EC: Guidance on RFNBO targets in the RED | 2024

On 02 September 2024 the European Commission published a communication that acts as a guidance for the purpose of transposing and implementing the revised Renewable Energy Directive (RED III), particularly on the targets for consumption of RFNBOs in industry and transport. The document does not have any legal force itself, but does give direction to how Member States should interpret those targets.

The document clarifies many issues like:

• The interpretation of the refinery route, i.e. the allocation of hydrogen consumption at refinery level. All RFNBOs that end up in the transport sector (in terms of energy), but also the hydrogen that is used for desulfurization will count towards the transport target. This means that even if the energy content of the renewable hydrogen does not end up in transport, its application in the refinery can/will still be paid for with money meant for realising climate reduction in the transport sector.
• How to handle the use of renewable hydrogen in biorefining: If RFNBOs are used as intermediate products for the production of biofuels and that RFNBO is counted towards the targets (via the refinery route), then for the calculation of the GHG intensity of the biofuel the input of the RFNBO should be considered as a fossil input, to avoid double counting.
• How ‘industry’ should be defined, i.e. which sectors are regulated in the industry
• How to calculate the numerator and denominator of the industry targets
• How to interpret mass balancing of renewable hydrogen in the gas grid. This is only allowed if the consumer, i.e. the one extracting from the grid, is physically separating the hydrogen from the mixture of gases in the grid. This is problematic for synthetic methane producers that want to transport the methane via the grid.

Read the full Communication C(2024) 5042 by clicking the image on the right.

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