ABSTRACT
The traditional “colour-coding” system for classifying hydrogen is inadequate for characterising its environmental impact. Consequently, policies are shifting towards carbon-intensity benchmarks and broader sustainability criteria. This transition highlights the need for reliable certification systems that can trace environmental attributes throughout the value chain. This chapter critically analyses the European Union (EU) legal framework governing the classification of hydrogen as renewable and low-carbon. It reviews the regimes applicable to “renewable fuels of non-biological origin” (RFNBOs) under the Renewable Energy Directive and to “low-carbon fuels” under the Gas Directive, each of which is supplemented by Delegated Acts (DAs) setting detailed certification rules. The analysis emphasises the central role of certification schemes as compliance instruments and examines their practical operation. Emphasis is given to RFNBO implementation challenges, particularly concerning Power Purchase Agreements (PPAs) and Guarantees of Origin (GOs). In parallel, the chapter assesses the Delegated Act on low-carbon fuels, examining its emission accounting methodology and evaluating its alignment with the RFNBO methodology. By identifying key similarities and differences between RFNBOs and low-carbon fuels, the chapter ultimately assesses whether the EU framework effectively balances market creation, long-term sustainability, decarbonisation goals, and competitiveness in the emerging hydrogen economy.
