January 12, 2026
by Mhamed Samet, FCHEA
The U.S. Department of Energy (DOE) released an updated version of the 45VH2-GREET lifecycle analysis model, the analytical tool used to support implementation of the Section 45V Clean Hydrogen Production Tax Credit, in December 2025. The update represents a constructive step forward for industry, expanding hydrogen production pathway coverage, improving technical functionality, and incorporating refinements that better reflect real-world project configurations.
While the technical updates themselves are important, the broader significance is what they signal: continued responsiveness by DOE to stakeholder input and data, and steady progress toward a more practical, comprehensive framework for evaluating clean hydrogen projects. FCHEA and its members have consistently emphasized the importance of ensuring that federal clean hydrogen policy frameworks accommodate the full diversity of production technologies and integrated systems under development today. The inclusion of additional pathways and the refinement of key assumptions in this update are aligned with that objective.
Expanded Coverage of Key Production Pathways
One of the most notable elements of the December 2025 update is the inclusion of several hydrogen production pathways that more closely align with technologies actively being developed and deployed by industry. Newly represented pathways include:
- Partial oxidation of methane;
- Hydrogen by-product from chlorine (chlor-alkali) manufacturing;
- Co-electrolysis of carbon dioxide and water; and
- Reforming pathways with carbon capture and storage (CCS), including configurations with co-produced steam.
Many of these pathways have been priorities raised by industry in past technical discussions and public engagement processes. Their inclusion broadens the range of projects that can be evaluated using a consistent, Department of Treasury-recognized lifecycle framework and helps ensure that emerging and integrated systems are not excluded simply due to modeling limitations.
Technical Refinements that Improve Usability
In addition to new pathways, the update introduces several functional and data improvements, including:
- Adjustments to the pressure functional unit, allowing more accurate treatment of projects that produce hydrogen at lower pressure without immediate compression.
- Corrections to natural gas supply chain scaling behavior and renewable natural gas transmission assumptions.
- Updated default values for methane leakage and flaring efficiency, reflecting more recent analytical work.
What This Means for Industry
Taken together, the December 2025 revisions strengthen the 45VH2-GREET model as a practical compliance and planning tool. Expanded pathway representation and improved technical flexibility should help more projects assess their potential eligibility under Section 45V in a streamlined and transparent manner.
From an industry perspective, this is a positive step in the ongoing evolution of the 45V implementation framework. It reflects an approach that is:
- Technically rigorous;
- Increasingly aligned with real-world system designs; and
- Responsive to feedback from project developers, technology providers, and other stakeholders.
FCHEA Perspective
Continued dialogue will remain important as DOE and Treasury further refine modeling tools, guidance, and implementation practices. Ensuring that lifecycle methodologies remain transparent, technically robust, and adaptable will be essential to supporting investment certainty and accelerating deployment across the U.S. hydrogen ecosystem.
Overall, the December 2025 45VH2-GREET update represents a constructive and welcome advance—one that supports both environmental integrity and practical project development as the clean hydrogen market continues to scale.
