Regarding
the Proposal for a Regulation establishing a framework of measures to accelerate industrial capacity and decarbonisation in strategic sectors (Industrial Accelerator Act)
The Bulgarian Hydrogen, Fuel Cell and Energy Storage Association (BGH2A), as an organisation bringing together scientific expertise and industrial potential in the field of clean hydrogen technologies and policies, welcomes the European Commission’s initiative to adopt an Industrial Accelerator Act aimed at accelerating industrial capacity and industrial decarbonisation.
BGH2A considers that there is a need to further increase the ambition, scope and clarity of the proposed measures in order to respond effectively to growing geopolitical challenges, unfair trade practices and the lack of sufficient market incentives for clean technologies, including hydrogen.
In this context, we present the following position and recommendations.
Acceleration of Permitting Procedures and the Need for Strong Measures
The Act highlights the important role of lead markets for low-carbon products “made in Europe” in stimulating clean energy technologies. At the same time, however, the specific provisions do not provide sufficient support for achieving this objective.
We recommend:
- Introducing a mandatory requirement to stimulate/prioritise low-carbon products in public procurement;
- Increasing the proposed quotas (above 25%) for the use of low-carbon steel and other materials;
- Introducing a clear and timely label for low-carbon products, based on a “graduated assessment scale” that takes into account carbon footprint and the degree of recyclability;
- Introducing clear deadlines for permitting procedures;
- Accelerating the development of a legislative framework for strategic projects, including hydrogen projects, through the introduction of tax incentives, shorter permitting procedures and streamlined administrative processes, including at regional level. Priority support should be provided to projects for the production and use of green hydrogen under the Innovation Fund, as well as under national programmes promoting clean energy.
Creating a Market for Clean Technologies
The introduction of criteria for low-carbon products in public procurement is of fundamental importance. This will create certainty for investors and, in the near future, a real market.
We recommend:
- Clear definitions and harmonisation of standards for “low-carbon” and “renewable” hydrogen;
- Revising the requirements under RED III regarding the principles of “additionality” and “temporal and geographical correlation”;
- Explicitly including hydrogen technologies as part of low-carbon products in public tenders;
- Tax incentives to support businesses in adopting low-carbon products and technologies.
Investments
Encouraging investment and the creation of carbon-neutral industrial zones for accelerated development is key to building a hydrogen economy. Hydrogen, especially green hydrogen, is a key element for the decarbonisation of energy-intensive industries (steel, chemicals, transport). Therefore, we recommend:
- Supporting the development of hydrogen hubs and industrial ecosystems in Bulgaria, including as part of the European Hydrogen Valleys;
- Facilitating public-private partnerships;
- Promoting cross-border projects and connectivity of energy infrastructure.
In conclusion, it is necessary for Bulgaria to formulate and uphold a clear and coordinated national position on the proposed Regulation establishing a framework of measures to accelerate industrial capacity and decarbonisation in strategic sectors (Industrial Accelerator Act), including:
- Clear positioning of clean hydrogen as a strategic priority;
- Support for innovation and research activities;
- Development of skills and human capacity in the sector.
National Context
A clear national framework aligned with European policies is needed to ensure competitiveness and sustainable development. We recommend:
- Alignment between European policies and national strategies;
- Targeted support for regions with industrial potential for the deployment of clean energy technologies and manufacturing;
- Active positioning of Bulgaria in the development of the South-East Hydrogen Corridor as part of the European Hydrogen Backbone, with an integrated approach across the entire value chain;
- Updating the National Hydrogen Roadmap with the aim of creating an effective market and encouraging the development of a sustainable hydrogen economy.
Conclusion
BGH2A supports the Industrial Accelerator Act and believes that the Act creates a real opportunity to accelerate the transition to sustainable industry. At the same time, it is necessary to ensure that clean hydrogen technologies are clearly recognised and supported as a key element of this process.
