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In brief

On 23 March 2022, China’s National Development and Reform Committee (NDRC) and National Energy Administration released a plan on the development of hydrogen energy for 2021-20351 (“Plan“). As the first national-level industry plan for hydrogen development, the Plan recognizes hydrogen as a major component of China’s future national energy system, an important carrier for realizing green- and low-carbon transition to the net-zero economy, and a key direction of China’s strategic emerging industries.

China currently is the largest producer of hydrogen in the world but the industry is still in its early stage of development, facing problems in various areas such as innovation capabilities, technical equipment and policy support and regulatory framework. The aim of the Plan is to promote and guide an integrated, green and high-quality development of the hydrogen industry in China. To that end, the Plan sets out the main objective for the development of China’s hydrogen industry, namely, building up a complete hydrogen value chain by 2035 with a significant proportion of hydrogen produced from renewable energy to support China’s green energy transition.

This article provides a summary of recent market developments in China’s hydrogen sector, covering its value chain from production, storage, transport to end use application, government policy support to the industry, issues that are particularly challenging to the industry, as well as potential investment opportunities for foreign investors who are interested in participating in this booming market.

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This client alert has been prepared for clients and professional associates of Baker & McKenzie FenXun (FTZ) Joint Operation Office. Whilst every effort has been made to ensure accuracy, this client alert is not an exhaustive treatment of the area of law discussed and no responsibility for any loss occasioned to any person acting or refraining from action as a result of material in this presentation is accepted by Baker & McKenzie FenXun (FTZ) Joint Operation Office.


Stanley Jia is the chief representative of the Beijing office of Baker McKenzie. He has extensive experience working on foreign indirect investment projects in China, particularly those involving the energy, oil & gas and automotive sectors. Mr. Jia is ranked among the leading lawyers for corporate/ M&A in China by Chambers Asia Pacific, Chambers Global and Legal 500 Asia Pacific. He is also listed among the top lawyers for projects and energy in Legal 500 Asia Pacific, and for project finance in IFLR 1000.


Martin David is a principal in the Finance and Projects Practice Group at Baker McKenzie Wong & Leow and heads the Projects practice in Asia Pacific and Singapore. He is a former civil engineer and has market-leading experience in relation to greenfield IPPs in Asia, particularly in the renewables sector (wind and geothermal).


Li Zhang is a Special Counsel in Baker McKenzie Beijing office.


Kim Hock Ang is a principal in Baker McKenzie Wong & Leow's Finance & Projects Team, where he focuses on major infrastructure project development and energy projects development (including LNG), from the inception stage where the consortium is formed and investment structure is designed, to the project documentation, financing and sale of such brownfield asset post commercial operation date. Kim Hock has acted in several award-winning projects such as the Sarulla Geothermal Power Project. It is the largest single-contract geothermal power project in the world, and it won Finance Deal of the Year (Project) at the 2015 American Lawyer Asia Legal Awards, among other accolades.


Li Zeng is an associate of FenXun Partners which is a premier Chinese law firm. FenXun established a Joint Operation Office with Baker McKenzie in China as Baker McKenzie FenXun which was approved by the Shanghai Justice Bureau in 2015.

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