IKEM today published a study that examines the legal framework for the use of existing LNG terminal infrastructure to import hydrogen transport vectors. According to the analysis, a prerequisite for successful conversion is a reliable legal framework that sensibly integrates existing infrastructures and provides targeted support for the market ramp-up of green molecules.
In addition to dedicated hydrogen import terminals, LNG terminal locations can serve as logistical hubs for the import of hydrogen transport vectors in the future. In this way, they can contribute to a hydrogen-based and climate-neutral energy supply.
The LNG2Hydrogen sub-project of the hydrogen lead project TransHyDE is investigating the prerequisites for the sustainable and long-term use of LNG terminal sites. The project is funded by the Federal Ministry of Research, Technology and Space. In the project, IKEM analyzed the legal framework conditions for the conversion of existing LNG infrastructures and the construction of new hydrogen import terminals. The study, which has now been published, focuses in particular on issues relating to licensing law and energy industry law.
From a licensing perspective, the novelty of the technologies used gives rise to procedural uncertainties in the event of future retrofitting. Although legislative approaches to speed up the process are discernible, these have not yet been implemented. The study emphasizes that prompt implementation is crucial in order to create planning security for companies and facilitate the enforcement practice of the authorities.
There is also still a need for action at regulatory level: the national implementation of key requirements of the EU gas package has not yet been completed. Although a draft bill is available, the study makes it clear that swift and coherent implementation – particularly with regard to access and unbundling regulations – is of key importance. This is the only way to create legal certainty, safeguard investments in existing LNG infrastructure and at the same time ensure fair competitive conditions for green molecules.
Note: The study is based on the legal status at the end of February 2025. Later legislative or regulatory developments could not be taken into account.
