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FAQ

ReH2 Certification & CBAM Helpdesk

Frequently asked Questions

The FAQ section compiles the most common questions received from MED-GEM partner countries during Helpdesk sessions.

It aims to support knowledge sharing and provide quick access to reliable information on certification, methodology, and CBAM procedures.

The answers are concise, based on official EU sources (DG ENER, DG TAXUD, DG CLIMA) and technical guidance validated through MED-GEM consultations.

Categories:

  • Certification & RFNBOs
  • CBAM Reporting & Methodology
  • Carbon Sources & Emission Calculations
  • Partner Country Experiences

Certification & RFNBOs

ReH₂ refers to hydrogen produced through electrolysis using renewable electricity. RFNBOs (Renewable Fuels of Non-Biological Origin) is a broader category defined under the Renewable Energy Directive (RED II), which includes hydrogen and its derivatives (e.g. ammonia, methanol) produced from renewable sources that achieve at least 70% greenhouse gas (GHG) emission savings compared to the fossil baseline.

Three criteria apply: Additionality (new, unsupported renewable capacity), Temporal correlation (production and electricity in the same time window), and Geographical correlation (same/interconnected bidding zone).

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

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.

They de-risk audits, test data flows and verification, and align PtX chains with EU schemes. MED-GEM’s Morocco Tarfaya pilot offers a replicable blueprint.

Yes, it’s possible under mass balance rules, provided you can demonstrate the RFNBO share claimed equals the RFNBO actually produced/received. Proper record-keeping is essential.

No. A PPA/GO helps but is not always mandatorydirect connection options exist under the RFNBO methodology.

No. Bio-electricity leads to biofuel, not RFNBO. 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 calc for that process.

Schemes expect robust energy attribution and mass-balance tracking; hourly temporal correlation ramps up in 2030. Many producers leverage existing in-house/third-party digital tools; no single “official” tool is mandated.

Yes. Especially for complex chains. Pre-certification pilots help de-risk audits, structure data aggregation (GHG, mass balance), and align complex PtX chains with EU schemes and reduce time-to-certificate.

CBAM Reporting & Methodology

CBAM is in a transitional phase until end-2025: reporting only (no certificate payments), with simplified monitoring rules. The definitive period starts January 2026.

Producers must report direct emissions (from manufacturing) and, where applicable, indirect emissions (from electricity used). For hydrogen, this includes emissions from electrolysis, feedstock processing, and power generation.

An importer’s CBAM obligation can be reduced if a verified carbon price equivalent to the EU ETS was already paid. Currently recognised: EU ETS, Swiss ETS, UK ETS.

Guidance notes and worked examples (with GIZ / TÜV / PTX Hub) for hydrogen and fertilisers during the transition will be shared via the Helpdesk and the website’s Resources section.

The authorized declarant in the EU (importer or indirect representative) reports and bears financial duties; operators outside the EU provide embedded-emissions data but are not the paying entity.

Reporting continues through 2025. The Commission has proposed certificate purchases from Feb 2027 for 2026 imports (linked to 2026 EU ETS quarterly averages). (Subject to adoption.)

50-tonnes/year per importer mass threshold was proposed to simplify admin for the four industrial sectors; hydrogen and electricity are excluded from this threshold. (Subject to adoption.)

A reduction from 80%50% quarterly coverage, adjusted sell-back rules for certificates, and aligned timelines (e.g., declaration by 31 Aug). (Subject to adoption.)

Proposals would simplify default value use and remove verification of embedded emissions calculated purely with Commission default values during the transitional mechanics; details will be set in upcoming acts. (Subject to adoption.)

In the transition, GoOs/green certificates alone cannot define electricity emission factors. Actual factors may be used with direct link/PPA conditions per guidance. (Definitive-period rules forthcoming.)

Carbon Sources & Emission Calculations

Five families: Fossil (with carbon pricing & capture), Biogenic (RED II Art. 29 sustainability), Direct Air Capture (DAC)RFNBO-derived CO₂, and Geological CO₂ (under specific conditions).

To qualify as RFNBO, hydrogen 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 gCO₂eq/MJ of hydrogen, or roughly 3.4 tCO₂eq per tonne of H₂.

Yes. The life-cycle assessment (LCA) covers both direct process emissions and indirect emissions linked to electricity consumption. Using renewable electricity with Power Purchase Agreements (PPAs) or Guarantees of Origin significantly reduces the total emission factor.

Emission calculations are based on the EU’s Delegated Regulation 2023/956. Verification is performed by accredited certification bodies following TÜV-tested methodologies, ensuring full compliance and comparability across projects.

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

Operators may report differentiated grades within a CN code if monitoring allows; annual averages are possible, but per-product monitoring better reflects composition and emissions.

uring the transitional phase: Scope 1 (direct), Scope 2 (electricity), and precursors (when applicable). Some scope details may evolve after review.

Partner Country Experiences

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.

Contact & Support

For any additional questions, please contact:


helpdesk@med-gem.eu


You can also reach out through your National Focal Point (NFP) and Country Correspondent (CC).