Life Cycle Assessments Use in Hydrogen-related Policies: The Case for a Harmonized Methodology Addressing Multifunctionality

Legislation regulating the sustainability requirements for hydrogen technologies relies more and more on life cycle assessments (LCAs). Due to different scopes and development processes, different pieces of EU legislation refer to different LCA methodologies, with differences in the way multifunctional processes (i.e., co-productions, recycling, and energy recovery) are treated. These inconsistencies arise because incentive mechanisms are not standardized across sectors, even though the end product, hydrogen, remains the same. The goal of this paper is to compare the life-cycle greenhouse gas (GHG) emissions of hydrogen from four production pathways depending on the multifunctional approach prescribed by the different EU policies (e.g., using substitution or allocation). The study reveals a large variation in the LCA results. For instance, the life-cycle GHG emissions of hydrogen co-produced with methanol is found to vary from 1 kg CO2-equivalent/kg H2 (when mass allocation is considered) to 11 kg CO2-equivalent/kg H2 (when economic allocation is used). These inconsistencies could affect the market (e.g., hydrogen from a certain pathway could be considered sustainable or unsustainable depending on the approach) and the environment (e.g., pathways that do not lead to a global emission reduction could be promoted). To mitigate these potential negative effects, we urge for harmonized and strict guidelines to assess the life-cycle GHG emissions of hydrogen technologies in an EU policy context. Harmonization should cover international policies too, to avoid the same risks when hydrogen will be traded based on its GHG emissions. The appropriate methodological approach for each production pathway should be chosen by policymakers in collaboration with the LCA community and stakeholders from the industry based on the potential market and environmental consequences of such choice.