Additionality

In plain terms

RFNBO additionality answers one worry: an electrolyzer pulling existing renewable power off the grid just shifts fossil generation elsewhere. Under Delegated Regulation (EU) 2023/1184, the hydrogen counts only if it is backed by renewable capacity that did not exist before.

There are three main routes:

• Direct connection (Art. 3): the renewable plant feeds the electrolyzer by direct line or in the same installation, was commissioned no earlier than 36 months before it, and either has no grid connection or draws no grid power (shown by a smart meter).
• Grid power with PPAs (Art. 5): the producer holds renewable power purchase agreements, or owns generation, covering the claimed volume. The generator must be no more than 36 months older than the electrolyzer and must have received no operating or investment aid, with limited exceptions.
• Grid exemptions (Art. 4): for example, a bidding zone with over 90 % renewable share in the previous year, or with emission intensity below 18 gCO₂e/MJ (the latter still needs PPAs and correlation).

Typical range

The transitional rule in Art. 11 matters most for early projects: the Art. 5 new-capacity and no-aid conditions do not apply until 1 January 2038 to electrolyzers that come into operation before 1 January 2028.

Why it moves LCOH

Additionality usually means building or contracting new renewables for the electrolyzer instead of buying existing grid power. That ties LCOH to the cost of new capacity, and favours sites where new solar and wind are cheap.

Common mistake