Joint position of Norwegian trade unions and employers on the hydrogen and gas markets decarbonisation package

Nyhet, NHO Brussel


The United Federation of Trade Unions (Fellesforbundet), Industri Energi, Norwegian Oil and Gas (Norsk Olje og Gass), The Federation of Norwegian Industries (Norsk Industri), Energy Norway (Energi Norge), The Norwegian Confederation of Trade Unions (LO) and the Confederation of Norwegian Enterprise (NHO) refer to the European Commission’s proposal for a revised gas directive (2009/73/EC) and gas regulation ((EC) No 715/2009) published in December 2021.

We welcome the Commission’s proposal and support its objectives. Norway currently supplies a quarter of Europe’s natural gas consumption, shares the EUs climate targets and can deliver both renewable and low-carbon hydrogen going forward. Firstly, Europe needs to replace Russian energy imports, but ensuring hydrogen-readiness at the same time will secure the green transition when energy markets regain balance. Our organisations have submitted individual comments to the proposal. We share the same concerns and would therefore jointly ask European policy makers to consider the following recommendations:

Technology neutrality

We welcome the proposed technology neutral approach which includes all types of renewable and low-carbon hydrogen. Natural gas with CCS should qualify, as blue hydrogen can play an important role in bridging and fostering a hydrogen market in Europe. The methodology for calculating the emissions savings to reach the proposed GHG emission threshold for blue hydrogen is unclear and must be clarified. It is equally important for Norway that all renewable power from existing wind- and hydropower installations qualifies for green hydrogen production, not only new wind or solar power. Policy makers should not let an additionality principle hinder the urgent replacement of Russian energy imports or the establishment of a European hydrogen market.


We welcome the proposal allowing for blending up to 5% hydrogen into the natural gas system. Parallel work on the development of dedicated hydrogen transport infrastructure is equally important, as this allows for the most efficient use of renewable and low-carbon hydrogen. Potential impacts on end-users, including industries currently relying on pure natural gas, must be considered and addressed as the European hydrogen market grows. Clarification on how the blending rules should be applied at entry points is also needed. We recommend that the rules proposed for cross-border interconnection also applies to entry points for imported gas.


The proposed unbundling rules for hydrogen pipelines could prevent industrial actors investing in infrastructure, and TSOs from adapting existing systems to hydrogen. Consequently, the development of large-scale hydrogen projects could be hampered. We recommend that full ownership unbundling is not required in the initial roll-out phase.


CO2 transport

Natural gas pipelines may be repurposed to transport captured CO2. In the Commission communication on sustainable carbon cycles, the need of an internal market for storage and use of CO2 (CCUS) have been acknowledged. We recommend that the hydrogen and gas market decarbonisation package is followed by a proposal for a CCUS framework.

Partnership with Norway

 Norway is a stable and secure supplier of energy to the EU. Our European neighbours are our most important partners, both economically and politically. Through the EEA agreement, Norway is on equal footing with member states in the EU internal market. Hence, it is important that Norwegian stakeholders and authorities are considered equals in planning and developing Europe’s infrastructure and market for hydrogen.