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.

CBAM is in a transitional phase until end-2025. During the transitional phase which started on 1 October 2023 the reporting declarant (which could be the importer or the indirect customs representative) must report at the end of each quarter emissions embedded in CBAM goods imported quarterly, without paying a financial adjustment. The transitional phase is a preparation and learning phase for the definitive period. A comprehensive CBAM review is now taking place.

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 are allowed to freely choose between actual embedded emissions and default values with a mark-up. 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 to justify the use of actual emission factors.

The CBAM Regulation mentions the aim to expand the scope to all sectors covered by the EU-ETS. For now, the EC is working on an extension of CBAM to cover o so-called “downstream products” (i.e. products that are further down the value chain of the goods currently in scope).

During the transitional period (until 2026), producers can prepare documentation and engage with recognised certifiers, but only certified RFNBO hydrogen will be eligible for recognition and trade under EU regulations after full enforcement.

In theory, all carbon sources are eligible. However, with only some sources one will receive a very important deduction in the GHG calculation. The five main categories for the deduction are: Fossil (i.a. Listed activity/ with carbon pricing / until 2041), Biogenic (i.a. RED II Art. 29 sustainability), Direct Air Capture (DAC), RFNBO-derived CO₂, and Geological CO₂ (under specific conditions). Please see more details here: Identification of suitable carbon as feedstock for PtX products to be exported to Europe - PtX Hub

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.

33 questions answered in three months (Morocco, Lebanon, Palestine). Most frequent topics: RFNBO certification pathways, CBAM reporting templates, and carbon-source eligibility.

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.

By 2030, CBAM’s scope may expand following the comprehensive review; signals include consideration of down-stream goods and sectors often cited in discussions (e.g., glass, chemicals), but no official list is set yet.