would be stricter than that of most other countries. In the US and South Korea, hydrogen will be considered "clean" if emissions stay below 4kg CO2e/kg of hydrogen. Meanwhile, thresholds of 3.38kg and 3.4kg CO2e/kg apply for "low-carbon" hydrogen in the EU and Japan, respectively. The EU's specific definition of renewable hydrogen includes provisions on additionality and temporal and geographical correlation, which are absent from India's green hydrogen definition.
