Opinion

Policy volatility and investment risks in hydrogen exports profitability — An India playbook: Aashish Kasad, Senior Partner and National Leader for the Chemical and Agriculture Sector, Ernst & Young, India

The government projects Rs. 8 lakh crore of cumulative investment and 600,000 green jobs created across the value chain by 2030

  • By Aashish Kasad, Senior Partner, Ernst & Young | February 27, 2026

India’s National Green Hydrogen Mission (NGH), launched in January 2023, with an overarching objective to make India the global hub for production, usage and export of green hydrogen and its derivatives, is moving from vision to execution—and with it, a once-in-a-generation opportunity to position Indian developers, ports, and financiers at the center of the hydrogen trade, given a global demand of over 100 MMT of green hydrogen and its derivatives like green ammonia expected to emerge by 2030.

However, export profitability is inseparable from policy volatility at home and abroad.  European certification rules, border carbon pricing, and import auctions—and Japan’s 15-year CfD subsidies—can swing margins more than equipment costs or renewable tariffs. The edge lies in structuring projects that fit multiple policy regimes while securing policy-backed offtake.

India has signalled scale and intent: a 2030 target of 5 MMT/year of green hydrogen, incentives under Strategic Interventions for Green Hydrogen Transition (SIGHT), hub development, and a public R&D and standards framework.

The government projects Rs. 8 lakh crore of cumulative investment and 600,000 green jobs created across the value chain by 2030, with an explicit ambition to become a global export hub.

Recent tenders span green hydrogen hub Detailed Project Reports, transmission lines for Tuticorin and Kakinada, and cluster development calls—showing the enabling pieces are being assembled on the ground.

Solar Energy Corporation of India (SECI) has launched a call for proposals for Green Hydrogen Hubs, while specialized tenders target transmission systems for proposed green hydrogen/ammonia projects in Tuticorin (Tamil Nadu) and Kakinada (Andhra Pradesh). These corridors are the backbone for moving electrons to molecules and molecules to ships, synchronizing upstream renewables with downstream export logistics.

Why policy alignment is the new Levelized Cost of Hydrogen (LCOH)

For an Indian exporter, “clean” is not a slogan—it’s a passport.

In the EU, two Delegated Acts (Renewable Fuel of Non-Biological Origin (‘RFNBO’) define renewable hydrogen eligibility via additionality, temporal and geographic correlation between renewables (with no biomass involved) and electrolysis. These rules apply to imports, hence, Indian exports must satisfy EU definitions and documentary evidence—otherwise, they lose premium pricing, may be excluded from certain subsidies, and could face carbon border costs. [ec.europa.eu], [europex.org] Legal and technical analyses stress that RFNBO rules entered into force in 2024 with phased stringency, shaping contracts for e-ammonia/e-methanol and altering how PPAs, storage, and certification are structured.  Projects should be engineered for hourly-matched Energy Attribute Certificates (EACs) and additionality pathways, with contingency to adapt as EU guidance evolves.

The US also finalized its Section 45V clean hydrogen tax credit (Jan 2025), established by the Inflation Reduction Act, preserving the “three pillars” while adding flexibilities for at-risk nuclear and specific state regimes.

Even if India is producing for export, the US Section 45V credit matters for partners and competitors whose cost curves include up to $3/kg credits. Indian developers should benchmark against the US Section 45V credit-enabled producers to gauge competitive landed price parity in Europe/Japan.  Meanwhile, US rules lock projects into specific 45VH2-GREET model versions, which assesses emissions from "well-to-gate" (from raw material extraction to hydrogen production), including various production pathways like electrolysis and steam methane reforming with carbon capture, to determine eligibility and credit amount, encouraging lower-emission hydrogen —reminding us that regulatory model risk can be ten-year risk.

Europe’s H2Global and CBAM: Two Levers on Your Netback

Germany’s H2Global double-auction model has already converted ammonia imports to binding long-term contracts (2027–2033) at transparent price points, and expanded its budget architecture toward ~€3 bn to align with ten-year developer contracts. For Indian suppliers, these instruments provide bankable offtake—but they also create basis risk between fixed supply prices and shorter-dated resale tenders. Hence one needs to price the subsidy gap and be prepared for budget or policy changes in Germany and EU.

Simultaneously, the EU’s Carbon Border Adjustment Mechanism (CBAM) moves from reporting to payment obligations on January 1,  2026, covering hydrogen and fertilizers, with obligations phased alongside EU ETS free-allowance reductions to 2034. For exports of ammonia (India’s likely carrier), embedded emissions will translate to CBAM certificate costs unless you qualify as low-emissions under EU methodologies. CBAM simplifications adopted in 2025 eased admin for small importers, but hydrogen remained outside certain mass-based exemptions, maintaining compliance costs. This narrows the profitability window for grey or inadequately abated blue molecules.

Hence, while H2Global can secure revenue, CBAM can claw it back. Contract clauses must explicitly address CBAM pass-through, embedded emissions verification, and RFNBO eligibility. Without that, CBAM becomes a variable levy on an Indian exporter.

Japan’s 15-year CfD and Cluster Subsidies: The Second Anchor

Japan’s Hydrogen Society Promotion Act (2024) empowers two subsidy streams: long-term price gap subsidies (Contracts for Difference (CfDs) to bridge the cost gap for low-carbon hydrogen and derivatives (including ammonia) and cluster support for import and distribution infrastructure. The government signalled carbon intensity thresholds and a goal to start supply by FY2030 with continuity for ten more years post-support. That is both a demand signal and a timeline discipline for Indian exporters.

Industry briefings indicate Japan's Ministry of Economy, Trade and Industry (METI) will roll CfDs project-by-project, resembling H2Global’s market-making, while funding clusters to retrofit terminals and pipelines. This provides India with two strategic options: (1) bid into CfDs with Tuticorin/Kakinada–linked supply chains and (2) co-develop terminal capacity to ensure bankable logistics.  Currency exposure (JPY/INR) and reference price mechanics in CfDs will affect realized margins—hence companies will need to structure FX hedges and base-price disclosures with care.

India’s Corridors: Tuticorin and Kakinada as Export Springboards

Policy momentum meets geography at Tuticorin and Kakinada. Tender documentation shows tariff-based competitive bidding for transmission supporting green hydrogen/ammonia in the Tuticorin area, and independent transmission projects for Kakinada (Phase I)—a strong indicator that state agencies and central nodal bodies are aligning infrastructure with export ambitions. Pair these corridors with NGHM Hub selection (SECI’s CfP) and MNRE’s certification scheme to create integrated electron-to-molecule-to-terminal pathways.

Indian companies should also track the NGHM’s R&D and pilot schemes (including biomass-based hydrogen pilots led by BIRAC) that diversify production pathways and hedge feedstock risk. Given water and land constraints, a portfolio mix—coastal wind/solar, hybridized dispatch with storage, and select biomass/biogenic routes—can improve resilience under RFNBO and CBAM accounting.

Shipping and Terminals: Standards, Safety and Capex Timing Risk

 Ammonia remains the practical carrier for hydrogen exports, but maritime rules are still evolving. DNV’s latest white paper and class rules outline approval pathways and safety regimes for ammonia/hydrogen fuels, emphasizing crew training, bunkering safety, and alternative design approvals in the absence of fully mandatory IMO rules. For Indian terminals and port operators (Tuticorin/Kakinada), early alignment with class guidance reduces approval friction and mitigates future retrofit costs.

Peer-reviewed work captures adoption risks: NOx/N₂O management, fleet renewal hesitancy, and supply chain readiness across onboard and portside infrastructure. Terminal market analyses add that independent ammonia storage capacity is constrained and project realization rates are low due to cost and offtake uncertainty—making timing a first-order risk. Indian companies should price demurrage, premium storage, and contingency capex into models; delays in European/Japanese terminal readiness can erode margins even if Indian upstream plants are on time.

Competitive Yardsticks and Global Momentum

The International Energy Agency’s (IEA) reviews note that while investment is rising (clean hydrogen spending up ~70% in 2025), low-emissions hydrogen still accounts for <1% of global hydrogen demand, and project pipelines have been revised down due to policy and infrastructure uncertainty. Successful export plays will therefore be those anchored by policy-backed offtake and robust compliance strategies—rather than speculative merchant bets on green premiums.

Saudi Arabia’s NEOM demonstrates how long-term offtake and sovereign alignment de-risk mega-projects (≈4 GW renewables, first ammonia by 2027; 30-year offtake), but also how export profitability remains exposed to destination market rules and shipping safety standards. India’s advantage is proximity to East-West trade lanes, competitive renewables, and policy momentum—if we engineer multi-standard compliance and secure European/Japanese instruments, we can compete on delivered cost and policy certainty.

Indian Companies’ Checklist

Engineer for RFNBO & 45V compatibility

Design power sourcing, storage, and EAC strategies to meet EU hourly matching and additionality, while ensuring emissions baselines would satisfy US-style pillar logic. This preserves offtake optionality and avoids redesign costs if policy tightens.

Target policy-backed offtake first

Bid into H2Global (ammonia/methanol lots) and Japan’s CfDs with Tuticorin/Kakinada logistics mapped; include CBAM pass-through and RFNBO compliance warranties. Don’t rely on merchant arbitrage to Europe.

Build data and verification muscle

CBAM and RFNBO place heavy weight on audited emissions and correlation proofs. Invest early in metering, traceability, and third-party verification to minimize certificate surrender costs and contract disputes.

Co-develop terminals and safety regimes.

Partner with class societies to pre-approve bunkering and storage designs; synchronize port capex timelines with SECI hub schedules to reduce demurrage and storage pricing shocks.

Portfolio diversification

Blend electrolytic and high-capture blue (where acceptable to offtakers) and diversify offtake across EU/Japan to hedge localized policy shocks; leverage NGHM pilots to add biogenic routes where feasible.

In conclusion

India’s export profitability in hydrogen will be driven by policy impact as much as in engineering drawings. The combination of NGHM execution (hubs, Tuticorin/Kakinada transmission) and policy-anchored demand (EU H2Global, CBAM discipline; Japan CfDs and clusters) can turn cost advantages into bankable margins—if projects are structured for multi-jurisdiction compliance, long-term offtake, and logistics resilience. 

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