In a joint letter dated September 22, 2026, around two dozen associations addressed the European Commission. They demand that the announced targeted revision of the Delegated Regulation (EU) 2023/1184 be advanced without further delay. The regulation governs the production criteria for renewable fuels of non-biological origin (RFNBOs), which include green hydrogen.
Signatories include, among others, the Federation of German Industries (BDI), the German Association of Energy and Water Industries (BDEW), the Association of Municipal Enterprises (VKU), the German Association of the Automotive Industry (VDA), the Steel Federation, the German Hydrogen and Fuel Cell Association (DWV), the German Chemical Industry Association (VCI), FNB Gas, the Initiative for Energy Storage (INES), en2x, AquaVentus, as well as associations from Austria, the Netherlands, Belgium, and the Czech Republic.
Market development falls short of expectations
The associations welcome the Commission's announcement in the AccelerateEU communication to accelerate the revision of the production criteria. The Commission cites the market ramp-up, which has so far fallen short of expectations, as the reason. However, the continued delay in the revision and the lack of a clear timeline are "increasingly becoming a source of uncertainty," the letter states.
Companies along the hydrogen value chain are already making investment decisions for projects with long development periods and investment horizons that extend well beyond 2030. As long as it remains unclear when and how the production criteria will be adjusted, projects cannot reliably assess their business models, financing conditions, and future compliance costs.
Concrete demands on additionality and temporal correlation
The associations present concrete adjustment proposals. They demand that the full application of the additionality criteria be postponed until 2035. Additionality requires that new renewable energy plants be built for hydrogen production.
Furthermore, the temporal correlation between electricity generation and electrolysis should be maintained on a monthly basis instead of introducing an hourly correlation. Alternatively, the hourly correlation should, in the view of the associations, at least be postponed until 2035. The threshold for the exemption rule for bidding zones with a high share of electricity from renewable energies should be lowered from 90 to 80 percent.
According to the associations, these adjustments would reduce unnecessary costs and obstacles while ensuring the climate integrity of hydrogen production from renewable energies.
Proposal demanded before the end of the year
The associations call on the European Commission to promptly publish its proposal for the targeted review. A clear and reliable timeline should be set this month. The goal must be to present the final proposal before the end of the year.
"What we need now is not another lengthy phase of regulatory uncertainty, but a focused, targeted, and efficient decision-making process," the associations write. They offer the Commission support in the process with practical experiences of their members, project data, and technical expertise.
The discussion about the main obstacles arising from the current criteria for electricity procurement is mature. Associations, companies, and member states have provided extensive evidence and concrete adjustment proposals in recent years.
