Which EU member states signed the RFNBO non-paper at the Rotterdam Hydrogen Regulatory Forum?

Germany, Spain, Netherlands, Poland, and Austria formally submitted the non-paper at the 1st EU Hydrogen Regulatory Forum in March 2026. Czechia, Hungary, and Italy backed it in the room, bringing the coalition to eight member states.

What changes to the RFNBO Delegated Acts are EU member states requesting?

Three changes: extending the additionality transitional period to 2035 with ten-year grandfathering for early movers, retaining monthly temporal correlation until at least 2035, and dropping the renewable share threshold from 90 percent to 80 percent with sustainability criteria waived above that level.

When will the EU revise the RFNBO Delegated Acts?

The statutory review deadline is July 2028. With eight member states and major developers including Shell, RWE, and Hydrogen Europe aligned, draft revisions are expected well before the statutory date. The European Commission's commissioned ICF/Fraunhofer ramp-up study delivers its final report in Q4 2026.

How does HyGOAT help producers navigate RFNBO revision uncertainty?

HyGOAT's screening framework isolates additionality, temporal correlation, and renewable share as distinct gates, so producers can model both the current rulebook and the most likely revised version against the same project parameters before final investment decision.

Eight EU Member States Submit Formal Non-Paper to Revise RFNBO Delegated Acts

Key Highlights

Germany, Spain, Netherlands, Poland, and Austria submitted a formal non-paper at the 1st EU Hydrogen Regulatory Forum in Rotterdam. Czechia, Hungary, and Italy backed it in the room.
The non-paper requests extension of the additionality transitional period to 2035, retention of monthly temporal correlation past the current 2030 cutoff, and a reduction of the renewable share threshold from 90 percent to 80 percent.
The European Commission's own ICF/Fraunhofer ramp-up study, covering 38 developers across 19 countries, confirms that "the majority of project developers call for easing requirements." Final results are due Q4 2026.
Germany proposed a concrete grid emission intensity threshold: 180 g CO2 per kWh in 2028, declining 5 g per year thereafter.
Spain is already building its own national RFNBO certification system using e-Credits and expanded Guarantees of Origin.

What Changed

The 1st EU Hydrogen Regulatory Forum, held in Rotterdam in March 2026, produced a pointed political signal. Eight EU member states formed a public coalition demanding revision of the Renewable Fuel of Non-Biological Origin (RFNBO) Delegated Acts well before the statutory July 2028 review.

Three changes anchor the non-paper:

Additionality: extend the transitional period to 2035 (currently 2028) with ten-year grandfathering for early movers.
Temporal correlation: keep monthly matching until at least 2035, delaying the planned shift to hourly correlation.
Renewable share threshold: drop from 90 percent to 80 percent, with sustainability criteria waived above that level.

Major developer associations are aligned with the request. Shell asked for monthly matching extended to 2040. RWE described the willingness-to-pay gap as making RFNBO projects unbankable in their current form. Hydrogen Europe singled out the Delegated Act production rules as the single largest barrier to scale-up.

Why It Matters

The political coalition behind the non-paper is wider than any prior Commission revision pressure. With Germany, Spain, and the Netherlands in lockstep, plus the European Commission's commissioned study reaching the same conclusion as the developers, the Commission now faces a structural choice: revise the Acts on the developer-led timetable, or maintain the current framework against a coalition of member states whose own national systems are already drifting away from the harmonised rule set.

Spain's national RFNBO certification system, already under construction, signals what happens if Brussels delays. Member states will build national alternatives, and the EU-wide single market for RFNBO hydrogen fragments.

For project developers, the practical effect is uncertainty. Project parameters set against the current rulebook may face revision before final investment decision. For lenders, the same uncertainty translates into thinner financing windows and higher risk premia.

What to Watch Next

The Hydrogen Regulatory Forum is now established as the primary venue where revision pressure is being formalised. The Commission has not yet signalled whether it will accept the developer-led timetable or hold to the 2028 statutory review.

Three threads bear watching:

The ICF/Fraunhofer final report (due Q4 2026): whether the final stakeholder consultation widens or narrows the revision agenda.
Spain's national e-Credits system: whether other member states follow into national systems, fragmenting the single market for RFNBO hydrogen.
Geographic correlation reform: notably absent from the non-paper. Non-EU producers face structural compliance challenges that the proposed revision does not address.

HyGOAT Implications

Every certification readiness assessment now operates against a moving target. Producers building toward RFNBO compliance need to model both the current rulebook and the most likely revised version. HyGOAT's screening framework already isolates additionality, temporal correlation, and renewable share as distinct gates. The proposed changes do not collapse those gates, they shift the thresholds inside each one.

Indian exporters watching this revision should be particularly attentive. The relaxation is being designed for EU domestic producers facing bankability constraints. Whether the revision also addresses geographic correlation issues affecting non-EU suppliers remains an open question for the next round of stakeholder consultations.