1. Introduction

Hydrogen energy is emerging as a key pillar in the global transition towards renewable energy sources. With its versatile applications in energy storage, transportation, and industrial use, hydrogen has gained significant attention as a sustainable alternative to fossil fuels. Türkiye is positioning itself to become a player in the hydrogen economy, though regulatory and infrastructural developments are still required.

  1. What is Hydrogen and Where It Is Used?

Hydrogen is a clean and versatile energy carrier that plays a crucial role in the transition to sustainable energy systems. As the most abundant element in the universe, hydrogen can be produced from various sources and used in multiple sectors, including power generation, transportation, and industrial applications.

Hydrogen is primarily used in:

  • Energy Storage: Hydrogen can store excess renewable energy, providing a reliable backup power source when solar or wind energy is not available.
  • Transportation: Fuel cell vehicles (FCVs) use hydrogen to generate electricity, offering a zero-emission alternative to conventional internal combustion engines.
  • Industrial Applications: Hydrogen is extensively used in refining processes, ammonia production, and steel manufacturing, reducing carbon emissions in traditionally high-emission industries.
  1. Types of Hydrogen Production

Hydrogen production methods vary based on the energy sources used. The three primary classifications are:

  • Green Hydrogen: Produced through electrolysis using electricity generated solely from renewable sources, such as wind or solar power. Since no fossil fuels are involved, the process results in zero carbon emissions.
  • Gray Hydrogen: Derived from fossil fuels, particularly natural gas, using steam methane reforming (SMR). This method emits carbon dioxide (CO2) as a byproduct, contributing to greenhouse gas emissions.
  • Blue Hydrogen: Produced similarly to gray hydrogen but incorporates carbon capture and storage (CCS) technology to prevent CO2 emissions from being released into the atmosphere. This approach makes hydrogen production more environmentally sustainable.
  1. Türkiye’s Approach to Hydrogen Energy

The Turkish government has recognized the strategic importance of hydrogen and has initiated investments to accelerate the development of a hydrogen ecosystem. One of the most significant projects in this field is the “Güney Marmara Hydrogen Coast – HYSouthMarmara Project”, which will establish Türkiye’s first hydrogen valley in the Southern Marmara region. The project has secured a €7.5 million grant from the European Commission and is expected to be completed within five years. The hydrogen valley concept aims to integrate production, storage, transport, and utilization across the entire value chain, fostering a localized hydrogen economy.

Despite these advancements, Türkiye currently lacks a comprehensive legal framework regulating hydrogen production, distribution, and safety standards. To fully capitalize on hydrogen’s potential, the country must develop legislation addressing:

  • A methodology to account for regional emissions from hydrogen production.
  • Performance-based global technical regulations to ensure the safety of hydrogen energy systems.
  • Regulatory guidelines for hydrogen usage and storage infrastructure.
  • Standardization of hydrogen refueling infrastructure and fuel quality.
  1. Regulatory Landscape in the European Union

The European Union has taken a proactive approach by implementing a regulatory framework for hydrogen, particularly focusing on green hydrogen—hydrogen produced through electrolysis powered by renewable energy. The EU’s rules are primarily governed by Delegated Acts CDR 2023/1184 and CDR 2023/1185, which set out:

  • The criteria for hydrogen to be classified as renewable fuels of non-biological origin (RFNBOs).
  • The methodology for calculating greenhouse gas (GHG) emissions associated with hydrogen production.
  • Compliance requirements for hydrogen exported to the EU, making these regulations highly relevant for Turkish producers targeting the European market.

For hydrogen to be classified as RFNBO-compliant, it must meet specific conditions, including:

  • Direct connection to a renewable energy source (such as solar or wind) or use of grid-sourced electricity where renewables constitute over 90% of the supply.
  • A carbon footprint below approximately 3kg CO2e/kg H2 on a well-to-wheel basis.
  • Compliance with Additionality, Temporal Correlation, and Geographical Correlation criteria to ensure sustainability and traceability.
  1. Understanding the Additionality Principle

Delegated Act CDR 2023/1184 establishes the conditions under which electricity supplied from renewable energy sources (RES) qualifies hydrogen production as fully renewable. Compliance with these conditions allows hydrogen or its derivatives to be certified as RFNBO under the Renewable Energy Directive (RED II) (2018 Recast).

The Additionality principle ensures that hydrogen production does not divert existing renewable energy from other uses. To qualify as fully renewable, the electricity used for green hydrogen production must:

  • Originate from a newly developed RES facility (no older than 36 months at the start of the hydrogen plant’s operation).
  • Avoid taking power from the existing grid unless it meets strict requirements proving that the hydrogen production prevents curtailment of renewable power.
  • Ensure that grid-sourced electricity is at least 90% renewable within the designated electricity market bidding zone.
  • Meet a greenhouse gas emissions limit of approximately 3 kg CO2e per kg H2 on a well-to-wheel basis.

Moreover, the Additionality principle includes Temporal and Geographical Correlation criteria. From January 2030 onward, hydrogen production must occur within the same one-hour period as the production of electricity from the contracted renewable energy source. Additionally, hydrogen and renewable energy production facilities must be located within the same interconnected bidding zone.

  1. Comparisons with the United States’ Hydrogen Policies

The United States has also introduced significant incentives to support hydrogen production, particularly through the Inflation Reduction Act (IRA) of 2022. The IRA provides a production tax credit for low-carbon hydrogen, with the highest incentive of $3 per kilogram available for hydrogen that emits no more than 0.45 kg CO2e per kg H2. The U.S. approach is considered more flexible than the EU’s stringent regulatory framework, potentially making American hydrogen more cost-competitive for global export.

Furthermore, the Infrastructure Investment and Jobs Act of 2021, known as the “Bipartisan Infrastructure Law”, authorized a total of $8 billion in federal funding for hydrogen development. Accordingly, the U.S. government has established seven regional hydrogen hubs (H2Hubs), all but one of which will use renewable energy sources as at least one method of hydrogen production, to foster industrial-scale hydrogen production and usage, ensuring long-term commercial viability for hydrogen stakeholders.

  1. The Path Forward for Türkiye

To enhance its position in the hydrogen market, Türkiye needs to:

  1. Establish a Clear Regulatory Framework: Aligning with international standards, particularly EU regulations, will be crucial for Turkish hydrogen exports.
  2. Encourage Private Investment: Offering financial incentives and tax benefits can attract investment in hydrogen production facilities.
  3. Develop Hydrogen Infrastructure: Expanding hydrogen refueling and storage capabilities will be critical for integrating hydrogen into the transportation and industrial sectors.
  4. Promote International Collaboration: Engaging in partnerships with the EU and the U.S. could accelerate technological advancements and market integration.

Conclusion

Hydrogen has the potential to play a transformative role in Türkiye’s energy landscape. While initial steps have been taken through pilot projects and international collaborations, a well-defined regulatory framework is essential for Türkiye to emerge as a competitive player in the global hydrogen economy. By addressing the legislative gaps and aligning with international standards, Türkiye can position itself as a key hydrogen producer and exporter in the years to come.

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