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7 February 2023
Mr David Fredericks. PSM
Secretary
Department of Industry, Science, Energy and Resources
GPO Box 2013
CANBERRA ACT 2601
By email: GuaranteeOfOrigin@industry.gov.au
Dear Mr Fredericks
A Guarantee of Origin for Australia
The Minerals Council of Australia (MCA) acknowledges the government’s consideration of previous feedback and notes the advanced policy position.
Hydrogen has increasing potential as a major export market for Australia – one far exceeding potential domestic consumption. The development of a Guarantee of Origin represents an opportunity for international leadership to establish processes that define this and future export activities.
Ensuring technology neutrality in a Guarantee of Origin scheme
The MCA supports the development of technologies that will be vital for a low emissions future.
Australia has an opportunity to demonstrate leadership in developing standards for emerging technologies – in particular hydrogen production and export.
Previously there has been a strong focus on the method of hydrogen production. Instead, standards should be focussed on the emissions intensity of the final product, ensuring it meets a certain threshold to be described as ‘clean’.
The MCA supports a technology neutrality approach is adopted and, consistent with the International
Energy Agency, colour coding of hydrogen should be avoided.
The current government policy appears consistent with this position saying:
The use of ‘Guarantee of Origin’ to describe the Australian Government’s scheme is a purposeful one.
The scheme would provide necessary information about a product’s origin, life cycle emissions and
attributes. It would not categorise the emissions intensity through definitions such as ‘green’ or
‘low emissions’ at this stage. This approach allows the GO scheme to be used to demonstrate
Australian products meet requirements for low-emissions products used by various markets both
domestically and internationally.
However, the policy allows for potential future colour categorisations. Colour-coding is inconsistent with the position adopted by the International Energy Agency and is unlikely to be accepted at any stage by the Organization for International Standards (ISO).
A technology neutral approach will allow for Australian producers to supply low-emissions hydrogen based on available and emerging technologies while achieving the aims of the Guarantee of Origin; namely buyers making purchasing decisions via a market based on price and emissions intensity.
Technology neutrality would entail the government being indifferent as to how clean hydrogen is produced, and more concerned with the standard to which it has been produced.
Standards and certification
The MCA supports development of clean hydrogen standards through Standards Australia (SA) involving industry, government and other stakeholders, with a view to ISO alignment.
Within the emergent hydrogen export market, there is an opportunity to collaborate with key importers to road test the scheme at every step. The current policy paper does not look at this, instead viewing
Japan simply as a customer rather than partner in the development of global standards.
Regarding the international Partnership for Hydrogen and Fuel Cells in the Economy (IPHE), the policy paper states:
The Department will continue to work with the IPHE to ensure that the emissions accounting methodologies
being developed for the GO scheme are internationally aligned. The (ISO) has also signalled interest in
developing the IPHE agreed methodologies into formal international standards.
The MCA opposes an initial IPHE-aligned domestic scheme to transition to an international one, rather the scheme should be developed with Japan as a leading trading partner and IPHE member.
This work can be developed through each country’s national standards body. Both countries are strong supporters of standards developed through the ISO.
Importantly, as previously stated, any standards or certifications developed by SA through the IPHE or
ISO should avoid describing hydrogen as ‘green’. Instead, hydrogen that meets the agreed standard for emissions intensity should be considered ‘clean’.
Future export opportunities for Australia
The MCA agrees a Guarantee of Origin scheme may also set a precedent for exports of other
Australian products capable of playing a role in the clean energy transition.
In the coming decades, Australia may well export more ammonia than hydrogen. Ammonia is easier to transport and store, leaks can be more easily detected (unlike in the case of hydrogen which is odourless) and it is an established export industry (over 120 international ports have facilities for ammonia storage).
For buyers, ammonia has the advantage that it can be used:
a) In industry, notably for fertiliser production but also in manufacturing and water purification
b) When co-fired with coal to produce electricity and eventually possibly fully replace coal in coal
fired power generators (this is the subject of research in Japan)
c) Converted to hydrogen to help achieve net zero goals in foreign jurisdictions.
Therefore, a well-designed GO standard for hydrogen, with Australia as a leader, potentially impacts ammonia (NH3) and other hydrogen carriers like methanol (CH 3OH). Together with hydrogen, these offer ways to promote the decarbonisation of a range of sectors such as aviation, maritime transport, long-haul transport, and heavy industries.
Finally, the MCA supports the establishment of a Guarantee of Origin for hydrogen that demonstrates international leadership for accepted standards and protocols for future trade and investment.
Yours sincerely
TANIA CONSTABLE PSM
CHIEF EXECUTIVE OFFICER
Minerals Council of Australia | 2
