From pilot to practice: RFNBO certification for hydrogen is gaining momentum
Current developments on RED III, Delegated Acts and implementation in the Member States — and what this means for projects and supply chains.
Renewable hydrogen is widely regarded as a key enabler for the defossilisation of industry and transport. However, whether hydrogen is considered “renewable” in regulatory terms is not determined by a colour label, but by clearly defined criteria — and, above all, by robust, auditable evidence. This is precisely where the European framework for RFNBOs (Renewable Fuels of Non-Biological Origin) comes in: it makes requirements more comparable across the EU, while at the same time increasing complexity in practical implementation along value chains and across borders.
In this article, we place the most recent developments in context, look at harmonisation (and its limits), and show why recognised certification systems such as ISCC EU RFNBO and the CertifHy EU RFNBO Scheme are gaining importance in practice.
What are RFNBOs — and why are they so relevant?
RFNBOs include liquid or gaseous renewable fuels of non-biological origin — in practice primarily renewable hydrogen and derivatives produced from it (e.g., e-fuels). This is crucial for companies because RFNBOs are increasingly relevant in EU-level policy frameworks and in national implementation — for example through target trajectories for use in transport and industry.
The market is visibly moving from “concept” to “reality”: in some Member States, requirements are being designed in a more ambitious and more concrete way than the EU minimum level — which further increases the need for reliable certification and comparable evidence.
“Latest developments”: more clarity through EU rules — higher requirements for evidence
For practical implementation, the EU rules that specify when electricity used for electrolysis is recognised as renewable and how GHG emissions are to be accounted for are particularly influential.
Two Delegated Regulations are central here:
- Commission Delegated Regulation (EU) 2023/1184: methodology and conditions under which electricity for RFNBOs is considered (fully) renewable — including, among other elements, requirements on additionality as well as temporal and geographical correlation.
- Commission Delegated Regulation (EU) 2023/1185: methodology for GHG accounting of RFNBOs (and RCF) as well as requirements/threshold logics within the RED system.
What does this mean in practice? RFNBO projects now require significantly clearer evidence relating to electricity sourcing, system boundaries, emission factors and the MRV logic (Measurement, Reporting, Verification).
In short: “hydrogen as such” is not enough — what matters is demonstrable compliance with the criteria.
Harmonisation in practice: an EU-wide framework — but partly different national implementation
In principle, the framework is harmonised. In practice, however, differences arise in the “process wrapper” — in particular through transposition into national law, national responsibilities, and different recognition and reporting pathways.
Typical harmonisation gaps that companies experience in projects include:
- Responsibilities & recognition: Who recognises certification bodies and evidence — and under which procedure?
- Reporting & registry processes: Which data interfaces and reporting logics are required nationally?
- Transitional and interpretation issues: How are requirements (e.g., electricity criteria) interpreted operationally until processes are “bedded in”?
For companies with cross-border supply chains or off-takers, this means: the technical core evidence becomes more comparable across the EU — but national implementation can still be project-relevant.
Why certification systems are becoming so important now
As the need for evidence grows, the value of established certification systems increases: they help translate requirements into auditable processes — including defined documentation, audit logic and chain-of-custody rules.
A relevant step was the EU recognition of voluntary schemes that also cover the requirements of the Renewable Energy Directive (RED) for RFNBOs:
- The European Commission recognised ISCC EU as a voluntary scheme, including for RFNBOs and RCF (Implementing Decision of 19 December 2024).
- REDcert and the CertifHy system were likewise recognised as a voluntary scheme to demonstrate RFNBO compliance (also 19 December 2024).
For companies, this is an important signal: an EU-recognised scheme can increase comparability — provided it is correctly embedded in national enforcement/implementation.
RFNBO certification is increasingly moving from a regulatory requirement to established practice. Since the beginning of last year, the number of RFNBO certifications has risen noticeably. A key milestone was reached in early April 2025, when Air Liquide became the first company in Germany to successfully complete RFNBO certification under the ISCC EU scheme for a 20-MW electrolyser in Oberhausen. The case study illustrates how compliance documentation and auditing interact in practice—and highlights the growing importance of certified RFNBO quality for market communication and relationships with off-takers.
Looking ahead: standardisation as an additional driver of harmonisation
Alongside regulation, standardisation is gaining weight — as a translator between requirements, technology and auditable practice. In parallel to the legal framework, standards and guidance are being further developed to make sustainability requirements along the value chain more comparable and more standardised. For international supply chains in particular, this is a central lever: less room for interpretation, greater interoperability.
Germany: establishing and enforcing the 37. BImSchV — why “provisional recognition” matters during the implementation phase
In Germany, the crediting of electricity-based fuels towards the GHG quota is operationalised via enforcement of the 37th Ordinance for the Implementation of the Federal Immission Control Act (37. BImSchV). The German Environment Agency is setting up an evidence system for this purpose and provides, among other things, information, templates and application documents.
For companies, the key point is: enforcement is designed so that sustainability and GHG evidence is transparent, comparable and independently verifiable — including clear evidence chains across the data trail.
During the implementation phase, provisional recognition of certification bodies therefore plays a role as a transitional instrument: it enables certification, and evidence processes to function in ongoing enforcement while registry and detailed processes are further specified (e.g., forms, interfaces, process requirements).
What does this mean very practically for affected companies?
The earlier data chains, system boundaries, roles/responsibilities and plausibility checks are set up in an auditable manner, the more smoothly recognition, evidence and market access processes will work — even if requirements are further tightened.
Looking back: Status as of April 2025
Against this background, our update from April 2025 should also be understood: DEKRA Certification GmbH reported on provisional recognition as a certification body in the RFNBO context and on the practical implementation of an RFNBO certification audit. With the latest developments, the focus is now shifting even more strongly toward what truly carries projects through implementation: harmonisation, robust evidence, data integrity and independent assessment.
More information: Current implementation status on the 37. BImSchV, including evidence system, templates/downloads and requirements: