Executive Summary

The European Union has promoted the liberalisation reform of the natural gas market since the 1980s, with unbundling gradually becoming a core policy instrument in this process. Third-party access (TPA) provides an institutional pathway for the grid connection and market competition of renewable and low-carbon gases, and unbundling has thereby gradually transformed from a market competition tool into a regulatory instrument serving climate objectives. The EU's experience with unbundling in the natural gas sector has prompted discussions on extending this regime to hydrogen industry. While the market value and decarbonisation function of unbundling have been widely recognised, the structural deficiencies inherent in the regime itself, combined with the high degree of uncertainty characterising the hydrogen market as an emerging sector, have made the applicability of unbundling in the hydrogen sector a focal point of controversy in energy law. Taking the EU, China and the United States as three comparator jurisdictions, this article systematically examines the historical experience and institutional defects of unbundling in the natural gas sector, explores the feasibility of extending unbundling to the hydrogen sector from the dual perspectives of market efficiency and climate governance, and offers preliminary proposals for institutional optimisation.