Renewable Fuels of Non-Biological Origin (RFNBO)

In plain terms

RFNBO is how EU law says "green hydrogen". The Renewable Energy Directive, (EU) 2018/2001, Art. 2(36), defines RFNBOs as liquid and gaseous fuels whose energy content comes from renewable sources other than biomass. Hydrogen from electrolysis qualifies only if its electricity meets the 2023/1184 rules; derivatives such as ammonia and e-methanol can qualify on the same basis.

Two delegated regulations, both adopted on 10 February 2023, set the detailed rules. Keep them apart:

Regulation (EU) 2024/1408 later aligned a technical term in 2023/1184 with the amended Directive; the thresholds did not change.

Typical range

To count, an RFNBO must achieve at least 70 % greenhouse gas savings against the fossil reference, calculated with the 2023/1185 method; Commission guidance C/2025/2983 confirms the threshold. Under RED Art. 22a, Member States must ensure at least 42 % of hydrogen used in industry is RFNBO by 2030, and 60 % by 2035.

Why it moves LCOH

RFNBO rules constrain plant design. They decide which electricity counts, when, and from where. Meeting them can mean oversized renewables, storage or lost production hours, which all raise LCOH. Hydrogen that fails them cannot count toward EU targets, which limits its value to EU buyers.

Common mistake