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Clare Lonergan
Director, Guarantee of Origin
Department of Climate Change, Energy, the Environment and Water
Australian Government
GPO Box 3090, Canberra ACT 2601, Australia
Dear the Guarantee of Origin teams,
Re: Exposure Draft of the Guarantee of Origin Methodology Determination Amendment
The Australian Hydrogen Council (AHC) commends the Australian Government on launching the Guarantee of Origin Scheme (GO Scheme) in November 2025 and promptly expanding to additional methodologies and products. We welcome the opportunity to assist in the technical design of each.
The AHC is the peak body for the hydrogen industry and our membership includes companies from across the value chain. Our members are at the forefront of Australia’s hydrogen industry, developing the technology, skills and partnerships necessary to ensure that hydrogen and its derivatives play a meaningful role in decarbonising and strengthening Australian industry.
The GO Scheme enables the international trade of hydrogen and derivatives, aligning with emerging international best practice, and positioning Australia as a trusted and credible partner. Furthermore, this robust certification scheme continues to grow in importance as Australia develops domestic policies that will utilise its reporting, support decarbonisation claims and provide confidence in these nascent markets.
The AHC welcomes the opportunity to provide feedback on this round of GO Scheme consultation that looks to expand the methodologies and products under the Product GO (PGO) to:
- Hydrogen produced from gas reforming
- Hydrogen produced from solid gasification and pyrolysis
- Aluminium production pathway
We are pleased to see the continued alignment with other policies and processes, especially the consistency with National Greenhouse and Energy Reporting (NGER) practices. Alongside this, as a voluntary scheme, the flexibility in monitoring and measuring methods (i.e. default values, direct, invoice and mapping tool) is appreciated.
These methodologies have been designed alongside industry experts and appear logical. With the current member feedback received, the AHC is supportive of these proceeding in their current form.
However, there were a series of questions regarding details so far unspecified. This included the classification of feedstocks, how carbon capture and storage (CCS) will be factored into methodologies, and the process for mixed batches.
For feedstocks, it remains unclear if bio feedstocks will be transparently categorised as is done in some international schemes, such as in the RED III[1] or GREET model[2], and whether this would touch on indirect land use change (ILUC). These classifications factor the sustainability of feedstocks beyond carbon emissions, including discouraging or limiting the use of biomass that interferes with prime crop land. In the case of the FuelEU Maritime decarbonisation regulation, food and feed crop-based fuels are not-compliant and go so far as to be “considered to have the same emission factors as the least favourable fossil fuel pathway for that type of fuel.”[3] We would not necessarily look for the objective nature of the GO Scheme itself to make these judgement calls, but to facilitate interoperability with international policies and cater for transparent categorisation, where required. For planning purposes, the AHC would like clarity on whether a feedstock categorisation framework is intended for the GO Scheme, especially considering the current focus of the Australian Government through the National Food Security Strategy[4] and National Bioenergy Feedstock Study.[5]
As for CCS (and CCUS), it would have been expected that this was included as an optional factor for gas reforming. Clarity on carbon management practices and the timeline for their inclusion in the GO Scheme would be beneficial to the confidence of domestic projects.
Further to this, as some facilities phase decarbonisation (including for hydrogen derivatives production), it is expected that there will be cases of mixed feedstocks (e.g. hydrogen from both gas reforming and electrolysis). We understand that the GO Scheme is still in early stages of rollout and further methodologies are upcoming, but would appreciate prompt clarity on the proposed process of how mixed batches will be calculated.
More generally, the AHC would like to reiterate the importance of a two processes as the Guarantee of Origin teams continue the development of the scheme:
- Timelines for scheme expansion. We are pleased that the scheme commenced and is expanding in a rolling manner. We understand that there is a priority list for expansion and this generally follows the Future Made in Australia priorities in order to be accessible for the array of Australian Government funding mechanisms in development. However, members that produce hydrogen through other methods (e.g. photocatalysis) or are working on alternative hydrogen carriers (e.g. methylcyclohexane) seek transparency on when these would likely be available for certification. While these alternative production methods for hydrogen may not be actively producing commercial volumes or may be a technology unique to one Australian project, the structure of the GO Scheme will be necessary for progress with partners and buyers. If a comprehensive timeline cannot be provided at this stage, it would be ideal to understand the growing list of products and methodologies that the Australian Government is considering, and in priority order. This was covered in an earlier consultation[6] but the status of this proposal is uncertain.
- Certainty on interoperability and export. AHC appreciates that the GO Scheme has been developed with interoperability in mind, aligning with international certification schemes and processes. Noting that the GO Scheme reports until the final Australian port for export, members request clarity on how the data will be transferred to international buyers and schemes. We note that the Australian Government is working towards mutual recognition between international schemes and have suggested that the GO Scheme public register will likely be sufficient for a manual process in the meantime.
The AHC and its members would be pleased to continue providing insights and assist in the design for these processes. With the establishment of this robust scheme, more will hinge on its progress and prompt development.
If you wish to discuss any element of this submission in further detail, please contact me at [email protected].
Kind Regards,
Natasha Cerexhe
Policy Manager
Australian Hydrogen Council
[1] European Union (2023) ‘Directive (EU) 2023/2413 of the European Parliament and of the Council’, Official Journal of the European Union, October, https://eur-lex.europa.eu/eli/dir/2023/2413/oj/eng.
[2] U.S. Department of Energy (2025) Guidelines To Determine Life Cycle Greenhouse Gas Emissions of Clean Transportation Fuel Production Pathways Using 45ZCF-GREET, January, https://www.energy.gov/sites/default/files/2025-01/45zcf-greet_user-manual.pdf.
[3] European Union (2023) ‘Regulation (EU) 2023/1805 of the European Parliament and of the Council’, Official Journal of the European Union, September, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1805.
[4] Collins, J. (2025) Feeding Australia: Albanese Labor Government’s plan to secure our food future, media release, Department of Agriculture, Fisheries and Forestry, 4 March, https://minister.agriculture.gov.au/collins/media-releases/feeding-australia.
[5] Collins, J. (2025) Laying the foundations for Australia’s bioenergy feedstock industry, media release, Department of Agriculture, Fisheries and Forestry, 2 October, https://minister.agriculture.gov.au/collins/media-releases/national-bioenergy-feedstock-strategy.
[6] DCCEEW (2023) Australia’s Guarantee of Origin Scheme: consultation on scheme design, emissions accounting and renewable electricity certification, Australian Government, September, https://consult.dcceew.gov.au/aus-guarantee-of-origin-scheme-consultations-on-design.