Hydrogen law, regulations & strategy in Turkiye

Hydrogen plays a vital role in Türkiye's efforts to develop a zero-carbon economic model, supporting its economic growth plans and 2053 net-zero carbon emission targets.  Recently implemented policies and strategic plans have heightened the focus on green hydrogen in Türkiye. Notably, the National Hydrogen Technology Strategy and Roadmap (“Roadmap”), published in January 2023 by the Republic of Türkiye Ministry of Energy and Natural Resources (“Ministry”), has positioned Türkiye as a global leader in green hydrogen economies. According to the Roadmap, Türkiye plans to develop its renewable energy infrastructure and increase the share of renewable energy in the country’s total electricity generation to 76% by 2027 1 .

There have also been a number of new hydrogen plant projects since the first green hydrogen energy plant was built in Bandırma/Balıkesir in 2022: 2

1. Among the prominent initiatives is the HYSouthMarmara project, also known as “Hydrogen Valley”, which has a budget of EUR 36,700,000. The project has secured EUR 8,000,000 from the European Union’s (“EU”) Horizon Clean Hydrogen Partnership Programme. As part of this initiative, the first sodium boron hydride plant, enabling hydrogen storage, will also be constructed in the same region.
2. The GAZBİR-GAZMER Hydrogen Project ("R&D Centre") aims to test and manage the process of mixing hydrogen into the natural gas pipeline. According to recent studies, up to 20 per cent hydrogen can be mixed into the lines to interact with the steel pipes and ensure smooth transmission of natural gas.
3. Two other projects are green hydrogen plants to be built by Türkiye Petrol Rafinerileri A.Ş. in Kırıkkale and Batman in 2025, which will produce green hydrogen using solar power plants.
4. The Energy Market Regulatory Authority has also granted a licence to Türkiye Petrol Rafinerileri A.Ş. to produce 1 GW in addition to the current 450 MW capacity after the company acquired Entek Elektrik A.Ş., which owns power plants across Türkiye.

In addition, there are 32 facilities with excellent accessibility for producing iron and steel using hydrogen in the vicinity of these planned projects. Additionally, according to the Roadmap, studies will be conducted to explore the use of low-cost hydrogen near its production sites. With numerous pipelines spanning east to west, including both transit and non-transit pipelines, Türkiye also has the potential to transport liquid hydrogen or produce significant quantities of ammonia as an end product. 3

Although there are indirect provisions concerning hydrogen technology, there are currently no specific regulations governing hydrogen production(or related transport and storage)  in Türkiye.

In terms of recent developments, the Ministry has published the Roadmap to develop strategies for creating a domestic and national programme to support and implement research and technology development, with particular emphasis on the importance of the domestic development of hydrogen technologies. While the Roadmap addresses hydrogen production, storage, distribution, and related technologies, it also considers hydrogen research and development both within Türkiye and globally.

The main vision outlined in the Roadmap is to produce and utilise green hydrogen technologies to meet domestic needs while exporting any surplus to generate revenue in the energy sector 4 . Furthermore, the Roadmap recognises the current lack of regulation surrounding hydrogen production and sets a goal of establishing primary regulation in this area.

The recently launched HYSouthMarmara project is currently the largest project in Türkiye focused on hydrogen production. Often referred to as a "Hydrogen Valley," the concept denotes a cluster where hydrogen is produced, stored, and consumed, and where companies both produce and use hydrogen. The project has a budget of EUR 36,700,000 and is supported by the EU’s Horizon Clean Hydrogen Partnership Programme 5 . It is also the highest-budgeted project in the history of the European Framework Programmes within the Horizon Europe dimension.

To  facilitate the implementation of Türkiye’s first green hydrogen production technology, a 30 kW PEM electrolyser will be developed, and the green hydrogen produced will be stored and used at the Bandırma Energy Base. This process includes the design, manufacture, assembly, and installation of Türkiye’s first domestic PEM electrolyser system with the highest capacity to date, and the realisation of a green hydrogen production system capable of producing 5 Nm³/hour. The fundamental aim in the Valley is to produce 500 tonnes of hydrogen per year 6 .

The South Marmara region, where the project will be implemented, has unlimited access to water and is a region where two of Türkiye’s most important natural gas and oil pipelines pass. In addition to hydrogen production, the project also includes plans for the processing and use of boron. Specifically, a sodium borohydride plant with a production capacity of 10 tonnes per annum will be constructed, with the primary aim of advancing hydrogen storage solutions.

As a result of this project, the South Marmara Region could become the first carbon-neutral area in Türkiye in line with the 2053 targets 7 .

Although there are no specific regulations on hydrogen production (or related transport and storage) in Türkiye, the Roadmap establishes clear targets to advance green hydrogen production. It sets targets to reduce the cost of green hydrogen production to below 2.4 USD/kgH2 by 2035 and below 1.2 USD/kgH2 by 2053 and to ensure that the installed power capacity of the electrolyser reaches 2 GW by 2030, 5 GW in 2035 and 70 GW by 2053 8 .

The Roadmap also includes 13 different policies, to:

1. review the current legislation and make it suitable for hydrogen production, transportation, storage and use;
2. develop an incentive mechanism for the use of domestic components in the production and storage of green hydrogen;
3. develop certificate programmes for green hydrogen and ensure their traceability;
4. encourage R&D and P&D for the development and production of domestic and national technologies (electrolyser, fuel cell, etc.);
5. engage in public and private sector partnerships to encourage commercial demand and investments;
6. cooperate internationally on issues related to industry, technology, standards and certification development, supply chain and trading opportunities;
7. promote widespread use of green hydrogen in all relevant industries, especially those where carbon emissions are difficult to reduce (chemistry, iron and steel, transportation, glass, ceramics, etc.);
8. ensure continuity in employment by training qualified labour in hydrogen technologies;
9. carry out R&D activities for the production of hydrogen and synthetic gas from lignite and organic wastes;
10. increase the production and share of renewable energy to increase green hydrogen production;
11. contribute to the gradual decarbonisation of the heating sector by blending hydrogen existing natural gas lines;
12. use domestic resources, particularly boron, in hydrogen storage;
13. export excess green hydrogen and ammonia to other countries, especially to the European market, with our domestic technologies 9 .

The Roadmap also acknowledges the current lack of legislation and prioritises aligning existing laws with the needs of hydrogen production, alongside drafting new regulations where necessary. It underscores the importance of nationalisation in hydrogen technologies and proposes the establishment of new R&D centres to advance these objectives.

Development 3:

The GAZBIR-GAZMER Hydrogen Project was established as an R&D centre and has been active for 3 years. This laboratory was created to address challenges associated with the logistics and storage of hydrogen after production. Given that the process of combining hydrogen with natural gas has become increasingly significant in Türkiye, the primary objective of the R&D Centre is to test and manage the integration of hydrogen into the natural gas network.

According to the R&D Centre studies, when 20% hydrogen is added to natural gas, the fuel mixture containing 20% hydrogen requires 8% less volume (m³) than pure natural gas to achieve the same heating level. Experimental results also showed that the combustion efficiency increased from 39.32 per cent to 44.4 per cent by increasing the hydrogen blending ratio to 30 per cent. 10

These results have led to the establishment of a hydrogen village (“HyVillage”) project. In HyVillage, the aim is to mix hydrogen with natural gas in certain proportions and to supply the mixed gas to residential buildings, process test laboratories and central heating test laboratories. 11  This approach aims to fulfil the primary goal of the HyVillage project: providing green hydrogen to residential areas.

As a result of these developments, it has been estimated that up to 20 per cent hydrogen can be integrated into Türkiye’s existing natural gas distribution systems without requiring any modifications 12 . Consequently, hydrogen produced in Türkiye could be transported and stored using existing natural gas pipelines without incurring additional costs.