EU Low-Carbon Hydrogen Regulation 2025/2359 Now in Force
EU Delegated Regulation 2025/2359 creates a parallel low-carbon hydrogen pathway alongside RFNBO. CertifHy has already launched dual certification.
Key Highlights
- Commission Delegated Regulation (EU) 2025/2359 entered into force: low-carbon hydrogen methodology now applicable across EU member states
- Effective from November 2025; implementation confirmed as of February 2026 (Italy: effective 4 Feb 2026)
- CertifHy immediately launched a Low-Carbon Voluntary Scheme under the regulation's methodology
- Nuclear hydrogen pathway remains unresolved - EU consultation scheduled Q2 2026, decision by July 2028
- India's GHCI is RFNBO-aligned; no parallel low-carbon pathway defined yet
The Regulation
Commission Delegated Regulation (EU) 2025/2359 establishes the methodology for calculating greenhouse gas (GHG) emissions savings from low-carbon fuels under the Renewable Energy Directive (RED III).
This is a separate regulatory pathway from RFNBO (Renewable Fuels of Non-Biological Origin). Where RFNBO requires renewable electricity additionality, the low-carbon pathway applies to hydrogen produced with significant GHG reductions versus the EU's fossil fuel baseline - covering nuclear, high-efficiency natural gas with CCS, and certain grid-connected production.
Scope and Calculation
- Covers full lifecycle emissions: input supply → processing → transport/distribution → end-use
- Additionality requirement: Similar to RFNBO but less stringent on timing (grid additionality windows under review)
- Emissions intensity threshold: Producers must demonstrate GHG savings vs. the EU fossil-fuel baseline
- Voluntary certification schemes: CertifHy, ISCC, and other authorised bodies can issue "low-carbon" compliance certificates
The Certification Landscape Now
| Hydrogen Type | EU Regulatory Path | Certification Scheme |
|---|---|---|
| Renewable (wind/solar PPA) | RFNBO (RED III) | CertifHy, ISCC RFNBO |
| Low-carbon (nuclear, CCS gas, high-efficiency grid) | Low-Carbon Fuels Delegated Act 2025/2359 | CertifHy Low-Carbon (new), ISCC TBD |
| Grey hydrogen | No regulatory pathway | No certification |
What Changed
CertifHy launched its low-carbon certification service on the same day the regulation went into force - signalling that the market's largest RFNBO scheme is repositioning as a dual-pathway certifier.
ISCC is evaluating its response. TÜV is positioning. The certification bodies understand what this regulation means: producers now have optionality, and whoever builds the tooling to support both pathways captures a larger share of the compliance market.
For producers, this has immediate practical implications:
- Grid-connected projects previously excluded from RFNBO due to additionality rules may qualify under the low-carbon pathway
- Nuclear-adjacent production is not yet classified under either pathway (decision July 2028), creating 12-18 months of certification ambiguity for early movers
- CCS-enabled hydrogen gains its first formal EU certification route
Why It Matters
The EU has formally expanded hydrogen certification beyond a single renewable electricity requirement. This has two effects:
- More supply becomes certifiable - volumes that couldn't access EU compliance markets under strict RFNBO can now pursue the low-carbon pathway
- Certification complexity increases - producers designing for EU export in 2026 must now choose between two frameworks, or model both, depending on their electricity source and buyer requirements
HyGOAT Implications
India's GHCI is currently RFNBO-aligned. If Indian producers target EU markets via the low-carbon pathway (e.g., using high-efficiency grid electricity with a demonstrable GHG reduction), they would need CertifHy or ISCC low-carbon certification - not GHCI alone.
This creates a multi-framework certification scenario for export-oriented Indian producers: GHCI for domestic compliance + RFNBO or low-carbon certification for EU market access. Platforms that can manage both simultaneously will have a structural advantage as India's export pipeline matures.
Watch points for Q2-Q3 2026: the nuclear PPA consultation and ISCC's decision on whether to adopt the low-carbon pathway alongside its RFNBO offering.
Frequently Asked Questions
What is EU Delegated Regulation 2025/2359 and what does it establish?
Commission Delegated Regulation (EU) 2025/2359 establishes the GHG emission savings methodology for low-carbon fuels under RED III. It entered into force November 2025 and creates a formal EU certification pathway for hydrogen produced with significant reductions versus the EU fossil-fuel baseline - covering nuclear, high-efficiency natural gas with CCS, and certain grid-connected production. This is a parallel pathway to RFNBO, not a replacement.
How does Regulation 2025/2359 differ from the earlier RFNBO additionality Delegated Act?
The RFNBO Delegated Act governs renewable hydrogen produced from dedicated renewable electricity with strict three-part additionality rules (temporal matching, geographic correlation, new capacity). Regulation 2025/2359 applies a lifecycle GHG savings methodology with less stringent additionality requirements - meaning grid-connected projects previously excluded from RFNBO may now qualify. CertifHy has already launched a dual-pathway certification service under the new regulation, and ISCC is evaluating its response.
Why does this regulation matter for hydrogen producers designing EU export strategies in 2026?
Producers now face two EU compliance pathways with different eligibility criteria, additionality rules, and certification bodies. Grid-connected or CCS-enabled projects shut out of EU markets under strict RFNBO rules can now pursue the low-carbon route and access EU compliance buyers. The tradeoff is increased complexity - producers must model both frameworks against their electricity source, buyer requirements, and cost structure. Choosing the wrong pathway could limit buyer optionality or require recertification later.
How does this affect Indian producers using HyGOAT who target EU buyers?
India's GHCI is RFNBO-aligned, giving Indian renewable hydrogen producers a clear domestic-to-EU certification pathway. If a producer uses grid electricity with demonstrable GHG reductions and targets EU buyers via the low-carbon route instead, they would need CertifHy or ISCC low-carbon certification in addition to GHCI - creating a multi-framework compliance scenario. HyGOAT is designed to support this from a single emissions data set, avoiding the cost and duplication of managing separate certification processes for domestic and export compliance.