Joint Letter: Calling for Speedy Targeted Amendment Process of the Delegated Act (EU) 2023/1184 on RFNBO Production Criteria

Read the joint letter here.

The ramp-up of renewable hydrogen in Europe is progressing significantly slower than anticipated. Against a backdrop of geopolitical tensions, continued fossil energy price volatility, regulatory inconsistencies, and a rapidly intensifying international race for industrial leadership, investment decisions are being delayed and, with them, the ramp-up of hydrogen across the European Union. As a result, Europe risks losing industrial capacity, manufacturing know-how, and technological leadership in hydrogen and hydrogen-based value chains at precisely the moment when energy resilience, industrial competitiveness, and decarbonisation should, on the contrary, be reinforced.

In this context and against the backdrop of a stifling regulatory framework, we, the undersigned, welcome the European Commission’s announcement, in the AccelerateEU communication of 22 April 2026, to undertake a targeted revision of the production criteria for renewable hydrogen as laid down in Delegated Regulation (EU) 2023/1184. This announcement signals an important political recognition that while the market ramp-up has been slower than expected, changes need to be made to the existing frameworks while safeguarding existing investments and commitments.

We, representing stakeholders from across the renewable hydrogen and RFNBO value chain, including sectors directly involved in electrolysers manufacturing, project development, infrastructure deployment, hydrogen offtake, industrial use and market integration, support the direction set out in the joint Member State initiative of March 2026. In line with their letter, we urge the Commission to undertake a timely, efficient, and targeted revision of the Delegated Regulation (EU) 2023/1184 that focuses on the provisions most critical for projects’ viability in the current market phase. This review should focus on short-term relief in key areas such as:

• extend the transition phase for the additionality requirements from 2028 to at least 2035 to address the slower-than-expected build-out of renewable generation, hydrogen infrastructure, and offtake markets;
• postpone the application of monthly temporal correlation beyond the current timeline until at least 2035;

Any changes to the Delegated Regulation shall be accompanied by robust grandfathering and investment protection for first movers for the lifetime of a project. This would simultaneously ensure that projects that have already been developed, contracted, funded, or advanced towards an FID under the rules at the time of the investment decision are not put at risk, and guarantee a practical effect to the Commission’s objective of “safeguarding existing investments” as set out in the AccelerateEU Communication.

Download the joint letter below.