HydrogenEuropeonPwC’s Clean Hydrogen Lead Markets report PwC’s Clean Hydrogen Lead Markets report(theReport),commissioned by Hydrogen Europe,aims tofindappropriate market-making measures to develop lead markets supporting Europe’scompetitiveness andcleanindustrial transition.Lead marketsarea key pillarofthe EU’sCleanIndustrial Deal,itsindustrial frameworkfor competitiveness. TheReportrepresentsan impartial legaland economic analysis of market-making modelsreadily available for policymakers, evaluating themfrom the standpoint ofeffectiveness, viability,andrelevance for the hydrogen industry. Lead marketsaimto create reliable demand for low-carbon industrial products(namelyforlow-carbon steelandfertiliser products).Their purpose is to support marketentryof these productsandaffect procurement preferences until they can compete with conventional products. Throughestablishing lead markets for CO₂-reduced steeland ammoniaused in climate-friendly end-products,hydrogen demand will be incentivised indirectly as part of the industrial transformation.While leadmarkets are an importantpartin industrial policy,they arejustonepartofa successfulhydrogenmarketramp-up. Models and approaches in theReport,supported by the hydrogen industry TheReportoutlinesa set ofmarket-making regulatory measurestodeveloplead markets. In thecontext ofclean steel,theReport focuses onprimarysteel production–throughthehydrogen-baseddirect reduction of iron and electric arc furnaceroute. •Measuressuch as“Voluntary use of labels” and “Public procurement” are significant,but inthemselves notsufficientto provideanadequatepush.The starting point for establishingeffective lead markets must be a common, robust,and transparent definition ofclean steel,through a product-based labelling and certification system.Hydrogen Europe thereforeemphasises the importance of a clean steel definition,based on a sliding-scaleapproach,togetherwith aprimary steelperformance metric,1without whichsteel producers would beincentivised to maximise scrap use,whichislimited bygrowing scarcityof scrapandothertechnicalissues. For a deep transformation of the steel industry,continuedinvestment inhydrogen-based primary steelmaking is essential.•“Final product-based levy financed CfD”and“tax incentives”may be supported by theindustry, especiallywhen it comes topredictable and reliable financing schemes on finalproducts through compulsory EU-wide implementation.While theywouldrequiresubstantialpublicinvestment,the measures would create animmediate positiveonthe hydrogen andsteel industriesalike.•A“Sector-specific quota”can have a significant impact, provided adequate enablingconditions are implemented EU-wide, including protection against global overcapacity, aneffective CBAM,and competitive energy prices.If implemented correctly,clear, measurable market andinvestment certainty can be built up, boosting investor confidence and mobilisingprivate investment. •A“Supplier quota”,although important to consider,couldbe a misguidedapproach, asrightfully considered by the Report. There is a real risk that it would be bypassed orcircumvented, essentially leading to carbon leakageandat the same time increasing steelprices without enabling optimisation along the value chain. The measure could jeopardise theEuropean steel industry’s competitiveness, limiting its ability to invest in decarbonisationthrough hydrogen. In the context ofclean fertilisers, the Reportevaluates measures relatedtoclean ammoniaproducedwithclean hydrogen. •A“Food-based Levy FinancedCfDModel”couldbean effective tool inensuringofftakingofclean andlow-carbon fertilisersas well as creating amarket environment in whichpredictableand reliable financingcanramp up demand.•A“BonusModel”shows great potential in overcoming the price burden for low-carbon andrenewable fertilisersbutneeds to be implemented in a way that recognises the complexitiesand particularities of theentirevalue chain.Itshouldnot put moreadministrative oroperational burden on any player in the sector.•A“Supplier Quota”,although an important element in the analysis of the market, would–likein the case of steel-be a misguided approach to take. Risks in implementing such ameasure are both in creating an uneven playing field for imports, as well asputtingunnecessarystrain on avulnerable European fertiliserindustry. Measures and approachesbuilding on theReport Furthermeasures not reflectedin theReportthatbenefit the wider discussion about leadmarketsaredetailed below.These may not beexpressly supportedbyHydrogen Europebuthavepotentialfortheindustry. •“Automotive credits”, wherebycar manufacturersareprovided with flexibility in reachingtheirfleet emission targets by integrating the production phase(i.e. the use of clean steel)ofpassenger cars and light duty vehicles, based on verifiable andcertified emission reductions.This wouldprovidemanufacturers withameaningfulincentive to use low-emission steel.Inthisscheme,thecalculation methods should remainsimple,a