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The European Union (EU) identified sizeable needs for both local production and imports of renewable hydrogen by 2030, as enshrined in the 2020 EU Strategy on Hydrogen. But how sustainable, exactly, can the production of such huge amounts of renewable hydrogen be? EU lawmakers also decided to require from both EU and non-EU hydrogen producer’s adherence to the sustainability criteria that apply to bioenergy since 2009. The need for sustainability criteria in the context of bioenergy arose from the massive deforestation caused by the production of biofuels, generating greenhouse gases, destroying local biodiversity and linked to human rights violations. This chapter scrutinizes if and to what extent it makes sense to use the analogy to bioenergy for establishing sustainability criteria for renewable hydrogen, as the EU did. It finds that placing the production of renewable hydrogen under this regime is in principle welcome, as it establishes clear thresholds in terms of environmental and social impacts. However, the chapter questions the details of the premise that a system which was tailored to bioenergy may successfully be applied to hydrogen, one-on-one. Additionally, it analyses whether the flaws of the existing sustainability criteria may also extend to renewable hydrogen.
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