Position paper on the 37th BlmschV – An important step forward, open questions remain

Federal politicians are currently working on revising the 37th Federal Immission Control Act (BlmschGV). This amendment is expected to be passed in March 2024. This project sets several important steps for ramping up the hydrogen supply in Germany. But what exactly is it about?

A central point is the precise definition of green hydrogen. The 37th BlmschV implements the long-awaited EU Delegated Act from RED II national law and thereby describes how to implement the basic principles of “renewable energy”, “temporal correlation”, “geographical correlation” and “additionality” for our customers. Due to the integrated storage function of our ZZE technology, our electrolyser is particularly suitable for meeting these criteria today and in the future.

Another central point is recognising how green hydrogen can be counted towards meeting the transport sector’s greenhouse gas reduction quota. The transport sector must reduce its emissions yearly through a greenhouse gas reduction quota. With the reform of the 37th BlmschV, green hydrogen will be counted three times towards quota fulfilment, giving market development a big boost.The life cycle emissions must also be calculated to use green hydrogen in the transport sector. There is already another EU Delegated Act for this from RED II. These life cycle emissions include, for example, the transport of green hydrogen to the H2 filling station, which for safety reasons can only be done with diesel trucks, or the electricity consumption of the H2 filling station, e.g., in the compressors. We believe there is still a need for federal policymakers to take action. These details can significantly facilitate or hinder the ramp-up of the use of green H2 in mobility. More information can be found here (German only).