  
  
INF/TE/SSD/W/30  
 
30 November 2023  
(23-8109) Page: 1/21 
  Original: English  
 
  
TRADE AND ENVIRONMENTAL SUSTAINABILITY STRUCTURED DISCUSSIONS (TESSD)  
COMMUNICATION FROM THE UNITED KINGDOM  
The following communication, dated 20 November 2023, is being circulated at the request of the 
delegation of the United Kingdom.  
 
_______________  
 
 
HYDROGEN ENERGY AND TRADE  
Technical non -paper by the United Kingdom  
Contents  
1   INTRODUCTION  ................................ ................................ ................................ ..........  2 
1.1   Executive summary  ................................ ................................ ................................ ... 2 
1.2   Hydrogen in meeting global decarbonisation efforts  ................................ ........................  2 
2   ROLE OF SERVICES  ................................ ................................ ................................ ...... 3 
2.1   Technical services  ................................ ................................ ................................ ...... 4 
2.2   Ancillary services  ................................ ................................ ................................ ....... 4 
3   CHALLENGES IN HYDROGEN TRADE AND UPTAKE  ................................ .......................  5 
3.1   Non-tariff measures in hydrogen trade  ................................ ................................ .........  5 
3.2   Barriers to uptake  ................................ ................................ ................................ ...... 7 
4   VALUE CHAIN DIAGRAMS  ................................ ................................ ............................  8 
4.1   Polymer Electrolyte Membrane (PEM) Electrolyser Plant  ................................ ..................  10 
4.2   On-Board High -Pressure Hydrogen Tank  ................................ ................................ ...... 13 
4.3   Polymer Electrolyte Membrane (PEM) Fuel Cell System  ................................ ..................  14 
4.4   Pressurised Alkaline Electrolyser Stack Value Chain Table  ................................ ...............  15 
4.5   Solid Oxide Electrolyser Value Chain Table  ................................ ................................ ... 16 
4.6   Green Hydrogen Supply Chain Model  ................................ ................................ ...........  17 
5   OVERVIEW OF EXISTING AND PLANNED CERTIFICATION SYSTEMS AND 
REGULATORY FRAMEWORKS FOR HYDROGEN, AMMONIA AND OTHER 
HYDROGEN -BASED FUELS  ................................ ................................ ..............................  19 
 
 
  INF/TE/SSD/W/30  
 
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  1  INTRODUCTION  
1.1  Executive summary  
This paper This paper explores some goods and services associated with production of and trade in 
hydrogen. We begin by summarising the importance of hydrogen technology in meeting global 
decarbonisation efforts. We describe environmental services which are notable a cross the hydrogen 
lifecycle and provide some examples  of barriers to trade and uptake. We also develop indicative 
'value chain diagrams ', describing goods and services across the hydrogen lifecycle.  
This paper is intended to contribute to our shared evide nce base. We welcome comments on this 
paper and collaboration with others to further develop this report, including exploring further barriers 
to trade and ideas to overcome them.  
This individual report follows from the UK 's earlier technical paper titled 'Building our evidence base 
around environmental goods '1, shared with TESSD in March 2023 and the technical paper on 
Offshore Wind2 shared with the TESSD in May 2023.  
1.2  Hydrogen in meeting global decarbonisation efforts  
Low carbon hydrogen can be produced using electrolysis (using low carbon electricity e.g. from 
renewables or nuclear) or from fossil fuels with carbon capture, utilization, and storage (CCUS). 
Alternative production methods may also be low carbon, such as biomass gasification and me thane 
pyrolysis subject to them meeting certain standards such as the UK 's domestic Low Carbon Hydrogen 
Standard.3 Whilst there are many methods to producing low carbon hydrogen, green hydrogen is 
the most sustainable, making it the ideal production metho d. It is likely to facilitate a fully 
decarbonised power sector due to the flexibility that hydrogen production and storage can provide.  
Hydrogen could be well suited for use in 'hard to abate ' sectors where other decarbonisation options 
are limited, incl uding heavy transport modes (such as aviation, maritime and heavy road freight). 
Hydrogen can serve as a thermal fuel, similar to natural gas, and could be used for electricity 
generation by employing modified gas turbines or fuel cells. Moreover, hydrogen  can be converted 
into various derivative fuels and feedstocks, such as ammonia. This versatility allows low -carbon 
hydrogen4 to integrate into current export value chains and facilitate decarbonised production of 
what have historically been emissions int ensive commodities, including steel, aluminium, and 
ammonia.5 
Hydrogen can be produced through electrolysis, a process that employs electricity to split water into 
hydrogen and oxygen; 'green hydrogen ' is produced when renewable electricity is used for th is 
process. When renewable electricity is used for this process, it enables the storage of renewable 
energy which can then be converted back into electricity when needed. In some cases, hydrogen 
production can also come from the storage of surplus renewabl e energy that would otherwise have 
been lost. This enables a more reliable and flexible power grid, allowing for integration of renewables 
into the wider energy system. Hydrogen is one of the few available options for storing electricity 
over days, weeks o r months .6 
 
1 INF/TE/SSD/W/23 . 
2 INF/TE/SSD/W/26 ; INF/TE/SSD/W/26/Add.1 . 
3 The UK Low Carbon Hydrogen Standard is just one of the many domestic standards globally. Many 
countries have their own domestic standards, and work is underway to develop interoperability between the 
various standards globally. More on this in Section 3.  
4 Low carbon hydrogen generally means any hydrogen produced with lower emissions than the 
incumbent fossil fuel -based methods. However, each country has its own de finition and standards for 
low-carbon hydrogen. See below for the UK Low -Carbon Hydrogen Standard and section 5 for an overview of 
hydrogen standards worldwide.  
5 'International Trade Rules for Hydrogen and its Carriers: Information and Issues for Conside ration', 
International Partnership for Hydrogen and Fuel Cells in the Economy , https://www.iphe.net/iphe -dp-h2-
trading -doc-feb-2022, pg. 14.  
6 https://www.iea.org/fuels -and-technologies/hydrogen . INF/TE/SSD/W/30  
 
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  In 2020, global demand for unabated hydrogen reached 90 million metric tons, primarily driven by 
the refining and chemicals sectors for ammonia7 and methanol production .8, 9 Currently, hydrogen 
used in these sectors is primarily derived from  fossil fuels, contributing to approximately 6% of 
global natural gas consumption, 2% of coal consumption, and approximately 830 million metric tons 
of annual CO2 emissions. Low -carbon hydrogen production represented less than 1% of total 
hydrogen producti on in 2022, but it has grown 5% compared to 2021.10 To advance the adoption of 
clean hydrogen technologies, such as electrolysers, fuel cells, and hydrogen production with CCUS, 
it is essential to scale -up low carbon hydrogen production technologies to red uce costs.11 
Hydrogen can be produced in a more diverse array of locations around the world than fossil fuels, 
which are more geographically linked to resource availability. As the costs of green hydrogen 
production decrease, there will be an influx of new  and diverse participants, making hydrogen more 
competitive.12 This affords new players opportunities to participate in the energy trade and could 
incite shifts in bilateral relations, global interdependence and political dynamics .13 Over 30 countries 
and regions have hydrogen strategies that cover import or export plans, indicating substantial future 
growth in cross -border hydrogen trade.  
According to a report by IRENA, Africa, the Americas, the Middle East, and Oceania have the 
strongest technical potent ial for the production of green hydrogen14, although the constraints on 
transporting it in a way that protects its low carbon credentials are expected to create low carbon 
hydrogen export opportunities for other global regions.15 However, the capacity to produce large 
quantities of low -cost green hydrogen varies considerably. While access to abundant renewable 
resources is advantageous in the race for clean hydrogen, it may not be sufficient. Other factors, 
including existing infr astructure, the current energy mix, capital costs, and access to necessary 
technologies, play significant roles.16  
2  ROLE OF SERVICES  
There is a wide variety of services required for the generation and use of hydrogen energy. Technical 
services in the hydrogen sector involve expertise in advanced technologies related to hydrogen 
production, storage, transportation, and utilisation. Ancil lary services in the hydrogen sector refer 
to various supporting functions and activities necessary to ensure the effective and reliable operation 
of hydrogen infrastructure and systems.  
 
7 Ammonia has many uses but about 80% ammonia produced is used in agriculture as fertiliser. 
Ammonia is produced in the Haber -Bosch process where  hydrogen is mixed with nitrogen and together 
processed at high temperature and pressure with a catalyst to produce ammonia.  
8 Methanol  (CH3OH) is a liquid chemical used in thousands of everyday products, including 
plastics,  paints, cosmetics and fuels. Hydrogen is used as a key ingredient in the production of methanol 
through a  process called hydrogenation. The most common method involves the reaction of carbon monoxide 
(CO) and hydrogen (H2) in the presence of a catalyst.  
9 'International Trade Rules for Hydrogen and its Carriers: Information and Issues for Consideration', 
International Partnership for Hydrogen and Fuel Cells in the Economy, https://www.iphe.net/iphe -dp-h2-
trading -doc-feb-2022, pg. 14. 
10 https://www.iea.org/energy -system/low -emission -fuels/hydrogen . 
11 https://www.iea.org/fuels -and-technologies/hydrogen . 
12 'Geopolitics of the Energy Transformation: The Hydrogen Factor', International Renewable Energy 
Agenc y, https://www.irena.org/Publications/2022/Jan/Geopolitics -of-the-Energy -Transformation -Hydrogen , 
pg. 10. 
13 Ibid., pg. 11. 
14 IRENA finds that these regions will be most able to generate cheap renewable electricity, thus best 
placed to produce competitive green hydrogen.  
15 Ibid., pg . 13. 
16 Ibid., pg . 13. INF/TE/SSD/W/30  
 
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  2.1  Technical services  
• Engineering:  Engineering services are used to des ign hydrogen energy systems. This 
includes the design of hydrogen production, storage, and transportation systems.17 
• Construction:  Construction services are used to build hydrogen energy systems. This 
includes the construction of hydrogen production facili ties, hydrogen storage tanks, and 
hydrogen refuelling stations.18 
• Operation and maintenance:  Operation and maintenance services are used to keep 
hydrogen energy systems running smoothly. This includes tasks such as refuelling hydrogen 
fuel cells, monitorin g hydrogen production systems, and repairing hydrogen storage tanks.19 
• Testing and certification:  Testing and certification services are used to ensure that 
hydrogen energy systems meet safety and performance standards. This includes tasks such 
as testing hydrogen production systems, hydrogen storage tanks, and hydrogen refuelling 
stations, and certifying that these systems meet relevant standards.20 
• Research and development:  Research and development is needed to develop new 
hydrogen energy technologies and  to improve the performance of existing hydrogen energy 
technologies. This includes tasks such as developing new methods for hydrogen production, 
storage, and transportation, and developing new hydrogen fuel cell technologies.21 
2.2  Ancillary services  
• Consulti ng: Consulting services are used to provide advice and guidance on hydrogen energy 
projects. This includes tasks such as identifying potential hydrogen energy projects, 
developing hydrogen energy project plans, and securing financing for hydrogen energy 
projects.22 
• Financing:  Financing services are used to provide funding for hydrogen energy projects. This 
includes tasks such as arranging loans, issuing bonds, and providing equity investments for 
hydrogen energy projects.23 
• Insurance:  Insurance services are  used to protect against financial losses associated with 
hydrogen energy projects. This includes tasks such as insuring hydrogen production facilities, 
hydrogen storage tanks, and hydrogen refuelling stations.24 
• Regulatory support:  Regulatory support is n eeded to ensure that hydrogen energy projects 
can be developed and operated safely and efficiently. This includes tasks such as developing 
regulations for hydrogen production, storage, and transportation, and providing guidance on 
how to comply with these regulations.25  
• Public engagement:  Public engagement is needed to raise awareness of the benefits of 
hydrogen energy and to build support for hydrogen energy projects. This includes tasks such 
as developing public awareness campaigns, and working with loca l communities to address 
any concerns about hydrogen energy projects.26 
 
17 UK Hydrogen Strategy,  
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1175494/
UK-Hydrogen -Strategy_web.pdf , pg. 25-29. 
18 Ibid. 
19 Ibid. 
20 Ibid. 
21 Ibid.  
22 Ibid. 
23 Ibid. 
24 Ibid. 
25 Ibid. 
26 Ibid. INF/TE/SSD/W/30  
 
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  These are just some of the ancillary and technical services that are required for the development 
and operation of the hydrogen sector. The demand for these services is expected to gro w rapidly in 
the coming years as the hydrogen sector grows.  
3  CHALLENGES IN HYDROGEN TRADE AND UPTAKE  
Challenges pertaining to growth of a hydrogen economy can be broken down into two broad 
categories – trade measures which includes both tariff and non -tariff barriers, and barriers to uptake. 
Non-tariff measures can impact the international trade of hydrog en-related products and services 
whilst a barrier to uptake refers to the obstacles in adopting and using hydrogen technologies. Both 
should be assessed holistically to develop a robust global hydrogen market. We remain clear, 
however, that non -tariff meas ures which affect trade in environmental goods may have been 
introduced for sound environmental rationale and may even ensure the environmental compatibility 
of such goods.  
3.1  Non-tariff measures in hydrogen trade 
• Standards and certification schemes for hydrogen: One of the leading trade barriers27, 
in this instance, is the lack of coherence in definition, standards and certification28 relating to 
hydrogen and hydrogen -related goods and services.  This issue and solutions for overcoming 
it are currently being considered in a number of multilateral forums, for example, the 
International  Partnership  for Hydrogen  and Fuel Cells in the Economy  (IPHE)29 and the 
Hydrogen Technical Collaboration Programme .30  
Product definition  is paramount; a product must be precisely characterised in a contract because if 
the product delivered does not match, this will be grounds for a trade dispute. There are presently 
different methods to categorise products. For instance:  
• Within the WTO fra mework, products are categorised by HS codes. The preceding process 
or production methods (PPM) and the subsequent use case are not normally included.  
• ISO develops voluntary, consensus -based, market relevant International Standards that 
comply with WTO pr inciples. They could be about producing a good, managing a process, 
delivering a service, or supplying materials but ISO does not provide conformity 
assessments or certifications.  
With hydrogen trade, both the physical characteristics and the GHG equivale nt emissions of the 
hydrogen are expected to need definition, and in some jurisdictions possibly the production 
technology.31 In terms of trade, there is a discrepancy between the Most -Favoured Nation (MFN) 
tariff rates at borders, which are based on the HS code of the good and do not include PPMs, and 
the market and regulatory systems developing for low carbon hydrogen behind b orders, where the 
GHG footprint (i.e. PPM) is becoming an important feature.32  
Presently, the colour scheme often used for hydrogen, such as "green" or "blue" hydrogen, implies 
a characterisation of the production route, but does not provide any quantific ation of its effect on 
 
27 Barriers to trade can be broadly broken into two categories - tariff and non -tariff barriers. Tariff 
barriers include import, export, specific, and ad valorem tariffs. Non -tariff barriers include product standards 
and regulations, customs procedures, intel lectual property protection, subsidies and dumping, anti -dumping 
duties etc. Technical trade barriers are a type of non -tariff barrier that include standards, certifications, and 
technical regulations like labelling and packaging. These are merely a few ex amples of trade barriers and are 
not exhaustive.  
28 Standards are established criteria that define the characteristics, performance, or quality of goods and 
services. They provide a common reference point and ensure consistency and uniformity in various ind ustries 
and sectors. Certifications are formal assessments or declarations by a third party, such as a certification body 
or authority that goods and services comply with specific standards or requirements.  
29 https://www .iphe.net/ . 
30 https://www.ieahydrogen.org/ . 
31 'International Trade Rules for Hydrogen and its Carriers: Information and Issues for Consideratio n', 
International Partnership for Hydrogen and Fuel Cells in the Economy, https://www.iphe.net/iphe -dp-h2-
trading -doc-feb-2022, pg. 22.  
32 Ibid., pg. 23. INF/TE/SSD/W/30  
 
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  emissions.33 Several certification systems, regulations and standards to define hydrogen using the 
emissions intensity as key indicator already exist or are under development ( refer to section 5) . 
Many share common features, such as emissions intensity as a crucial indicator, or a focus on 
hydrogen production, but vary on system boundaries or the emissions intensity levels imposed.34 If 
left unaddressed, this  may become a barrier as investments that will lead to trade in low -emission 
hydrogen will rely on international recognition of standards and certificates.35 
 
 
 
From a trade perspective, however, the precise nature of the standard is less pertinent than its 
existence. Allowing the key characteristics of a product to be defined means contracts can be drawn 
up for trade, helping to unlock the supply chain by reassuring both producers and end users that 
they are referring to the same product.36 As with all current trade, the burden  of greenhouse gas 
emissions will vary for different combinations of hydrogen production and use. Mechanisms to 
recognise and price both embedded and cross -border emissions will affect hydrogen trade as they 
will other commodities.37 Developing definitions  based on a common methodology or agreed 
standard to determine the GHG intensity of hydrogen can simplify the certification process, and an 
ISO technical specification38 is currently under development. A common definition would allow for 
comparison of the emissions intensities between different production pathways and producers, while 
still leaving governments the possibility to define acceptable emissions intensity level s, taking into 
account local circumstances and opportunities. Countries may set different thresholds but use a 
 
33 'Towards hydrogen definitions based on their emissions intensity' , International Energy Agency, 
https://www.iea.org/reports/towards -hydrogen -defini tions-based -on-their-emissions -intensity , pg. 33. 
34 Ibid. 
35 https://www.iea.org/energy -system/low -emission -fuels/hydrogen   
36 'International Trade Rules for Hydrogen and its Carriers: Information and Issues for Consideration', 
International Partnership for Hydrogen and Fuel Cell s in the Economy, https://www.iphe.net/iphe -dp-h2-
trading -doc-feb-2022, pg. 25. 
37 Ibid. 
38 https://www. iso.org/standard/65628.html . Case Study: The UK Low Carbon Hydrogen Standard (LCHS)  
 
In April 2022, the UK Government published the  LCHS  to ensure that low carbon hydrogen 
production contributes to the UK 's carbon red uction targets. The standard was published as 
guidance and is used as an eligibility criteria for Government subsidy schemes, such as the Net 
Zero Hydroge n Fund  and the Hydrogen Production Business Model.  
 
The LCHS establishes two key things:  
 
• A threshold of 20gCO2e/MJ LHV for "well-to-gate" emissions (i.e. emissions from hydrogen 
production), and  
• A methodology for calculating emissions.  
The standard was designed to balance environmental integrity with burden to industry. 
Consultation  with industry stakeholders and experts showed that the 20gCO2e/MJ LHV threshold 
and accompanying methodological choices achieves bal ance and encourages growth by 
supporting market development.  
 
In the absence of a common international standard for low carbon hydrogen, the UK developed 
the LCHS in a way to support the UK 's ambition to have 10GW production capacity by 2030. The 
standard however is in -keeping with the IPHE methodology  for production emissions and the UK 
committed in its recent Update to Market  to keepi ng both standards and certification aligned 
internationally, where appropriate.  
 
The UK intends to update the LCHS at regular review points to ensure it remains fit for purpose 
and reflects the growing understanding of how new technologies  work in practic e. Version 2 of 
the LCHS was published in April 2023, and Version 3 is currently being developed in consultation 
with key stakeholders.  INF/TE/SSD/W/30  
 
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  common methodology to determine emissions intensity, which would ensure interoperability 
between different countries.39  
Clear regulations and ce rtification systems based on the emissions intensity of hydrogen production 
can bring much -needed transparency, which also acts as reassurance to enable investments in 
production and demand applications, as well as investment in hydrogen trade infrastructu re.40 
Interoperability in this context can help hydrogen producers to reach offtake agreements with 
multiple potential clients in different markets, without the need to certify their product individually 
for each client, region and regulatory authority.41 Work has begun within international forums to 
coordinate solutions for interoperability between schemes, with the UK playing an active role in work 
under the IPHE 's Hydrogen Certification Mechanisms Taskforce42 and the Hydrogen TCP 's Hydrogen 
Certification  Task43 which are looking at gaining a deeper understanding of certification mechanisms 
across the globe and the development of a "Mutual Recognition Framework".  
• Framework for the recognition of skills in hydrogen services: As renewable energy 
targets incr ease globally, the availability of skilled workers risks becoming a bottleneck for 
deployment . Hiring fresh talent is proving difficult; businesses are hiring from the utilities and 
the industrial sector because the transfer of skills from traditional sec tors to renewable energy 
is more direct.44 
OPITO, a UK -based skills body for the energy sector, is working towards a Skills Passport, which will 
streamline the transfer of skills and address the lack of recognition of cross -sector skills. For 
instance, this passport will support oil and gas workers who, through their choice or the natural 
reduction of jobs, will need to move to another energy sector. Specifically, the Energy Skills Passport 
will display a worker 's current qualifications and the  required credentials to transition into another 
energy sector, proving workers have recognised qualifications and training needed to access 
worksites.45 
Aside from technical skills, the absence of regulations and policies can also act as a barrier to the 
development of a hydrogen economy, especially in the case of developing countries; there is, thus, 
a need for skilled workers performing ancillary services like regulatory support, financing, and 
consulting etc.  
When considering hydrogen trade barriers, M embers should work through existing fora to address 
the need for a single framework to recognise skills and standards across the renewable energy 
sector; harmonising standards and certifications of skilled workers could be crucial in addressing the 
barrier  to trade in hydrogen services.  
3.2  Barriers to uptake  
• Electrolyser Availability:  Stakeholders have expressed a concern that the global availability 
of electrolysers for hydrogen production could lead to a bottleneck as global hydrogen 
production ramps up.46 There are currently thirty -one countries with a hydrogen strategy, of 
which fifteen have electrolyser -specific targets, and eighteen countries currently in the process 
of developing strategies.47 The IEA 's projected global hydrogen demand by 204048 against 
 
39 'Towards hydrogen definitions based on their emissions intensity' , International Energy Agency, 
https://www.iea.org/reports/towards -hydrogen -definitions -based -on-their-emissions -intensity , pg. 34. 
40 Ibid., pg. 30. 
41 Ibid, pg . 31. 
42 https://www.iphe.net/working -groups -task-forces . 
43 https://www.ieahydrogen.org/task/task -47-hydrogen -certification/ . 
44 https://www.spglobal.com/marketintelligence/en/news -insights/latest -news-headlines/skills -
shortage -imperils -global -energy -transition -71565735 . 
45 https://opito.com/media/news/opito -awarded -5-million -through -just-transition -fund-to-deliver -
energy -skills-passport . 
46 https://www.spglobal.com/marketintelligence/en/news -insights/latest -news-headlines/electrolyzer -
manufacturing -could -become -bottleneck -in-global -hydrogen -ramp-up-70893243 . 
47 2022 Update from Bloomberg NEF, https://about.bnef.com/blog/us -states -aiming -for-100-clean-
power -total-22/. 
48 International Energy Agency, Global demand for hydrogen from electrolysis and fossil fuels with CCUS 
by scenario, 2030 and 2040  (Oct 2020), https://www.iea.org/data -andstatistics/charts/global -demand -for-
hydrogen -from-electrolysis -and-fossil-fuelswith -ccus-by-scenario -2030-and-2040. INF/TE/SSD/W/30  
 
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  planned electrolyser projects by developers highlights that currently less than half of the 
expected future hydrogen demand would be met by the planned electrolyser project pipeline 
(45%).49 A lack of availability of affordable raw minerals has been cited as a reason for the 
shortage of electrolysers; the green hydrogen sector has to compete with other green 
industries for access to the same raw materials.50  
• Lack of Transport and Storage Infrastructure: As a response to the Hydrogen Production 
Business Model consultation51, experts working on hydrogen in the UK government noted a 
lack of transport and storage (T&S) infrastructure acting as a potential barrier to the 
widespread use of low carbon hydrogen, as a result of which the UK is now develo ping T&S 
Business Models.  This barrier to uptake is not limited to the UK; globally there are only about 
5,000 kilometres of hydrogen transmission pipelines around the world (compared with more 
than 3 million kilometres for natural gas)52 and only 470 hydr ogen refuelling stations.53 
Natural gas infrastructure could be repurposed for hydrogen but not all regions of the world 
have existing infrastructure.54, 55 
4  VALUE CHAIN DIAGRAMS  
We introduced value chain diagrams for environmental goods in our technical pa per titled 'Building 
our evidence base around environmental goods '56, as a powerful tool for organising key information 
relating to goods.  
Value chain diagrams visualise and describe a range of manufacturing activities or production 
processes that are appl ied to raw material inputs and intermediate products as these are 
transformed into final goods, which  combine to form technological solutions to environmental 
challenges.  
These diagrams describe both goods and services, production and trade. They can there fore drive 
research into trade barriers and connected problems and can be used to hold information through 
annotations to the diagrams.  
By bringing together these different kinds of information, they can deepen our understanding of the 
relationship between  goods, services, production, trade – and the environment, and can help us 
develop better and more coordinated trade, industrial, and environmental policies.  
The value chain diagrams in this section have been annotated with commodity codes for illustrative  
purposes only . Simple names of products are generally insufficient for seeking formal classification 
opinions because they do not contain an explanation of the product 's essential characteristics. These 
characteristics would need to be compared with the explanatory notes of the harmonised system to 
seek a formal opinion.  
The information within these diagrams is sourced from four sources: the Advance Propulsion Centre 's 
report on fuel cells and hydrogen tanks57, the Scottish governments paper on Electrolysers58 and 
 
49 Bloomberg NEF 'Hydrog en Production Database ' (Jan 2022),  https://www.bnef.com/interactive -
datasets/2d5fb18e5f001461?datahub=2d5fb18e5f001462&tab=H2%20%2B%20CCS .  
50 https://www.spglobal.com/marketi ntelligence/en/news -insights/latest -news-headlines/electrolyzer -
manufacturing -could -become -bottleneck -in-global -hydrogen -ramp-up-70893243 . 
51 https://www.gov.uk/government/publications/hydrogen -production -business -model . 
52 IRENA (2021), 'Making the breakthrough: Green hyd rogen policies and technology costs' , 
https://www.irena.org/ -
/media/Files/IRE NA/Agency/Publication/2020/Nov/IRENA_Green_Hydrogen_breakthrough_2021.pdf?la=en&ha
sh=40FA5B8AD7AB1666EECBDE30EF458C45EE5A0AA6 , pg. 24.  
53 Ibid.  
54 Ibid. 
55 Although natural gas pipelines can be repurposed for transporting  hydrogen, countries must be 
mindful about repurposing natural gas infrastructure to ensure we still maintain security of supply for gas.  
56 INF/TE/SSD/W/23 . 
57 Advance Propulsion Centre UK, 'Automotive fuel cell system and hydrogen tank value chains ', 
https://www.apcuk.co.uk/app/uploads/2021/10/APC -Fuel-Cell-Value -Chain -Report.pdf . 
58 'Assessment of Electrolysers', Scottish  Government, https://www.gov.scot/publications/assessment -
electrolysers -report/pages/1/ . INF/TE/SSD/W/30  
 
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  the National Renewable Energy Laboratory 's (NREL) paper on PEM Electrolysers59, and Optimat 's 
paper on Supply Chains to Support a Hydrogen Economy .60 This publication builds on that by 
applying a value chain framework to the contents of these papers and annotating these value chains 
with relevant trade policy information, as illustrated by the com modity codes. This paper also 
contains supply chain map on setting up a green hydrogen plant.  
Note: the commodity  codes in these diagrams are for illustrative purposes only. The classification of 
these goods has not been quality assured by customs classif ication experts.  
 
59 National Renewable E nergy Laboratory, 'Manufacturing Cost Analysis for Proton Exchange Membrane 
Water Electrolyzers ', https://www.nrel.gov/docs/fy19osti/72740.pdf . 
60 Optimat, 'Supply Chains to Support A Hydrogen Economy' , 
https://assets.publishing.service.go v.uk/government/uploads/system/uploads/attachment_data/file/1092371/s
upply -chains -to-support -uk-hydrogen -economy -wood -template.pdf .   
  INF/TE/SSD/W/30  
 
- 10 - 4.1  Polymer Electrolyte Membrane (PEM) Electrolyser Plant  
Electrolysers can convert the electricity provided from renewable energy sources into chemical energy and combined with fuel cells could transform hydrogen 
back into electricity. This system should lead to an efficient storage and rapid wider diffusion of the electricity to the gr id.61 
A PEM electrolyser cell stack has a number of components, these include a c athode, an anode and a selectively permeable proton exchange membrane, as well 
as cell separators or bipolar plates, and flow distributors such as porous transport layers (PTL 's). Depending on the application and energy source PEM electrolysers 
can be scal ed up or down utilising multiple stacks to produce the energy output required. Water is fed consistently into the electrolyse r and is split by an electrical 
current into its component molecules hydrogen and oxygen. At the anode the water reacts to form oxy gen, positively charged hydrogen ions (protons) and 
electrons. The electrons then flow around an external circuit and the hydrogen ions move across the selectively permeable mem brane to the cathode where they 
recombine with the electrons to form hydrogen g as. This gas can then be used straight away or stored as a liquid or gas for future use.62 
PEM electrolysers are already commercially available.  
Diagram  1 is a value chain of the materials and processes involved in making a PEM electrolyser stack . Diagram  2 is a value chain of the components and 
processes involved in assembling the entire PEM electrolyser plant . 
 
  
 
61 https://www.sciencedirect.com/science/article/abs/pii/S0959652620312312 . 
62 https://www.tfphydrogen.com /news -insights/blogs/the -process -of-pem-electrolysers -and-the-benefits -of-them.   
  INF/TE/SSD/W/30  
 
- 11 - Diagram 1  
 
  
  
  INF/TE/SSD/W/30  
 
- 12 - Diagram 2  
 
  
  
  INF/TE/SSD/W/30  
 
- 13 - 4.2  On-Board High -Pressure Hydrogen Tank  
This is an annotated value chain of on -board hydrogen which provides the relevant carbon fibre production processes for tank manufacturing. These tanks to 
store compressed hydrogen gas in Hydrogen Fuel Cell Electric Vehicles; the compressed hydrogen gas is then converted into ele ctricity by an on -board fuel cell 
system.  
 
 
  
  
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- 14 - 4.3  Polymer Electrolyte Membrane (PEM) Fuel Cell System  
The fuel cell value chain covers all critical steps required to manufacture membrane electrode assemblies (MEA) and complete assembly of fuel cell system in a 
vehicle. This fuel cell system converts the hyd rogen gas stored in the hydrogen on -board tank into electricity that powers the Hydrogen Fuel Cell Electric Vehicles, 
in contrast with a regular electric vehicle which draws its electricity from a battery.  
 
  
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- 15 - 4.4  Pressurised Alkaline Electrolyser Stack Value Ch ain Table  
Alkaline electrolysers are a more mature technology with a long history of deployment in the chlor -alkali industry. This value chain table identifies the 
subcomponents, materials, and manufacturing activity and their related trade codes in producing an ALK  electrolyser stack. The ancillary components that make 
up an ALK electrolyser plant are similar to a PEM electrolyser; the main difference between ALK and PEM electrolysers is the materials used in making the 
electrolyser stacks.  
 
Pressurised Alkaline Ele ctrolyser Stack  
Sub-component  Materials  HS/CN Code  Services/  CPC Code  
Anode  Nickel -coated 
perforated stainless 
steel CN 7220902090  Metal mining and 
processing, metal 
coating  metal mining and processing - CPC 8621, 
ISIC 05, 07, 08  
metal coating - CPC 88731, ISIC 2592  
Cathode  Nickel -coated 
perforated stainless 
steel CN 7220902090  Metal mining and 
processing, metal 
coating  metal mining and processing - CPC 8621, 
ISIC 05, 07, 08  
metal coating - CPC 88731, ISIC 2592  
Electrolyte  Potassium hydroxide 
5-7 molL -1 CN 2815200000  Chemical processing  Chemical processing - CPC 88421 or CPC 
88427  
Separator  Zr02 stabilized with 
PPS mesh  ZrO2 (Zirconium 
Dioxide) - CN 
2825600010  
PPS Mesh 
(Polyphenylene Sulfide 
Mesh) -  Metal mining and 
processing  metal mining and processing - CPC 8621, 
ISIC 05, 07, 08  
Porous transport layer 
anode  Nickel mesh (not 
always present)  CN 8543900000 or 
7508900000  Metal mining and 
processing  metal mining and processing - CPC 8621, 
ISIC 05, 07, 08  
Porous transport layer 
cathode  Nickel mesh  CN 8543900000 or 
7508900000  Metal mining and 
processing  metal mining and processing - CPC 8621, 
ISIC 05, 07, 08  
 
    
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- 16 - 4.5  Solid Oxide Electrolyser Value Chain Table  
The core component of a SOE is a solid oxide electrolyte. This is typically a ceramic material that conducts oxygen ions at high temperatures (typically around 
500-1000°C or 932 -1832°F). The solid oxide electrolyte serves as a barrier between the anode and cathode compartments and allows oxygen ions to move 
through it while blocking the passage of electrons. Solid Oxide Electrolysis (SOEC) is quickly approaching commercialisation.  This value chain table identifies the 
subcomponents, materials, and manufacturing activity and their related trade codes i n producing a solid oxide electrolyser stack.  
 
Solid Oxide Electrolyser Stack  
Sub-component  Materials  HS/CN Code  Services  CPC Code  
Fuel 
electrode/Cathode  Nickel Oxide + Yttria - Stabilised 
Zirconia (YSZ)  Nickle Oxide - CN7501200000  
Yttria - Stabilised Zirconia (YSZ) - 
HS280530  Ceramics, metal 
coating  ceramics - CPC 88534, ISIC 
2393 
metal coating - CPC 88731, 
ISIC 2592  
Electrolyte  YSZ HS280530  Ceramics, metal 
coating  ceramics - CPC 88534, ISIC 
2393 
metal coating - CPC 88731, 
ISIC 2592  
Oxygen 
electrode/Anode  lanthanum strontium cobalt 
ferrite (LSCF)/ lanthanum 
strontium manganate (LSM)  lanthanum strontium cobalt ferrite 
(LSCF) - 2846904000 or 2846909000  
lanthanum strontium manganate 
(LSM) - 2846904000  or 2846909000  Ceramics, metal 
coating  ceramics - CPC 88534, ISIC 
2393 
metal coating - CPC 88731, 
ISIC 2592  
Current collector  Silver/gold/platinum/nickel 
mesh  silver mesh - 8543900000 or 
7106920000  
gold mesh   -8543900000 or 
7108138000  
platinum mesh -8543900000 or 
7110198000  
Nickel mesh -8543900000 or 
7508900000  Precision engineering  CPC 83322, ISIC 7110  
Sealing gasket  Mica/thermiculite  Mica- 2525 
Thermiculite - this is a brand product - 
cannot find HS details  Ceramics, precision 
engineering  ceramics - CPC 88534, ISIC 
2393 
precision enginee ring- CPC 
83322, ISIC 7110  
Interconnector  Stainless steel  HS 7218  Precision engineering  CPC 83322, ISIC 7110  
 
    
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- 17 - 4.6  Green Hydrogen Supply Chain Model63 
This is a supply chain of a green hydrogen plant; it details the goods and services involved at every stage of setting up a green hydrogen plant. Diagram 3 is the 
first part and is continued by diagram 4 below.  
Diagram 3  
 
 
63 Optimat, 'Supply Chains to Support A Hydrogen Economy', 
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/at tachment_data/file/1092371/supply -chains -to-support -uk-hydrogen -economy -wood -template.pdf , 
pg. 122.  
  
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- 18 - Diagram 4  
 
 
  
  
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- 19 - 5  OVERVIEW OF EXISTING AND PLANNED CERTIFICATION SYSTEMS AND REGULATORY FRAMEWORKS FOR HYDROGEN, AMMONIA AND OTHER 
HYDROGE N-BASED FUELS64 
 
64 'Towards hydrogen definitions based on their emissions intensity ', International Energy Agency, https://www.iea.org/reports/towards -hydrogen -definitions -based -on-
their-emissions -intensity , pg. 63. Purpose  Name  Market/  
jurisdiction  System 
boundary  Product  Demand 
sector  Status  Chain of 
custody  Production  
pathways  Emissions 
intensity 
level (kg 
CO2 -eq/kg 
H2) 
Regulatory  UK Low Carbon Hydrogen 
Standard; UK Low Carbon 
Hydrogen Certification 
Scheme  United 
Kingdom  Well -to-gate Hydrogen   
Operational 
(certification scheme 
under development)   
Electrolysis, natural gas with 
CCUS, biomass and waste  2.4 
Regulatory  Renewable Transport Fuel 
Obligation  United 
Kingdom  Well -to-point 
of delivery  Hydrogen  Transport  Operational  Mass balancing  Renewable energy excluding 
bioenergy  4.0 
Regulatory  EU Taxonomy  European 
Union  Well -to-gate Hydrogen   
Operational   
All 3.0 
    
Hydrogen - based 
synthetic fuels      
3.4 
Regulatory  Renewable Energy Directive  European 
Union  Well -to-wheel  Hydrogen, 
hydrogen - based 
synthetic fuels   
Under development  Mass balancing  Renewable electricity: low - 
carbon electricity (<65g 
CO2 -eq/kWh)  3.4 
        Compressed H2 from SMR 
w/o CCUS using natural gas  14.1 
        Liquefied H2 from SMR w/o 
CCUS using natural gas  18.1 
        Compressed H2 from SMR 
w/o CCUS using biomethane  11.9 
Regulatory  Low-carbon fuel standard 
(LCFS)  California 
(United 
States)  Well-to-wheel  Hydrogen  Transport  Operational  Book -and- 
claim  Liquefied H2 from SMR w/o 
CCUS using biomethane  15.5 
        Compressed H2 from 
electrolysis using grid 
electricity  19.8 
        Compressed H2 from 
electrolysis using solar or 
wind electricity  1.3 
Regulatory  Clean Hydrogen Production 
Tax Credit  United States  Well-to-gate Hydrogen   Under development   All 2.5-4 2.5 -1.5 
1.5-0.45 <0.45    
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- 20 - Regulatory  Clean Hydrogen Investment 
Tax Credit  Canada  Well-to-gate Hydrogen 
Ammonia   Under development   Electrolysis, natural gas with 
CCUS  2-4 0.75 -2 
<0.75 <4  
Regulatory  France Ordinance No 2021 -
167 France  Well -to-gate 
including 
manufacturing 
of technologies  Hydrogen  All sectors  Under development  Book -and- 
claim and mass 
balancing  All High -carbon 
hydrogen: > 3 
H2 regardless 
of energy 
source Low -
carbon 
hydrogen: s 
3.38 H2. 
regardless of 
energy source 
Renewable 
hydrogen: s 
3.38 H2. from 
renewable 
sources  
Funding 
programme  H2Global  International  Well -to-point 
of delivery  Ammonia 
methanol 
synthetic 
kerosene   Operational  Mass balancing  Renewable electricity  3.0 
Voluntary  Zero Carbon Certification 
Scheme (Smart Energy 
Council)  Australia  Well -to-gate Hydrogen 
ammonia, steel   Operational  Mass balancing  Renewable electricity  - 
Voluntary  Guarantee of Origin 
certificate scheme 
(Australian Government)  Australia  Well -to-gate Hydrogen, 
hydrogen 
carriers   Under development  Mass balancing  Renewable electricity  - 
Voluntary  Standard and Evaluation of 
Low- Carbon Hydrogen 
Clean Hydrogen and 
Renewable Hydrogen (China 
Hydrogen Alliance)  China  Well -to-gate Hydrogen   Operational  Not specified  All Low-carbon 
hydrogen: 14.5 
Renewable 
hydrogen clean 
hydrogen: 4.9  
Voluntary  CertifHy  European  
Union  Well -to-gate Hydrogen   Operational  Book -and- 
claim  Renewable electricity  Green 
hydrogen: 4.4  
Nuclear electricity, fossil 
fuels with CCUS  Low-carbon 
hydrogen: 4.4  
Voluntary  Low-carbon hydrogen 
certification system (Aichi 
Prefecture  Japan  Well -to-gate Hydrogen   Operational  Book -and- 
claim  Renewable electricity. biogas  - 
Voluntary  Green Hydrogen Standard 
(Green  
Hydrogen Organisation)  International  Well -to-gate Hydrogen   Operational  Not specified   
Renewable electricity  1 
Ammonia   Under development   0.3 kg CO2 -
eq/kg N Hs    
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- 21 -  
 
__________  Voluntary  Climate Bonds Standard & 
Certification Scheme  International  Well -to-gate Hydrogen   Operational   Electrolysis, natural gas and 
waste biomass  2022: 3.0 
2030: 1.5 
2040:0.6 
2050:0.0  
 
 
 
 
 
 
 
Voluntary   
 
 
 
 
 
 
SUD TÜV CMS 70   
 
 
 
 
 
 
European  
Union   
 
 
Well -to-gate  
 
 
 
 
 
 
 
Hydrogen    
 
 
 
 
 
 
 
Operational   
 
Book -and- 
claim  Renewable electricity  1.1 
Transport  Biomethane, glycerine  2.3-3.4 
Outside  Renewable electricity  1.1 
transport  Biomethane glycerine  2.1-3.2 
 
 
Well -to-point  
of delivery    
 
Mass  
balancing  Renewable electricity  2.8 
Transport  Biomethane, glycerine  4.5-5.6 
Outside  Renewable electricity  2.7 
transport  Biomethane, glycerine  4.3-5.4 
Voluntary  World Business Council of 
Sustainable Development  International  Well -to-gate Hydrogen   Proposal  Not specified  All Reduced -
carbon 
hydrogen: 6 
Low-carbon 
hydrogen: 3 
Ultra -low-
carbon 
hydrogen: 1  
Voluntary  Ammonia Energy 
Association  International  Well -to-gate Ammonia  All sectors  Under development  Not specified  All  