H2 quality requirements

This LAP is concerned with the gas quality issues for hydrogen injection and transport in the low pressure DSO local gas grid, including gas quality monitoring and metering in relation to payment terms and responsibilities for monitoring and metering


Requirements related to the quality of hydrogen (in relation to the composition of the gas(blend) as well as its physical property
Hydrogen quality is a term to describe the gas quality for use in the natural gas grid.
Is it a barrier?
Type of Barrier
Structural barriers, Operational barriers, Economic barriers, Regulatory gap
Assessment Severity
If the quality of the gas mixture doesn’t match the specifications, the DSO is not allowed to accept injection into the grid - the DSO has to operate in a safe and reliable manner


Question 1 What is the basis for the billing of Hydrogen and Hydrogen Natural Gas Mixtures? Only the energy flow (kWh) or are other properties involved?
In Austria it is the energy content – expressed in kWh and the payment for the provisions of the peak capacity in KWh/h
Question 2 What are the legal and administrative requirements and responsibilities with regard to real-time Measurement Technologies for the monitoring and billing of Hydrogen Natural-Gas Mixtures? Do they differ from the requirements for natural gas?
Not clarified yet but following the so far used approach in the natural gas sector, there is no difference between the monitoring and billing of hydrogen natural gas mixtures in comparison to the monitoring and billing of pure natural gas from the technical perspective. The DSO is responsible for the safe and reliable operation of the grid, hence the DSO accepts gas (mixtures) at the specified quality only otherwise there might be huge problems regarding billing and operation of the grid. The DSO is metering the amount of the gas and the quality with a gas–phase chromatograph. The supplier of gas has to guarantee the compliance of the fed in quality with the specifications. If feeding in pure hydrogen into the system – which has to be properly mixed with the natural gas so that the gas quality will be harmonised in the entire relevant gas grids – the question of responsibility will have to be solved otherwise the market take up pf hydrogen will be hindered. .
Question 3 Are there other hydrogen quality related legal and administrative requirements to allow the injection of hydrogen in the grid?
Of course the gas mixture has to be injected at the required pressure and according to the reported schedules in terms of volume and time and there might be a need for regulations dealing with the balancing energy. On top there has to be sufficient transportation capacity available.
Question 4 How is the responsibility in your country organized with regard to the measurement and other injection related quality requirements? Is this the responsibility of the producer, the DSO or a third party?
It is up to the DSO to measure the volumes and quality of the injected gas (mixture but it is up to the producer to supply the mixture at the specified quality. In case the DSO becomes owner of the measuring equipment – including gas chromatograph – he will charge the out of it resulting costs to the hydrogen supplier – of following the currently applied methodology )

National legislation:

EU Legislation:

  • Directive 2009/73/EC concerning common rules for the internal market in natural gas
    Directive 2009/73/EC establishes common rules for the transmission, distribution, supply and storage of natural gas.

    Its provisions and obligations apply to Hydrogen Gas by virtue of Article 1 (2), which states that the rules established by this Directive for natural gas, including LNG, shall also apply in a non–discriminatory way to biogas and gas from biomass or other types of gas in so far as such gases can technically and safely be injected into, and transported through, the natural gas system.

    Article 25 establishes the “Tasks of the distribution system operator” which include: ensuring the long-term ability of the system to meet reasonable demands for the distribution of gas […];shall provide any other distribution, transmission, LNG, and/or storage system operator with sufficient information […] as well as to ensure that the system operator does not discriminate between system users or classes of system including, including e.g. when setting rules for the charging of system users, etc

    Article 32 sets the rules on “Third party access”: access to the transmission and distribution system, and LNG facilities shall be based on published tariffs, applicable to all eligible customers, including supply undertakings, and applied objectively and without discrimination between system users.