RFNBO & EU Compliance
EU delegated acts, additionality rules, temporal correlation, and certification pathways for renewable fuels of non-biological origin.
2 articles
RFNBORFNBO Additionality Rules Explained: The 36-Month Rule, the 2028 Cliff and the 2038 Grandfather Clause
What RFNBO additionality requires today: the 36-month rule, the no-subsidy test, the 1 January 2028 cliff and 2038 grandfathering, and how to design for them.
RFNBOThe RFNBO Rules Are Being Rewritten: What the 2026 Revision Could Change, and How to Design for Both Outcomes
The EU is rewriting its green hydrogen rules. What the 2026 RFNBO review could change on additionality and hourly matching, and how to design for both.
About RFNBO & EU Compliance
Hydrogen sold into the EU as a renewable fuel of non-biological origin (RFNBO) has to meet rules on where its electricity comes from and when it is used. Those rules shape plant design, not just paperwork: they affect renewable sizing, storage and the operating pattern of the electrolyzer.
The RFNBO rules are being rewritten explains what the 2026 revision of the delegated act could change, and how to design a project that works under either outcome. It is written for teams that need to commit to a design before the final text is known.
The core concepts each have their own glossary entry: additionality, temporal correlation and geographic correlation. Read in that order, they show what a compliant plant has to prove about its power supply, and why the answer depends on the grid it connects to.
For export projects outside the EU, including in Morocco, these rules decide whether the hydrogen or its derivatives qualify as RFNBO in the EU market. They therefore belong in the earliest design studies, alongside the resource assessment, rather than at the certification stage.