Low Carbon Hydrogen Standards: A Comprehensive Look

Posted on 06 February 2024

Thanuja Bandara
Engineering Analyst

Comes from a background of Chemical Engineering and specialised in energy market research and biofuel techniques.


As the world transitions towards a sustainable future, hydrogen has emerged as a promising source in the energy transition, with its potential to decarbonise various sectors. In the United Kingdom, several frameworks including UK Hydrogen Strategy, Energy Security Strategy, and Powering Up Britain were introduced. To support these frameworks ‘UK Low Carbon Hydrogen Standard’ (LCHS) has been introduced as a critical step, providing a meticulous methodology for assessing hydrogen production emissions throughout its lifecycle.

Standard Compliance 

The concept of Standard Compliance to the LCHS is applied to Consignments rather than entire Hydrogen Production Facilities. Before a facility begins producing consignments, claims of Standard Compliance cannot be made. Instead, claims of likely Standard Compliance may be asserted, especially for purposes such as eligibility for government subsidy schemes.

For a Consignment to be considered compliant (Standard Compliance) with the LCHS, it must meet the following criteria:

  • Have a Final GHG Emission Intensity of 20 grams of carbon dioxide equivalent per megajoule of Hydrogen Product (20.0 g CO₂ e/MJLHV Hydrogen Product).
  • Be produced by a Hydrogen Production Facility that satisfies all Conditions of Standard Compliance.

To meet the conditions of compliance, a Hydrogen Production Facility must:

  • Employ an Eligible Hydrogen Production Pathway.
  • For any Solid Carbon Outputs, adhere to requirements regarding Solid Carbon Permissible End Use, transfer of liability, and accounting.
  • Follow the GHG Emission Intensity Calculation Methodology using Lower Heating Values and the System Boundary applicable to the Pathway Inputs.
  • Establish and annually review a Fugitive Hydrogen Emissions Risk Reduction Plan and provide a Fugitive Hydrogen Emissions Annual Report every year during operations.
  • Report the Final GHG Emission Intensity and Environmental Characteristics monthly for every Discrete Consignment and provide Raw GHG Emission Intensities of each Discrete Consignment monthly, split by Emission Category.

Furthermore, ensuring compliance includes meeting evidence requirements for particular inputs and outputs, such as biogenic feedstock or energy inputs, concerning the relevant electricity supply configuration. It’s essential to procure and cancel Renewable Energy Guarantees of Origin (REGOs) certificates annually. Effective implementation also calls for establishing a dependable Data Collection and Monitoring Procedure (DCMP) in collaboration with the Delivery Partner.

Non-Compliant Consignments:

Any Consignment failing to meet the GHG Emission Intensity Threshold, or any Condition of Standard Compliance is deemed non-compliant with the LCHS. Discrete Consignments not meeting the GHG Emission Intensity Threshold but satisfying all Conditions of Standard Compliance may be considered within a Weighted Average Consignment.

Eligible Hydrogen Production Pathways: 

The LCHS focuses on specific pathways deemed eligible for compliance. These pathways include:

  • Electrolysis
  • Fossil gas reforming with CCS
  • Biogenic gas reforming
  • Biomass gasification
  • Waste gasification
  • Gas splitting producing Solid Carbon

The Lifecycle Approach:

The LCHS adopts a comprehensive lifecycle approach, considering every stage of the hydrogen production process. From feedstock acquisition and transportation to distribution and storage. This methodology helps in understanding the complete environmental impact of hydrogen production.

Pathway-Specific Methodologies:

Recognising the diversity of hydrogen production pathways, the LCHS provides specific methodologies tailored to different pathways. For instance, when fossil fuels are used with carbon capture and storage (CCS), the standard accounts for emissions associated with extraction, processing, and CCS efficiency. Electrolysis focuses on the carbon intensity of the electricity source, emphasizing the importance of integrating renewable energy.

Biomass gasification is also addressed, considering emissions from cultivation, processing, and conversion, along with potential carbon sequestration benefits. This pathway-specific approach ensures accurate assessments, reflecting the unique challenges and opportunities of each hydrogen production method.

Materiality Threshold:

In order to streamline the reporting and verification process, the LCHS introduces a materiality threshold. This threshold focuses on significant emission sources, allowing stakeholders to prioritise their efforts on the most impactful aspects of hydrogen production. This pragmatic approach simplifies the process and enhances the efficiency of reporting and verification procedures.


In order to guarantee that hydrogen production is in line with sustainability objectives, the UK Low Carbon Hydrogen Standard serves as a strict and transparent framework. The LCHS sets a high bar for the sector and opens the door for ethical and sustainable hydrogen generation in the UK.

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