| dc.description.abstract | This thesis examines the regulatory challenges of importing renewable hydrogen from Chile into the European Union (EU). Renewable hydrogen has been identified as a cornerstone of the EU’s decarbonisation strategy, with binding targets of 10 million tonnes of domestic production and 10 million tonnes of imports by 2030. Chile is a central prospective partner in this strategy due to its exceptional solar and wind resources, competitive production costs, and proactive national policies. However, the incorporation of Chilean renewable hydrogen into the EU market requires strict compliance with a complex EU regulatory framework primarily designed for internal conditions.
The research investigates two dimensions. First, it assesses the implementation of the EU’s hydrogen rules —particularly the Renewable Energy Directive III, the Delegated Regulation 2023/1184 on Renewable Fuels of Non-Biological Origin, and the Delegated Regulation 2023/1185 on GHG Methodology— in the Chilean context. Second, it evaluates whether the EU legal framework sufficiently addresses the broader environmental and social impacts of renewable hydrogen projects developed abroad. Methodologically, the thesis combines legal desk research with semi-structured interviews of key Chilean industry stakeholders to evaluate the adequacy, feasibility and implications of EU regulations when applied extraterritorially.
The analysis reveals significant implementation challenges. Central EU concepts such as bidding zones, temporal and geographical correlation, and the 90% renewable electricity share requirement have no direct equivalents in Chile’s electricity systems, complicating compliance for project developers. Certification mechanisms, Guarantees of Origin, and power purchase agreements also face structural limitations in Chile, likely making direct connections between renewable generation and hydrogen facilities the main compliance pathway. While Chile is rapidly increasing its renewable energy share and improving transmission infrastructure, current discrepancies with EU requirements create legal uncertainty and may disincentivise investment.
In parallel, the EU framework largely limits its sustainability focus to electricity input and greenhouse gas emissions reductions. Case studies of flagship projects in Chile’s Antofagasta and Magallanes regions demonstrate additional environmental and social risks, including pressure on water resources, ecosystem degradation, and conflicts with local communities. Chile’s environmental impact assessment system provides a solid procedural base, yet substantive protections remain uneven. The EU’s limited treatment of such externalities may undermine the overall sustainability and legitimacy of its hydrogen imports strategy.
The thesis concludes that, while EU regulations provide a robust foundation for ensuring the climate integrity of renewable hydrogen, their rigid application to third-country contexts generates compliance barriers and neglects significant sustainability dimensions. To address these shortcomings, the EU should develop clearer guidance on equivalence for non-EU electricity systems, recognise credible international certification schemes, and progressively integrate environmental and social safeguards into its hydrogen import regime. Such adjustments would enhance legal certainty, strengthen EU–Chile cooperation, and align renewable hydrogen imports with the EU’s broader climate, environmental and human rights objectives. | |
