Feedback to the Commission IIA on ‘Hydrogen and Gas Markets Decarbonisation Package’

The progressive evolution of the gas legislative framework is a necessary prerequisite to ensure gas markets are ready to integrate and foster the use of renewable and low-carbon gases while maintaining a high-level of security of supply and guaranteeing an efficient price formation. Traded markets for hydrogen and other decarbonised gases, supported by dedicated certificates and/or Guarantees of Origin (GOs), will have a key role to play in the decarbonisation of the EU energy system, in line with the European Green Deal and the 2030 and 2050 targets. In addition, traditional natural gas markets will need to remain in place during the transition period and their well-functioning must not be undermined.

The future regulatory framework for decarbonised gases should build, to the extent possible, on the successful blueprint of the existing European wholesale gas market, which has established well integrated markets and liquid trading hubs. Although traded markets for renewable and low carbon methane and hydrogen are not yet mature, establishing clear principles in the regulatory framework (including non-discriminatory network access, clear unbundling rules and cross-border interoperability) will support the uptake of decarbonised gases and will help to provide the predictable framework needed for liquid and competitive gas markets.