The EU Commission is once again discussing the hydrogen ramp-up. At the center of the deliberations is the loosening of the RFNBO criteria for green hydrogen. But another topic could weigh even more heavily, as insiders report. The previously binding targets for renewable hydrogen for each member state could be replaced by an indicative target at EU level. That would be a fundamental change of system: nationally attributable responsibility would turn into a common European ambition, for whose non-fulfillment, in the end, no one is responsible.
States have been responsible so far
The EU directive RED III has so far stipulated that by 2030 at least 42 percent and by 2035 at least 60 percent of the hydrogen used in industry must be renewable. If these targets have to be met at the member state level, national funding instruments and concrete demand arise. An indicative EU target would eliminate this binding character. States could wait and hope for the achievements of others. This will be a topic when politicians and the hydrogen industry meet in October for the European Hydrogen Week in Brussels.
Yes, green hydrogen is still expensive, many industrial offtakers are shying away from long-term contracts, and infrastructure as well as import chains are emerging more slowly than expected. A national quota can place a particular burden on countries with high hydrogen consumption and energy-intensive industry.
But it does not follow from this that Brussels should abolish national responsibility. The quota was created because a market for renewable hydrogen does not develop on its own. Investors finance electrolyzers and supply chains only if they can rely on dependable demand. The development in the refinery sector shows that quotas set important incentives for the ramp-up in the member states. A non-binding EU target does not offer this security. In this way, market confidence cannot be (re)established and long-term, bankable hydrogen demand beyond 2030 cannot be secured. Today’s relief thus threatens to become tomorrow's investment obstacle.
Flexibility in meeting the targets, but binding commitment to the goal
Europe therefore needs neither regulatory rigidity nor a departure from its ambitions. The fulfillment of the quotas can be made more flexible, for example through tradable certificates, joint procurement or the transferability of RFNBO volumes between member states. Flexibility in fulfillment, however, is something different from non-binding goals.
The real answer lies on the demand side: carbon contracts for difference, green lead markets and procurement quotas, as well as secured offtake agreements. Those who instead replace national obligations with an indicative EU target create a classic responsibility problem: everyone commits to the goal, but each waits for the other.
Germany should advocate in Brussels for a framework that is flexible, investment-friendly and nevertheless binding. Green hydrogen will not become competitive by Europeanizing responsibility and abolishing binding commitments at the national level.
