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27th March 2025
Director, Guarantee of Origin and Trade Section
Department of Climate Change, Energy, the Environment and Water
Australian Government
GPO Box 3090, Canberra ACT 2601, Australia
Re: Future Made in Australia (Guarantee of Origin) Rules 2025
The Australian Hydrogen Council (AHC) commends the Australian Government for recent the passage of the Future Made in Australia (Guarantee of Origin) Bill 2024. As we noted in our responses to previous consultations,1 the Australian GO Scheme has been much anticipated. The development of comprehensive legislation that establishes robust carbon certification processes will build confidence in the Australian hydrogen industry. The legislation will enable the international trade of hydrogen and derivatives and is aligned with emerging international best practice, positioning Australia as a trusted and credible partner.
The AHC is the peak body for the hydrogen industry and our membership includes companies from across the hydrogen value chain. Our members are at the forefront of Australia’s hydrogen industry, developing the technology, skills and partnerships necessary to ensure that hydrogen and its derivatives such as ammonia and methanol play a meaningful role in decarbonising Australian industry.
The AHC welcomes the opportunity to provide feedback on this first tranche of Guarantee of Origin rules related to:
• scheme registration;
• the registration of scheme profiles;
• the certification of products; and
• the registration of renewable electricity generation facilities.
We understand that this is the first consultation on the draft subordinate legislation and that further consultation will occur on (amongst other things) the Methodology Determination for Hydrogen production from electrolysis (which sets out how emissions will be calculated for this pathway), the
Renewable Electricity Guarantee of Origin (REGO) Measurement Standard, the Cost Recovery Impact
Statement and the Cost Recovery Regulations.
This first tranche of rules deals largely with the administrative processes governing registration for participation in the scheme, as well as setting out the definitions for eligible entities, sites and sources of energy under the scheme.
1
DCCEEW (2023) Australia’s Guarantee of Origin Scheme: consultation on scheme design, emissions accounting and renewable electricity certification, Australian Government, September, https://consult.dcceew.gov.au/aus- guarantee-of-origin-scheme-consultations-on-design
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While the majority of this is logical and uncontroversial, there remain some questions from within the membership that should be clarified in further tranches. This includes:
• Reporting on pressure. For both liquid and gaseous products, the quality of the product is
measured as the percentage of hydrogen present. However, for a product that is a gas, this also
requires the pressure to be reported on. While this could be useful information to some buyers,
it is unclear why it is relevant to the quality or even within the scope of the GO Scheme.
Especially as reporting on this is expected to add cost, we ask for clarity on this point.
• Reporting government support. Similarly, it is unclear why the profiles are expected to record
whether the entity receives government funding. As this will not impact the quality, emissions
accounting, or saleability of the products produced, this addition appears out of scope. This
information is publicly available elsewhere and therefore unnecessary in this context.
• Compliance across profiles. In order to create a PGO certificate, all parties along the supply
chain must participate in the GO Scheme and report. While it is the Producer’s responsibility to
ensure that all parties comply, there remains a risk that a product’s emissions cannot be verified
based on an external party (such as a transporter). While we anticipate that compliance with the
GO Scheme would be written into contracts between these parties, this may provide a barrier to
entry into a voluntary scheme.
• Measurement devices. AHC understands that measurement methodologies will be covered in
later consultations, however, we ask that there is flexibility or provisions for existing facilities so
as to limit any necessary design changes (and costs associated with this).
• Record keeping. Clarity on the length of time that records should be retained.
The AHC and members are keen to see the extension of the GO Scheme to green metals and low carbon liquid fuels, and are eager to continue engagement on the GO Scheme rules and regulations; we call on the Australian Government to continue to seek the views of industry.
If you wish to discuss any element of this submission in further detail, please contact me
Kind Regards,
General Manager, International
Australian Hydrogen Council
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