The criteria center around two aspects. First, whether the electricity to produce the hydrogen is actually renewable. More criteria than just the source of electricity are relevant here. Second, the GHG emissions of the product which need to be calculated and which need to be below a certain threshold (28.2 gCO2eq/MJ). More information are summarized here: Policy brief on EU requirements for renewable hydrogen and its derivatives - PtX Hub

Certification is managed by voluntary schemes recognised by the European Commission (e.g. CertifHy, ISCC EU, RedCert). Then, third-party auditors verify that production meets the sustainability and emission-saving criteria set by RED II and its Delegated Acts

Pre-certification is an optional activity that can help to de-risk audits, test data flows and verification and more. MED-GEM’s Morocco Tarfaya pilot offers a replicable blueprint.

No. Hydrogen produced by bio-electricity leads to a biofuel hydrogen, not RFNBO hydrogen. You may use bio-electricity for non-relevant energy inputs (e.g., building heat) without affecting RFNBO renewability; where bio-electricity powers a non-relevant process that is counted (e.g., CO₂ capture), its emissions are included in the GHG calculation for that specific process.

We are not aware that specific rules for such cases exist, but we recommend getting in touch with the RFNBO Certification Schemes (ISCC, CertifHy and REDcert) directly and inquire dedicated feedback to specific cases.

In general, back-to-back contracts between RE producer & intermediary and intermediary & RFNBO producer or sleeved PPAs between the three entities are possible under the condition that the PPA clearly identifies the installations that produce the amount of renewable electricity that is used to produce the RFNBO – the same condition applies for parent/sister companies or project sponsors.

Demonstrating additionality in the context of the EU RFNBO requirements, is required per project case and is to be done by the project that is seeking alignment with these requirements – not by countries.

The EU Delegated Regulation (EU) 2023/1184 sets the obligation for “reliable information demonstrating compliance,” but it does not prescribe specific documents.

The specific types of proof with regards to additionality may include:

With regards to Art. 5 (a)  “The installation generating renewable electricity came into operation not earlier than 36 months before the installation producing the renewable liquid and gaseous transport fuel of non-biological origin.” 

• PPAs, company metering systems.
• Commissioning documents or operation permits for installation(s) producing RFNBOs.
• Relevant operational plans, data originating from the bidding zone’s TSO or DSO (whichever apply) to verify the first date of electricity injection, data such as commercial contracts and production data supporting the commissioning date of the installation producing RFNBO.

With regards to Art 5 (b) “The installation generating renewable electricity has not received support in the form of operating aid or investment aid”

• Description of supporting schemes for renewable electricity in the relevant countries, bidding zones, states or regions along with a list of supported installations in the context of these supporting schemes originating from a public and trusted source (governmental and / or institutional).
• Where no trusted source is available, the absence of support shall be supported by a statement found in the Power Purchase Agreement or self-declaration from the Economic Operator, stating that the installation(s) producing renewable electricity have not received support in the form of operating aid or investment aid.
• Where an installation is identified as having received support, the reimbursement of such support shall be evidenced by financial statement.

The main role of the certification schemes is to translate the EU requirements into a certification approach for RFNBOs. With the official recognition of three of them specifically for RFNBOs (ISCC, CertifHy, REDcert), these three have fulfilled this task. Currently, since the EU RFNBO requirements do not address sustainability issues other than electricity sourcing and GHG emissions from the final product, certification schemes are not required to do so either.

During the transitional phase, both direct and indirect emissions of CBAM covered goods must be reported. At the present stage, for the definitive period direct emissions must be reported for CBAM covered goods in the iron and steel, hydrogen, aluminum and electricity (as a CBAM good) sectors and both direct and indirect emissions must be reported in the fertilizers and cement sector.

An importer’s CBAM obligation in terms of the number of CBAM certificates to be surrendered can be reduced by the specific emissions covered by a carbon price effectively paid in the country of origin. The European Commission is currently working on the rules for the deduction of the carbon price effectively paid in the country of origin.

Guidance documents and worked examples (by GIZ) on the application of the CBAM GHG methodology during the transitional period and other relevant considerations for hydrogen and fertilisers will be shared via the Helpdesk and the website’s Resources section.

Responsibility for financial obligations and penalties lay by the reporting declarant. This can be the importer or the indirect custom representative. Installations in third countries are not responsible for financial obligations and penalties under CBAM.

No, the entry into application of CBAM has not been postponed. The Omnibus I simplification package provided for a specific treatment for the first year of the CBAM financial adjustment. Declarants will be able to purchase CBAM certificates from February 2027 to cover the emissions embedded in the CBAM goods they will have imported during 2026. The CBAM provisions as part of the Omnibus simplification package have already been adopted.

A 50-tonnes/year per importer mass threshold was introduced to simplify admin, exclude small importers and potentially also a wide range of export-oriented installations, while preserving CBAM climate and environmental integrity.  Hydrogen and electricity are excluded from this threshold.

The 80% rule (% of emissions that should be covered by CBAM certificates at the end of each quarter by the reporting declarant since the start of the year) has been moved down to 50% and declarants will be given the choice between two options for the calculation. The 1/3 rule (the number of certificates eligible for repurchase by NCAs was limited to one third of the total number of CBAM certificates purchased by the authorised CBAM declarant during the previous calendar year even if the purchase year is different. After the simplification, all certificates which the Regulation forced a declarant to buy can be sold back and apply to the same year as the year of purchase.

Declarants can now choose between actual embedded emissions and default values with a mark-up. New default values based on country averages have been adopted by the European Commission. Default values feature mark-ups. During the definitive period actual emissions have to be verified by an accredited verifier. The verification of embedded emissions based on default values has been removed

Market-based specific emission factors, determined for example by Guarantees of Origin or Green Certificates cannot be used by themselves to justify the use of actual emission factors.

The eligibility of carbon credits under Article 6 of the Paris Agreement will be considered for a potential reduction as stated by Amending Regulation (EU) 2023/956 as regards the extension of its scope to downstream goods and anti-circumvention measures. The precise details will be provided by the still to be proposed Implementing Regulation for accounting the carbon price paid abroad.

Published CBAM benchmarks will be reviewed after finalization of EU-ETS benchmarks in Q1/26 If revised, new CBAM benchmarks will apply from 1/1/2027.

Please see recital (10) of Comission Implementing Regulatoin 2025/2620

The EU-ETS price that will be used as a reference to determine the price of CBAM certificates for 2026 imports will be determined retroactively (as the first CBAM declaration has to be filed by the reporting declarant in 2027) based on the quarter of import. For each quarter an average of the EU-ETS actions will be calculated.

The price of a quarter will be calculated during the first calendar week of the following quarter, and published on the first working day of the calendar week following the calculation week.

The first publication is expected on Tuesday, 7 April. For transparency and operational purposes, publication will take place both on the European Commission’s CBAM webpage and in the CBAM Registry.

Please see Art. 1 of Implementing Regulation: 2025/2548 and European Commission a announcement.

New default values have been adopted for the definitive period. These are no longer based on world averages per CN code but on country averages. Default values now feature marks-ups. Fertilizers feature a mark-up of 1% for the years 2026, 2027 and 2028. The lowest in comparison with the other sectors.

The default values and mark-ups shall be revised by December 2027 at the latest.

Please see: COMMISSION IMPLEMENTING REGULATION (EU) 2025/2621

Typical textile activities such as spinning, weaving, dyeing and garment manufacturing are not listed ETS activities and usually do not exceed the combustion thresholds required for inclusion. Therefore, textile products themselves are not directly covered. 

However, several upstream chemical processes used to produce synthetic fibres are often covered by the EU ETS. The production of bulk organic chemicals — such as precursors for polyester, nylon, acrylic and elastane — can fall under scope of the EU-ETS rules when carried out in large industrial installations.

As the Carbon Border Adjustment Mechanism (CBAM) must mirror the scope of the EU-ETS, textiles are not in CBAM scope.

The European Commission has indicated that CBAM could gradually expand to additional ETS sectors in the coming years. If organic chemicals or polymers are added in a future extension synthetic fibre inputs could be affected.

The rules for calculating the emissions related to electricity for both, electricity imported into the customs territory of the Union and electricity used in the production of CBAM goods are set in Annex II D of Commission Implementing Regulation (EU) 2025/2547 with regards the methods for the calculation of emissions embedded in goods. 

In summary, for the calculation of emissions related to electricity the determination of an emission factor for electricity is needed which is then multiplied by the amount of electricity consumed in MWh.

Emission factors for electricity used in the production of CBAM goods shall be determined based on either: 

1. The average emission factor of the country of origin electricity grid, made available in accordance with Annex IV of Regulation (EU) 2023/956;
2. An alternative default value, where sufficient evidence is submitted based on official and public information to demonstrate that the average emission factor of the grid of a third country or group of third countries, in which electricity was produced, is lower than the values established in accordance with point (a).
3. Actual emission factors for electricity may be used if a direct technical link between the installation in which the imported good is produced and the electricity generation source or if the operator of the installation has concluded a power purchase agreement with a producer of electricity located in a third country for an amount of electricity  equivalent to the amount for which the use of specific value is used.

Elements of evidence to be provided are described in point D.4.3 of Commission Implementing Regulation (EU) 2025/2547.

The emission factor for calculating the specific embedded emissions of imported electricity shall be established as follows:

1. The specific default value for a third country, group of third countries or region within a third country.
2. Where no specific default value is available pursuant to point (a), the CO2 emission factor in the EU.
3. An alternative default value determined on the basis of the available and reliable data provided can be used where a country, or group of third countries, submits sufficient evidence based on official and public information to demonstrate that the CO2 emission factor in the third country, group of third countries or region within a third country from where electricity is imported is lower than the values in accordance with points (a) and (b), and where certain conditions are fulfilled.
4. Actual Embedded emissions if the authorized CBAM declarant can demonstrate (elements of evidence are described in D.2.4 of Commission Implementing Regulation (EU) 2025/2547) that the cumulative criteria (a) to (d) provided in point 5 of Annex IV to Regulation (EU) 2023/956 are met. (The latter may be subject to changed as proposed by amending Regulation (EU) 2023/956, please see the following question and answer)

The main proposed changes are:

1. The method used to calculate the emission factor for imported electricity should be modified so as to take into account the electricity produced from all sources, including non-fossil fuel sources. As a result, revised default values for imported electricity should be calculated and made available by the Commission.
2. To facilitate the determination of embedded emissions of electricity on the basis of actual emissions, the conditions for applying actual embedded emissions in imported electricity should be made more flexible. In concrete:           
   • It should be clarified that certain power purchase agreements concluded between intermediaries may be used.
   • ·       The criteria to demonstrate absence of physical network congestion at any point of the network at the time of import should be removed.
   • ·       The criteria to prove the direct connection to the Union transmission system should be removed.
   • ·       The need to demonstrate a firm nomination of the allocated interconnection capacity where capacity is allocated through implicit capacity allocation should not be necessary.
3. With regards to default values for embedded indirect emissions: When a country or group of third countries can demonstrate that the average electricity mix emission factor or CO2 emission factor of price-setting is lower than the default value for indirect emissions, apart from that  CO2 emission factor, also the average mix emission factor can be used for the establishment of an alternative default value. This should also incentivise taking into account the electricity produced from all sources, including non-fossil fuel sources.

It should be noted that the above-mentioned elements in points a. to c are part of a legislative proposal and therefore not yet binding.

Some of the main changes are summarized below:

1. Regarding monitoring and determination of actual emissions:
   • Operators of installations should make a monitoring plan available in order to support the calculation and verification of actual embedded emissions. Please check Art. 5 of of COMMISSION IMPLEMENTING REGULATION (EU) 2025/2547
   • Operators shall also prepare an emissions report (‘operator’s emissions report’) and a summary thereof. Please check art. 10 of COMMISSION IMPLEMENTING REGULATION (EU) 2025/2547
2. Regarding specific elements of the methodology, changes can be checked under the following sections:
   • For Ammonia: under section 3.7 of COMMISSION IMPLEMENTING REGULATION (EU) 2025/2547
   • For Urea: under section 3.9 of COMMISSION IMPLEMENTING REGULATION (EU) 2025/2547

A deduction can be claimed if a carbon price has already been effectively paid in the country of origin. The CBAM Regulation defines a ‘carbon price’ as the “monetary amount paid in a third country, under a carbon emissions reduction scheme, in the form of a tax, levy or fee or in the form of allowance under a greenhouse gas emissions trading system. 

Only the carbon price that has been “effectively paid in the country of origin” will count for a reduction of the number of CBAM certificates, meaning that any rebate or other form of compensation will be taken into account to establish the carbon price effectively paid.

The European Commission is preparing an implementing act setting out additional details for the deduction of the carbon price effectively paid in the country of origin including the role of Art. 6 credits under the Paris agreement.

As from 2027, the European Commission may, for third countries where carbon pricing rules are in place, determine and make available default carbon prices for those third countries and publish the methodology for their calculation to simplify and facilitate monitoring and reporting of a carbon price effectively paid.

The European Commission is working on a supporting study to:

• Analysethe design of various carbon pricing instruments (carbon taxes and emission trading systems)
• Develop methodological approaches for attributing a share of the total carbon price to the CBAM embedded emissions and for the conversion to a number certificates
• Develop possible approaches for the certification of the carbon price (incl. governance, evidence required, qualifications of certifier).

If actual values are used, embedded emissions must be verified by an accredited verifier.

Third country based (outside the EU) candidates can also become accredited verifiers. They will have to apply for accreditation to an EU National Accreditation body.

For now, just EU Member States National Accreditation Bodies (NABs) are the ones authorized to accredit verifiers under CBAM.

Accreditation of verifiers should start in 2026, verification at installations in early 2027 and first CBAM declarations will be submitted by 31 May 2027.

The candidate verifier is already an accredited verifier under the EU ETS for a relevant group of activities and they are granted accreditation for the related CBAM activities (simplified procedure) 

Or,

Candidate verifier submits a new application to an EU Member State National Accreditation Body.

To qualify as RFNBO, hydrogen (and derivative) production must achieve at least 70% GHG emission savings compared to the fossil baseline of 94 gCO₂eq/MJ. This corresponds to a maximum of 28.2 gCO₂eq/MJ of hydrogen (and derivative), or roughly 3.4 tCO₂eq per tonne of H₂.

A valid RFNBO certificate can support zero indirect emissions for hydrogen in transitional reporting. Reporting still occurs; process is simplified pending the 2025 review.

The pilot confirmed the technical feasibility of applying EU RFNBO standards in the Southern Mediterranean. It highlighted the need for Early coordination with certification bodies, Access to high-quality electricity data, and Clear national frameworks for renewable attribution.

The Helpdesk follows a monthly cycle with weekly steps for submission, response, and review. Complex issues are discussed during Week 3 online sessions (Monday 10:00–14:00 CET).
Quarterly thematic sessions complement this schedule to address priority topics identified by partner countries.

Submit updates through the Helpdesk form. Selected case studies may feature in “Question of the Month” or regional highlight videos.

Mass balance in mixed streams/storage, renewable attribution without mature GO systems, plant-level data alignment with verifier expectations, and default vs. actual CBAM methodology.

Start with capacity building on the CBAM methodology, use sector e-learning/templates, and build minimum MRV blocks so that when exposure grows, data quality and processes are already in place.

The CBAM Regulation mentions the aim to expand the scope to all sectors covered by the EU-ETS. For now, the European Commission has made a legislative proposal to expand CBAM scope to include 180 steel and aluminum-intensive products (down-stream goods), like machinery and appliances, ensuring emissions are reduced rather than relocated. Extension to further down-stream goods and new sectors is being considered.