In recent years, the European Union has been defining more clearly its commitment to hydrogen as a strategic energy vector for the decarbonisation of industry, heavy transport, and certain energy uses that are difficult to electrify.

Within this process, and following a path already familiar in other industrial sectors, the concept of the digital hydrogen passport is beginning to consolidate. This tool is designed to provide traceability, transparency, and legal certainty to a market that is still incipient but expected to grow rapidly.

Although its regulatory development is not as advanced as that of the battery passport, the approach is similar: to establish a harmonised system, applied progressively, that allows the unequivocal identification of how and where the hydrogen circulating in the European market is produced, which energy sources are used, and what environmental impact it entails. In this way, the passport emerges as a key element to avoid market distortions, combat greenwashing, and ensure that hydrogen genuinely contributes to the EU’s climate objectives, and not merely in a nominal sense.

A model inherited from the battery passport, adapted to energy logic

The conceptual similarity between the hydrogen passport and the battery passport is not coincidental. Both respond to the same regulatory logic, based on life cycle control, digitalisation of key information, and the creation of trust in strategic markets. In the case of hydrogen, however, the challenge is greater in certain respects, since it is not an individual physical product, but an energy flow that is produced, transported, and consumed in batches, often crossing borders and very different energy systems.

This difference explains why the focus of the hydrogen passport is less on materials and more on the process, particularly on the energy source used and the emissions associated with each kilogram produced. Progressively, this system will make it possible to classify hydrogen according to its environmental performance, facilitate access to public incentives, and, in the medium term, establish maximum emission limits that will condition the viability of certain projects. As occurred with batteries, this regulation not only structures the market, but also raises the competitive bar, favouring those actors capable of demonstrating, with verifiable data, the real sustainability of their operations.

Added to this logic is an increasingly relevant geopolitical and commercial dimension. In a scenario in which Europe expects to import a significant share of the hydrogen it will consume in the future, the passport becomes a common language that allows comparison of production carried out under different regulatory frameworks. In this way, it prevents imported hydrogen from competing at an advantage over hydrogen produced within European territory by not internalising the same environmental requirements, reproducing a scheme already observed in the battery sector.

In addition, the inherited model introduces a new culture of data management in the energy sector. The passport does not merely certify a static attribute, but accompanies hydrogen throughout its value chain, integrating technical, environmental, and administrative information. This forces the different actors to cooperate more closely, share information, and professionalise sustainability management, transforming a traditionally opaque market into one that is progressively more transparent and traceable.

The structural role of LCA and implications for industry

At the technical core of the hydrogen passport lies Life Cycle Assessment (LCA), which shifts from being a voluntary environmental evaluation tool to becoming a structural and strategic requirement for operating in the European market. Through harmonised methodologies, LCA makes it possible to quantify the emissions associated with all relevant stages of hydrogen, from primary energy generation to final use, providing an objective basis for regulatory and commercial decision-making.

This change implies a profound transformation in the way hydrogen projects are conceived. It will no longer be sufficient to declare the use of a renewable source or a given technological process; it will be necessary to demonstrate, with verifiable data, what the real impact of the system as a whole is. In this sense, LCA consolidates itself as a design and optimisation tool, capable of identifying bottlenecks, energy inefficiencies, or phases that are particularly emission-intensive.

The structural integration of LCA will also have direct effects on business decision-making. Aspects such as plant location, the choice of energy suppliers, transport solutions, or even the final destination of hydrogen will be assessed not only in terms of cost, but also based on their environmental performance throughout the life cycle. Those companies that incorporate these methodologies at an early stage will be better positioned to anticipate future regulatory thresholds and an increasingly demanding market.

Finally, the role of LCA goes beyond the purely environmental dimension to become an element of sector governance. By providing a common scientific basis, it reduces regulatory uncertainty, facilitates comparability between projects, and strengthens the credibility of hydrogen as a key vector of the energy transition. In this context, the hydrogen passport does not merely certify a product, but consolidates a new standard for how sustainability is measured, communicated, and managed in the energy system of the future.

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