Introduction

In January 2023, the Ministry of New and Renewable Energy, Government of India (“MNRE”) issued the “National Green Hydrogen Mission” (“Mission”) – which laid down the vision and the foundational framework for the development of green hydrogen sector and its derivatives. The mission was aimed to undertake capacity building for a targeted production of  atleast 5 (five) million metric tonne (“MMT”) of green hydrogen per annum by 2030, with the potential increase of upto 10 (ten) MMT. The MNRE, subsequently, issued the “Green Hydrogen Standard for India” on August 18, 2023 (“Standards”), which defines “green hydrogen” to mean “hydrogen produced using renewable energy, including, but not limited to, production through electrolysis or conversion of biomass.” Under the Standards, India has set a relatively stricter threshold of “a well-to-gate emission” (i.e., including water treatment, electrolysis, gas purification, drying and compression of hydrogen) of not more than 2 kg CO2 equivalent/kg of hydrogen measured as an average over the previous 12 (twelve) months (“Emission Threshold”). The Standards contemplated a detailed methodology for measurement, reporting, monitoring, on-site verification and certification of green hydrogen and its derivates, which was to be issued by the MNRE. In accordance with the Standards, the MNRE has issued the “Green Hydrogen Certification Scheme of India” on April 29, 2025 (“Certification Scheme”).

The Certification Scheme aims to establish a standardized and credible framework for the certification of green hydrogen and consequently, sets out the methodology for the measurement, monitoring, reporting, on-site verification, and certification of green hydrogen projects. The MNRE will designate an implementing agency as the nodal authority responsible for monitoring and certification of green hydrogen projects based on the verification reports from accredited agencies.

Certification Scheme – Key Highlights

(i)      Scope – The Certification Scheme encompasses all aspects of a green hydrogen project, which ranges from production of green hydrogen to its compression, purification and on-site storage. However, the processes involved in the transportation and storage of hydrogen outside the project boundary, its subsequent conversion into carriers, reconversion and utilization have been exempted from the scope of the Certification Scheme.

(ii)     Applicability – The ‘green hydrogen certificate’ (i.e., the ‘final certificate’) contemplated under the Certification Scheme will be mandatory for the following green hydrogen facilities or producers^[1]:

(a)      those receiving any incentive or subsidy from the Government of India (under the “Strategic Interventions for Green Hydrogen Transition Scheme”) or any State government for production of green hydrogen;

(b)     those intending to sell or use green hydrogen in India;

(c)      those receiving any type of exemption or concession from the Government of India or any State government; and

(d)     those having consumers in India for partial quantity while the balance quantity is exported.

The Certification Scheme exempts the mandatory certification requirement in the following cases:

(a)      green hydrogen production facilities with an annual capacity of ≤10 tons, however, such production facilities may apply for the green hydrogen certificate on a voluntary basis;

(b)     producers exporting 100% (one hundred per cent) of their output without availing any incentives or concessions from the Government of India or any State government, however, this exemption is only for the ‘final certificate’ (as discussed below) and such producers are required to report their quantity of production and emissions^[2] in accordance with the importing country’s standards.

(iii)    Eligible Pathways – The Certification Scheme recognises (a) electrolysis, and (b) conversion of biomass, as the eligible pathways for production of green hydrogen. It, however, also clarifies that the choice of production pathway does not by itself guarantee compliance and production facilities are required to be designed, installed and operated in a manner which ensures compliance on a continual basis. Producers are allowed to propose new pathways to MNRE with necessary evidence and the technical committee is required to review and assess their inclusion in the list of eligible pathways.

(iv)    System Boundary – The “system boundary”^[3] adopted in the Certification Scheme includes all direct emissions and indirect emissions from electricity or fuel used during green hydrogen production. For green hydrogen produced through electrolysis, emissions from water treatment, electrolysis, purification, drying, compression, and on-site storage are to be included. For green hydrogen produced through conversion of biomass, the non-biogenic emissions arising from biomass processing, heat/ steam generation, conversion, on-site gas purification, drying, compression and on-site storage of hydrogen are to be included in the calculation.

The emissions from on-site conversion or use of input materials (e.g., water, catalysts, salts) brought within the project boundary will also be included in the emission intensity calculations. Producers are required to provide the final composition of the hydrogen produced as well as the pressure at which it has been produced to be documented on the certificate.

(v)     Materiality Threshold – Under the Certification Scheme, an emission source is considered immaterial if it contributes less than 1% (one per cent) of the Emission Threshold and collectively, all immaterial sources account for less than 5% (five per cent) of the Emission Threshold (for system boundaries as discussed above). However, if an emission source is within the 1% (one per cent) threshold but its exclusion would cause the total excluded emissions to exceed 5% (five per cent) of the Emission Threshold, that source must be treated as material and included in the emission intensity calculation. Similar emission sources are to be considered together to avoid multiple claims for exclusion, which when aggregated may exceed the materiality threshold.

(vi)    Renewable Energy Consideration – The Green Hydrogen Standard mandates the use of renewable energy^[4] (sourced from a renewable energy project and transmitted through a dedicated or common transmission line) for ‘green’ certification. Renewable energy certificates or carbon credits cannot be claimed as renewable energy sources, however, energy procured through the green tariff mechanism and power exchanges (such as, through Green Day Ahead Market) will be considered as renewable energy.

The producers can claim electricity to be from renewable energy sources, if: (a) the producer has executed 1 (one) or more power purchase agreements with renewable energy developers, whereby the electricity generated from the renewable energy projects is atleast equal to the amount of electricity that is being claimed as fully renewable (including transmission and distribution losses); and (ii) it can be demonstrated that the electricity consumption claimed has been effectively produced by such renewable energy projects. In case of electricity not certified as fully renewable, appropriate transmission and distribution losses are to be accounted for calculating the emission intensity.

The producer will be required to provide necessary certificates from the appropriate load despatch centre to evidence its green energy consumption. Any consumption of non-renewable energy during the course of operation of the green hydrogen facility and the consequent emissions are to be included in the overall emission intensity calculation.

(vii)   Evaluation Cycle and Emissions Quantification – The evaluation of emission intensity calculations are to be carried out on a financial year basis, and the period of evaluation cannot exceed more than 12 (twelve) months. However, producers can apply for ‘provisional certificate’ (as discussed below) on monthly basis.

The producers are required to estimate both emission and emission intensity associated with the hydrogen production by using the methodology outlined in the Certification Scheme. Where specific guidance has not been provided in the methodology, relevant Indian and ISO standards – such as IS/ISO 14064 (Parts 1, 2, 3) and ISO 19870:2023 will be applicable.

The producers are required to implement a “Green Hydrogen MRV framework” (i.e., a plan for quantification and monitoring of emissions), which should include details on the emission source streams, activity data monitoring, monitoring instruments, written procedure on data control, procedure on calibration of monitoring instruments, frequency of data monitoring and recording, emission factor details, etc. (“MRV Framework”). All critical monitoring equipment must be calibrated and certified by authorized agencies.

(viii) Monitoring and Verification – Producers are required to maintain detailed records of production, up to the point of captive use or sale to the first purchaser, for at least 5 (five) evaluation cycles or from the of date of commencement of operations (if the date of commencement is less than 5 (five) years). Producers are also required to: (a) specify whether the hydrogen has been converted into a hydrogen carrier for sale to the first purchaser; (b) maintain daily records of production, its parameters (physical and chemical) and energy consumption from various sources (both aggregated and disaggregated; and (c) track water and feedstock consumption, losses, and other key production details.

The Certification Scheme requires every producer to appoint a carbon verification agency accredited by the Bureau of Energy Efficiency (“ACV Agency”) by March 31, every year, to verify their emissions and status of compliance. The ACV Agency is required to carry out the verification in accordance with the MRV Framework and thereafter, submit the verification report and statement through the “Green Hydrogen Certification Portal”^[5].

(ix)    Certification Process – The Certification Scheme contemplates grant of certificates for the green hydrogen facility as well as the quantity of hydrogen produced, and covers different stages of the green hydrogen facility – from project inception to commissioning and operations. The categories of certificates are as follows:

(a)      Two-stage certification for green hydrogen facilities – concept certificate (at initial stage) and facility level certificate (at commissioning stage); and

(b)     Two-stage certification for quantity of hydrogen produced – provisional certificate and final certificate.

Each of the certificates to be issued under the Certification Scheme have been discussed in brief, below:

(a)      Concept Certificate – The concept certificate is a voluntary certificate issued at the design stage of a green hydrogen facility. It certifies that the facility’s design meets the requirements of the MRV Framework and can produce hydrogen in accordance with the requirements of the Standard. Producers can apply for this certificate any time after design/concept/FEED (front-end engineering design) has been approved and phased projects, at the same site, are allowed to obtain multiple concept certificates.

(b)     Facility Level Certificate – The facility level certificate is mandatory for green hydrogen production facilities and is a pre-requisite for obtaining a ‘provisional’ or ‘final certificate’. It certifies that the production facility has complied with the requirements of the MRV Framework and can produce hydrogen in accordance with the requirements of the Standard. For multi-phase projects at the same site, separate certificates are required to be obtained for each phase. Producers can apply for this certificate at any time after the “consent to operate” has been obtained for the facility in accordance with applicable laws.

(c)      Provisional Certificate – The provisional certificate is a voluntary, auto-generated certificate that producers can apply for through the “Green Hydrogen Certification Portal”, by submitting actual production data in accordance with the MRV Framework. It certifies that hydrogen produced during a specific period (i.e., minimum 1 (one) calendar month and maximum upto 11 (eleven) months) complies with the Standard. However, this certification is subject to final verification and approval by an ACV Agency. If the ‘facility level certificate’ has been obtained after the start of operations, the first provisional certificate will be issued from the date of receipt of the “consent to operate” and will be valid until the end of that calendar month.

(d)     Final Certificate – The final certificate is a mandatory certification to be obtained on annual basis for producers or facilities identified in paragraph (ii) discussed above. It certifies that the hydrogen produced by these facilities qualifies as ‘green’ and will only be issued if the average emission intensity stays within the Emission threshold for the relevant financial year.

Each final certificate will carry a unique identification for each 100Kg (one hundred kilograms) of hydrogen produced and will specify the project details, production year and emission intensity values. If the annual average emission intensity exceeds the threshold, the entire quantity of hydrogen produced during that financial year from the relevant facility will not qualify as green.

The final certificate is intended to serve as a label guaranteeing the origin of green hydrogen production and its chain of custody. The Certification Schemes provides that the final certificate can be transferred and can also be used to claim carbon credits under the Carbon Credit Trading Scheme, 2023 issued by the Ministry of Power, Government of India on June 28, 2023.

(x)     Non-Compliance and Consequences – MNRE or its designated agency can withdraw certificates issued to a producer or production facility in the following cases:

(a)      if the producer has been issued a provisional certificate in any one evaluation cycle, but the actual emissions for such cycle after the verification by the ACV Agency or review by the technical committee for the final certificate is ascertained to be above the Emission Threshold; and

(b)     if the producer has been issued atleast 1 (one) provisional certificate, but fails to apply for the final certificate within the deadline prescribed under the Certification Scheme.

In case of first non-compliance, the provisional certificate for that cycle will be withdrawn. If a second instance of non-compliance occurs within 3 (three) years of the first non-compliance, the producer will be barred from applying for a provisional certificate in the next evaluation cycle. Any provisional certificate already issued for that cycle will be cancelled, and the producer will be required to re-apply for a ‘facility level certificate’. In case of third or subsequent occurrence, MNRE reserves the right to impose additional penalties, including suspending the producer’s eligibility to apply for certificates for a defined period.

Footnotes:

[1] For the purposes of this note, the term “producer” means any entity setting-up green hydrogen production facilities in India.

[2] For the purposes of this note, the term “emission” means the release of greenhouse gases into the atmosphere as a result of the processes involved in the production of hydrogen.

[3] “System Boundary” has been defined under the Certification Scheme to mean “processes for Green Hydrogen production which are covered in the GHG emission intensity calculation.”

[4] The definition of “Renewable Energy” has been adopted in the Certification Scheme from the Standards, which defines it to mean “electricity generated from renewable sources, which is either stored in an energy storage system or banked with the grid as per the policy directive/regulations.”

[5] The Certification Scheme contemplates creation of a dedicated “Green Hydrogen Certification Portal” to implement the certification process and the verification of compliances to be fulfilled by green hydrogen producers.