Hydrogen Guarantees of Origin (GO): CertifHy vs. Green-e Standards

Green-e Renewable Fuels: The North American Voluntary Standard

Overview: Expanding from Biomethane to Hydrogen

Center for Resource Solutions (CRS) developed Green-e Renewable Fuels certification, beginning with biomethane (published September 2021). (Source) Green-e is the leading North American certification for renewable energy claims, with a 25-year track record in renewable electricity certification. The expansion into renewable fuels reflects market demand for credible voluntary certification beyond compliance-driven systems.

Green-e is designed to be flexible enough to incorporate many different fuel types. (Source) The program architecture allows for modular addition of fuel-specific requirements while maintaining common principles across all certified fuels: transparency, environmental integrity, consumer protection, and double-counting prevention.

Development Timeline: Hydrogen Standard in Progress

The hydrogen standard is following a structured stakeholder consultation process:

• First 60-Day Stakeholder Comment Period: Q1 2025. (Source)
• Second 60-Day Stakeholder Comment Period: Q3 2025. (Source)
• Final inclusion of renewable hydrogen into Green-e Renewable Fuels Standard: Q4 2025. (Source)

Key Issues Being Addressed in the Hydrogen Standard

Key issues CRS is exploring for renewable hydrogen include: renewable electricity vintage, geographic considerations, and facility age (for electrolytic hydrogen); use of pipelines; carbon intensity; various production technologies (e.g., electrolyzers using renewable electricity; SMR using biomethane); and other environmental and emissions considerations. (Source)

Renewable Electricity Vintage and Temporal Matching

For electrolytic hydrogen, the standard must define acceptable temporal correlation between renewable electricity generation and hydrogen production. Options under consideration include hourly matching (strictest), daily matching, monthly matching, or annual matching. Stricter matching reduces grid emissions impact but increases complexity and cost for producers.

Geographic Considerations and Grid Boundaries

Should renewable electricity and hydrogen production be in the same grid region (e.g., same ISO/RTO)? Or is cross-border electricity sourcing acceptable? Geographic restrictions prevent renewable electricity from high-renewable regions being used to "green" hydrogen produced in high-carbon grids, but they also limit market liquidity and increase costs in regions with limited renewable resources.

Facility Age and Additionality

Should renewable electricity come from new facilities commissioned after a certain date, or can existing renewable generation be used? Additionality requirements ensure that hydrogen production drives new renewable energy deployment rather than diverting existing renewable electricity from other uses. However, strict additionality limits the pool of eligible renewable electricity and increases costs.

Pipeline Use and Blending

Can certified renewable hydrogen be injected into natural gas pipelines and later separated, or must it be transported via dedicated hydrogen infrastructure? Pipeline blending enables use of existing infrastructure but complicates chain-of-custody tracking and raises questions about contamination and quality degradation.

Carbon Intensity Thresholds

What maximum lifecycle GHG intensity qualifies as "renewable hydrogen"? The EU uses a 70% savings threshold (approximately 3.4 kg CO₂e/kg H₂). Should Green-e adopt the same threshold, a stricter threshold (e.g., 80% or 90% savings), or near-zero emissions? Stricter thresholds improve environmental integrity but exclude some production pathways (e.g., grid-connected electrolysis in moderate-carbon grids).

Production Technologies: Electrolysis vs. SMR with Biomethane

Should Green-e certify only electrolytic hydrogen using renewable electricity, or also hydrogen from SMR using certified biomethane? Biomethane-based hydrogen can achieve low lifecycle emissions if the biomethane is truly additional and sustainably sourced. However, biomethane supply is limited and already contested across multiple end-uses (heating, transport, power generation).

Program Goals for Hydrogen Certification

Green-e aims to ensure renewable hydrogen is created from sustainable renewable resources, meets highest environmental standards, and customers are protected in purchase and ability to make verifiable usage claims. (Source) Specifically, the standard will:

• Prevent double-counting of renewable attributes between hydrogen, electricity, and fuel markets
• Require transparent disclosure of production method, GHG intensity, and renewable energy sourcing
• Establish audit and verification procedures for production data and certificate issuance
• Provide model contract language for hydrogen purchase agreements specifying certified renewable hydrogen
• Create a public registry of certified hydrogen producers and certificate transactions

CertifHy vs Green-e: A Practical Comparison

CertifHy and Green-e serve different regulatory and market contexts. Understanding the differences is critical for producers deciding which certification to pursue and buyers determining which certificates meet their needs.

Implementation Reality: What Producers and Buyers Must Do

Producer Side: Data, Metering, and Certification Process

1. Metering Infrastructure

Producers must install certified metering equipment to measure hydrogen production output (kg H₂ or MWh LHV) and, for electrolytic hydrogen, electricity input (MWh). Meters must meet calibration and accuracy standards defined in the certification scheme (typically ±2% accuracy for production meters, ±1% for electricity meters). Metering data must be logged at intervals sufficient for temporal matching requirements (hourly logging for schemes requiring hourly matching).

2. Data Management Systems

Producers must maintain digital records of:

• Production volumes (timestamped, metered output)
• Electricity sourcing (for electrolysis): renewable energy certificates (RECs), power purchase agreements (PPAs), grid supply contracts, with timestamps matching production periods
• GHG calculations: lifecycle emissions per kg H₂, including upstream electricity emissions, electrolyzer efficiency losses, and any emissions from compression/storage
• Sustainability documentation: renewable electricity additionality evidence (commissioning dates, grid connection agreements), geographic correlation (facility locations, grid zones)

3. Audit Preparation

Third-party auditors verify production data annually (or more frequently for high-volume producers). Audits include:

• Meter calibration certificate review and on-site meter inspection
• Cross-checking metered production against electricity consumption (electrolyzer efficiency validation)
• REC/PPA contract review to verify renewable electricity sourcing claims
• GHG calculation methodology review and spot-checking of emission factors
• Registry transaction review to confirm no double-issuance or double-counting

4. Certificate Issuance Frequency

CertifHy issues certificates monthly based on verified production data. Producers submit production reports by the 10th of the following month; certificates are issued within 30 days after verification. Green-e (for biomethane) issues certificates quarterly; hydrogen issuance frequency will be defined in the final standard.

5. Cost Structure for Producers

Typical certification costs include:

• Application fee: €2,000–5,000 one-time (varies by scheme and facility size)
• Annual certification fee: €5,000–15,000 (based on production volume)
• Metering and IT infrastructure: €20,000–50,000 capital expenditure for certified meters, data logging systems, and registry integration
• Third-party audit: €10,000–25,000 annually (for medium-scale producers; larger facilities may pay more)
• Certificate issuance fee: €0.10–0.30 per MWh (paid per certificate issued)

Buyer Side: Purchase, Cancellation, and Claims

1. Certificate Purchase and Cancellation

Buyers purchase certificates from producers (bundled with physical hydrogen delivery) or from brokers/traders (unbundled). Certificates must be cancelled (retired) in the registry within a specified period (typically 12–18 months after issuance) to claim the renewable attribute. Cancellation is irreversible—once cancelled, the certificate cannot be re-sold or transferred.

2. Claims Substantiation

Buyers making public renewable hydrogen claims must:

• Specify the quantity of certified renewable hydrogen purchased and cancelled (in kg or MWh)
• Disclose the certification scheme (e.g., "CertifHy EU RFNBO certified")
• Disclose the production method (e.g., "electrolytic hydrogen from wind power")
• Disclose the geographic origin (country or region of production)
• Disclose the vintage (year of production)
• Avoid misleading claims (e.g., cannot claim "100% renewable hydrogen" if only a portion of hydrogen purchases are certified)

3. Disclosure Requirements for Sustainability Reporting

Corporate buyers reporting renewable hydrogen use in sustainability disclosures (CDP, GRI, TCFD, CSRD) must provide:

• Certificate cancellation receipts (from registry)
• Quantity of certified hydrogen purchased (typically reported in tonnes H₂ or MWh LHV)
• GHG emissions avoided vs. fossil hydrogen baseline (calculated using lifecycle emissions from certificates)
• Certification scheme used and link to scheme documentation

4. Audit Trail for Buyers

Buyers must retain for at least 5 years:

• Hydrogen purchase agreements specifying certified renewable hydrogen
• Certificate transfer confirmations (from registry)
• Certificate cancellation receipts (from registry)
• Invoices showing hydrogen delivery quantities matching certificate volumes
• Internal allocation records if hydrogen is used across multiple business units or products

Evidence and Audit Trail (What Auditors/Verifiers Will Ask For)

Production Data Requirements

Metered Hydrogen Output

Auditors require timestamped production logs showing:

• Hydrogen production volume (kg H₂ or MWh LHV) per hour/day/month
• Meter calibration certificates (valid, unexpired, from accredited calibration lab)
• Meter maintenance logs (calibration checks, any replacements or repairs)
• Data logging system integrity (no gaps, no unexplained anomalies)

Electricity Input and Sourcing (for Electrolytic Hydrogen)

Auditors verify renewable electricity sourcing through:

• Power Purchase Agreements (PPAs): Contracts showing committed renewable electricity supply, delivery schedules, and pricing
• Renewable Energy Certificates (RECs): REC purchase receipts and cancellation confirmations, with matching timestamps to hydrogen production periods
• Grid supply documentation: Utility bills and grid connection data (if claiming grid electricity as renewable, must demonstrate compliance with grid sourcing rules)
• Temporal correlation logs: Hour-by-hour (or month-by-month, depending on scheme requirements) matching of renewable electricity supply to hydrogen production

GHG Calculations

Auditors verify lifecycle GHG calculations per scheme methodology:

• Emission factors used (must match scheme-approved sources, e.g., EU RED default factors, IPCC factors)
• System boundaries (what emissions are included: electricity upstream, electrolyzer manufacturing, compression, transport)
• Efficiency assumptions (electrolyzer efficiency, compression energy, any fugitive losses)
• Calculation worksheets showing step-by-step GHG accounting from inputs to final kg CO₂e/kg H₂ result

Chain of Custody (Especially for Derivatives)

Why Chain of Custody Matters for Derivatives

Hydrogen is often converted into derivative products: ammonia (NH₃), methanol (CH₃OH), synthetic kerosene (e-SAF), or steel (using hydrogen as a reducing agent). When the derivative product is sold with a "renewable" or "green" claim, buyers and auditors must verify that the hydrogen input was certified and that the chain of custody was maintained from hydrogen production to final product.

Mass Balance Tracking

Producers of derivatives must maintain mass balance records showing:

• Hydrogen input (kg H₂, with certificate IDs)
• Conversion efficiency (e.g., kg NH₃ produced per kg H₂ input)
• Co-products or waste streams (if any)
• Output allocation (how certified hydrogen attributes are allocated to output products)

For example, an ammonia plant producing 100,000 tonnes NH₃/year using 18,000 tonnes H₂/year must demonstrate:

• 18,000 tonnes of certified renewable hydrogen were purchased and used as input (with certificate cancellation records)
• No uncertified hydrogen was blended into the ammonia production process during the claim period
• 100,000 tonnes of ammonia output can claim "produced from renewable hydrogen" attribute

Blending and Segregation

If certified and uncertified hydrogen are both used in the same facility, producers must either:

• Physical segregation: Use separate production lines, tanks, or batches for certified vs. uncertified hydrogen (preferred by auditors)
• Mass balance accounting: Track certified and uncertified inputs/outputs mathematically, allocating certified attributes proportionally to output products (acceptable but requires more rigorous documentation)

Contractual Proof and Certificate Registries

Hydrogen Purchase Agreements

Contracts must explicitly state:

• Quantity of certified renewable hydrogen to be delivered (kg or MWh)
• Certification scheme (e.g., "CertifHy EU RFNBO" or "Green-e Renewable Hydrogen")
• Delivery schedule and location
• Certificate transfer obligations (who is responsible for transferring certificates to buyer)
• Claims rights (buyer has exclusive right to make renewable hydrogen claims based on delivered certificates)

Registry Transaction Records

All certificate issuance, transfers, and cancellations are recorded in electronic registries (CertifHy Registry, Green-e Registry, or national GO registries). Auditors require:

• Certificate issuance confirmations (showing unique certificate IDs, production period, quantity)
• Transfer confirmations (showing certificate ownership passed from producer to buyer, with timestamps)
• Cancellation receipts (showing certificates were retired for buyer's use, with cancellation date and reason)

Producer Checklist: Data and Evidence Needed

Case Studies (2 Worked Examples)

Example A: EU Electrolyzer Project Obtaining CertifHy EU RFNBO Certification

Example B: US Hydrogen Producer Preparing for Green-e Certification

Devil's Advocate (7 Objections to Hydrogen Certification)

Objection 1: Certification Cost Burden on Small Producers

The objection: Certification fees, metering infrastructure, audit costs, and administrative overhead are prohibitively expensive for small-scale hydrogen producers (e.g., <500 kg/day). A €35,000/year certification cost represents 5–10% of revenue for small producers but <0.5% for large producers, creating market concentration and excluding SMEs.

When valid: True for small producers serving niche markets (e.g., industrial gases, lab supply) where buyers do not require certification. Certification costs can exceed the market value of environmental attributes for low-volume producers.

Mitigation: CertifHy and Green-e are exploring simplified certification pathways for small producers: group certification (multiple small producers share audit costs), self-declaration with spot-check audits (for producers <1,000 tonnes/year), or digital metering solutions reducing infrastructure costs. Additionally, some national GO systems are subsidizing certification costs for SMEs to prevent market exclusion.

Objection 2: Geographic Fragmentation Limits Market Liquidity

The objection: CertifHy operates in Europe, Green-e in North America, and other regions (Asia-Pacific, Middle East, Latin America) lack standardized certification schemes. A producer in Japan exporting hydrogen to Europe must obtain CertifHy certification; a European producer exporting to the US must obtain Green-e certification. This fragmentation increases costs, prevents economies of scale, and limits cross-border trade.

When valid: True. Geographic fragmentation is a fundamental challenge. No global harmonization framework exists (unlike renewable electricity, where I-REC serves as a global standard alongside regional schemes).

Mitigation: International standards bodies (ISO, IEA) are developing harmonization frameworks. The Global Hydrogen Trade Coalition (industry-led initiative) is advocating for mutual recognition agreements between CertifHy, Green-e, and emerging Asian schemes (e.g., Japan's J-Credit, Australia's ACCUs). Some producers are obtaining multiple certifications to serve global markets, but this increases costs by 20–40%.

Objection 3: Temporal Matching Debate: Hourly vs. Monthly vs. Annual

The objection: Strict hourly matching (requiring renewable electricity generation to occur in the same hour as hydrogen production) ensures grid emissions impact is minimized. However, it dramatically increases costs (electrolyzer utilization drops from 80–90% to 40–60% if constrained to solar/wind availability hours) and limits deployment speed. Conversely, annual matching (allowing renewable electricity from any hour of the year to count toward hydrogen production) enables high electrolyzer utilization but may increase grid emissions if electrolyzers operate during high-carbon hours and "offset" with renewable electricity from other hours.

When valid: Both sides have merit. Hourly matching is environmentally superior but economically challenging. Annual matching is economically viable but environmentally weaker. The "right" answer depends on grid carbon intensity and policy goals.

Mitigation: CertifHy EU RFNBO adopts a phased approach: monthly matching (2027–2029), transitioning to hourly matching (2030+). This gives producers time to adapt electrolyzer operations and renewable energy procurement strategies. Green-e is evaluating similar phased timelines. Some producers are voluntarily adopting hourly matching today to future-proof their certification and command higher price premiums in voluntary markets.

Objection 4: SME Access Barriers: Data Systems and Technical Expertise

The objection: Certification requires sophisticated metering, data logging, GHG calculation software, and registry integration. Large producers have dedicated sustainability teams and IT infrastructure. SMEs lack these resources and cannot afford to hire consultants or purchase specialized software. This creates a "certification gap" where only large, well-capitalized producers can access certified hydrogen markets.

When valid: True for SMEs in developing regions or niche markets. Lack of technical expertise is a bigger barrier than cost for many small producers.

Mitigation: Certification schemes are developing standardized software templates and low-cost SaaS solutions for data management and GHG calculations. Some national governments and industry associations offer free technical assistance programs for SME hydrogen producers. Additionally, industry consolidation (large producers acquiring small producers or offering certification-as-a-service) is reducing barriers by centralizing technical expertise.

Objection 5: Pipeline Blending Ambiguity and Chain-of-Custody Complexity

The objection: Hydrogen injected into natural gas pipelines (up to 20% H₂ by volume is technically feasible in most pipelines) cannot be physically separated downstream. If renewable hydrogen is blended with fossil hydrogen in a pipeline, how can downstream buyers claim "renewable hydrogen" when the physical molecules are indistinguishable? Mass balance accounting (tracking renewable hydrogen input and allocating certificates to downstream output) is mathematically sound but conceptually confusing for buyers and raises greenwashing concerns.

When valid: Legitimate concern. Pipeline blending is common in Europe (especially Germany, Netherlands) where hydrogen is injected into gas grids for transport and later separated. Without clear chain-of-custody rules, blending enables greenwashing.

Mitigation: CertifHy NGC Scheme complies with EECS Rules, promoting sectoral standardization and harmonization across Europe, including mass balance protocols for blended hydrogen. (Source) Certification schemes are developing strict mass balance rules: producers must meter renewable hydrogen input and fossil hydrogen input separately, maintain blending ratios, and allocate certificates proportionally to output volumes. Some buyers prefer dedicated hydrogen pipelines or trucked hydrogen to avoid blending complexity altogether.

Objection 6: Derivative Product Accounting Complexity

The objection: Hydrogen is often converted into ammonia, methanol, or synthetic fuels. How should renewable hydrogen attributes be allocated to derivatives? If 1 kg of renewable hydrogen produces 5.67 kg of ammonia, does the entire ammonia output get certified, or only a fraction? What if the ammonia production process uses fossil natural gas for heat (common in Haber-Bosch plants)? Can the final product claim "renewable ammonia" if only the hydrogen input is renewable but heat comes from fossil sources?

When valid: Major complexity, especially for multi-input processes (e.g., methanol production using renewable hydrogen + captured CO₂, where CO₂ may come from fossil sources). Allocation rules are not yet standardized across schemes.

Mitigation: CertifHy EU RFNBO provides allocation guidance: derivatives can claim "produced from renewable hydrogen" if (1) renewable hydrogen input is certified, (2) mass balance is maintained, and (3) lifecycle GHG savings still meet RED thresholds (accounting for fossil inputs in derivative production). Green-e is developing similar rules. Industry is converging on "renewable hydrogen content" labeling (e.g., "ammonia produced with 100% renewable hydrogen, 40% fossil heat") to provide transparency without oversimplifying complex production processes.

Objection 7: Competing Schemes and Standard Proliferation

The objection: CertifHy, Green-e, I-REC Hydrogen (in development), national GO systems (25+ across EU Member States), and emerging schemes in Japan, Australia, and the Middle East create a fragmented landscape. Producers must choose which schemes to pursue; buyers must understand differences between schemes; and auditors must be trained on multiple standards. This proliferation increases transaction costs, confuses markets, and delays scaling.

When valid: Universally valid. Standard proliferation is a transitional problem as the hydrogen market matures. Electricity markets experienced similar fragmentation in the 2000s before consolidating around a few dominant schemes (I-REC, Green-e, European GO system).

Mitigation: Industry consolidation is likely over 2026–2030. Dominant schemes (CertifHy in EU, Green-e in North America) will absorb smaller schemes or establish mutual recognition agreements. International standards bodies (ISO TC 197 on hydrogen technologies) are developing harmonized certification frameworks. National governments are aligning national GO systems with CertifHy standards to minimize fragmentation within the EU. Producers should prioritize schemes with official regulatory recognition (CertifHy EU RFNBO for EU compliance, Green-e for US voluntary markets) to minimize risk of certification becoming obsolete.

Outlook to 2027–2030

National GO Systems Rolling Out Across EU Member States

RED II Article 19 directs EU Member States to implement national hydrogen GO systems. (Source) As of December 2025, approximately 12 EU Member States have operational systems (Netherlands, Germany, France, Spain, Denmark, Sweden, Finland, Belgium, Austria, Portugal, Ireland, Italy). The remaining Member States are expected to launch systems by 2027.

Impact on CertifHy NGC

CertifHy NGC bridges the gap where no national system is operational. (Source) As national systems come online, CertifHy NGC will transition from a gap-filler to a premium voluntary certification for producers seeking cross-border recognition or higher environmental standards than minimum national GO requirements. Producers currently using CertifHy NGC can seamlessly transition to national GOs (both systems comply with EECS Rules, ensuring registry compatibility).

Green-e Hydrogen Standard Finalization and Early Certifications

Final inclusion of renewable hydrogen into Green-e Renewable Fuels Standard is expected in Q4 2025. (Source) First certifications are anticipated in Q1–Q2 2026, with initial focus on large electrolysis projects in California, Texas, and the Pacific Northwest (regions with high renewable electricity penetration and strong corporate hydrogen demand).

Market Development Timeline

• 2026: 5–10 early adopter producers certified; certificate volumes <10,000 tonnes H₂/year (primarily voluntary corporate procurement)
• 2027: 50–100 certified producers; certificate volumes 50,000–100,000 tonnes/year (expansion to industrial buyers: steel, chemicals, refining)
• 2028–2030: 200+ certified producers; certificate volumes >500,000 tonnes/year (mainstream market adoption; certification becomes baseline expectation for voluntary corporate procurement)

Convergence Pressures (or Persistent Fragmentation) Between Voluntary and Compliance Schemes

Forces Driving Convergence

• Corporate buyer demand: Multinational companies operating in both EU and North America want a single certification that satisfies both compliance (EU RED) and voluntary (North America corporate procurement) requirements. Dual certification increases costs and complexity.
• Producer efficiency: Large hydrogen producers with global sales want to minimize certification overhead. Mutual recognition agreements between CertifHy and Green-e would allow a single audit to satisfy both schemes.
• Standards harmonization: ISO and IEA are developing international hydrogen certification frameworks that could serve as a common foundation for regional schemes. If CertifHy, Green-e, and emerging Asian schemes align with ISO standards, technical differences will narrow over time.
• Policy alignment: US federal hydrogen policy (e.g., 45V tax credit for clean hydrogen production) is adopting lifecycle GHG thresholds similar to EU RED II (70–75% savings vs. fossil baseline). This policy convergence reduces technical divergence between schemes.

Forces Maintaining Fragmentation

• Regulatory sovereignty: EU RED compliance is a legal requirement enforced by Member States; Green-e is a voluntary market standard. These fundamentally different regulatory contexts limit full convergence.
• Market differentiation: Voluntary schemes (Green-e, CertifHy NGC) may choose to maintain stricter standards than compliance schemes (CertifHy EU RFNBO) to command price premiums. For example, Green-e may require hourly matching while EU RFNBO allows monthly matching through 2029, creating a "premium tier" vs. "baseline compliance tier."
• First-mover advantage: CertifHy has been leading the way in certifying renewable hydrogen and its derivatives since 2014. (Source) Established schemes have network effects (more producers, more auditors, more buyer recognition) that make it difficult for new schemes to compete, even if technically superior.
• Regional differences in hydrogen production: Europe prioritizes electrolytic hydrogen from renewable electricity; North America has more diverse production pathways (including SMR with carbon capture, biomass gasification). Certification schemes reflect these regional preferences, making full harmonization unlikely.

Most Likely Outcome (2027–2030)

Partial convergence: CertifHy and Green-e will establish mutual recognition agreements for core data fields (production quantity, GHG intensity, renewable electricity sourcing), allowing producers to obtain dual certification with a single audit. However, scheme-specific requirements (e.g., temporal matching rules, additionality thresholds, geographic correlation) will remain differentiated to reflect regional policy priorities and market demands. Producers serving both EU compliance and North American voluntary markets will need to meet the stricter of the two schemes' requirements.

Technology and Market Trends Influencing Certification

1. Scaling of Renewable Hydrogen Production

Global renewable hydrogen production is projected to grow from ~1 million tonnes/year (2025) to 10–20 million tonnes/year (2030). As production scales, certification will transition from a niche premium product to a baseline market requirement—similar to how renewable electricity certification evolved from voluntary (pre-2010) to mainstream (post-2015).

2. Derivative Markets (Ammonia, E-Fuels, Steel)

Certified renewable hydrogen attributes will increasingly be embedded in derivative products. CertifHy EU RFNBO certifies hydrogen and e-fuels from non-biological sources meeting RED II criteria. (Source) By 2030, certified "green ammonia" and "e-SAF" (synthetic aviation fuel) may represent larger certificate volumes than direct hydrogen sales.

3. Hydrogen Imports and Export Certification

Europe will import 5–10 million tonnes/year of hydrogen by 2030 (from North Africa, Middle East, Australia). Exporting countries will need to certify hydrogen to EU standards (CertifHy EU RFNBO or equivalent national schemes) to access the European market. This will drive global adoption of EU-aligned certification standards.

4. Carbon Border Adjustment Mechanism (CBAM) and Hydrogen

The EU's CBAM may be extended to hydrogen and hydrogen-based products (ammonia, steel) by 2028–2030. If so, imported hydrogen will need certified GHG intensity data to calculate CBAM liabilities. CertifHy EU RFNBO provides the GHG data framework required for CBAM compliance, creating a regulatory driver for certification beyond voluntary markets.

What Producers and Buyers Should Do Now

1. Producers in EU: Obtain CertifHy EU RFNBO certification immediately if serving compliance markets. Transition to national GOs when your Member State system launches. Maintain dual certification if exporting outside EU.
2. Producers in North America: Monitor Green-e standard finalization (Q4 2025). Prepare metering, data systems, and PPA contracts now to enable fast certification in Q1 2026. Consider CertifHy NGC if exporting to Europe.
3. Buyers (compliance): RED II/III requirements make certified hydrogen a prerequisite for market access in Europe. (Source) Require CertifHy EU RFNBO or equivalent in all hydrogen procurement contracts for EU compliance applications.
4. Buyers (voluntary): Specify certification scheme requirements in hydrogen procurement RFPs (CertifHy NGC for Europe, Green-e for North America). Require GHG intensity data and chain-of-custody documentation for derivatives.
5. All stakeholders: Participate in standards development (CertifHy, Green-e, ISO working groups) to influence emerging rules. Early engagement reduces risk of unfavorable requirements being locked in.