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Level 3, 32 Walker Street
North Sydney, NSW 2060
www.hifglobal.com
HIF Asia Pacific submission
Future Made in Australia (Guarantee of Origin) Rules 2025 – Exposure draft (Tranche 1)
HIF Asia Pacific (HIF) thanks the department for the opportunity to comment on the proposed rules for the Guarantee of Origin scheme.
HIF is a wholly owned subsidiary of HIF Global, which operates the world’s first fully-integrated e-
Fuel plant at Haru Oni in southern Chile. Haru Oni entered production in 2022 and the company now has five further large-scale projects in development, in Chile, the United States, Uruguay, Brazil and
Australia (Tasmania).
Shareholders include Chilean utility AME, investment firm EIG, technology specialists Baker Hughes,
Porsche, which were joined in 2024 by Japanese entities Idemitsu Kosan, Mitsui OSK and JOGMEC, a government agency.
HIF Tasmania was one of only six projects shortlisted for the Commonwealth’s $2bn Hydrogen
Headstart program in late 2023.
E-Fuels are a drop-in substitute for conventional fuels and are made from renewable hydrogen and recycled carbon dioxide (CO2). The proposed HIF Tasmania plant will use locally generated renewable energy to power a circa 230MW electrolyser array to produce hydrogen. This will be combined with CO2 captured from sustainably sourced biomass to create e-Methanol, which can be used directly in shipping, or further synthesised into e-Gasoline, e-SAF or e-Diesel. The plant is anticipated to employ between 150 and 200 people when it enters operations.
HIF aims to produce approximately 300,000 tons of e-Methanol annually from its HIF Tasmania facility under development in North West Tasmania. The relative maturity of overseas markets for low carbon fuel means the plant is primarily envisaged as an export opportunity for Australia. It is therefore essential that the product is in full compliance with stringent certification requirements, particularly those outlined in EU legislation.
Considering this context, HIF would like to share the following observations:
Methodology Determination
Regarding Section 12 (Production profile registration), HIF understands that minimum, optional, and conditional modules are dictated by the methodology determination in respect of a product. HIF is principally concerned with green hydrogen-based e-Methanol.
In order for HIF to reach Final Investment Decision for the project and unlock the benefit of being at the forefront of a nascent industry for Australia, we suggest that a methodology determination by the
Minister is made for e-methanol and other low carbon liquid fuels on an accelerated timeline.
March 27th, 2025
We welcome the proposed prioritisation of hydrogen production to enable compliance with the requirements of the Hydrogen Production Tax Incentive (HPTI), as it should be noted that green hydrogen production via electrolysis is a sub-process within HIF’s proposed production process for e-Methanol.
HIF is eager to work closely with the regulator to ensure a compliant methodology is in place in time to satisfy HIF’s obligations to offtakers.
PGO treatment for hydrogen derivative products (e.g. e-Methanol)
Further to the above, HIF wishes to clarify, with respect to Division 3.3 (Registration of PGO certificates) whether the production of hydrogen derivative products such as e-Methanol will require the registration of a single PGO type (e-Methanol) or multiple PGOs individually (green hydrogen and e-Methanol).
As an example, in producing e-Methanol, HIF’s proposed production process involves the synthesis of green hydrogen produced via electrolysis, and CO2 extracted from biomass. As such, we wish to understand whether separate PGOs would require registration for the production of green hydrogen, as well as the final product, being e-Methanol.
Considering that HIF is intending to rely on the HPTI, and as we understand green hydrogen PGOs are required as evidence to claim the HPTI, it is HIF’s preference that separate PGOs can be registered for each product, as each PGO would serve different purposes (i.e. green hydrogen PGOs for HPTI, and e-Methanol PGOs relevant for European markets and RFNBO certification).
Production profile registration within the exclusive economic zone
Regarding Section 12(1)(c) of the Rules where it states, in the context of the Production profile registration, that a requirement to register a production profile is: “the production pathway only occurs within the exclusive economic zone”. HIF asks to clarify whether the production pathway considers only the “production modules” to operate within the exclusive economic zone, while inputs to those production modules (for example biomass pellets, or gasifier bed consumables) can themselves be created outside of Australia for use by the production modules.
HIF's production process may rely on imported feedstocks, which we anticipate will be accredited under internationally recognised sustainability standards. Consequently, HIF prefers that these inputs not be considered part of the production pathway. This approach would allow the sourcing and processing of these feedstocks to occur outside the exclusive economic zone without affecting compliance for the PGO certification.
Additional attributes to be added to a PGO
Regarding Section 20 (1) (h) of the Rules states, in the context of the Certificate content, that “any other attribute the holder of the production profile considers necessary for the purposes of compliance with an international scheme” can be included in the certificate, as long as (Section 22
(1)) evidence is provided that it “would accurately represent an attribute of the product to which the certificate relates; and is necessary for the purposes of compliance with an international scheme”.
While this inclusion is welcomed, to streamline the process and accommodate international compliance needs – which is the aim of the Clause – HIF proposes the Rules to establish a pre-
approved list of optional attributes that align with international schemes, particularly the European
RED II(I) legislation. This pre-approved list must be regularly updated and attributes from this list can be included in PGO certificates without additional evidence requirements.
We appreciate your time in reviewing our submission. Please feel free to reach out to HIF with any questions or requests for additional information.
CCO, HIF Asia Pacific
