How to obtain a certificate for your green hydrogen

What kind of hydrogen is involved?

You will need a certificate to demonstrate that your green hydrogen or green hydrogen carrier qualifies as RFNBO and meets the criteria set out in the Renewable Energy Directive. This applies to all owners in the supply chain. As such, it includes companies responsible for the storage, transportation and use of green hydrogen (or hydrogen carriers). The abbreviation RFNBO stands for Renewable Fuels of Non-Biological Origin. This encompasses green hydrogen and energy carriers produced from green hydrogen, such as ammonia, methanol, LOHCs (liquid organic hydrogen carriers) and other synthetic fuels (including those used in transport). This term is derived from the Renewable Energy Directive (RED).

What criteria does RFNBO hydrogen need to meet?

For your hydrogen to qualify as RFNBO hydrogen in compliance with the Renewable Energy Directive, it must meet 3 criteria set out in the RED III Directive. These criteria were also part of RED II, but they were limited to hydrogen for transport at that time.

1. Your hydrogen needs to be produced using ‘additional’ renewable electricity, such as solar or wind energy. This requirement means that new electrolysers cannot use power from existing wind or solar farms commissioned more than 3 years prior to the electrolysers themselves. This prevents the depletion of existing renewable electricity sources. To meet this requirement, RFNBO hydrogen can only be produced if renewable electricity is generated at the same time and in the same geographic area. These criteria are outlined in Article 27.6 of RED III and in Commission Delegated Regulation (EU) 2023/1184.
    
2. Your hydrogen must deliver a reduction of at least 70% in greenhouse gas emissions, relative to the production of grey hydrogen from natural gas. A calculation method defined in Commission Delegated Regulation (EU) 2023/1185 must be used for this purpose. This is specified in Article 29a of RED III.
    
3. The sustainability information for your RFNBO hydrogen must remain linked to the green hydrogen (in accordance with the mass balance system outlined in paragraphs 1 and 2 of Article 30 of RED III). Therefore, this holds true even when it is traded from a producer to an end user, possibly through intermediaries. Are you interested in learning more about mass balance? If so, you may want to read Articles 15 and 19 of Commission Implementing Regulation (EU) 2022/996.

RED III was only recently adopted in Europe.
The Commission Delegated Regulations and Commission Implementing Regulation mentioned earlier will be amended to accommodate the changes introduced in RED III. These regulations have been the subject of much debate, and many questions are still being raised.

Other RFNBO hydrogen carriers are also eligible for certification

You can also certify other RFNBO hydrogen carriers, such as ammonia and methanol, in accordance with the criteria outlined above. This is only possible if the hydrogen carriers are produced from hydrogen that has been certified as RFNBO, in compliance with the RED criteria. Accordingly, the requirement for a 70% reduction in greenhouse gas emissions also extends to hydrogen carriers. This implies that transport-related greenhouse gas emissions must also be taken into account. The same applies to greenhouse gas emissions resulting from the conversion of one energy carrier into another (e.g. the production of ammonia from hydrogen).

Low-carbon hydrogen is not the same as RFNBO hydrogen

In the future, certification of low-carbon hydrogen may also be an option. Low-carbon hydrogen reduces emissions by at least 70%, but does not satisfy the other two criteria for RFNBO hydrogen. The term ‘low-carbon hydrogen’ is derived from the European Commission’s decarbonisation package. In due course, the European Commission will announce details of the method for calculating greenhouse gas emissions for low-carbon hydrogen.

Verification through Guarantees of Origin

Hydrogen can also be certified through Guarantees of Origin. These guarantees are not sufficient to prove that the hydrogen complies with the 3 criteria for RFNBO hydrogen. Nonetheless, they may be used as supporting evidence to verify compliance with those 3 criteria. The European Commission has yet to reach a conclusion regarding the relationship between Guarantees of Origin and voluntary schemes. This page will be updated once the situation becomes clearer.

What proof can you provide to show that your hydrogen is compliant?

One way to demonstrate that your hydrogen or hydrogen-derived energy carrier complies with the RED criteria for RFNBO classification is through certification. To be eligible for this certificate, you must comply with a set of rules (certification schemes). These certification schemes were created specifically for this purpose. The European Commission is tasked with assessing and approving the schemes. In RED III, they are described as ‘voluntary schemes’, reflecting the fact that certification is undertaken voluntarily. As the owner of the hydrogen, you have the option to forgo certification. However, without a certificate, the hydrogen does not qualify as RFNBO hydrogen under the RED criteria.

Would you like to find out which certification schemes have already been approved and which are currently under review? Visit the European Commission’s website to learn more. The website also provides details of the assessment protocol used by the European Commission to review the RFNBO schemes.