EuLA (2021) Position on the EC roadmap on the Hydrogen and Gas Markets Decarbonisation Package

The European Lime Association (EuLA) welcomes the initiative of the European Commission (EC) to receive feedback on the inception impact assessment on the Hydrogen and Gas markets Decarbonisation Package, revising Directive 2009/73/EC and Regulation (EC) No 715/2009. Ensuring common rules for the internal market in natural gas and enabling conditions for access to the natural gas transmission networks is key to ensure the decarbonisation of the lime sector. This reform shall be an opportunity to consolidate & develop Carbon Capture and Storage (CCS) and Carbon Capture and Utilisation (CCU) structures.


  • The EC roadmap mentions that “Direct electrification is for most uses the most cos-effective and energy-efficient way to decarbonise final energy demand”. In cases where “alternative mitigation options are not available[1]”, we call the policymakers to strengthen the role of capturing CO2 via CCS & CCU, by supporting those sectors wishing to contribute to the decarbonisation objective.
  • Taking into account this request, EuLA supports key elements of the inception paper, notably:
    • The reform should enable fair competition between smart electrification, energy efficiency, and renewable and low-carbon gases like hydrogen and bio-methane, of CCU technologies in achieving decarbonisation targets.
    • The necessity to create cross-border infrastructure ready for decarbonised gases and CO2 transportation.
    • The need to take into account structural changes in the consumption of gaseous fuels as expected under any decarbonisation scenario.
    • Policy coherence with the different pieces of legislations adopted to reach the EU Green Deal objectives, including the role of ETS as a positive price signal to encourage valorisation and use of CO2.
  • A more integrated approach to infrastructure network planning supported by the right legislation, aiming to reduce electricity oligopolies within the EU internal market. Renewable and low-carbon hydrogen are part of the EU’s decarbonisation efforts.
  • The need to include hydrogen pipeline transportation in the current regulatory framework. It should be the same for the transportation of CO2.
  • Ensuring the emergence of cost-effective hydrogen infrastructure.
  • Facilitation of local and decentralised production of renewable and low carbon gases including synthetic-methane and e-fuel in general.
  • Ensuring more holistic and inclusive infrastructure planning, in particular for the gas, hydrogen and electricity markets.
  • Requirement of a cost-effective development including through repurposing of existing natural gas infrastructure.

Against that background, EuLA considers that the base line scenario (no policy change) is not an option. To achieve carbon neutrality, the transport and infrastructure of not only hydrogen, but e-fuel in general and CO2 should be considered in a very coordinated manner. These gases equally participate to pave the way for a CO2 neutral industrialisation of Europe. Access to transport infrastructures for hydrogen, e-gaseous fuels and CO2 should be affordable for all industries, not only the major emitters or consumers. Access should be geographically largely spread at a cost reflecting the “public service” nature of these networks.

[1] Fraunhofer (2019): “Industrial Innovation: Pathways to deep decarbonisation of Industry. Part 2: Scenario analysis and pathways to deep decarbonisation”. March. (Pp. 50). Available at: (Accessed on 8 March 2021)