Green Hydrogen - Standards, Certifications, and Labels

International Journal of Hydrogen Energy 59 (2024) 654–667
Contents lists available at ScienceDirect
International Journal of Hydrogen Energy

journal homepage: www.elsevier.com/locate/he
Renewable hydrogen standards, certifications, and labels: A state-of-the-art

review from a sustainability systems governance perspective
Fred Gale a, Daniel Goodwin a, Heather Lovell b, Hannah Murphy-Gregory b, *, Kim Beasy c,
Marion Schoen b
a
School of Social Sciences, College of Arts, Law and Education, University of Tasmania, Locked Bag 1340, Launceston, TAS, 7250, Australia
b
School of Social Sciences, College of Arts, Law and Education, University of Tasmania, Private Bag 22, Hobart, TAS, 7001, Australia
c
Faculty of Education, College of Arts, Law and Education, University of Tasmania, Locked Bag 1307, Launceston, TAS, 7250, Australia
A R T I C L E I N F O A B S T R A C T
Keywords: A range of existing and newly developed hydrogen standards, certification and labelling (SCL) schemes aim to
Hydrogen promote the role of ‘renewable’, ‘clean’ or ‘green’ hydrogen in decarbonising energy transitions. This paper
Governance analyses a sample of these SCLs to assess their role in the scaling up of renewable hydrogen and its derivatives. To
Certification
analyse these hydrogen SCLs, we embellish a novel conceptual framework that brings together Sustainability,
Standards
Systems Thinking, and Governance (SSG) literatures. The results reveal noteworthy scheme differences in
Sustainability
Renewable energy motivation, approach, criteria, and governance; highlighting the complex, interconnected, and dynamic reality
within which energy systems are embedded. We consider whether the sustainable utilisation of renewable
hydrogen is well-served by the proliferation of SCLs and recommend an SSG-informed approach. An SSG
approach will better promote collaboration towards an authoritative, global, multistakeholder, compromise on
hydrogen certification that balances economic considerations with social, and environmental dimensions.
1. Introduction elements or from the thermal treatment of biomass. For example, carbon
emissions associated with electrolysis from renewable electricity sup
The 2015 Paris Climate Agreement has generated halting momentum plies are far lower than those generated via SMR and CG without CCS,
within states, markets, and civil society to decarbonise the current glo estimated at zero or slightly above using onshore wind or solar [4].
balised, fossil-fuel powered political economy [1]. While solar, wind and Currently, however, very little hydrogen is produced via electrolysis.
wave power are expected to play important roles in achieving the Governments are construing the global policy task as rapidly scaling up
1.5–2.0◦ Celsius Paris targets, hard-to-decarbonise sectors such as hydrogen production from electrolysis using combinations of renewable
long-haul transport, heavy industry, energy storage, shipping, and energy, low carbon electricity, or fossil fuels with CCS [5].
aviation will require different solutions [2]. As the most ubiquitous In pursuit of decarbonisation, national hydrogen strategies are being
element in the universe, hydrogen generated from renewable sources developed and budgets passed to fund hydrogen development [6]. States
will likely have a role to play in decarbonising such sectors due to unique are positioning themselves as potential producers or consumers of
features that include a capacity to store and deliver concentrated, hydrogen energy based on geographic region, resource endowment, and
continuous power with (close to) zero carbon dioxide and other green technological capacity. Some, like Australia and Chile, have excellent
house gas emissions [3]. solar and wind resources and anticipate exporting ‘renewable’ hydrogen
However, hydrogen production today is carbon intensive and at scale to countries that do not, like Germany and Japan. The nascent
dominated by two production pathways: steam methane reforming renewable hydrogen economy is even leading to speculation over a new
(SMR) and coal gasification (CG). Hydrogen can also be produced using geopolitical-economics of energy where hydrogen ‘superpowers’ like
methods with lower lifecycle emissions, particularly from electrolysis to Australia displace petrostates like Saudi Arabia [5]. Manufactured in
split water molecules into their component hydrogen and oxygen renewable energy hubs, the vision sees hydrogen transported around the
* Corresponding author.
E-mail addresses: Fred.Gale@utas.edu.au (F. Gale), Daniel.Goodwin@utas.edu.au (D. Goodwin), Heather.Lovell@utas.edu.au (H. Lovell), Hannah.Murphy@utas.
edu.au (H. Murphy-Gregory), Kim.Beasy@utas.edu.au (K. Beasy), Marion.Schoen@utas.edu.au (M. Schoen).
https://doi.org/10.1016/j.ijhydene.2024.02.038
Received 14 November 2023; Received in revised form 30 January 2024; Accepted 3 February 2024
Available online 10 February 2024
0360-3199/© 2024 The Authors. Published by Elsevier Ltd on behalf of Hydrogen Energy Publications LLC. This is an open access article under the CC BY license
(http://creativecommons.org/licenses/by/4.0/).
F. Gale et al. International Journal of Hydrogen Energy 59 (2024) 654–667
world via networks of pipelines or converted into derivates such as unsustainable, fossil-fuel energy CHANS to one based on renewable
liquid organic hydrogen carriers (LOHC) for transportation by tankers energy to remain within Earth’s ‘Safe Operating Space’ [13]. Embedding
and trucks. A substantial trade in hydrogen gas and its derivatives (such the renewable hydrogen energy transition within an SSG perspective
as ammonia, methanol, LOHCs like methylcyclohexane, and aviation widens the lens to include greenhouse gas (GHG) emissions and
fuels) is also envisioned [7]. non-GHG emissions-related effects. While the former are covered in
Increasing hydrogen production from electrolysis and other sources detail in the literature, the latter are not. Yet these include critical
and trade across borders raises many complex technical, economic, so environmental (e.g. water use, water and soil pollution, biodiversity
cial, political, and environmental issues [8]. To address these, govern loss, and deforestation), social (e.g. land grabbing, loss of amenity, vi
ments, corporations, and civil society are developing (in some cases sual pollution, and Indigenous and First Nations rights), and economic
upgrading) standards, certification, and labelling schemes (collectively (e.g. supply chain, cross-sectoral, geographic, and incumbency) effects.
hereafter ‘SCLs’) to support decarbonisation goals and the hydrogen In this paper we describe and compare the large number of SCLs being
trade. In this article we analyse SCLs from a sustainability systems proposed to help manage the scaling up of renewable hydrogen and its
governance perspective, thereby adding to the relatively neglected derivatives, evaluating a subset of schemes from an SSG standpoint to
scholarship on green hydrogen governance. We interpret the concept of reveal significant differences in motivation, approach, criteria, and
‘standards’ broadly and consider how these are implemented via regu governance. We seek to make sense of, and analyse, what has become a
lation and certification and labelling schemes to verify and demonstrate confusing array of competing hydrogen SCLs.
compliance. Fig. 1 provides a summary of our conceptualisation of the To undertake this descriptive-evaluative analysis, the review is
relationship between standards, certification, and labels located within structured as follows. In the next section, we set out our SSG framework,
the broader governance landscape. This includes the multi-layered in followed by an account of the methodologies adopted. In section three,
puts and drivers shaping the development of standards and the actors we present the results, comparing and contrasting hydrogen SCLs with
implicated in SCL governance. each other and against our SSG perspective. In the final discussion-
In this paper, we approach the analysis of SCLs through a Sustain conclusion section, we consider whether the nascent hydrogen in
ability, Systems Thinking, and Governance (SSG) perspective. This dustry is well-served by the proliferation of SCLs observed or whether a
approach builds on the idea that energy is a fundamental basic human global, chamber-based, stewardship council, roundtable, deliberative,
need [11], the provision of which can be conceptualised from a coupled multistakeholder process—now well established in the broader sus
human and natural systems’ standpoint (CHANS) [12]. The hydrogen tainability SCL field—is a better approach.
challenge is best understood as one of shifting humanity from a global,
Fig. 1. General model of SCL schemes showing inputs into standard setting and management, routine governance of certification and participation of actors. Note: a
standard may not necessarily lead to a certification scheme or a certification scheme to a label. Authors own work with reference to Refs. [9,10].
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2. Sustainability systems governance of Rome report, The Limits to Growth. Employing computer simulations
of population growth, resource use, and emissions, the report projected
Our SSG conceptual framework brings together three literatures: world society would crash in the early 21st century from a combination
Sustainability, Systems Thinking, and Governance. We briefly review of over-demand, under-supply, and pollution [29]. Despite the demon
the academic literature on each topic below, covering their theoretical strated power of hard-systems models, practitioners later identified
origins as well as their application to renewable hydrogen. deficiencies in applications to more complex business and social settings
[16]. A new ‘soft systems’ approach developed that applied systems
2.1. Sustainability thinking in contexts where both means and ends were contested.
Checkland’s Soft Systems Methodology (SSM) [30] has been widely
Analysts of ‘sustainability’ and ‘sustainable development’ note the applied in government and industry, empowering managers to delib
term is employed in both generic and substantive senses [14,15]. erate over the systemic nature of a problem to identify viable solutions.
Generically, ‘lower-case’ sustainability means ‘on-going’, ‘enduring’, or An early application of SSM in the Sustainability field was Clayton and
‘continuing’. This ‘adjectival’ approach sees the word appended sepa Radcliffe’s 1996 book Sustainability: A Systems Approach [31], which
rately to economic, social, and environmental phenomena with little undertook a systematic comparison of coal, nuclear, and tidal energy
cross-referencing or integration. Such an approach is compatible with projects.
‘weak sustainability’, a widely used term that refers to a willingness to Hard and soft systems thinking approaches were criticised in turn for
trade off natural capital against human-made capital such as occurs an underlying managerialism and elitism. Critical Systems Thinking
when ‘low economic value’ rainforest is clearfelled to make way for (CST) emerged to render systems’ analysis and practice more democratic
‘high economic value’ palm oil plantations. Advocates of ‘strong sus by paying closer attention to how system boundaries were set [32]. In
tainability’ object to these kinds of trade-offs. As Thiele notes: “Sus hard and soft systems thinking, system boundaries were set by govern
tainability is not the effort to maximize a singular good. It requires us to ment officials or corporate executives with pre-defined interests such as
combine, integrate, and balance ecological health, economic welfare, enhancing national security or productivity. CST highlighted how such
social empowerment, and cultural creativity” [15], p. 9]. an approach could oppress minorities and workers [28], visiting harm
Thiele’s alternative, ‘strong’ sustainability concept can be traced on the vulnerable and powerless. From a CST perspective, setting system
back to the 1987 World Commission on Environment and Development boundaries and determining system function are critical elements of
(WCED, also the Brundtland Commission). The report, Our Common practice that may lack legitimacy when undertaken by managerial elites.
Future, set out its widely cited definition of Sustainable Development as Consequently, CST calls for more participatory, representative and
development that “meets the needs of the present without compromising deliberative governance processes that bring the full array of actors into
the ability of future generations to meet their own needs” [16]. The common dialogue [32,33].
WCED emphasised three aspects of Sustainability: the basic human Systems thinking bears on renewable hydrogen’s sustainability in
needs (BHNs) humans have for water, food, shelter, clothing, security, several ways. Firstly, relating to how renewable hydrogen integrates
energy and so forth; the requirement to meet the basic needs of all into the wider energy system and, in particular, whether additionality of
people (both today’s and future generations); and the importance of renewable energy is considered or how the wider sustainability impacts
governance arrangements that integrate its economic, social, and envi of biomass or nuclear energy are substantiated [22]. Secondly, systems
ronmental dimensions. Upper-case Sustainability means securing the concepts are inherent in GHG accounting methodologies where
provision of BHNs today and into the future, achieved by governance hydrogen SCLs take different approaches to defining which emissions
arrangements that fully and meaningfully integrate its economic, social, are or are not included [34]. More than defining the systems boundaries,
and environmental dimensions; and this is the definition we adopt research points to the need for methods that effectively track hydrogen
throughout this review. from production, through to its trade and use to minimise environmental
Scholars in the field of hydrogen’s role in energy transitions note a impacts [35] and mitigate social risks being displaced onto vulnerable
need to develop sustainability strategies incorporating economic, envi populations [8]. Thirdly, lifecycle analysis highlights how the prolific
ronmental, and social evaluations [17]. To date, however, many con use of green hydrogen may itself be problematic due to wider system
ceptualisations of sustainability assessment for hydrogen has limited the impacts tied to embedded energy, land use, and rare materials, indi
scope of criteria. For example [18,19], restricted the environmental and cating, from a systems perspective, the need to consider demand-side
social impacts to those associated with CO2 (global warming potential energy solutions [36].
and the social cost of carbon, and SO2 emissions (acidification poten
tial). However, emerging research points to the criticality of diverse 2.3. Governance
sustainability concerns. For example, social risks in the hydrogen supply
chain related to child labour, fair wages, workplace rights, and gender Sustainability issues have been an especial focus of the governance
discrimination [20] as well as the need to include environmental im literature. In the immediate post-war period, the broad view was that
pacts such as the burden electrolysis could have on water resources [21]. the act of governing—that is governance—was undertaken exclusively
Recently, authors have broadened the conceptualisation of renewably by governments employing legislation, policy and regulation backed by
hydrogen sustainability to include multiple criteria for evaluating eco the force of law [37]. By the 1980s this straightforward idea was
nomic, environmental, and social, as well as governance, and technical reconsidered in fields such as sociology, public policy, and international
dimensions [8,22–24]. Similarly, which elements should constitute a relations as scholars began to investigate ‘governance without govern
sustainability assessment has been investigated in relation to bioenergy ment’ [38]. Broadly defined as “steering and coordinating the affairs of
systems [25,26] and bio-based products [27] where research has un interdependent social actors based on institutionalised rule systems”
covered differences in opinion among stakeholder groups, highlighting [39], governance has been conceptualised as occurring in several ways
the challenges associated with defining sustainability. by a diversity of entities acting alone or in cooperation [40].
An important feature of the governance literature is its multi-actor
2.2. Systems thinking perspective. Corporations and civil society actors are recognised as
performing governance roles alongside governments. In the standards
Systems thinking emerged during the 1939-45 World War via the field, corporations govern when they formulate and deploy standards
efforts of scientist-soldiers to develop cybernetic systems to track and within global production networks that oblige subsidiaries and pro
destroy moving targets, notably ships and airplanes [28]. A celebrate ducers to conform to designated quality, management, and performance
application of hard systems thinking to Sustainability was the 1972 Club requirements [41]. Civil society actors do similarly when they develop
656
standards and labels like FAIRTRADE [42]. Finally, experts also govern as we were interested in the ‘new’ hydrogen SCLs that aim to promote
through standards, when these have far-reaching effects on other actors’ the role of ‘renewable’, ‘clean’ or ‘green’ hydrogen in decarbonising
behaviour constituting forms of ‘governmentality’ [43]. Such ‘private’ energy transitions. In our search we did include broader technical
governance arrangements by business and civil society raise important standards aiming to establish methodologies for GHG emissions ac
democratic issues regarding the degree to which those affected by them counting as well as regulatory and voluntary standards that set out rules
participate in their development. In many cases, actors become ‘rule for hydrogen to be classed as ‘green’, ‘renewable’ or ‘low carbon’.
takers’ with no, or only very limited, involvement in standard-setting Because the academic literature on hydrogen SCLs was sparse we also
processes that impose costs on them. Thus, the normative literature on reviewed a selection of comparative studies of SCL schemes undertaken
governance highlights several democratic deficits, leading analysts of by international organisations like the International Renewable Energy
‘good governance’ to propose broader-based participatory, deliberative, Agency (IRENA), national agencies like GIZ (Deutsche Gesellschaft für
multistakeholder, and chamber-based arrangements [44]. Within the Internationale Zusammenarbeit), not-for-profit agencies like Konrad
renewable hydrogen literature, research has identified that governance Adenauer Stiftung, and public financial institutions like the Inter-
criteria and indicators relating to sustainability should consider partic American Development Bank (IDB). Table 1 summarises the studies
ipatory processes for civil society [22], the facilitation of innovation in consulted. An important feature of these studies is that a majority have
system design and operation [19], procedural justice focusing on the input from German organisations.
participation of relevant stakeholders [8], and regulatory [45], political The comparative studies informed the scope of SCLs to include in this
and policy implications [46]. review and led to snowball sampling of official documents, websites and
media reports setting out the structure, operation, and content of
2.4. Towards a conceptual framework to examine SCLs hydrogen SCLs. We note that our aim was not to compile a definitive and
exhaustive list of hydrogen SCLs but, rather, to represent (among other
A diversity of conceptual frameworks is used to analyse SCLs [47]. things) a diversity of schemes covering various geographic regions,
We recognise that there is a significant scholarship in Sociology on SCLs types of proponents, and regulatory contexts. In most cases, scheme
(e.g. Busch, 2011 [43]) which we do not engage with in this paper, documentation was available in English enabling direct access by our
focusing instead on political science and interdisciplinary sustainability Anglophone team. Where schemes existed in another language, we used
concepts. Within political science the majority of scholars employ Google Translate to understand the basic content and supplemented this
rational and sociological institutionalism within a neo-positivist with secondary sources including corporate reports, consulting com
conception of social reality, although a subset of scholars utilise alter mentaries, and media releases. Our review, including compilation of
native, constructivist epistemologies based on governmentality [48] and supporting documents, took place up until August 2023 and therefore
neo-Marxist approaches [49,50]. Whether mainstream or critical, the this analysis will not capture more recent developments or revised edi
SCL literature has mostly eschewed systems theory, preferring to focus tions of SCL documentation. The degree of detail about a scheme varied
reductively on slices of the complex, interconnected, and emergent widely: for example, Australia’s Smart Energy Council’s Zero Carbon
socio-natural totality. For instance, in the energy field in the controversy Certification Scheme contains very little governance or standards in
over biofuels, a narrow techno-economic focus on feedstock production formation requiring reliance on a range of media releases. In contrast,
and manufacturing was able to demonstrate a theoretical contribution to CertifHy™ provides detailed documents about how it sets, governs, and
climate change mitigation. However, when production of biofuels was operationalises its standards. Once we had compiled a list of SCLs we
situated within the larger ‘telecoupled’ trade and investment CHANS undertook the following:
context [51], significant social and environmental ‘externalities’ in the
form of labour exploitation and biodiversity loss were identified. • We documented scheme status (whether under development or
As summarised by Ref. [51] in a Science article outlining the CHANS available), main proponent/s, terminology used to describe (or label)
approach: “Progressing toward global sustainability requires a systems hydrogen such as ‘green hydrogen’, geographic coverage, and
approach to integrate various socioeconomic and environmental com whether participation is voluntary or mandatory;
ponents that interact across organizational levels, space, and time”. • We examined the preambles, overviews, and context statements to
While a CHANS perspective helps in capturing these wider contexts, it determine a scheme’s organisational form (classified according to its
does not overcome its own tendency towards technocratic conceptions basic legal status as a government department, business corporation,
of governance linked to uncritical acceptance of modernist institu or non-profit foundation). Organisational form was assessed by
tions—notably, states, markets, and experts. By bringing the CHANS reviewing websites (especially ‘about’ and ‘governance’ pages). The
approach into dialogue with the larger literature on governance and SCLs’ stated purpose was then assessed by reviewing the documen
Sustainability, our conceptual framework enables the field of hydrogen tation to identify relevant themes. For example, a theme of ‘market
SCLs to be analysed from a perspective that is more outside-in than facilitation’ was referenced as ‘accelerate commerciality of low-
inside-out. That is, it not only enables the integration of socioeconomic emissions products’ in the A-GO scheme, as ‘facilitate cross-border
and natural phenomena across different levels, space, and time, but it trade’ in the UK-LCHCS, and as ‘advance and facilitate the produc
also opens up space to critique how this integration is being accom tion, procurement and use’ of hydrogen in the CertifHy scheme;
plished. This is achieved by not accepting that governance is only • Next, to better understand the structure and operation of hydrogen
legitimately performed by states and that Sustainability is nothing more SCLs, we selected a subset of schemes to examine their technical,
than what actors make of it. In summary, and building on the emergent systems, governance, and s/Sustainability features. The subset was
literature relating to renewable hydrogen’s sustainability (e.g. Refs. [8, selected to achieve a diversity of scheme type and geographic region
22,36]), our SSG conceptual approach brings economic, environmental with an emphasis on available schemes in key exporting and
and social dimensions of Sustainability together with system thinking importing jurisdictions. Firstly, we documented and compared in
and governance perspectives. formation on their technical features including system boundaries,
eligible production pathways, emission thresholds, criteria for
3. Methodology additionality, and chain of custody models. Next, we documented
their governance features drawing on available literature and web
To undertake the analysis of hydrogen SCLs, we initially reviewed site information, focusing on how they engage in democratic delib
academic articles on the topic. Articles focusing only on individual and eration over standards development.
narrow technical equipment standards—such as ISO 26142:2010 • Finally, we examined the degree to which they expressed an inte
Hydrogen detection apparatus — Stationary applications—were excluded grated conception of Sustainability as the balancing of economic,
657
Table 1 a
Peer reviewed academic articles.
A list of comparative studies of hydrogen SCLs: academic and ‘grey’ literature.
Author Date Abridged Title Published by
social, and environmental dimensions. To do this, we employed a set
Velazquez Abad, A., 2020 Green hydrogen Energy Policy of keywords that reflected Sustainability’s underlying economic,
Dodds, P. E.a [34] characterisation social, and environmental dimensions and employed these to un
initiatives
White, L., Fazeli, R., 2021 Towards emissions Energy
dertake keyword searches of the selected schemes’ standard docu
Cheng, W., Aisbett, certification schemes for ments. This was the formal, written standard where that existed; in
E., Beck, F., international trade in other cases, if no written standard was available, a search of sec
Baldwin, K., hydrogen ondary documentation was employed. Keyword searches are a
Howart, P., O’Neill,
common and intuitive, if basic, technique in content analysis [64].
La [52]
Liu, W., Wan, Y., 2022 Green hydrogen International Journal of They provide an objective, although indicative, means to assess a
Xiong, Y., Gao, P.a standard in China: Hydrogen Energy document’s orientation towards a topic of interest, with relative
[53] Standard and frequencies providing insights into the priorities of SCL designers.
evaluation of low- The keywords chosen to assess the economic dimension of Sustain
carbon hydrogen,
ability were: ‘economy’, ‘trade’, ‘market’; for the wider,
clean hydrogen, and
renewable hydrogen. non-emissions, environmental dimension: ‘environment’, ‘biodiver
Boyle, C., Duenner, Dec Requirements for the Commissioned by GIZ; sity’, ‘water’ (treatment or source); and for the social dimension:
D., Muñoz, F., 2021 production and export authored by ILF ‘social’, ‘labour’, ‘community’. In all cases the search included
Duran, F., Altmann, of green-sustainable Ingeniería, Chile
spelling variations and different suffixes: thus ‘labor’ as well as ‘la
M., Schmidt, P., hydrogen Limitada and Ludwig-
Krenn, P [54]. Bölkow bour’, were included.
Systemtechnik LBST
Wenger, B. & Wagner, Dec Hydrogen certification Konrad Adenauer 4. Results and discussion
E (eds). 2021 in Australia, Germany Stiftung’s Periscope
Contributors and Japan Series, Regional
4.1. Overview of hydrogen SCLs
Hewitt, M., Sailer, Programme Australia
K., Kimura, S., and the Pacific,
Aisbett, E [55]. Barton, ACT, Australia We compiled 25 hydrogen SCLs (Table 2, which also provides the
Sailer, K., Reinholz, Jan Global Harmonisation German Energy SCL acronyms used henceforth) and divided these into schemes ‘under
T., Lakeit, K., 2022 of Hydrogen Agency/World Energy
development’ (if the details were still being negotiated) and ‘available’
Crone, K [56]. Certification Council, Berlin,
Germany
(if they had produced a standard and/or had commenced a certification
Heinemann, C., Apr Comparing Öko-Institut e.V. and pilot). Of the 25 schemes, 7 were assessed as ‘under development’ and
Mendelevitch, R., & 2022 sustainability of RES- adelphi (Freiburg & the remaining 18 as ‘available’. The distinction is not clearcut, however.
Seebach, D., Piria, and methane-based Berlin) We have listed the French L’Association Française pour l’Hydrogène et les
R., Exkardt, J., hydrogen
Piles à Combustible (AFHYPAC) scheme as under development following
Honnen, J [57].
Asia Pacific Economic July Low-Carbon Hydrogen Ernst & Young an extensive search of the France Hydrogène website (which replaced
Cooperation 2022 International Standard Limited AFHYPAC in 2020) failed to reveal any additional information beyond
(APEC) [58] – Post-Workshop Velasquez Abad and Dodd’s 2020 Energy Policy article where it is first
Report
referenced [34]. Similarly, in mid-2023, the US Clean Hydrogen Pro
Aisbett, E., Cheng, Aug Approaches to certifying Australian National
W., MacGill, I., 2022 Australian-Germany University, Canberra,
duction Standard and the UK Low Carbon Hydrogen Certification
White, L [59] Hydrogen Supply ACT, Australia Scheme were completing public consultations and remained in the
Chains ‘under development’ category. We list schemes like the Roundtable for
Jinks, B. and Gamage, Jan Creating a Global IRENA and RMI (UAE Sustainable Biomaterials and the Australian Clean Energy Council’s Zero
C., Gielen, D., Kock 2023 Hydrogen Market and USA)
Carbon Certification Scheme as ‘available’ if relevant protocols have
Blank, T [2]
Sieler, E, Dorr, H [60] Mar Certification of green Adelphi consult been published (RSB) or operations certified (SEC-ZCCS).
2023 and low carbon GmbH/Japanese- Based on our thematic interpretation of documents, the stated pur
hydrogen German Partnership pose for developing hydrogen SCLs differed. Common motivations
Team
identified were decarbonisation, market facilitation, transparency, en
IEA [61] April Towards hydrogen International Energy
2023 definitions based on Agency
ergy security, and sustainability. The two dominant stated purposes
their emissions intensity (based on frequency) for developing a scheme were decarbonisation and
Sailer, K., Klingl, S., May Establishing a National Deutsche Energie- market facilitation. While the focus on decarbonisation is unsurprising
Matosic, M., 2023 Hydrogen Standard Agentur GmbH given it is a core rationale for the renewed interest in hydrogen as an
Reinholz, T., (dena), Berlin,
energy carrier, the emphasis on market facilitation highlights the
Schmidt, C [10]. Germany
Gischler, C., Daza, E., June Unlocking Green and Inter-American important role allocated to governments and business in employing
Galeano, P., 2023 Just Hydrogen in Latin Development Bank, hydrogen in energy transitions. For example, one of the three pillars of
Ramirez, M., America and the Washington, D.C., Japan’s Aichi Prefecture views its Low-Carbon Hydrogen Certification
Gonzalez, J., Caribbean USA scheme is “sustained development of a regional low-carbon hydrogen supply
Cubillos, F.,
Hartmann, N.,
chain” [65]. Such business-government corporatism was also evidenced
Pradelli, V., in the UK’s Low Carbon Hydrogen Certification Scheme. Two secondary
Márquez, J., objectives of its proposed SCL scheme are “to stimulate market growth and
Gutiérrez, J., incentivise the production of low carbon hydrogen” and “facilitate
Hermosillo, J.,
cross-border trade in low carbon hydrogen” [66].
Rodriguez, C.,
Souilla, L., S/sustainability was identified as another motivation featuring in
Rabinovich, J [62]. scheme documentation. The ISO, EU Taxonomy, GH2, ISCC, REDCert,
González, J., June Advisory Report on the Hinicio, lüdwig and RSB, all explicitly reference the concept of S/sustainability. For
Altmann, M [63]. 2023 Development of a Green bolkow example [66], RSB states that “The intent of this standard is to ensure that
Hydrogen Certification systemtechnik, and
Scheme in Chile World Bank Group
…. negative environmental, social and economic impacts related to their
658
Table 2
A summary of the general features of the Hydrogen Standard, Certification, and Labelling Schemes in the corpus.
Ref Name, abbreviation, and reference Status SCL Proponents Terminology Geographic Type Assessed Order
document/s used to evaluate ‘Stated Regions of Thematic
Purpose’ Purposesc
[1] Aichi Prefecture Low-Carbon Available S, C Government-Business Low Carbon H2 Aichi Voluntary MF, D
Hydrogen Certification Scheme (AP- Partnership Prefecture,
LCHCS) [65], Kimura in [55] Japan
[2] Ammonia Energy Association (AEA) Under S, C Business Attributes of NH3 Global Voluntary MF, D
[68] development
[3] Australian Guarantee of Origin Under S, C National Government Clean H2 Australia Voluntarya MF, T, D
scheme (Government of Australia, development Attributes of H2
DCCEEW) (A-GO) [69,70]
[4] Bureau Veritas Renewable Hydrogen Available S, Business Green H2, Global Voluntary MF, D, H, T
Certification (BV-RHC) [71] C, L Renewable H2,
Low Carbon H2
[5] CEN/CENELEC CLS JTC 6 Under S Inter-governmental H2 (referring to EU Voluntary MF, PS
(International-EU) Hydrogen in development Organisation Clean, Renewable &
Energy Systems [72] Low Carbon H2)
[6] CertifHy™ [73,74] Available S, Government-Business Low Carbon H2 EU, EEA, Voluntary MF, D, T
C, L Partnership Green H2 Switzerland
[7] China Hydrogen Alliance Standard Available S Business Low carbon H2 China Voluntary M, DF
(C-HAS) [53] Clean H2
Renewable H2
[8] Clean Hydrogen Production Under S National Government Clean H2 United States Voluntarya ES, MF
Standard (U.S. Department of development
Energy) (CHPS) [75]
[9] dena biogas Register [76] Available S, Government Synthetic H2 biogas Germany Voluntary T, D
C, L
[10] EU Renewable Energy Directive Available S Regional Government Renewable Fuel of EU Regulatory D
(RED II) [77,78] Non-Biological Origin
(RFNBO)
[11] EU Taxonomy [79] Available S Regional Government Criteria for EU Voluntarya D, ES
sustainability
[12] France Hydrogène (formerly Under n/a Business Renewable Hydrogen France Untraced U
L’Association Française pour development
l’Hydrogène et les Piles à
Combustible, AFHYPAC) [34]
[13] Government of India, Green Available S Government Green H2 India Untraced D, MF
Hydrogen Standard for India (I–H2
Standard) [80]
[14] Green Hydrogen Organization Green Available S, Business Green H2 Global Voluntary D, T, H, BSS
Hydrogen Standard (GH2) [81,82] C, L
[15] H2Global Stiftung (H2Global) [83] Available S Business-Government Climate Neutral H2 Germany & Voluntaryb MF, D
Partnership Green H2 Global
[16] International Organization for Under S Inter-governmental Attributes of H2 Global Voluntary T, MS, MF, D
Standardization Technical Development Organisation
Committee 197 (ISO) [84]
[17] International Partnership for Available S Inter-governmental Attributes of H2 Global Country- D, T, MF, EnS,
Hydrogen and Fuel Cells in the Organisation dependent MS
Economy Green House Gases
Methodology (IPHE) (2003/2020)
[85].
[18] ISCC Plus and EU (International Available S, Government–Business RFNBO Global Voluntary BSS, MF
Sustainability & Carbon C, L Partnership
Certification) (ISCC) [86–88]
[19] Low Carbon Fuel Standard, Available S Government Low carbon California Regulatory D, AP, MF
California Air Resources Board (C- transportation fuels
LCFS) [89]
[20] REDcert [90] Available S, Business H2 from electrolysis EU and Voluntary C, D
C, L using renewable designated
energy countries
[21] Roundtable for Sustainable Available S, Multistakeholder Renewable H2 Global Voluntary BSS
Biomaterials Global Fuel C, L
Certification (RSB-GFC) [67,91,92]
[22] Smart Energy Council’s Hydrogen Available S, C Business Zero Carbon H2 Australia Voluntary MF, D
Australia’s Zero Carbon Certification Zero Carbon NH3
Scheme (SEC-ZCCS) [93–96]
[23] TÜV Rheinland [97] Available S, Business Renewable H2 Global Voluntary D
C, L Low carbon H2
[24] TÜV-SÜD CMS 70 [98] Available S, Business Green Hydrogen Global Voluntary D
C, L Green-Hydrogen+
[25] UK Low Carbon Hydrogen Under S, National Government Low carbon H2 United Voluntary D, MF
Certification Scheme (UK development C, L Kingdom
Government, DESNZ) (UK-LCHCS)
[66]
a
Mandatory for certain funding or reporting requirements.
659
b
Funding programme. Column 9 acronyms are APR = air pollution reduction, BSS = broad spectrum Sustainability, C = compliance with REDII, D = decarbon
isation, ES = environmental sustainability, EnS = energy security, H = harmonisation, MF = market facilitation, MS = methodology standardisation, PS = public
safety, S = sustainability, T = transparency, U = untraced.
c
’Assessed Order’ refers to the relative weight the reviewed standards give to different objectives. The analysis was based on a qualitative assessment of each
standard’s documentation, especially those sections referencing aims, objectives, goals, purposes, and principles.
[advanced fuels] production are minimised …." [67]. A second notable 4.2. Technical features of hydrogen SCLs
feature of the sample of hydrogen SCLs taken as a group was their
voluntary nature. All but two are ‘voluntary’ as a business can choose to Table 3 presents data on the technical features of our subset of ten
forego whatever benefits the SCL offers without contravening national schemes which revealed a large diversity of approaches. These included
laws, although others are mandatory for certain funding or reporting (i) different system boundaries; (ii) diverse terminologies; (iii) alterna
requirements. Being certified to the US’s Clean Hydrogen Production tive ‘clean’ hydrogen pathways; and (iv) distinct thresholds for denoting
Standard (CHPS) will only be necessary if a company seeks funding ‘desirable’ from ‘undesirable’ hydrogen.
under its scheme; similarly, Australia’s proposed GO scheme is volun
tary and only applies to those facilities that see a benefit in being 4.2.1. System boundaries
certified, likely because they intend to export hydrogen and derivatives Our SSG conceptual framework draws attention to the power dy
abroad. The only two fully regulatory schemes in the sample were Cal namics involved in setting system boundaries. Hydrogen SCLs employ
ifornia’s Low Carbon Fuel Standard and the EU’s REDII scheme. The different systems boundaries (both spatial and phenomenal) depending
former obliges producers to either invest in renewable energy like on the importance attributed to carbon emissions in the hydrogen life
hydrogen or purchase Renewable Energy Certificates to offset their cycle assessment (LCA) and the view taken of the wider impacts of
mandatory carbon reduction commitments. REDII sets out specific tar rolling out the related infrastructure. Focusing on the spatial dimension
gets for emissions reduction and renewable energy and defines the re and narrowing down to the emissions phenomenon, Fig. 2 depicts the
quirements for how they can be met. available LCA options being used by schemes for GHG accounting
A final feature of the emerging hydrogen SCLs was the diversity of ranging from a comprehensive cradle/well-to-grave to very partial ‘gate-
focus and associated terminology. The goal of some schemes is only to to-gate’ approaches which only account for the emissions from the
define a technical threshold for ‘low carbon’, ‘green’, ‘clean’, or production of hydrogen and not the emissions from inputs into or out
‘renewable’ hydrogen. Once a technical specification has been agreed, puts from the process. Well-to-point of delivery or well-to-tank bound
no effort is made to operationalise the standard by developing an aries include transport-related emissions and may include emissions
associated certification or labelling scheme. The IPHE exemplifies this from the reconversion of hydrogen or its derivatives depending on the
technical approach, as it aims to “develop a mutually agreed upon meth scheme [4] Moreover, in the absence of an international accounting
odology for determining the greenhouse gas emissions associated with the framework to facilitate interoperability or convergence of schemes,
production of hydrogen” [85]. Another example is the regulatory stan there are gaps in the LCA philosophy in determining where one scheme
dards for hydrogen required by the EU’s RED II Delegated Acts, but ends and another begins, particularly in the case of exports. Table 3
which are not mandated to be operationalised by any SCL. Most schemes shows that seven of the ten schemes in our subsample include a
listed in Table 2 do not terminate at the standards development phase, well-to-gate approach, requiring Scope 1 emissions directly produced by
however; many seek to operationalise a concept of ‘clean’, ‘green’, the hydrogen plant to be added to Scope 2 emissions indirectly produced
‘renewable’, or ‘sustainable’ hydrogen via the addition of certification from upstream inputs. For ‘renewable’ hydrogen, a key upstream input
and labelling components. In addition to specifying a set of hydrogen is emissions from the electricity powering the electrolyser and any
attributes, such SCLs require procedures to assess when a specific pro associated processes required for liquefaction, or ammonia or methanol
duction facility or batch of hydrogen conforms to the standard and manufacture. Schemes generally do not include Scope 3 emissions,
whether and what kind of label to issue. Because almost all schemes are which result from the transportation of hydrogen or its reconversion
largely voluntary, certification requires inviting applicants to join the from ammonia. Three schemes in our subsample include a well-to-wheel
scheme; assessing (directly or via a third-party certifying body) whether boundary: C-LCFS, ISCC, and RSB.
the applicant’s practices conform to the scheme’s standard; and issuing a A great deal hinges on the selection of the LCA boundary. It can be
certificate to those deemed compliant. A further step involves licensing debated whether a well-to-gate boundary is the most appropriate if the
an applicant to utilise a product label to publicly signal the product’s goal is to transition rapidly out of fossil fuels to a renewable energy
compliance to the standard, often important when retailing it to final CHANS where hydrogen plays a critical role. National hydrogen stra
consumers in the pursuit of a price premium. tegies envision a significant role for hydrogen in the global economy and
These varying arrangements generate complex inter-scheme dy the transportation, storage, and reconversion of hydrogen carriers could
namics. For example, TÜV-SÜD is an established certification body that generate significant emissions. From within our SSG conceptual frame
provides certification services to corporations in fields such as quality work, not taking account of all the GHG emissions involved in the pro
management (ISO9001), environmental management (ISO14001), and duction, transport, and use of hydrogen is a serious flaw and will mislead
Forest Stewardship Council Chain of Custody [97]. The company has decisionmakers about appropriate decarbonisation strategies involving
recently developed its own proprietary hydrogen SCL, SCS70. However, hydrogen.
in addition to offering certification to SCS70, TÜV-SÜD is also accredited Authors own work adapted from Refs. [34,61].†Reconversion may or
as a certifying body to the CertifHy standard. TÜV-SÜD is thus able to may not be included in the Consumption Gate/User/Point of Deliver
offer ‘dual certification’ to both its own SCS70 and CertifHy’s standard, y/Tank depending on a scheme’s system boundary definition. ‡ The
which can be an important competitive advantage. Dual certification GHG accounting methodology and point of delivery of H2 for a certifi
benefits producers of hydrogen who can obtain two certificates while cation scheme may not coincide with the ultimate physical delivery
undergoing a single audit. The benefits to TÜV-SÜD (and other organi point and use of H2 particularly if it is exported outside of the jurisdic
sation like Bureau Veritas providing similar services) are that it may be tion of a certification scheme. Image attribution: Dieter Tracey, Coastal
able to outcompete other certifiers by offering the equivalent of a CRC (ian.umces.edu/media-library); Tracey Saxby, Integration and
two-for-one deal in certification. Application Network (ian.umces.edu/media-library).
4.2.2. Terminology for thresholds

While a problematic consensus of sorts exists on the well-to-gate
660
F. Gale et al.
Table 3
Summary of technical features, governance features, and Sustainability keyword count for selected schemes. Symbols indicate whether the proportion of keywords for each Sustainability dimension was considered
Balanced (28–38% of total keywords found), Overbalanced (>38%), Underbalanced (<28%).
Scheme Technical features Governance features s/Sustainability keyword count
reference summary
System Production Carbon thresholds Additionality Chain of Governance Structure Organisational Stated Principles Total Econ Env Soc
boundary pathways (kg CO2eq/kg H2) custody Type
A-GO Well-to- Electrolysis, SMR- Not stated Not stated Mass Government led Bureaucratic Trustworthy, Transparent, 223 87% 11% 1%
User CCS, CG-CCS Balance (proposed). Overseen by Practical, Consistent, Flexible
CER
AP-LCHCS Well-to- Electrolysis, Not stated New RE Book & Government led Partnership Not stated 13 38% 15% 46%
Gate Biogas, Sodium installations Claim industry consortium
hydroxide managed by Chebu
byproduct H2 Prefecture
CertifHy™ Well-to- All Green or Clean H2: Not stated Book & Industry led consortium Partnership Uniqueness; Transparency; 31 29% 61% 10%
Gate 4.4 Claim and steering committee Immutability; Ownership;
with three different Operator reliability; End of life;
stakeholder pools and Consumption period;
stakeholder platform Rectification; Disputes.
C-HAS Well-to- All Green or Clean Not stated Not To be determined To be GHG emissions reduction 25 88% 12% 0%
Gate H2:4.9 referenced determined
Low Carbon
H2:14.51
C-LCFS Well-to- All Ranges from Not stated Book & Government led; Bureaucratic Confidence, Reliability 179 67% 32% 1%
Wheel Renewable (solar, Claim Overseen by California
wind) H2: 1.3 to Air Resources Board
SMR w/o CCUS: (CARB)
14.1
661
GH2 Well-to- Electrolysis 1.0 Expected but not Not Industry committee Foundation (self- Sovereignty & subsidiarity; 313 39% 37% 25%
Gate required referenced with six working groups appointed Proportionality (materiality);
advising GH2 board board) Harmonisation; Consultation;
Transparency; Independent
verification, concerns and appeals;
Further development of the
standard
ISCC Well-to- H2 produced from Not stated To be demonstrated Mass- Membership association Foundation (self- General principlesa: Openness; 153 58% 14% 28%
Wheel renewable energy Balance with stakeholder appointed Reliability; Consistency; Integrity;
committees and a board) Quality; Transparency;
general assembly
International Journal of Hydrogen Energy 59 (2024) 654–667

RSB-GFC Well-to- Renewable Not stated To be demonstrated Mass- Roundtable structure Foundation Legality; Planning & monitoring: 340 18% 58% 24%
Wheel electrolysis Balance with five chambers to (elected board) Greenhouse gas emissions; Human
represent economic, and labour rights; Rural and social
environmental and development; Local food security;
social interests Conservation; Soil; Water; Air
quality; Technology, inputs, waste;
Land rights.
SEC-ZCCS Well-to- Renewable Not stated Not stated Not Industry council Foundation Not stated 14 86% 7% 7%
Gate electrolysis, specified (elected board)
Biogas, SMR
TÜV-SÜD Well-to- Renewable Ranges from H2 demonstrated by (i) Book & Industry (certification Corporate Not stated 21 76% 24% 0%
CMS 70 Gate or electrolysis, from RE and B&C: New RE; (ii) Claim, Mass organisation)
Well-to- Biomethane SMR, 1.1 to H2 from Development funds; Balance
point of Pyro-reforming of biomethane/ (iii) Technology
delivery glycerine, Biomass glycerine with MB: mix
5.6
a
ISCC has additional standard principles, for example, for agricultural biomass: Environmentally Responsible Production to Protect Soil, Water and Air; Safe working conditions; Compliance with human and labour
rights and health and safety; Compliance with applicable laws and relevant international treaties; Good management practice.
Fig. 2. Simplified lifecycle boundaries for hydrogen SCLs (excluding cross-border export and scheme interoperability).
carbon-accounting boundary in our subset of SCLs, far less agreement is the A-GO); some state that biomass is presently excluded, such as GH2;
evident on what the desirable carbon-intensity thresholds should be or and others, such as TÜV SÜD, allow for hydrogen production from
what to term them. Some schemes employ a colour-code, others use biomass. Thus, it seems pertinent that SCLs should also consider the
terms like ‘clean’, ‘low-carbon’, or ‘renewable’, and others again prefer emissions and ecological footprint of biomass (and other emergent
to list hydrogen’s attributes. This situation is confusing, and the production methods) and thus, from a wider systems perspective, its
complexity means that emerging hydrogen SCLs are hard to compare. potential to impact on land use and community.
The Chinese Hydrogen Alliance Scheme (C-HAS) blends a ‘renewable’
and ‘green’ approach by distinguishing Low-Carbon from Renewable 4.2.4. Additionality
and Clean H2, each with different emission thresholds. In contrast, the Schemes differ on the approach taken to the issue of ‘additionality’.
Australian Government’s draft Guarantee of Origin scheme (A-GO) takes The issue has been succinctly summarised as ‘the requirement that new
an attributes approach, enumerating several features of a batch of electrolysing capacity is supplied by renewable electricity from new,
hydrogen on its GO certificate and leaving it to the market to determine dedicated sources’ [99], p.2] In the absence of renewable electricity
which combination of these best meets consumer requirements. In other from ‘new, dedicated sources’, the concern is that the large-scale ramp
jurisdictions, thresholds are being specified in standards that link to up in the production of hydrogen from electrolysis will divert existing
wider policy frameworks. One example is the voluntary schemes with a renewable energy from more efficient uses and result in fossil fuel en
European presence (e.g., Certify, RSB and ISCC), which are moving to ergy use elsewhere in the system. From a systems perspective, addi
integrate the RED II Delegated Acts emissions threshold requirements tionality is thus a critical consideration when assessing emissions from
into their certification schemes. hydrogen production. Pototschnig [100] identifies three basic solutions:
establishing the existence of a physical, commercial, or system-wide link
4.2.3. Production pathways between renewable electricity and produced hydrogen. Establishing a
Schemes differ on the technological pathways for hydrogen to direct physical link is the simplest and clearest way to demonstrate
qualify as ‘green’, ‘clean’, or ‘renewable’. The A-GO scheme explicitly additionality. In this case, the renewable energy is clearly new and
considers electrolysis, SMR, and CG pathways; Japan’s AP-LCHCS additional, and the produced hydrogen can be categorised as low- or
scheme restricts production to electrolysis, biogas, and sodium hy zero-emissions. However, it will make more technical or commercial
droxide by-product H2; the GH2 scheme only references electrolysis. sense to many producers to use energy from the grid. In this case, it is
Some schemes, like CertifHy, recognise all pathways including SMR and important to ensure that the grid electricity is renewable and additional
CG with CCS, nuclear power, and biomass options, all of which may and does not result in fossil-fuel produced electricity being deployed for
qualify as ‘low-carbon hydrogen’. Issues arise in both the strict and more other less efficient uses. Producers can secure renewable energy from the
permissive approaches to choosing pathways. Restrictive approaches grid by negotiating Power Purchase Agreements (PPA) with a provider.
may prevent technological innovation—for example, innovations in Ensuring additionality in this context can be achieved by geographic and
SMR with CCS may enable ‘blue hydrogen’ to be economically and temporal ‘matching’ as described in the EU’s REDII.
technically competitive with renewable energies. Alternatively, overly The subset of SCLs we studied take different approaches to addi
permissive approaches may provide a lifeline to fossil fuel and nuclear tionality. Some ignore the issue completely, others treat it as an attribute
industries and retard the rapid transition to a renewable energy future. for potential inclusion, and others again address it in detail. Aisbett et al.
Moreover, there are other production pathways they may qualify as [59] analyse several schemes including four in our subsample (CertifHy,
renewable such as the thermal treatment of biomass (e.g. pyrolysis, A-GO, ZCHS, and GH2) on the approach taken to additionality. They
gasification). Some SCLs do not mention biomass gasification (such as note that the initial CertifHy scheme was permissive in requiring only
662
the surrender of a renewable energy certificate to demonstrate ‘grid default to a formal, consultative, bureaucratic notion of democracy so
electricity eligibility’, but that future iterations are expected to align normalised as not to require any explanation. The process involves those
with EU RED requirements. As of August 2023, the CertifHy™ website in charge seeking the views of the public through established consul
states that their scheme is pending recognition by the European Com tative procedures, such as the public release of draft proposals for
mission as an EU Voluntary Scheme, which will mean hydrogen certi comment via formal submissions. In the case of hydrogen, the degree to
fication as a Renewable Fuel of Non-Biological Origin (RFNBO) will which such formal consultative processes may be ‘captured’ by powerful
have to comply with the additionality requirements of EU REDII. In actors in the sense of exerting undue influence is unclear. However,
contrast, in the context of Australia’s A-GO, additionality is treated as many political economic studies detail how special interests can skew
another hydrogen attribute. As the draft A-GO consultation document policy outcomes in their favour in specific circumstances (e.g. see
states: “The GO scheme does not require time matching to be demonstrated, Ref. [105]. The concept of ‘stakeholder’ is ambiguous in this respect.
however participants could voluntarily produce or source LGCs [Large-scale The term homogenises the nature of the feedback received across
Generation Certificates] or REGOs [Renewable Energy Guarantee of Origin different sectoral interests masking whether specific interests have been
certificates] that demonstrate this” [70]. GH2 adopts another approach. able to exercise undue influence. As an example, the A-GO scheme’s
According to Bartlett [101], the GH2 scheme offers a flexible approach consultative documents highlight the importance of stakeholder con
to additionality by empowering companies to defend the approach sultations during trials of the A-GO scheme but do not clarify to what
chosen to a third-party auditor: the GH2 Standard “puts the burden of extent the broader communities where such trials were held were
proof on green hydrogen producers to demonstrate their sustainability cre consulted.
dentials, taking the wider context of the project and stakeholder views into Several schemes actively promote their ‘stakeholder’ and ‘multi
account”. stakeholder’ credentials, demonstrating an awareness that SCLs need to
demonstrate a degree of internal democratic accountability. The ISCC
4.2.5. Use of offsets scheme highlights ‘multistakeholder’ membership on its website and
From an SSG perspective, the quantity and quality of emissions off stresses the role these play in electing directors to the board at annual
sets is integral to any assessment of the broader decarbonisation impacts general meetings. A review of its list of 235 members in early 2023 [106]
and benefits of hydrogen projects. The Integrity Council for the Volun revealed, however, that only 10 were from the non-corporate sector. The
tary Carbon Market defines offsetting as the ‘compensation for an enti organisation has no requirement to balance interests or values at the
ty’s greenhouse gas emissions within its scope by achieving an board level, as it does geographic location and gender. Of the eight
equivalent amount of emission reductions or removals outside the board members listed on its website in early 2023, six had corporate
boundary or value chain of that entity’ [102]. The voluntary carbon backgrounds and two were from academia. Geographically, six were
market for offsets is controversial as it is poorly regulated and concerns European, with one each from Singapore and North America; and six
have been raised over the quality of the projects included, the were men and two were women.
non-permanency of some of the claimed carbon sequestration, the ex An important feature of many hydrogen SCLs is the requirement for
istence of double-counting, and the potential for ‘greenwash’ [103], technical expertise in hydrogen production, energy markets, and certi
among other issues. Hydrogen SCLs with regulatory components need to fication, accreditation, and labelling systems. The complexity of the
consider whether to permit or exclude carbon offsets, with significant energy sector and the variety of feasible hydrogen production pathways
differences between schemes. Schemes in Europe that obtain approval as makes it very difficult for non-energy experts to participate in decision-
Voluntary Schemes under REDII will only certify RFNBOs that comply making. Yet such participation is a democratic requirement from an SSG
with offsetting requirements. The A-GO scheme sets out two options: to perspective given the enormous and potentially negative collateral im
exclude them in line with the methodology of the IPHE; or to include pacts of the roll-out of large-scale hydrogen projects and because these
them in line with its preferred ‘attributes’ approach. Under the second features of governance are necessary to enable sustainable development
option, an A-GO certificate would provide information about gross and [8]. A recognised solution to the expertise-democracy conundrum is to
net carbon emissions and the kinds of offset projects involved. ISCC’s employ a chamber-based model of governance with expertise either
scheme adopts another approach, permitting offsets when they are embedded in each chamber or separated in an expert advisory body. RSB
outsourced to a sister company, ClimatePal. is the only scheme in our subsample to fully embrace this governance
approach, dividing stakeholders into five chambers to engage in
4.3. Governance arrangements cross-interest and cross-value Sustainability dialogues. Its five chambers
represent the following interests and values: (i) Biomass producers and
SCLs evidence a diversity of governance arrangements. As noted in industrial biomaterial/bioenergy producers; (ii) Retailers/blenders,
the SSG section, governance arrangements vary in terms of participa transportation industry, users of biomaterials and banks/investors; (iii)
tion, deliberation, and interest/value balancing reflecting differences in Rights-based NGOs and trade unions, rural development, food security,
how organisational democracy is practiced. In the field of SCLs one can smallholder farmers, indigenous people, and community-based civil
distinguish between bureaucratic, corporate, foundation (self-appointed society organisations; (iv) Environment or conservation organisations
and elected), and partnership arrangements based on how they are le and climate change or policy organisations; and (v) Intergovernmental
gally incorporated. Each practices ‘democracy’ differently, with gov organisations, governments, research/academic institutions, and
ernment bureaucracies and corporations implicitly locating it at the standard-setters. Other schemes adopt elements of a chamber-based
level of elected and delegated officials as a natural feature of the statist model. For example, the Certify Steering Committee consists of 15
Westphalian settlement, while corporations, foundations, and partner representatives from 3 different stakeholder pools: (i) Producers &
ships locate it within the organisational governance structure itself, processors, (ii) Traders, logistic operators and users, and (iii) NGOs,
increasingly through the language of ‘multistakeholder democracy’. research, public sector. Moreover, there is evidence of certification
Whether organisational structure matters in terms of SCL effectiveness is schemes merging their capability and collaborating to meet regulatory
an active and controversial area of inquiry in the literature (e.g. see or funding requirements, as in the recent agreement between CertifHy
Ref. [104]). In this section we merely focus on comparing approaches to and RSB.
scheme governance. The results from Table 3 revealed several inter We identified two other SLC governance dimensions of significance.
esting findings. The first relates to the type of standard developed, which varied from
From the analysis, a first observation is that several SCL schemes seek learning-by-doing to pre-agreed, formal, measurable, performance-
to persuade the public that they are organisationally ‘democratic’ to based standards. Different types of standards grant those operational
some degree. Government schemes like A-GO, AP-LCHCS, and C-LCFS ising and auditing them more or less discretion. Thus, it is useful to
663
distinguish between technical-, management-, and performance- referenced but not discussed; and (iii) Sustainability issues are refer
oriented standards and how these are combined in specific schemes. enced and engaged with. For our subsample, C-HAS, SEC-ZCCS, and AP-
GH2, for example, defaults to a management standard in most cases. Its LHCS are examples of the first strategy, making no mention of the wider
governing documents establish three levels of ‘obligation’: those context their SCL is embedded in. The A-GO scheme provides a good
‘required’ or ‘must’ are obligatory; those ‘expected’ and ‘should’ need to example of the second approach: wider issues are mentioned but
be considered; and those ‘recommended’, ‘encourage’, ‘may wish’ and deemed ‘out of scope’ [70], p.8]. Three exceptions to the proclivity for
‘could’ are discretionary. While most standards contain such a hierar hydrogen SCLs to not engage with wider Sustainability dimensions are
chy, the danger exists that a very comprehensive and inclusive standard the RSB, ISCC, and GH2 schemes. The RSB scheme explicitly claims to be
defaults to one that is narrower in application when the number of delivering Sustainability, embedding the concept within the original
‘required’ and ‘musts’ are heavily outweighed by terms permitting a Brundtland idea of balancing the economic, social, and environmental
significant degree of discretion. Such appears to be the case with many dimensions of biomaterials extraction, production, trade, and use.
of the hydrogen SCLs analysed in our database including GH2’s Green However, from our content analysis it may be that it overemphasises the
Hydrogen Certification scheme. This observation is unsurprising as it environmental and social dimensions to the detriment of the economic
has been extensively documented in other fields, including biofuel cer dimension. The ISCC places Sustainability at its centre: its goal is to
tification, where a proliferation of industry-driven standards likely “contribute to and promote environmentally, socially and economically
weakened sustainability objectives [107]. sustainable production and use of agricultural and forest biomass” and other
biomaterials [109], p.8]. However, the keyword search appears to
4.4. Sustainability dimensions of SCLs indicate that it underestimates the environmental dimension of Sus
tainability in favour of the economic and social. Likewise, the GH2
Results from the keyword-based content analysis used to assess SCLs’ scheme states that its Standard “tracks the overall social, environmental
engagement with the economic, social, and environmental dimensions and governance performance of green hydrogen production” [81], p.6].
of Sustainability revealed several interesting features. First, the SCLs Based on keyword frequency, it appears to be the most balanced of the
differ in the degree to which the selected terms are reflected in scheme standards in our sample.
documents. While partly an artifact of the methodology (some schemes
are better documented, the choice of keywords is selective, and each 5. Conclusion
keyword may not be contextually equivalent) it is nonetheless surprising
that, for example, the CertifHy scheme only has 31 ‘hits’ across the This article presents a state-of-the-art review of hydrogen SCLs from
economic, social, and environmental categories compared to others such a Sustainability systems governance perspective. This enables the di
as GH2 which has 313 hits. A major reason for the difference is that the versity of schemes to be compared in terms of their contributions to
CertifHy scheme is narrowly crafted around technical issues including Sustainability, defined in Brundtland terms, while seeking distance from
carbon accounting methodologies, whereas other schemes like GH2 a set of conscious and unconscious biases infecting our modern political
have a broader remit. Schemes with low hits that may signal a narrow economic ‘mindware’ [110] to do with individualism, nationalism,
technical focus include AP-LCHCS, SEC-ZCCS, TÜV-SÜD, and C-HAS. marketism, progress, and equality. It also entails a significant broad
Perhaps unsurprisingly, a second feature of our SCL sample is that ening of the boundaries of the system beyond those currently employed
economic issues are a major focus of many schemes. On average, the in most analyses. Instead of focusing narrowly on accounting for GHG
keyword searches for the A-GO, C-HAS, SEC-ZCCS and TÜV-SÜD emissions and on facilitating the trade in hydrogen, our SSG approach
schemes all returned above 70% for the economic criteria Using this encompasses the full range of technical, economic, social, and envi
keyword search criteria, the C-HAS and A-GO schemes are the most ronmental impacts. This attempts to put into perspective a fuller version
‘economic’ oriented, the former with 88% in the economic category; the of the impact of the roll-out of renewable hydrogen at scale, which
latter, with 87%. The least economically orientated scheme was RBS include potential impacts on water, biodiversity, local and indigenous
with 18% of total keywords being economic, 58% ‘environmental’ and communities, local business, and so forth. Moreover, from a systems’
24% ‘social’. perspective, the evaluation of any need for green hydrogen should
A third observation is that the ‘social’ dimension of Sustainability necessarily consider alternative demand-side energy solutions [36]. We
was underrepresented, markedly so in some instances. The SCL with the identified 25 hydrogen SCLs that differ significantly in objectives, ter
highest frequency social keywords was Japan’s AP-LCHCS, representing minology, concept of s/Sustainability, governance arrangements,
46% of all keywords: although this finding was skewed by the orga scheme type, and level of development. We conclude by noting, as
nizing committee having the term ‘social’ in its title. Other schemes with others have done, for example IRENA & RMI (2023) [2], that the
higher frequency social keywords were ISCC (28%), GH2 (25%), and renewable hydrogen and broader energy sector is not well served by this
RSB-GFC (24%). These three schemes are explicitly promoting them proliferation of SCLs. Not only are limited energies and resources
selves as ‘s/Sustainable’ and thus the higher proportion of social key divided across states, corporations, NGOs, and experts, but the diversity
words found in the document search is expected. Finally, five schemes of schemes is sowing the seeds of confusion within diverse communities
returned very few results for the social keyword searches. These were A- and publics over the meaning of ‘green’, ‘clean’, ‘renewable’, ‘low-
GO, C-LCFS, C-HAS, SEC-ZCCS and TÜV-SÜD CMS70. Given the recog carbon’, and ‘Sustainable’ hydrogen. We also agree with the conclusion
nised social concerns attending the role out of large-scale hydrogen (e.g. of the IRENA & RMI report: ‘None of the existing hydrogen certification
see Ref. [20]), it is a concern that half our subsample contains virtually systems are suitable for cross-border trade. In addition, there are gaps in
no keyword language addressing them. This evidence suggests that standards and in ecolabelling and certification design, resulting in
hydrogen is following the same pathway as biofuels and coffee: a study insufficient information in certificates to allow fair comparison across
by WWF [108] concluded that many biofuel certification schemes had borders’ [2], p9]. This conclusion may seem familiar to followers of
limited environmental and social criteria; and research by Raynolds biofuel certification where a need for an international approach and
et al. (2007) highlighted challenges to enhancing both social and envi further harmonisation to help secure sustainable outcomes has been
ronmental elements of fair trade coffee [42]. The implied need to engage diagnosed as hampered by disparate regional standards [26].
more holistically with sustainability, evident in our analysis, chimes Conceptualising energy as a basic human need, the global energy
with a similar sentiment emerging in academia [8,17,22]. system would be better served by taking an SSG approach to under
From our keyword-based content analysis we summarise three standing SCLs’ structure, function, current operation, and required
alternative strategies as being employed to address Sustainability: (i) operational improvements. From this standpoint, all people are entitled
Sustainability issues are not referenced; (ii) Sustainability issues are to renewable, clean energy as a basic human need and thus also a basic
664
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International Journal of Hydrogen Energy 59 (2024) 654–667

Contents lists available at ScienceDirect

International Journal of Hydrogen Energy

Renewable hydrogen standards, certifications, and labels: A state-of-the-art

4.2.2. Terminology for thresholds

International Journal of Hydrogen Energy 59 (2024) 654–667

[1] UNFCCC. 2023 Synthesis report on GST elements. 2023.

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