Author: Kerstin Reisch

Our parliamentary breakfast on November 25, 2025, sent a clear message: The era of hesitation is over. Industry is prepared; technologies are in place – yet decisive political action is still lacking. The signals from the sector could not be stronger:

• Alexander Voigt (Turn2x): Spain, France and Italy lead the way. Germany must stop standing on the sidelines.
• Jörg Selbach-Röntgen (Biogeen): Industrial demand for green molecules is soaring – a Green Gas Quota System will reduce risks and facilitate investments.
• Lena Burchartz (Thüga): Gas grid transformation is underway, but without clear financing it risks becoming a paper tiger.
• Markus Sammut (Trading Hub Europe): Legally secure quota implementation is feasible and can be based on existing IT systems.
• Christian Friebe (STOFF2): Planning security is needed to allow our industrial customers to invest now in a resilient future proof energy system.

Our joint position paper (download here) calls for an investment booster for green hydrogen and green molecules. Why? Because Germany remains 80% dependent on fossil energy imports – often from politically unstable regions. This vulnerability jeopardizes our economic stability and energy security. Green hydrogen and biomethane provide the solution: they strengthen resilience, create future-proof jobs, and secure our industrial foundation.

Our three key demands:

1. Adopt the GHG reduction quota and an ambitious RNFBO sub-quota without delay.
2. Designate H₂-ready backup power plants as anchor customers for the H₂ core network.
3. Launch the green gas quota in 2026.

Germany has the potential to deploy 10 GW of electrolysis capacity by 2030 and meet EU targets. Industry stands ready, infrastructure is expanding, technologies are proven. What’s missing? A stable domestic market that guarantees investment security and unlocks export opportunities.

The opportunities are clear and within reach. Any further delay will jeopardize Germany’s position as a leading industrial nation. It is time for bold, decisive action.

In a joint letter to Federal Minister Katherina Reiche, 14 leading NGOs, industry associations and companies are calling for a clear alignment of the power plant strategy with the development of green hydrogen. They view this as a significant opportunity to enhance Germany’s position as a hub for innovation and industry, while also achieving its climate goals.

The signatories emphasise that hydrogen power plants are an ideal complement to the electricity system. They enable flexible power generation during periods of low renewable output and contribute to energy security. At the same time, they create reliable demand for green hydrogen, an essential driver for investment and the development of a domestic hydrogen economy.

Germany already has strong production capacities for electrolysers and can further expand its technological leadership through targeted demand policies. An accelerated hydrogen ramp-up would also strengthen industry, prevent relocation, and economically secure the planned hydrogen core network.

The unconventional alliance of NGOs, industry associations and companies therefore call for binding decarbonization pathways for new gas-fired power plants. The power plant strategy could thus become the driving force behind a resilient, climate-neutral, and economically strong energy future.STOFF2 is one of the initiators of the paper.

Germany currently covers almost 80% of its primary energy consumption with fossil fuels. This high dependence on energy imports from politically unstable countries results in significant geopolitical risks for the economy. To maintain Germany as an industrial leader, this import dependency must be reduced and the resilience of the economy strengthened.

Germany is a technology leader in green hydrogen and electrolysis. By establishing an independent supply chain for green hydrogen, dependence on fossil resources can be reduced. The upcoming federal government should initiate specific measures to promote the industrial ramp-up of electrolyzer production. These include:

• Continuation and strengthening of existing instruments such as GHG quotas in transport,
• Introduction of a green gas quota, and
• Creation of lead markets for products that require hydrogen in their production.

Electrolyzers “Made in Germany” can effectively contribute to the transformation of the industry and optimize the use of renewable energies like wind and sun. In addition to STOFF2, McPhy, Sunfire, and thyssenkrupp nucera are highly committed to this effort. You can find our detailed position paper here (in German only).

The Federal Grid Regulator in Germany (BNetzA) is consulting on the hydrogen balancing mechanism for hydrogen grids “WasABi” for the second time until the end of February 2025. What sounds very dry at first glance has a major impact in practice on the ramp-up of the H2 economy and on the economic viability of future ZZE projects that feed hydrogen into the German H2 core grid. Following the current consultation, we expect a decision by the BNetzA that will provide orientation and planning security for all actors involved along the H2 value chain. 

In the electricity supply, there are already flexibility markets for different periods: primary and secondary control power as well as minute reserve. These markets are now very attractive, particularly due to the successful ramp-up of wind and solar energy, for example, battery storage systems that charge when electricity prices are low and provide electricity when electricity prices are high. The batteries – just like the Zinc-Zwischenschritt electrolysis (ZZE) in the future – thus make a significant contribution to the integration of renewable energies into an electricity system with a high level of supply security. 

The creation of a similar system is now planned for the future H2 core network, and that is exactly what WasABi is about. The aim is for all users of the H2 core network to be incentivized according to their abilities to support the overall system and maintain H2 supply security for all users of the infrastructure around the clock. 

Every 15 minutes, each balancing group records the amount of hydrogen fed in and fed out. Balancing is carried out continuously and does not have to be balanced every 15 minutes by the actors involved. The sum of all balancing groups is calculated for the entire H2 core grid. The network status is determined according to the current deviations and those expected in the coming hour as well as the pre-defined technical limits of the H2 core grid: 

• Green: No activities required. All H2 producers and H2 customers can use the network without restrictions, even if their balancing group is not balanced. 
• Yellow: Compensation measures are being taken to bring the entire network back into the green zone as quickly as possible. To do this, the balancing groups are first divided: on the one hand, balancing groups that support the network (“helpers”), and on the other hand, balancing groups that burden the network and have led to the jump into the yellow phase (“causers”). The “causers” must pay a compensation payment for the deviation in their balancing group, and the “helpers” are financially rewarded for their behaviour. 
• Red: Immediate initiation of compensatory measures up to and including shutdown of H2 customers by network operators. 

What does this mean specifically for STOFF2 customers? The ZZE produces green hydrogen and, thanks to its high flexibility, can simultaneously bid on the flexibility markets for electricity and gas. We assume that this will enable additional revenues that will significantly improve profitability for our customers. WasABi is now creating the legal framework for a flexibility market in the H2 core network, which our flexible Zinc-Zwischenschritt electrolysis can perfectly serve. This means that our ZZE plants can respond particularly well to the demand of H2 users. This means that our customers’ balance sheet is balanced and there is no threat of compensation payments. In addition, the ZZE plants can effectively support the entire network as “helpers” in the yellow and red phases and thus generate attractive additional revenues beyond the pure delivery of green hydrogen. 

Future called, said it’s great!

The use of hydrogen is not just a trend but a crucial tool in the implementation of national CO2 reduction targets and the fulfilment of European and international climate protection agreements. This recognition by politicians is a significant step. The revised national hydrogen strategy in the summer of 2023 and the agreement on the H2 core network laid the foundation for transforming the gas supply in collaboration with the gas industry. In addition, the law on municipal heat planning passed by the Bundestag at the end of 2023 and the gas network area transformation plans (GTP) initiated by the gas industry form the first essential basis for planning security for all players along the energy supply value chain.

At the same time, it is still unclear how H2 security of supply will be organised on a market basis in the emerging H2 network. The landscape of actors is diverse: On the one hand, there are H2 producers who provide green H2 from fluctuating wind and PV power, and in the future, H2 producers of blue hydrogen, for example, in Norway. On the other hand, there are H2 customers with relatively constant demand, such as industry and commerce, those with seasonally fluctuating demand, such as heat customers, and customers with high H2 demand precisely when the wind is not blowing and the sun is not shining, such as H2 backup power plants. In addition, depending on requirements and with different lead times, investments can be made in other storage technologies – from decentralised energy storage to H2 caverns.

For the future H2 market design, we propose a non-discriminatory market environment that allows all technically available solutions to make their best possible contribution to H2 supply security. This approach, called the 3-stage model, ensures fairness and effectiveness in the upcoming H2 market.

With this first approach, we invite all interested stakeholders and interest groups to develop our idea further or to bring alternative ideas into the specialist discussion that is now beginning. How can we best use the flexibility potential of H2 suppliers, H2 storage facilities and H2 customers? What can we learn from the rules of the electricity and natural gas market? How do we deal with the initially low liquidity in the future H2 flexibility market? All this needs to be clarified together; we look forward to the debate.