에너지전환 관점에서 본 한국 “수소전문기업 지정제도”의 구조적한계와 제도 개선 방안: 수소 연계 연료·수소화합물을 중심으로

초록

This study examines the structural limitations of Korea's Hydrogen Specialized Enterprise(HSE) program inlight of the global expansion of the hydrogen value chain beyond gaseous hydrogen toward hydrogen-linked fuels andcompounds, including ammonia(NH₃), methanol(CH₃OH), and Power-to-X(PtX)-based e-fuels. The domestic cleanhydrogen certification framework, which was established through statutory amendments in 2022 and subsequentministerial regulation revisions in 2023, remains structurally disconnected from enterprise-level support mechanismsunder the current HSE designation system. This paper identifies four principal reform options: (i) administrativeclarification of hydrogen-linked fuel revenues as hydrogen-sector sales; (ii) establishment of a pre-HSE investmentdriventrack for firms lacking a proven revenue track record; (iii) fast-track linkage between clean hydrogen certificationand HSE designation; and (iv) advanced support system for global supply chain response. These proposals are informedby comparative analysis of the U.S. Inflation Reduction Act (IRA §45V and §45Z, as modified by OBBBA P.L. 119-21) andthe EU Renewable Energy Directive III(RED III) RFNBO framework.

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