Author: Kerstin Reisch

The GHG reduction target and the tradability of guarantees of origin for meeting this target have created a competitive market for renewable energy sources in the transport sector. The current legal framework sets out the progression of the GHG reduction target up to 2030. The price of the certificates fluctuates in line with supply and demand. The GHG reduction quota and its annual increase ensure stable or rising demand. Furthermore, the Act contains further provisions designed to ensure fair competition between different renewable energy sources, e.g. multiple counting of the use of certain energy sources towards quota fulfilment. In recent years, the price of guarantees of origin has plummeted to around €100 per tonne of GHG savings. A key reason for this lies, among other things, in the sudden supply of enormous quantities of certificates from biofuels with dubious certification originating from Asia.

The Act on the further development of the GHG reduction target, finally adopted by the Bundestag on April 22^nd and by the Bundesrat on May 8^th, addresses this challenge by the GHG reduction target which will be maintained until 2040 with further annual increases, by implementing EU requirements under the Renewable Energy Directive III, and by adjusting the details of the eligibility of different energy sources in line with their maturity and current developments.

The Act provides for a further increase in the GHG reduction target (left axis) as well as the introduction and annual increase of a minimum RFNBO sub-target, which is intended to incentivise and safeguard the roll-out of H2 in transport. This will create a stable and steadily rising demand for high-quality RFNBO hydrogen at H2 filling stations and refineries.

In addition, the legislator has introduced further measures to stabilise the prices of guarantees of origin and to improve the steering effect.

• Biofuels derived from palm oil, soya oil, residues from oil palm cultivation, biofuels with a high risk of indirect land-use change, and biofuels derived from animal oils and fats will no longer be recognised.
• Furthermore, a prerequisite for the recognition of an energy source – particularly biofuels – within the framework of the GHG reduction quota is the possibility of an on-site inspection in the country where the biofuel is produced, carried out by the competent authority of an EU Member State.
• As soon as it is identified that the GHG reduction target has been exceeded by a significant margin, the GHG reduction target for all subsequent years will be raised further.

With these measures, the legislator aims to effectively and efficiently prevent projects of dubious origin from driving down the market price for all stakeholders and thereby penalising reputable market participants.

The existing multiple counting of certain energy sources enables policymakers to provide special support for individual energy sources. In this way, policymakers steer competition between energy sources to a certain extent and make it easier for the industry to meet its quotas. If multiple counting decreases, this has the effect on the market of tightening the GHG reduction quota for all energy sources.

The multiple counting for e-mobility will decrease linearly from 2034. As a result, the e-mobility fleet existing in Germany in 2034 will generate only a third of the GHG certificates in 2036. Policymakers therefore anticipate a sharp rise in e-mobility during this period. The multiple counting for H2 and RFNBO will decrease later, i.e. from 2036 onwards. The later reduction in multiple counting for RFNBO, together with the mandatory minimum RFNBO sub-quota, will result in a stable competitive advantage for H2 in the mobility sector.

For aviation, the draft bill also sets out additional guidelines. This is intended to transpose the relevant EU legislation, ‘ReFuelEU Aviation’, into national law. The EU stipulates that synthetic aviation fuels must account for at least 2% of the total in Europe by 2025, at least 6% by 2030, at least 20% by 2035 and at least 34% by 2040. The draft bill stipulates a levy or penalty payment of €4,700 per tonne in the event of non-compliance. For synthetic aviation fuels based on RFNBO, a minimum sub-quota of 1.2% is set for 2030, 5% for 2035 and 10% for 2040. In the event of non-compliance, German distributors face a compensation payment of €17,000 per tonne. With these concrete measures, policymakers aim to ensure compliance with ReFuelEU Aviation.

The law now passed clearly demonstrates the current government’s commitment to sensibly developing the GHG quota system as a key instrument for the transformation of the transport sector. A wide range of measures will help ensure that the instrument effectively steers the market and triggers investment. We expect the price of GHG allowances or certificates to recover gradually between now and 2030 and stabilise at a significantly higher level than today.

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!