April 30, 2026
Kiko Network
Kiko Network submitted the opinion to the Office of the High Commissioner for Human Rights (OHCHR) which calls for input on technologies related to climate change and their impacts on human rights.
Comment Submission on Risks and Human Rights Violations Associated with Ammonia Co-firing
Introduction
In response to the call for input by the United Nations Office of the High Commissioner for Human Rights (OHCHR) regarding technologies related to climate change and their impacts on human rights, we submit the following comments focused on the misguided decarbonization strategy by the Japanese government, particularly as it promotes the use of hydrogen/ammonia fuels.
This submission highlights impacts on the climate and human rights stemming from “transition technologies”, particularly thermal power generation using hydrogen/ammonia, promoted by the Japanese government.
While hydrogen/ammonia co-firing technology is presented as a means of decarbonization, in reality it could prolong fossil fuel dependency, further exacerbate climate change and therefore have severe impacts on human rights.
Specifically, by violating the right of current and future generations to be protected from the effects of climate change, it could also affect the right to access water and food. This could infringe upon the UN General Assembly resolution adopted in July 2022, “the human right to a clean, healthy and sustainable environment” (A/RES/76/300).
Furthermore, we believe that there are challenges in ensuring the fundamental rights; access to information, participation in decision-making, and access to effective remedy, which are the three pillars of the UN Guiding Principles on Business and Human Rights.
The impact is likely to be concentrated on the following demographics:
- Residents living near power plants
- Communities in ammonia producing regions
- Low-income households which are particularly vulnerable to rising energy prices
- Agricultural workers affected by rising fertilizer prices
- People in technology-importing countries
- Future generations
１．General Questions
While the Japanese government emphasizes CO2 emission reduction during combustion when promoting hydrogen/ammonia fuel and co-firing technologies in thermal power plants, the overall emission reduction effect across the entire lifecycle, including manufacturing and transportation, remains uncertain. In particular, current strategies are based on the premise of relying on hydrogen/ammonia derived from fossil fuels (so-called “gray” hydrogen/ammonia). Despite the lack of commercial demonstration of co-firing technology in thermal power plants, it is being promoted as a primary decarbonization technology, which will lead to the continued use of existing fossil fuels (coal and LNG) and locked-in future CO2 emissions. This will hinder the expansion of renewable energy and improvement of energy efficiency, delaying the transition to low-risk alternatives. Furthermore, it exacerbates human rights violations and environmental destruction in the upstream manufacturing processes of hydrogen/ammonia. There is also a risk of undermining the future generations’ right to a healthy environment.
In addition, there is insufficient disclosure of information regarding the adverse impacts on the environment and human rights of the hydrogen/ammonia manufacturing process, which shows the lack of transparency across the entire supply chain.
Furthermore, the responsibility and compensation systems in the event of damages are unclear, which poses a challenge from the perspective of ensuring the right to access remedy.
２．Links between climate-related technologies and defossilization
Although the Japanese government positions hydrogen/ammonia as “non-fossil energy”, the hydrogen and ammonia demanded by large-scale thermal power plants are likely derived from fossil fuels.
Meanwhile, major power companies and others are running advertisements describing hydrogen/ammonia as “CO2-free fire” and “carbon-free fuels”. However, such advertisements do not necessarily accurately explain the reality of hydrogen/ammonia fuel use and we believe that within climate change countermeasures these campaigns fall under “climate disinformation”. This kind of disinformation prevents consumers from making informed decisions and violates their right to access information.
The expansion of hydrogen/ammonia fuel use in large-scale thermal power plants may exacerbate environmental damage and human rights violations, such as health hazards, during the manufacturing process.
Furthermore, ammonia is a highly toxic substance that poses risks to environmental and human health throughout its supply chain, in the stages of production, transport, storage and use. For example, given that an existing ammonia plant has caused serious health problems due to ammonia leaks, local residents in North Sumatra, Indonesia have voiced opposition to plans for green ammonia production. It is essential to disclose information, including the risks of ammonia fuel, to nearby residents not only at manufacturing sites but also at thermal power plants that store and utilize large quantities of liquefied ammonia as fuel. Exposure to high concentrations of ammonia poses significant health and safety risks, and therefore, it is necessary to conduct proper impact assessments and safety management during fuel production and combustion.
Based on the UN Guiding Principles on Business and Human Rights, companies are responsible for conducting human rights due diligence throughout their entire supply chain. However, current effectiveness is insufficient, and responsibility tends to remain vague, especially in cross-border supply chains.
３．Finance and international cooperation
A significant amount of public funding is being invested in hydrogen/ammonia -related technologies. This deprives more effective and lower-cost opportunities for investment in renewable energy and energy efficiency improvements. With support from organizations such as the New Energy and Industrial Technology Development Organization (NEDO), Japan is developing technology, conducting demonstration experiments and developing transport vessels and infrastructure to export these technologies to Southeast Asia and the Global South as part of international cooperation. This risks delaying the energy transition of these countries and solidifying their long-term dependence on fossil fuels. Furthermore, increased demand for hydrogen/ammonia could impact existing the fertilizer market and affect access to food through increased agricultural costs. This impacts the right to food, particularly in vulnerable communities.
If hydrogen and ammonia are used as fuels, reliance on fuel imports will continue, cost of power generation will increase, and consumers will be forced to continue using high-cost electricity, particularly contributing to the possibility of increased burden on low-income households. International cooperation should be directed toward technologies that truly contribute to emission reductions with overwhelmingly fewer negative impacts on human rights.
Information
Call for Input – Technologies related to climate change and their impacts on human rights (Link)
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