Between Opportunity and Regulatory Alignment

Challenges for Brazilian Green Hydrogen in Meeting European Union Standards

Abstract

 Objective – This study aims to analyze the regulatory challenges faced by Brazil in aligning its green hydrogen (GH₂) and derivative production, such as green steel, with the requirements established by the European Union (EU).

Methodology – The research is based on a documentary analysis of regulatory frameworks in both Brazil and the EU, complemented by a comparative case study of the German hydrogen regulation model.

Originality/Relevance – The paper highlights the regulatory gap between Brazil’s export potential for GH₂ and the misalignment of its domestic framework with EU standards. The relevance lies in discussing regulatory convergence as a critical factor for Brazil’s competitiveness in a low-carbon global economy.

Findings – The results indicate that Brazil's current regulatory framework is insufficient and misaligned with key European criteria, particularly regarding additionality, temporal correlation, and traceability. The absence of a national certification system emerges as the main barrier to the export of GH₂ and green steel, undermining the country’s global competitiveness.

Theoretical/Methodological Contributions – This study bridges the fields of energy regulation, industrial policy, and international trade within the context of the energy transition.

Social and Environmental Contributions – On the social front, the research informs policy design for green reindustrialization. From an environmental perspective, it outlines how Brazil can leverage its renewable potential to accelerate global decarbonization by enabling the export of low-carbon hydrogen and its derivatives.