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3.2
Enabling ActivityC25, C27, C28

Manufacture of Equipment for the Production and Use of Hydrogen

Manufacturing electrolysers, fuel cells, purification equipment, and storage systems for clean hydrogen production and utilisation.

Substantial Contribution to Climate Change Mitigation

The activity covers the manufacture of hydrogen-related equipment including electrolysers for water electrolysis, hydrogen fuel cells, hydrogen purification and separation systems, hydrogen refuelling stations, and hydrogen storage tanks (both compressed gas and liquid). As an enabling activity, the manufactured equipment must directly enable hydrogen production or end-use with substantially lower lifecycle GHG emissions than fossil fuel alternatives.

Electrolysers must demonstrate system efficiency consistent with BAT levels (currently at least 65% LHV efficiency for PEM and alkaline technologies). Fuel cells must meet minimum power density and degradation-rate benchmarks defined in Clean Hydrogen JU specifications. The manufactured equipment must be compatible with hydrogen produced from renewable or low-carbon sources achieving lifecycle emissions below 3 tCO2e/tH2 as specified in the Delegated Acts under the Renewable Energy Directive (RED II/III).

The economic activity must not lead to lock-in of carbon-intensive assets. A lifecycle assessment in accordance with ISO 14040/14044 may be required to confirm net climate benefit over the equipment's operational lifetime.

Substantial Contribution to Climate Change Adaptation

The activity must comply with Appendix A of the Climate Delegated Act. A CRVA must be performed covering the manufacturing site and its supply chain exposure to physical climate hazards under RCP 8.5 projections.

DNSH: Climate Change Adaptation

A climate risk and vulnerability assessment in accordance with Appendix A must identify material physical climate risks to the manufacturing facility, including temperature extremes, flooding, and supply chain disruptions from climate events. Appropriate adaptation solutions must be implemented.

DNSH: Water and Marine Resources

The activity must comply with Directive 2000/60/EC (Water Framework Directive). Where the manufacturing process uses significant water volumes (e.g. membrane production, metal finishing), a water management plan must be in place ensuring no deterioration of water body status. Discharge must meet BAT-AEL limits from applicable BREF documents.

DNSH: Circular Economy

Manufacturing processes must use recycled or secondary raw materials where technically feasible. Platinum group metals and rare earth elements used in electrolysers and fuel cells must be recoverable at end of life. Products must be designed for disassembly, and a take-back or recycling scheme should be established.

DNSH: Pollution Prevention and Control

The activity must comply with the Industrial Emissions Directive (2010/75/EU). Emissions of VOCs, heavy metals, and particulates must remain within BAT-AELs. No SVHCs under REACH may be used unless justified and documented with a substitution plan.