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Australia’s budding hydrogen industry is rapidly expanding. With a recent influx of federal and state government funding, and the world’s largest green hydrogen project pipeline in place, Australia is well positioned to become a leading hydrogen producer and exporter. However, one outstanding aspect of this nascent industry – which could influence its future success – is the development of an internationally recognised certification scheme. Recently, there have been both government- and industry-led initiatives to develop such a scheme, although these initiatives remain in their early stages and their intended scope and application are presently unclear.

What are hydrogen certification schemes?

Certification schemes help verify that particular products meet certain standards. Outside Australia, the main hydrogen certification scheme currently in development is Europe’s industry-led CertifHy project, which is a “guarantee of origin” (GO) scheme. A GO is a certificate instrument that tracks a product through its supply chain, labelling the origin of that product and providing information about its source and manufacture. CertifHy permits hydrogen with lifecycle emissions below a defined limit to be certified “green” (if produced using only renewable energy), or “low-carbon” (if produced otherwise than from renewable energy). Australian government and industry-led certification initiatives are currently being modelled off aspects of the CertifHy scheme.

Why does Australia need its own hydrogen certification scheme?

Many prospective hydrogen consumers are setting increasingly ambitious emissions reduction targets, and expect transparency about the carbon footprint of hydrogen they may purchase. Demand for “green” hydrogen is rapidly increasing, whereas some other variants – such as “grey” hydrogen (produced using fossil fuels) – have a carbon footprint frequently incompatible with such ambitious emissions reduction targets. Commentators have, however, identified a number of potential issues with CertifHy, such as its (current) unavailability beyond EU member countries, and its focus on transport fuels. It is therefore crucial for Australia to be able to adequately certify the origins of its own domestically produced hydrogen (and derivatives), so it is attractive to potential consumers.

Government-led initiatives

In November 2019, the Council of Australian Governments’ Energy Council endorsed the National Hydrogen Strategy, outlining Australia’s desire to play a key role in the future development of an international hydrogen certification scheme. In mid-2020, the Australian government consulted with stakeholders and industry on the development of a certification scheme, and has since announced that it is working with other countries to agree on methods for determining carbon emissions generated from hydrogen production, with a GO scheme trial to be conducted in 2021. The trial will be funded as part of an AUD 275.5 million investment by the Australian government into clean hydrogen projects, announced under the 2021-2022 Budget in April this year. On 21 June 2021, the Australian government released a discussion paper on the design of a GO certification scheme for hydrogen in Australia (the GO Discussion Paper), inviting comments from industry and potential consumers until 30 July 2021. The stated aim of the GO Discussion Paper is to develop methods for transparent calculation of carbon emissions associated with hydrogen production, in order to allow consumers to “set their own definitions” of blue or green hydrogen, with reference to agreed international standards.

Industry-led initiatives

In December 2020, Australia’s Smart Energy Council (SEC) announced that its hydrogen division was developing a national Zero Carbon Certification Scheme (ZCCS) for renewable hydrogen, ammonia, steel and other derivatives. The ZCCS is a voluntary, industry-led GO-style scheme, which will operate as a “tracking” system by certifying that hydrogen and its derivatives are made entirely from renewable energy sources and providing an embedded carbon rating. The SEC has since announced a partnership with the German Energy Agency on the development of the ZCCS, and in April 2021 announced that the first project to be certified under the scheme will be the ActewAGL hydrogen refuelling station in Canberra. The initiative has generated strong interest both globally and domestically, with the Australian Capital Territory, Queensland and Victorian state governments both enrolling in the scheme. Most recently, Norwegian chemical company Yara confirmed it will seek to have its Western Australian renewable hydrogen and green ammonia production and export facility certified under the ZCCS, in order to guarantee its products’ green credentials for its customers both in Australia and overseas.

Where to from here?

It is expected further information about the ZCCS will be soon released as the SEC completes its first project. Given the Australian federal, state and territory governments continue to express support for low-carbon emissions hydrogen projects as well as true zero-emissions “green” hydrogen, it also seems likely that any GO scheme ultimately announced will follow in CertifHy’s footsteps and recognise not only green but also low-carbon hydrogen (unlike the ZCCS). Australia’s recently released GO Discussion Paper clearly contemplates this eventuality, outlining methodologies for a GO scheme covering electrolysis (“green”), coal gasification with carbon capture and storage (CCS) and steam methane reforming with CCS (“blue”). The role of carbon offsets (if any) will also need to be determined, with the GO Discussion Paper noting that CertifHy does not currently include the use of offsets for CCS. Regardless, it is crucial that Australia retains its current pace of development of a hydrogen certification scheme, in order to remain competitive in the swiftly moving global market.

This article was prepared with the assistance of Kirsten Foley and Harrie Bantick.


Tanya Denning, a Partner at Baker McKenzie, is a recognised expert in the energy and resources sector with over 20 years' experience and strong relationships with industry participants and regulators. She has a reputation as one of Australian's market leading experts in energy, particularly in cross border, multi-jurisdictional transaction, and projects and transaction that break new ground and require a solutions driven, innovative approach. Tanya provides an end-to-end specialist advice covering the full value chain of oil & gas (including LNG), electricity & new energy and resources, and has an acute understanding of the sensitivities and motivations of market players across these industries. Tanya has acted extensively on developing energy sector businesses; energy and resources M&A transactions; power generation (including renewables), energy storage and energy network (electricity and gas) project development, construction, operation and asset management; mining project development; wholesale energy trading and contracting (physical commodity and derivative contracts for electricity and gas including corporate PPAs, electricity retail sale, gas supply and gas transportation); connection application and agreements for the electricity grid; retail energy advisory work and contracting including new energy retail services; and energy and resources market regulatory reform and advisory work. Tanya's broad experience means that she has worked on various projects and supply, storage and transport matters across Australia and offshore, with current market knowledge of the negotiating positions and regulatory issues that arise and the solutions to address them. Tanya's experience has gained her leading recognition as Best Lawyers Australia 'Lawyer of the Year' in Oil & Gas for Melbourne from 2018 to 2020, listed in Best Lawyers Australia for 'Energy Law', 'Mining Law', 'Oil & Gas' and 'Natural Resources Law' since 2015 as well as 'Projects Lawyer of the Year', 2017 by Lawyers Weekly. Tanya is also the National President of AMPLA (Energy, Renewables & Resources Lawyers Association) and trusted advisor to several major electricity and downstream natural gas businesses operating in competitive wholesale and electricity markets.


Ilona Millar is a partner in the Environmental Markets team at Baker McKenzie's Sydney office. Ilona is an environmental and projects lawyer with a diverse range of experience in domestic and international climate change, carbon markets, environmental law and policy, and a strong background in all aspects of water management, planning and projects. She joined the Firm in 2008 from the Foundation for International Environmental Law and Development, and International Institute for Environment and Development, in London. Ilona regularly writes, teaches and presents on environmental topics — she has lectured on environmental law, environmental markets and international climate change law at UNSW, Sydney University and University College London and for the past six years has co-coordinated the international climate change law course at ANU where she is a visiting fellow at the College of Law. Ilona's extensive pro bono work includes advising a number of developing country governments and non-government organizations on international climate change negotiations, and advising the Wentworth Group of Concerned Scientists on water and natural resource management law. She is listed among the best lawyers for Climate Change by Best Lawyers Australia 2016.

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