What is the relationship between hydrogen as a CBAM product and the Renewable Energy Directive (EU) 2018/2001 (‘RED II’)?
In my company we are starting to investigate the issue and how it affects us. The truth is that we have a lot of questions to clarify, and we need some help. All comments and suggestions are welcome.
1 Answer
The Implementing Regulation states that “Where hydrogen produced has been certified in accordance with Commission Delegated Regulation (EU) 2023/1184(1), an emission factor of zero for the electricity may be applied.” (Annex II, Section 3.6). This implies that hydrogen certification as an “RFNBO” (renewable fuel of non-biological origin) under the Renewable Energy Directive can serve as proof of zero indirect emissions, eliminating the need for dual certification.
Should such certification be absent, the indirect emissions must be calculated following Annex III of the Implementing Regulation.