D8.9 Policy Recommendations Report

This report presents the policy recommendations developed within Work Package 8 (WP8) of the HyInHeat project to support the adoption of hydrogen technologies in the European steel and aluminium industries. Building on the findings of Deliverable D8.5 – Policy Mapping Document, it examines the evolution of the EU regulatory and funding framework between June 2025 and October 2026, identifying the main challenges and opportunities for industrial hydrogen deployment. The report assesses key European policy instruments, including the European Hydrogen Bank, the Clean Industrial Deal, the Net-Zero Industry Act, the Renewable Energy Directive (RED III), the EU Emissions Trading System (ETS), and the Carbon Border Adjustment Mechanism (CBAM), exploring their implications for industrial competitiveness, investment decisions and decarbonisation.

The analysis combines an updated review of EU hydrogen policies with insights from a stakeholder consultation involving 34 organisations across the steel, aluminium and hydrogen technology value chains, as well as discussions from the policy panel held during the HyInHeat final event on 27 October 2026. The findings identify high hydrogen costs, insufficient infrastructure, regulatory uncertainty and limited long-term financial support as major barriers to industrial adoption. They also highlight the different decarbonisation pathways of the steel and aluminium sectors and the need for sector-specific policy approaches. Particular attention is given to adapting nitrogen oxide (NOx) emission measurement methodologies to hydrogen combustion, an issue on which stakeholders from industry, technology providers and research organisations expressed a common position.

Based on these findings, the report proposes recommendations to strengthen the predictability of hydrogen funding, align infrastructure development with industrial demand, improve carbon pricing mechanisms, accelerate permitting procedures and harmonise hydrogen regulations across EU Member States. It also calls for a clearer long-term European Hydrogen Strategy that supports investment certainty while recognising the specific technological and economic needs of energy-intensive industries. Together, these recommendations aim to bridge the gap between European hydrogen policy ambitions and the practical conditions required for large-scale industrial deployment.

The report was prepared by European Aluminium, with contributions from stakeholders and HyInHeat consortium partners, including ESTEP, PNO and NTNU.

Authors

Francesca Cavezza | European Aluminium

Contributors

Chiara Deffendi | European Aluminium

Konstantinos Kollias | European Aluminium

Jonathan Tavenier | European Aluminium

Delphine Snaet | ESTEP

Patrick Lafontaine | ESTEP

Akhilesh Swarnakar | ESTEP

Mark Meijer | PNO

Moritz Langhorst | NTNU

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