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
Regulatory gap
Assessment Severity
At present there is no legal basis (law or regulation) for injection of hydrogen in the gas grid in Italy


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?
At present the injection of hydrogen and Natural Gas Mixtures in the gas grid is not foreseen and regulated. The only regulation is Gas Grid Code of Snam Rete Gas, passed by the Authority for the electricity, gas and water market, where is regulated only the presence of hydrogen with reference to bio–methane fed into the grid. Therefore the only Quality requirement is the maximum allowed concentration of hydrogen in bio–methane minor or equal to 0.5% by volume., Annex 11/A of the Grid Code.
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?
See previous reply Question 11
Question 3 Are there other hydrogen quality related legal and administrative requirements to allow the injection of hydrogen in the grid?
See previous reply Question 11
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?
The requirements for measurement of gas quality injected into the grid are foreseen in the Annex 11/b of the Gas Network Code
Describe the comparable technology and its relevance with regard to hydrogen

National legislation:

  • Gas Network Cod >
    Gas network regulation of SNAM Rete Gas defining the role of each party involved in gas transmission activities.

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.