ISO Must Improve Their Hydrogen Methodology and Add Climate Safeguards

In December of last year, I was in Dubai to witness the launch of the International Organization for Standardization (ISO’s) Technical Specification for Hydrogen Emission at COP28. This was accompanied by a Declaration of Intent on Mutual Recognition of Certification Schemes for Renewable and Low-Carbon Hydrogen and Hydrogen Derivatives, signed by the U.S. and three dozen other countries. This is a big deal. It signals firm intent by signatory countries to start building the foundations for a global market for the trade of clean hydrogen and its derivatives like steel or ammonia—and they plan on doing so by first enabling the interoperability of different hydrogen standards around the world. ISO want their standard to play a role in that cooperation. However, despite the fanfare, the product released by ISO, which is currently under development into an ISO standard, lacks key environmental considerations and guardrails and is liable to be used to greenwash hydrogen that is not as clean as is claimed. 

The role of international standards

ISO is an international non-governmental organization that develops standards for products and processes that aim “to make lives easier, safer and better.” For example—the special sunglasses you likely used to view the solar eclipse last month should have been made to comply with ISO 12312-2, ISO’s standard for safe eyewear for direct observation of the sun. The standards that ISO develops, by consensus between the national standards bodies that make up its constituent members, can offer reassurance that a product or process meets certain requirements, such as protecting your eyes from the sun. 

The ISO methodology for measuring hydrogen emissions needs a revamp

Recently, ISO have turned their attention to hydrogen and the question of how to assess the greenhouse gas (GHG) impact of its production and use. In this case, the ISO are developing a standardized way to do this calculation or assessment of hydrogen’s GHG impacts. But ISO is emphatically not designing a certification scheme for what should qualify as “clean”, “green” or “low carbon” hydrogen, nor what kind of level of GHG impacts are acceptable for hydrogen to be part of the transition to a net zero GHG emissions world. These questions are much more likely to be tackled by national legislation or trade agreements than by voluntary standards produced by the ISO. 

Nonetheless, there is a clear benefit to different participants in the emerging global clean hydrogen market all using the same “measuring stick” to compare the impact of their products on a like for like basis, in order to facilitate a market for truly clean, low-carbon hydrogen and its derivatives. For that reason, it is important for ISO to reconsider some key aspects of their methodology and ensure that their “measuring stick” is capturing an accurate record of hydrogen’s impacts. Cooperation on standards is only positive for the climate if those standards are robust and accurately capture the emissions impacts of hydrogen production. 

Summary of our recommendations for ISO: transparency and accuracy

NRDC, alongside eight other environmental groups and hydrogen developers, have written a letter to ISO with our concerns about their hydrogen emissions accounting methodology, and our recommendations to ensure the interoperability of global standards in a manner that fosters the development of a durable, truly clean industry that is not tainted by underreported climate impacts. More detail can be found in the letter, but here is a summary of our key recommendations:

1. The standard is only a methodology for calculating hydrogen production’s lifecycle emissions; it is not a definition of what counts as clean hydrogen. This highly important limitation must be transparently communicated. Otherwise, there is a danger that the ISO standard is used to greenwash dirty hydrogen as “ISO compliant”—lending it an air of climate legitimacy—simply for having done a calculation.
2. The current proposed standard relies on underreported and underestimated national averages for methane leakage—a dangerous and potent GHG. ISO must require that methane leakage be reported with far more accuracy and granularity to avoid legitimizing the climate value of hydrogen projects that sweep substantial GHG emissions under the rug.
3. Fossil fuel-derived hydrogen production that relies on carbon capture and storage must be monitored for capture rates and permanence of sequestration to accurately verify the full climate impacts through a robust and uniform process. 
4. Hydrogen produced via the electrolysis of water must credibly and rigorously account for the emissions that the production process induces on the electricity grid. Otherwise, hydrogen projects can claim that they are powered by 100% clean energy and have zero emissions based on sleight of hand accounting schemes, while in reality driving substantial fossil fuel generation on the grid. This is a major topic of debate in the context of the U.S. IRA clean hydrogen tax credits and worldwide and cannot be wholesale ignored by ISO. If a hydrogen project wants to claim lower-than-grid-emissions or zero emissions for electricity inputs, then it must demonstrate that it is powered by new clean energy projects that are within reasonable proximity and generating electricity during the same hours as the hydrogen is being produced (refer to this blog for further detail on the importance of those three criteria).
5. The science is clear that when it leaks into the atmosphere, hydrogen has a significant indirect warming impact. ISO should therefore require that hydrogen emissions be separately measured and reported alongside the lifecycle assessment. If measurement is not possible, hydrogen emissions must at least be estimated. Once accurate measurement equipment is available to monitor on-site leakage rates, hydrogen’s warming impact must be fully integrated into the lifecycle assessment.
6. Stakeholder input should be improved, for example by making published documents available to civil society stakeholders working on these issues free of charge, not hidden behind a pricey paywall as is currently the case.

The ISO standard will be a key early marker in the buildout of a global clean hydrogen market. It is critically important that it orients the nascent market in a sound, climate-aligned direction, and steers clear of becoming an exercise in smoke and mirrors. At risk is both trust in the bona fides of hydrogen that is evaluated and marketed with this ISO methodology and trust in hydrogen as a climate solution at all.