MOE-Fellowship: Marta Grzywacz

Sustainable Pathways for Green Hydrogen Imports from Africa: A Case Study of Poland and Germany

This research project investigated the regulatory conditions for importing renewable hydrogen into the European Union, using Germany and Poland as importing-country cases and Morocco and Namibia as potential exporting-country cases. The project examined the extent to which the regulatory frameworks of Morocco and Namibia provide the necessary conditions for exporting hydrogen that can be recognised as Renewable Fuels of Non-Biological Origin (RFNBOs) in the EU, and how different regulatory and import-readiness conditions in Germany and Poland may shape future import pathways. The main finding is that regulatory alignment is a core element of hydrogen trade infrastructure: renewable energy potential, project pipelines and transport infrastructure are insufficient if certification, traceability, lifecycle greenhouse gas accounting, third-party verification and proof-of-compliance systems are not operational. Germany appears significantly more advanced than Poland in terms of import readiness, while Poland risks becoming a passive recipient of imported hydrogen rather than an active market-shaping actor because it lacks a dedicated hydrogen import strategy, clearly defined import routes and a fully implemented RFNBO framework. On the export side, neither Morocco nor Namibia has yet established a fully operational RFNBO proof-of-compliance system for green hydrogen exports to the EU; however, Morocco currently offers more favourable enabling conditions due to its investment coordination model, proximity to Europe, domestic green ammonia demand and emerging certification and traceability capacity, whereas Namibia remains more legally fragmented, lacks a sector-specific hydrogen regulatory authority and relies more heavily on large-scale export-oriented projects. A further key result is that EU RFNBO compliance verifies renewable origin and greenhouse gas performance, but does not sufficiently address broader local sustainability impacts; therefore, environmental and social safeguards beyond RFNBO require measurable indicators and verification mechanisms, especially regarding water stress, land use, community benefits, labour conditions, local value creation and equitable revenue-sharing.

AZ: 30025/078

Zeitraum

04.02.2026 - 03.02.2027

Land

Polen

Institut

Fraunhofer-Institut für System- und Innovationsforschung ISI Abteilung Energiepolitik und Energiemärkte Geschäftsfeld Erneuerbare Energien

Betreuer

Dr. Jakob Wachsmuth