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10 March 2023

Open letter of the EU industry calling for a consideration of low carbon hydrogen in the calculation of RFNBOs targets

The signatories of this letter strongly support the EU’s decarbonisation ambition/objectives. The ongoing revision of the Renewable Energy Directive (RED III) will result in ambitious incentives for renewable hydrogen in industry and transport through binding targets. Focusing these targets on RFNBOs without taking into account the potential of low carbon hydrogen will slow down the decarbonization process in heavy industry and transport. We therefore call on co-legislators to design a pragmatic framework for hydrogen in RED III. This can be done by combining ambitious RFNBOs objectives and the needed recognition of low-carbon hydrogen to meet the triple challenge of decarbonization, security of supply and industrial leadership on key sectors for net zero.

We are involved in a global race. Taking into consideration the need for deployment speed throughout legislation will be key to keep the Union’s leadership on hydrogen and maintain a strong heavy industry basis in Europe. Low-carbon hydrogen is complementary to RFNBOs to scale up the final uses of hydrogen and its derivatives, and thereby to structure the whole related upstream value chain. Depending on the territories, it can unlock the delivery of larger hydrogen volumes, in a faster and more competitive way. More importantly, steady hydrogen supplies are needed for heavy industries to switch their process to clean hydrogen (e.g steel manufacturing, ammonia and methanol synthesis). This can be provided by a combination of low carbon hydrogen and RFNBOs especially when hydrogen transport and storage assets will take time to emerge. Finally, the current geopolitical context is a vivid reminder that producing hydrogen in Europe is essential to avoid creating new energy dependencies.

As RFNBOs binding targets are (rightly) ambitious, designing their calculation without any consideration for the volumes of low carbon hydrogen, will result in a severe lack of level-playing-field for low carbon hydrogen and will thereby obstruct the related projects. Such a framework would delay electrolysis industrial deployment and industry decarbonization, expose the EU hydrogen and heavy industries to significant risks, and create de facto a discrimination between Member States by limiting the potential to yield the benefits of their various energy mix.

We would like to propose, as a compromise, to exclude low carbon hydrogen consumed in industry and transport from the denominator used to calculate the binding volume objective of RFNBOs. This formula:

  • Takes into account the contribution of low-carbon hydrogen towards EU decarbonization;
  • Maintains a binding target for RFNBOs;
  • And increases the binding decarbonization effort (sum of RFNBOs and LCH) in Member States which would develop the production and uses of low-carbon hydrogen.

This proposal is not about introducing low carbon energy within the renewable energy directive nor limiting the potential of renewable hydrogen, but only a legitimate request for adjusting the denominator basis.

We support the EU’s ambition to become a global hydrogen leader and we are willing to invest. But, in the global race that is taking shape, we urgently need a pragmatic and balanced framework on clean hydrogen.

EU co-legislators have the opportunity to unlock the hydrogen potential during the next trilogue sessions on RED III. Let’s seize it!

Yours sincerely,



  • Fertilizers Europe – Antoine Hoxha, Director General
  • Eurofer – Adolfo AIELLO, Deputy Director General
  • CERAME-UNIE – Renaud BATIER, Director General
  • IFIEC – Peter CLAES, President
  • CEFIC – Nicola REGA, Energy Director
  • France Hydrogène – Philippe BOUCLY, President
  • Nuclear Europe – Yves DESBAZEILLE, Director General
  • CEA (Commissariat à l’énergie atomique et aux énergies alternatives) – Julie ODDOU, Director for European Affairs
  • Nuclear Hydrogen Initiative – Elina TEPLINSKY and Carlos LEIPNER, co-leaders
  • EDF – Alexandre PERRA, Group Senior Executive Vice President Innovation, Corporate Social Responsibility and Strategy
  • YARA – Luc HAUSTERMANS, Head of EU Public Affairs and Industry Relations
  • Vicat – Eric BOURDON, Deputy Director General
  • Arcelor Mittal – Eric NIEDZELA, Vice President Climate Action ArcelorMittal Europe – Chairman ArcelorMittal France
  • ČEZ – Ms. Zuzana Krejčiříková, Director of Public Affairs
  • Vynova – Christophe ANDRÉ, CEO/President
  • SLB – Olivier PEYRET, Chairman France, Director New Energy Europe
  • Essenscia – Els BROUWERS, Director Energy, Climate and Economy
  • WaterstofNet – Chris LEFRERE
  • Polish Cluster of Hydrogen Technologies – Piotr MAKSYS, Managing Director
  • Czech Hydrogen Technology Platform – Aleš DOUCEK, Chairman of the Board
  • Polish Electricity Association (PKEE) – Wojciech DĄBROWSKI, President of the Management Board
  • Finnish Energy – Jukka LESKELÄ, CEO
  • Hungarian Hydrogen and Fuel Cell Association – András TOMPOS, Ph.D., President
  • Romanian Association for Hydrogen Energy – Ioan IORDACHE, Executive Director
  • MVM Hungarian Electricity – Károly MÁTRAI, Chief Executive Officer
  • McPhy – Jean-Baptiste LUCAS, CEO
  • John Cockerill – Raphaël TILOT, President of John Cockerill Hydrogen
  • Genvia – Florence LAMBERT, CEO and President
  • Hycamite TCD Technologies Oy – Matti MALKAMÄKI, Chairman of the Board
  • Elyse Energy – Pascal Penicaud, President
  • Verso Energy – Antoine HUARD, General Director
  • H2V – Alexis MARTINEZ, CEO
  • Slovenské elektrárne, a.s. – Branislav Strýček, CEO
  • GIFEN – Anne-Sophie DEFAY, Director for European Affairs
  • Société française d’Energie Nucléaire (SFEN) – Valérie FAUDON, Delegate General
  • France Chimie – Magali SMETS, General Director
  • Alliance des minerais, minéraux et métaux (A3M) – Bruno JACQUEMIN, Delegate General
  • Union Française de l’Electricité (UFE) – Christine GOUBET-MILHAUD, President
  • Hidroelectrica – Bogdan BADEA, President of the Directorate
  • National Union of Employers (NUE) – RNDr. Miroslav Kiraľvarga, MBA, President
  • ICSI, Energy Department (Hydrogen, Fuel Cells etc) – Mrs. Dr. Math Elena CARCADEA, Head of Department
  • Romanian National Committee – World Energy Council – M Dr. Dan Gheorghiu, President
  • Romanian Association of Electricity Producers – Ms. Silvia VLASCEANU
  • Nuclearelectrica – Cosmin GHITA, CEO
  • Slovak Gas and Oil Association – Rastislav Nukovic
  • Probugas Katarína Lucinová, CEO & Chairman of the Board of Directors
  • ROMGAZ – Mr. Razvan POPESCU, CEO
  • Romanian Atomic Forum – Dr. Teodor CHIRICA, President Emeritus
  • Matador Group – Štefan Rosina, President of MATADOR Group

Open letter of the EU industry calling for a consideration of low carbon hydrogen in the calculation of RFNBOs targets

pdf (1.41 MB)

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