Reaction from Environmental Defense Fund Europe on the European Commission’s Published Delegated Act on Low-Carbon Hydrogen 

The European Commission’s adoption, of the Delegated Act (DA) on low-carbon hydrogen on July 8 is intended to signal progress towards a cleaner, more secure energy system. However, from a climate credibility perspective, the final text falls significantly short in ways that risk undermining Europe’s leadership, and investor and public confidence. 

While the DA sets a threshold of 70% GHG emissions savings compared to the use of unabated fossil fuels, crucially the Act adopts significantly lower default methane values for fossil gas than earlier drafts proposed - values that are well below the best available scientific estimates, including those published by the International Energy Agency (IEA), decades of peer-reviewed research, and high-resolution satellite data. A growing body of scientific literature using aircraft and satellite measurements consistently shows that methane emission intensities in major oil and gas regions are much higher than these defaults. For example, studies in U.S. basins report emission intensities ranging from about 1% to 8%, highlighting that the Act’s lower values likely underestimate the true scale of emissions. 

This choice has real consequences. It risks certifying fossil gas-based hydrogen as “low-carbon” even when its true climate footprint is far higher. This gap between policy and science doesn’t just weaken Europe’s climate ambition, it invites scepticism about the seriousness of its commitments, by significantly increasing the risk that real-world emissions reductions do not meet expected savings. In practice, this means that policies may look effective on paper but fail to deliver actual reductions in greenhouse gas emissions, undermining both climate goals and public trust. 

Equally worrying is the removal of the 40% penalty for producers who fail to submit methane intensity reports. That penalty was a key safeguard, designed to make transparency non-negotiable and push companies towards real, measured data instead of relying on generous defaults. Its removal undermines the credibility of the entire certification framework at precisely the moment Europe needs to demonstrate that its climate policy is robust, evidence-based, and fair. 

The Commission has committed to introducing country- and region-specific default values in 2028. While that is a welcome and necessary step, it does not address the immediate risk that today’s weaker default and reduced reporting requirements will lock in poor practices and higher emissions for years to come. 

If the EU wants its hydrogen policy to drive real decarbonisation, it must align default methane values with the best available science and reinstate strong incentives for accurate, transparent reporting. These measures are essential to deliver genuine emissions reductions, maintain public trust, and create a stable, credible investment environment that can support the transition to net zero. 

As climate impacts and public scrutiny intensify, Europe cannot afford to undermine its climate integrity or weaken its global leadership – the stakes are too high. 

 

Helen Spence-Jackson, Executive Director, Environmental Defense Fund Europe: 
“The EU will likely green-light high-emissions hydrogen under a “low-carbon” label. This undercuts climate goals and risks public trust. We need an honest, science-based policy with firm accountability. The Commission must fix this to ensure Europe’s hydrogen market truly delivers for the climate and earns investor and public confidence.” 

Anna Lóránt, Senior Policy Manager, EU, Environmental Defense Fund Europe:

“The latest version of the Delegated Act for Low-carbon Hydrogen has missed the opportunity of including realistic default methane values, which could have helped prevent the certification of products that are far from low-carbon in the real world. In addition, we’ve also lost an important incentive for companies to comply with reporting requirements of the EU’s world-leading methane regulation. The Commission should be urgently aligning standards with the best available science and restoring strong incentives for accurate, transparent emissions reporting.”