Position Paper

Joint Industry Letter on the Urgent Need for an RFNBO Certification Framework

The signatories of this letter welcome the regulatory clarity provided by this week’s entry-into-force of the RED II Delegated Acts on Article 27.3 and Article 28.5 that define the production criteria for Renewable Fuels of Non-Biological Origin (RFNBOs) and Recycled Carbon Fuels (RCFs). Now, these production criteria need to urgently be complemented with comprehensive certification framework.

Our sectors crucially depend on the large-scale availability of RFNBOs, supplied cost-competitively and securely across the EU for meeting the objective of climate neutrality.

Despite the entry-into-force of the relevant production criteria, the absence of a clear certification framework still hampers the scale-up of the EU’s RFNBO market. A harmonised RFNBO scheme is an essential precondition for counting RFNBOs towards the regulatory mandates defined in the RED III, as well as for their commercial development.

Both producers and consumers of RFNBOs require certainty that those volumes of hydrogen that are labeled ‘RFNBO’ truly comply with the production criteria described in the Delegated Acts. This certification must apply consistently across the EU, as well as be enforceable for imported volumes of RFNBOs.