Overall, RECS is of the opinion that the link between the cancellation of GOs and the claiming of the use of renewable electricity to produce hydrogen through electrolysis is not mentioned explicitly enough in this Delegated Act.

Unless this link is made clearer, there is a risk that this DA could be interpreted and implemented in such a way as to allow for double counting of the renewable attributes of a given unit of energy. Specifically, RECS’ response proposes changes to explicitly reference the need to always cancel guarantees of origin whenever claiming the use of a given MWh of renewable electricity.

RECS’ response to the DA can be downloaded here.