Invisible flames and China's grip on electrolysers
Invisible flames and China's grip on electrolysers What this tab covers How it is regulated and what could disrupt supply: hazard classification, rules in the EU, US and India, anti-dumping duties and other trade measures, and supply-risk notes.
Hazards
Classification
UN number
Key risks
Flammable gas cat 1A; gas under pressure
UN1049
Invisible flame, leaks easily, wide flammability range; ignition energy very low.
Main rules
Where
Rule
Effect
EU
RED III RFNBO targets (42% of industrial hydrogen renewable by 2030); Delegated Acts on additionality; CBAM covers hydrogen from 2026
creates demand for green hydrogen and taxes embedded carbon in imports
US
45V clean hydrogen production credit, tiered by lifecycle intensity, up to $3/kg (indicative)
main driver of US green and blue projects
Japan
Hydrogen Society Promotion Act (2024) with 15-year price-gap support (indicative)
supports imports of ammonia and hydrogen
India
Rule
Effect
National Green Hydrogen Mission (2023): 5 Mt a year target by 2030; SIGHT incentives
subsidised tenders for green hydrogen and ammonia
Green Hydrogen Standard for India (MNRE, 2023): at most 2 kg CO2e per kg H2, well-to-gate (indicative)
defines what counts as green for incentives
Gas Cylinders Rules 2016 and SMPV(U) Rules 2016 under PESO
licensing of storage and transport
Trade measures
EU CBAM from 1 Jan 2026 covers hydrogen (CN 2804 10)
Barriers to Chinese electrolysers outside China remain (IEA 2025)
Supply risk
Feedstock risk, not geological: grey hydrogen follows gas prices. Electrolyser supply is concentrated in China (nearly 60% of manufacturing capacity). Hydrogen itself is not on the EU, US or India critical minerals lists; the platinum group metals and iridium used in PEM electrolysers are.