July, 2024 No.46
This issue covers the following topic:
OIL, GAS AND OTHER RESOURCES / ELECTRICITY AND GAS SUPPLY
Passage of the Hydrogen Society Promotion Act and the CCS Business Act

Jiro Mikami
Eiji Miyagi
Yoshihisa Watanabe
Saori Kawai

OIL, GAS AND OTHER RESOURCES / ELECTRICITY AND GAS SUPPLY
Passage of the Hydrogen Society Promotion Act and the CCS Business Act
I.

Introduction

May 24, 2024 saw the promulgation of the “Act on Promotion of Supply and Use of Low-Carbon Hydrogen,etc., for Smooth Transition to a Decarbonized Growth-Oriented Economic Structure” (the “Hydrogen Society
Promotion Act”) and “Act on Carbon Dioxide Storage Business” (the “CCS Business Act”), which were passedby the current Diet session. The Hydrogen Society Promotion Act and the CCS Business Act are the first laws
in Japan focusing on, respectively, hydrogen- and ammonia-related businesses and carbon dioxide captureand storage businesses.
There has been increasing activity recently at the national level toward the realization of a decarbonizedsociety. In light of these developments, the Hydrogen Society Promotion Act and the CCS Business Act, which
serve as foundation for the widespread adoption of hydrogen and ammonia and the societal implementationof carbon dioxide capture and storage business, which are crucial for realizing a decarbonized society, are ofgreat significance. This newsletter provides an overview of these two new laws.

II.

Hydrogen Society Promotion Act(i)

Outline of the Hydrogen Society Promotion Act
The Hydrogen Society Promotion Act, which is scheduled to come into effect on the date specified bya Cabinet Order within a period not exceeding six months from the date of promulgation, sets out thefollowing key provisions:(a) Establishment of a basic policy by the competent minister to promote the supply and use of lowcarbon hydrogen;(b) Establishment of a planning and certification system for both supply and demand aspects of lowcarbon hydrogen;(c) Support measures through the Japan Organization for Metals and Energy Security (the“JOGMEC”), including price differential support and infrastructure development support forcertified businesses, as well as special measures for various regulations; and© 2024 Nagashima Ohno & Tsunematsu

(d) Establishment of criteria to which hydrogen suppliers should adhere.

(ii)

Purpose of and Basic Policy under the Hydrogen Society Promotion Act(a) Purpose
The Hydrogen Society Promotion Act aims to promote the early supply (domestic production or
import and supply) and use of low-carbon hydrogen by providing various support measures tobusinesses which have obtained the necessary planning certification. This promotion will
facilitate the smooth transition to a decarbonized growth-oriented economic structure, which isthe purpose of the GX Promotion Act (the Act on Promotion of Smooth Transition to a
Decarbonized Growth-Oriented Economic Structure; cf. Article 1 thereof).
“Low-Carbon Hydrogen” is defined as (i) Hydrogen, (ii) the amount of CO2 emitted from theproduction of which is less than a certain value, (iii) the use of which contributes to the reductionof CO2 emissions in Japan in light of international decisions on the calculation of CO2 emissions
and which (iv) meets certain other requirements specified in the Ordinance (the “Ordinance”)
of the Ministry of Economy, Trade and Industry (the “METI”) (Article 2, Paragraph 1.).
“Hydrogen” as used just above is defined as “hydrogen and its compounds, as specified by theOrdinance”. The interim report (the “Interim Report”) 1 released by the METI joint conference
prior to its submission to the ordinary Diet session envisioned that “hydrogen” would include
ammonia, synthetic methane, and synthetic fuels, but the details have been delegated to theOrdinance to be established in the future.
With reference to the notion of “carbon intensity” (the amount of CO2 emissions per unit ofhydrogen production) proposed by Japan at the G7 Sapporo Climate, Energy, and Environment
Ministerial Meeting in April 2023, the Interim Report indicates a benchmark value of 3.4 kg
CO2/kg-H2 as one standard for the amount of CO2, which is one of the requirements for “LowCarbon Hydrogen”; the specific benchmark value will, however, be determined in the future.
(b) Basic Policy
The competent minister 2 shall formulate a basic policy on the promotion of supply and use of
Low-Carbon Hydrogen (Article 3). This policy will describe (i) the significance and goals of the
supply and use of Low-Carbon Hydrogen, (ii) the priority contents to be implemented toward therealization of green transformation, and (iii) efforts toward the self-sustained supply of LowCarbon Hydrogen.
On the basis of this policy, the national government, local governments, and business operators
will be responsible for promoting the supply and use of Low-Carbon Hydrogen from theirrespective standpoints (Articles 4 through 6).

(iii)

Certification of Business Plans for Low-Carbon Hydrogen Supply and Special Measures for Support
and Regulations
The core of the Hydrogen Society Promotion Act is the introduction of a plan certification system,
support measures for certified businesses (price differential support and infrastructure development
support), and special regulatory measures.

“Interim Report” (January 29, 2024), Advisory Committee for Natural Resources and Energy, Subcommittee on Energy
Efficiency and New Energy, Subcommittee on Hydrogen and Ammonia Policies, Subcommittee on Resources and Fuels,
Subcommittee on Decarbonized Fuel Policies, Industrial Structure Council, Subcommittee on Safety and Consumer Product
Safety, Subcommittee on Hydrogen Safety.
2 Depending on the item, it will be both the Minister of Economy, Trade and Industry and the Minister of Land,
Infrastructure, Transport and Tourism or the Minister of Economy, Trade and Industry (Article 42, paragraph 1).
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Support forPrice Differential/
Development

Submission ofBusiness Plan

Satisfaction of
Certification Criteria

Certification

JOGMEC
Exceptions toRegulations

Suppliers/Users

High-Pressure Gas
Safety Act
Road ActPort & Harbor Act

Competent Minister(a) Certification of Business Plan for Low-Carbon Hydrogen Supply
Business operators importing or supplying Low-Carbon Hydrogen domestically (the“Supplier(s)”), as well as those utilizing Low-Carbon Hydrogen (the “Users”) may independently
or jointly prepare and submit a “Business Plan for Low-Carbon Hydrogen Supply, etc.” (the“Business Plan”) to the competent ministry. Upon receiving certification from the minister, these
operators become eligible for subsidies for price differential support and infrastructuredevelopment support. Additionally, they may receive special exemptions concerning the HighPressure Gas Safety Act, the Port and Harbor Act, and road occupancy regulations.
When certifying a Business Plan, the relevant minister must ensure that the submitted plan
meets all of the following certification criteria (Article 7, Paragraph 5). The certification criteria
are summarized as follows:

The contents of the Business Plan are appropriate in light of the basic policy.

The contents of the Business Plan are expected to be implemented smoothly and reliably.



The contents of the Business Plan should be economical and reasonable, and should
contribute to strengthening the international competitiveness of Japanese industries
related to the supply or use of Low-Carbon Hydrogen to a considerable extent.



If the applicant wishes to receive subsidies for price differential support and infrastructuredevelopment support, the applicant must conform to all of the following conditions:a)the Business Plan must be jointly developed by the Supplier and Users;b)

The supply of Low-Carbon Hydrogen is expected to start by a certain fiscal year and tocontinue for a certain period of time 3; andc)

It is expected that new capital investment and other business activities for the use of
Low-Carbon Hydrogen supplied in accordance with the Business Plan will be conducted

3 The “certain fiscal year” is to be determined by the Minister of Economy, Trade and Industry, and the “certain period oftime” is to be determined by the Ordinance, but the details have not been determined at this time.

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by the Users.


The port, road, etc. where the pipelines and storage tanks, etc. are to be developed must
be appropriate in light of the port plan, road conditions, and other land use conditions.

(b) JOGMEC Support Measures (price differential support, infrastructure development support)
The Hydrogen Society Promotion Act specifies that JOGMEC shall carry out the following
activities as part of its duties: providing subsidies (price differential support) to allocate funds
necessary for certified Suppliers to continuously supply Low-Carbon Hydrogen in accordancewith the relevant certified Business Plan (the “Certified Business Plan”); and to provide subsidies(infrastructure development support) to allocate funds necessary for such certified Supplier toestablish facilities for the storage or transportation of Low-Carbon Hydrogen, or other facilities
required for the implementation of the applicable Certified Business Plan, in accordance
therewith (Article 10, Item 1).
The Hydrogen Society Promotion Act does not provide detailed provisions regarding theconditions for the provision of subsidies, such as price differential support and infrastructuredevelopment support. It is anticipated that JOGMEC will establish such detailed subsidy-related
provisions in the future.
(c) Special Measures for Regulations (High Pressure Gas Safety Act, Road Act and Port and HarborAct)
The Hydrogen Society Promotion Act introduced a mechanism that allows certified Suppliers toreceive certain regulatory exemptions under the premise of a plan certification system.
a)Special Provisions of the High-Pressure Gas Safety Act
For certain hydrogen gases meeting the criteria of high-pressure gases as defined in theHigh-Pressure Gas Safety Act, manufacturing permits and various inspections (such ascompletion inspections and safety inspections) are conducted by prefectures and otherrelevant authorities. However, to expedite the process of large-scale supply and utilizationof Low-Carbon Hydrogen, it is deemed effective for the national government (rather thanprefectures or other local authorities) to comprehensively conduct manufacturing permits,completion inspections, and safety inspections for a certain period after the start ofmanufacturing. Therefore, the Hydrogen Society Promotion Act establishes a system, as a
special provision under the High-Pressure Gas Safety Act, whereby certified Suppliers are
exempted from the need for permits under the High-Pressure Gas Safety Act for
manufacturing and storage for a period of three years from the commencement of same,
upon approval or certification by the Minister of Economy, Trade, and Industry (Articles
12, 17, and 22).

b)Special Provisions for Road Occupancy Permits
If pipelines installed by certified Suppliers in accordance with Certified Business Plan meetcertain criteria, road occupancy permits must be granted (Article 31, Paragraph 2).

c)Special Provisions of the Port and Harbor Law
A Certified Business Plan is deemed to have obtained permission for the implementationof construction within port areas under Article 37, Paragraph 1 of the Port and Harbor Act(Article 11, Paragraph 1). Additionally, certain activities within waterfront district are
exempt from notification requirements (Article 11, Paragraph 2).

(iv)

Establishment of Criteria that to which Hydrogen Supplier Should Adhere
The Minister of Economy, Trade, and Industry is tasked with establishing criteria that should guide- 4 -© 2024 Nagashima Ohno & Tsunematsu

Suppliers in their efforts to promote the supply of Low-Carbon Hydrogen, taking into account (i) the
supply status of Low-Carbon Hydrogen by Suppliers, (ii) the technological standards related to the
supply, storage, transportation, and (iii) utilization of Low-Carbon Hydrogen, as well as (iv) the
economic viability and other factors related to the use of Low-Carbon Hydrogen (Article 32). The
details will be specified concretely after the enforcement of the law.

III.
(i)

CCS Business Act
Outline of the CCS Business Act
The new CCS Business Act does not serve as a comprehensive business law for the entire CCS value
chain but primarily focuses on (i) the establishment of a permit system for exploration drilling andstorage activities, together with regulation and safety measures concerning storage activities (Chapter2) and (ii) regulation and safety measures for pipeline transportation activities (Chapter 3) 4. The full
enforcement of the CCS Business Act will occur within two years from the date of its promulgation, as
stipulated by Cabinet Order. However, regulations related to prospecting will be enforced within six
months from the date of its promulgation, and other provisions will be gradually enforced (Article 1of the Supplementary Provisions). As of now, no details of any ordinance related to the CCS BusinessAct have been disclosed.

CCS Flow Chart

CO2 Emitting
Businesses

Covered by CCS Business Act※Only conduit transport business

CO2 Emission
SourceExhaustGas

Separation andCapture Operator

CO2

Separation andCapture equipment(ii)

Transportation
Service Provider
Pipelines, etc.

CO2

Prospector/Storage
Operator
Exploration drillingand Storage
Facilities

Establishment of Permit System for Exploration Drilling and Storage Activities, and Developmentof Business and Security Regulations for Storage Activities(a) Designation of Specified Areas and Establishment of Prospecting Rights and Storage Rights
The CCS Business Act does not determine storage and prospecting operators through a first-tofile system. Instead, the Minister of Economy, Trade, and Industry designates areas with existingor potential storage layers as “Specified Areas” and selects the most suitable operators forstorage activities or exploration drilling (the “Storage Activities”) through a public solicitation
process (Article 3 and subsequent articles). Those intending to conduct Storage Activities inSpecified Areas must apply to the Minister of Economy, Trade, and Industry in accordance with
the implementation guidelines for the Specific Area and obtain a permit for such activities foreach storage area, as well as for exploration drilling for each prospecting area (Article 4,
Paragraph 1). However, operators who have already obtained mining rights under Article 21,
Paragraph 1 of the Mining Act for petroleum, combustible natural gas, or other substances

It also regulates certain other matters, such as the introduction of a permit system for Prospecting of storage layers (Article
107).

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specified by Cabinet Order may only obtain a permit for Storage Activities or exploration drillingwhen intending to conduct such activities in their mining area (limited to areas outside theSpecified Areas) (Article 12).
Furthermore, persons other than operators who have obtained permits for Storage Activities(the “Storage Operator(s)”) cannot store carbon dioxide in storage layers, except for carbon
dioxide storage as stipulated by the Ordinance related to mineral extraction activities or otheractivities (Article 13, Paragraph 1). Similarly, individuals other than those who have obtained
permits for exploration drilling (the “Prospector(s)”) cannot conduct prospecting activities(Article13, Paragraph 2).
(b) Legal Nature of Prospecting Rights and Storage Rights
Storage Rights or Prospecting Rights (the “Storage Rights”), similarly to mining rights, aredeemed to be in rem rights (Article 12 of the Mining Act), and the provisions on real estate apply
mutatis mutandis unless otherwise stipulated in the CCS Business Act (Article 33). As a result, if
Storage Rights are infringed upon by a third party, the holder can exercise proprietary rights suchas the right to seek removal of the obstruction. However, unlike real estate under the Civil Code,Storage Rights may not be the subject of rights other than general succession, including
inheritance, assignment, disposition of delinquency, execution, provisional seizure andprovisional disposition (Article 34; provided, however, that they may be subject to a mortgage).
Additionally, they cannot be transferred without the approval of the Minister of Economy, Trade,and Industry under Article 17, Paragraph 1 or Paragraph 2 (except by inheritance) (Article 35,
Paragraph 1). Furthermore, instead of registration, the establishment, transfer, modification,
extinction, and disposal of Storage Rights as well as mortgages over Storage Rights, are carriedout by registration in the Storage Rights registration ledger (Article 36).
(c) Establishment and Effect of Storage Rights
When permit for Storage Activities is granted, the Minister of Economy, Trade, and Industry
publicly announces the fact that such permit has been granted, along with certain particulars
such as the name and address of the Storage Operator and the permitted storage area (Article24). Such announcement establishes the Storage Rights concerning the permitted storage area.
Moreover, the exercise of other rights pertaining to the land in the permitted storage area isrestricted to the extent necessary to prevent obstruction or interference with carbon dioxide
storage or prospecting conducted by the Storage Operator within the permitted storage area
(Article 25, Paragraph 1). The period during which other rights pertaining to the land are
restricted due to the establishment of Prospecting Rights shall be limited to the period from thedate of the announcement until the expiration of the validity period of the Prospecting permit
related to the Prospecting Right (Article 25, Paragraph 2).
(d) Major Business and Security Regulations for Storage Operatorsa)Time of Commencement of Storage
As a general rule, the Storage Operator, shall commence the Storage Activities within the
period specified by an METI Ordinance as the period normally considered necessary forcommencing Storage Activities (Article 37, Paragraph 1 and Article 58, Paragraph 1).

b)

Approval of Storage and Exploration Drilling Implementation Plans
The Storage Operator must establish a storage implementation plan for each permitted
storage area and obtain approval from the competent minister before commencing
Storage Activities (Article 38, Paragraph 1). The Storage Operator must not conduct
Storage Activities until such approval of the storage implementation plan is obtained(upon approval, an “Approved Storage Implementation Plan”) (Article 40). Similarly, theProspector must establish a drilling implementation plan for each permitted drilling area
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and obtain approval from the Minister of Economy, Trade and Industry before
commencing exploration drilling (Article 59, Paragraph 1). The Prospector must notconduct exploration drilling unless based on an approved drilling implementation plan
(Article 61).
c)

Monitoring and Reporting by the Storage Commencement Operator
Operators conducting Storage Activities within permitted storage areas, injecting carbon
dioxide into storage layers, and commencing Storage Activities (the “Storage
Commencement Operator(s)”) (Article 22, Paragraph 1) must monitor those mattersspecified by the Ordinance as necessary for confirming the conditions of carbon dioxide
storage in the storage layers within the permitted storage area, including temperature andpressure for the Storage Commencement Activities in accordance with the Approved
Storage Implementation Plan. Storage Commencement Operators must report the results
to the competent minister (Article 43, Paragraph 1 and 2).

d)Provision of Reserves by Storage Commencement Operators
The Storage Commencement Operator must take measures as stipulated by the METI
Ordinance. These include setting aside reserves and other funds in accordance therewith
to cover monitoring expenses for the period commencing on the cessation of injection ofcarbon dioxide into the storage layers within the permitted storage area, until such timeas the Storage Commencement Operator receives the permit for termination of Storage
Commencement Activities (Article 53, Section 5), together with other necessary costs for
implementing the Commencement.

e)Transfer to JOGMEC and Payment of Contributions
When the Storage Commencement Operator takes closure measures with the approval of
the competent minister, and obtains the relevant permit from the Minister of Economy,
Trade and Industry to terminate the Storage Commencement Activities, JOGMEC will be
notified accordingly, and a specific announcement will be made (Article 53). The Storage
Rights related to the Notified Storage Area (referred to as the permitted storage area for
notification to JOGMEC) shall be transferred to JOGMEC by virtue of such announcement(Articles 53 and 55). JOGMEC shall implement the management tasks of the Notified
Storage Area, including monitoring and other activities as prescribed by the competent
Ordinance, to confirm the stable storage of carbon dioxide in the storage layers within the
Notified Storage Area (Article 54). In order to cover the necessary expenses for suchmanagement operations, the Storage Commencement Operator must pay a certain
amount of contribution to JOGMEC for each fiscal year and for each premitted storage
area (Article 45).

f)

Safety Regulations
The Storage Operators are obliged to maintain the structures for storage in conformity
with technical standards specified by the METI Ordinance (Article 67, Paragraph 1), tomake reports in case of disaster (Article 68), to formulate and notify safety regulations(Article 69), to notify construction plans (Article 75), to conduct pre-use voluntary
inspection of the structures for storage, etc. (Article 76), and to conduct periodic voluntary
inspections (Article 77), etc.

(e) Liability of Prospectors and Storage Operators
The CCS Business Act imposes a no-fault liability on operators with respect to liability arisingfrom exploration drilling and Storage Activities (Article 124). In other words, if the storage ofcarbon dioxide in a storage layer, excavation of land for exploration drilling, discharge of well
water, or leakage of carbon dioxide stored in a storage layer causes damage to others, the- 7 -© 2024 Nagashima Ohno & Tsunematsu

Storage Operator in the permitted storage area at the time the damage occurred shall be liablefor compensation for such damage. As a general rule, compensation for damages shall be inmonetary terms; however, if recovery to the original state without incurring significantly more
expenses than the amount of compensation is possible, the victim may seek restoration damages
to such original state. Further, if the court finds it appropriate upon petition by the person liablefor compensation, the court may order restoration of the original state instead of compensationin monetary terms (Article 126, Paragraph 2, Item 3). The above is similar to the compensation
mechanism in the Mining Act (Article 109, Paragraph 1 and Article 111, Paragraphs 2 and 3 of
the Mining Act).

(iii)

Development of Business and Security Regulations for CO2 Pipeline Transportation Business(a) Notification System and Regulation of Terms and Conditions
Pipeline transportation assumes a physical connection between the storage site and theemission source via pipeline, which may lead to a natural monopoly in the region and a dominantposition of the transportation operator over the CO2 emitters. Therefore, the CCS Business Act
adopts a notification system (Article 78) and imposes certain regulations on businesses engaged
in the transportation of carbon dioxide through pipelines for the purposes of storage in storage
layers (including those equivalent to storage layers in foreign countries).
In particular, “Specified Pipeline Transportation Service Providers” (i.e., pipeline transportation
service providers engaged in the business of transporting carbon dioxide emitted from theactivities of other parties on behalf of other parties) are required to establish general terms andconditions for specified pipeline transportation services and notify the Minister of Economy,
Trade and Industry (Article 82, Paragraph 1; the same shall apply to amendments of such generalterms and conditions). In principle, it is prohibited to conduct pipeline transportation businessunder conditions other than those stipulated in such general terms and conditions (Article 82,
Paragraph 2). In addition, in certain cases, the Minister of Economy, Trade and Industry mayorder that such general terms and conditions be changed within a reasonable period (Article 82,
Paragraph 3). The Specified Pipeline Transportation Service Provider shall not give unjust
preferential treatment or benefits, or unjust disadvantageous treatment or disadvantage to any
specific person with respect to its business (Article 83).
(b) Safety Regulations
Pipeline transportation service providers are subject to the same safety regulations as are
Storage Operators, including the obligation to maintain pipeline transportation facilities inconformity with technical standards specified by the METI Ordinance (Article 86, Paragraph 1),
to make a report in case of disaster (Article 87, Article 68), to formulate and notify safety
regulations (Article 88), to notify construction plans (Article 90), to conduct pre-use voluntary
inspection of pipeline transportation facilities (Article 91), and to conduct periodic voluntary
inspections (Article 92, Article 77).

(iv)

Relationship with the Permitting System for Sub-seabed Disposal of CO2 under the Marine
Pollution Prevention Act
The current Act on Prevention of Marine Pollution and Maritime Disasters (the “Marine Pollution
Prevention Act”) stipulated that no person shall, as a general rule, dispose of oil, hazardous liquid
substances, or waste beneath the seabed (including storage beneath the seabed) (Article 18-7).
However, the disposal of “Specified Carbon Dioxide Gas” beneath the seabed is allowed only if the
Minister of the Environment grants a permit (Article 18-7, Item 2). With the enactment of the CCS
Business Act, the sub-seabed disposal permit system for Specified Carbon Dioxide Gas under the
Marine Pollution Prevention Act (Article 18-8 of the said Act) will be abolished (Article 14 of the
Supplementary Provisions of the CCS Business Act) and integrated into the CCS Business Act.

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IV.

Conclusion

In this newsletter, we have reviewed the newly Hydrogen Society Promotion Act and the CCS Business Act. In
addition to the enactment of future government ordinances and regulations, it is necessary to continue to
pay attention to business trends with respect to both the further development of the hydrogen business,
which is still in its early stages, the early social implementation of the carbon dioxide capture and storage
business.

[Authors]
Jiro Mikami, Partner+81-3-6889-7171 jiro_mikami@noandt.com
Mr. Mikami has extensive knowledge and experience in renewable energy and otherinfrastructure projects. He is currently involved in offshore windfarm, corporate PPA (including
virtual PPA), battery and hydrogen projects. He also specializes in the area of banking,structured finance, real estate and mergers and acquisitions.
Eiji Miyagi, Partner+81-3-6889-7674 eiji_miyagi@noandt.com
Mr. Miyagi specializes in general infrastructure and real estate transactions, including
renewable energy, real estate finance, project finance, formation and management of J-REITs
and private funds. Recently, he is also involved in hydrogen projects, agriculture, forestry andfisheries sectors and technology sectors.
Yoshihisa Watanabe, Partner+81-3-6889-7677 yoshihisa_watanabe@noandt.com
Mr. Watanabe is actively involved in resources and energy, construction and infrastructure,project finance, structured finance, J-REITs, real estate transactions, M&A/corporate,
agriculture, forestry and fisheries, and carbon neutrality and sustainability law.
Saori Kawai+81-3-6889-7262 saori_kawai@noandt.com
Ms. Kawai regularly advises financial institutions and developers on renewable energy projects(solar power, biomass, wind, battery and hydrogen) as well as PFI (Public FinanceInitiative)/PPP (Public Private Partnership) projects, utilizing her experience during her
secondment at the Development Bank of Japan. She has also wide experience in the area of
project finance and real estate transactions.

This newsletter is given as general information for reference purposes only and therefore does not constitute our firm’s
legal advice. Any opinion stated in this newsletter is a personal view of the author(s) and not our firm’s official view.
For any specific matter or legal issue, please do not rely on this newsletter but make sure to consult a legal adviser. We
would be delighted to answer your questions, if any.

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