In a joint letter to EU Energy Commissioner Dan Jørgensen, 16 state ministers from Germany have called for a pragmatic further development of the current RFNBO criteria. The aim is to create investment certainty for electrolysis projects and to avoid slowing the ramp-up of the European hydrogen economy through overly complex requirements.
High costs are slowing investment decisions
At the heart of the letter is the concern that the existing requirements of Delegated Regulation (EU) 2023/1184 significantly increase the costs of many hydrogen projects and thereby delay or entirely prevent investment decisions. The letter points out that numerous large-scale electrolysis projects have postponed or fully stopped their final investment decision despite funding.
Simple, investable and practicable
The signatories argue that a regulatory framework for the market ramp-up must be simple, investable and practicable in the initial phase. In their view, however, the current RFNBO requirements often achieve the opposite: high complexity, uncertainty among project developers and industrial off-takers, and economic disadvantages compared with other electricity consumers. At the same time, they emphasise that electrolysers can make an important contribution to flexibility, sector coupling and system integration.
Core elements of the proposed further development
- Extending the transitional phase for the additionality requirements until 2035
- More flexibility for temporal correlation, in particular the continued use of monthly correlation until 2035
- Examining whether lowering the threshold for the general exemption in electricity systems with very high shares of renewable energy could better support the objectives of the Delegated Regulation
In addition, a more consistent structuring of exemptions is suggested, for example by bundling the various exemptions within the Delegated Regulation. In the signatories' view, the review scheduled for 2028 should also be designed in such a way that investment certainty and long-term planning reliability for companies are preserved.
The letter is a strong industrial and energy policy signal: the ramp-up of the hydrogen economy is understood not as an isolated regional task, but as a shared European project. Particularly for industrial and port locations as well as regions with high renewable expansion potential, a pragmatic yet robust regulatory framework is decisive. The announced review of the RFNBO criteria could thus become a key lever for investment and the further market ramp-up of renewable hydrogen in Europe.