Comments on the Canadian Federal Government’s proposed Clean Hydrogen Investment Tax Credit and the definition of “Clean” Hydrogen

Submitted to the Department of Finance of the Government of Canada on January 6, 2023.


The term “clean hydrogen”  is increasingly used in government and business communications and strategies to refer to “low carbon hydrogen”. However, “clean hydrogen” is not guaranteed to reduce emissions. As noted by the Canadian Federal Government, “there is no single definition of what constitutes “clean hydrogen”, as there are a range of carbon intensities that may be associated with the production of hydrogen

Climate science tells us we need to decarbonise the global economy by mid-century at the latest to avoid the worst climate impacts. If the objective of ramping up the production of “clean hydrogen” is to replace fossil fuels and avoid exacerbating the climate crisis, then the definition of clean hydrogen must be compatible with the Intergovernmental Panel on Climate Change (IPCC) and Paris Agreement’s call for temperature rise to be limited to 1.5oC above pre-industrial levels.

The Federal Government published a Hydrogen Strategy for Canada, in December 2020, to accelerate the development of “clean” or “low carbon” hydrogen projects, despite the lack of adequate definition. It is now undergoing consultations to define “carbon intensity tiers for clean hydrogen” projects eligibility to receive clean investment tax credits. The proposed investment tax credit would be based on the lifecycle carbon intensity of hydrogen, like the carbon intensity tiers introduced in the U.S. Inflation Reduction Act to guide the level of support to clean hydrogen projects.

In this submission, the Hydrogen Science Coalition (HSC) proposes an objective, quantified and independent definition of “clean” hydrogen based on four key criteria to ensure it is compatible with the IPCC 1.5oC limit to global warming.

You can read our full submission here.


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