Hydrogen readiness: a Trojan horse for fossil fuel lock-in

The report analyzes the emergence of 'hydrogen readiness'—the declared ability of infrastructure to use hydrogen in the future—within EU law, private finance, and national policies. It argues that the concept is often used as a 'Trojan horse' to justify the continued construction and subsidization of fossil gas assets. The author identifies significant risks, including carbon lock-in, price volatility, and external energy dependencies, and concludes that the term should be abandoned unless assets can use 100% hydrogen from the outset.

• Hydrogen readiness is increasingly integrated into EU policy and law, including the TEN-E Regulation, the Sustainable Finance Taxonomy, State aid guidelines, and various EU funds such as the Recovery and Resilience Facility and the Cohesion Fund.
• The report defines hydrogen readiness generally as the 'declared ability of certain equipment or infrastructure to use hydrogen in the future,' but notes that the concept lacks a widely accepted definition and is often applied in an inconsistent and permissive manner.
• The use of 'hydrogen readiness' creates a 'lock-in risk' where long-lived fossil gas assets are maintained, potentially preventing climate targets from being met because hydrogen may be produced from fossil gas or may not be available at an economical price.
• Technical and economic barriers make the 'hydrogen economy' challenging: hydrogen production is energy-intensive, and converting existing fossil gas pipelines is complex and often economically unjustified due to issues like steel corrosion and leakage.
• The European Commission's application of hydrogen readiness in State aid decisions is described as 'very weak,' often approving aid for LNG terminals based on vague commitments to convert in the far future or non-public agreements.
• Germany has heavily adopted the concept in national law, using it to justify the LNG Acceleration Act and subsidies for CHP plants and gas boilers, though the report argues these commitments are often not 'legally padlocked.'
• The report identifies several other critical risks: price risk due to uncertain hydrogen costs, external dependency risk as hydrogen will mostly be imported, and financial risks such as asset stranding and litigation.
• The author recommends abandoning the 'hydrogen readiness' concept entirely unless infrastructure can use 100% hydrogen from the start. If the term is kept, the report proposes strict safeguards including firm conversion deadlines, upfront financing for conversion costs, and independent auditing.

APA

Burman, T., Jones, S. H., Nieuwbourg, S., & Ramo, G. (2025). Hydrogen readiness: a Trojan horse for fossil fuel lock-in. ClientEarth. https://www.clientearth.org/media/ykrhwrs5/raport-hydrogen-2025-04-_finall.pdf

Chicago

Burman, Thomas, Sam Hunter Jones, Stéphanie Nieuwbourg, and Guillermo Ramo. Hydrogen readiness: a Trojan horse for fossil fuel lock-in. ClientEarth, 2025. https://www.clientearth.org/media/ykrhwrs5/raport-hydrogen-2025-04-_finall.pdf.

Wikipedia

{{cite report |last1=Burman |first1=Thomas |last2=Jones |first2=Sam Hunter |last3=Nieuwbourg |first3=Stéphanie |last4=Ramo |first4=Guillermo |title=Hydrogen readiness: a Trojan horse for fossil fuel lock-in |publisher=ClientEarth |date=April 2025 |url=https://www.clientearth.org/media/ykrhwrs5/raport-hydrogen-2025-04-_finall.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{burman2025hydrogen, author = {Burman, Thomas and Jones, Sam Hunter and Nieuwbourg, Stéphanie and Ramo, Guillermo}, title = {{Hydrogen readiness: a Trojan horse for fossil fuel lock-in}}, institution = {ClientEarth}, year = {2025}, month = apr, url = {https://www.clientearth.org/media/ykrhwrs5/raport-hydrogen-2025-04-_finall.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }