With the adoption of Directive (EU) 2023/2413 (RED III), the EU is stepping up efforts to cut dependence on fossil fuels. The directive sets new, ambitious targets for renewable fuels of non-biological origin (RFNBO) across industry, with an important deadline for Member States to transpose this into national law by May 21, 2025. 

On September 2, 2024, the European Commission released a crucial Communication offering guidance to Member States on how to achieve the RFNBO targets in both industry and transport.  

Here’s a breakdown of key elements covered: 

• Clarifications on the scope of application for the RFNBO targets in Article 22a;  

• Insights into the relationship between RFNBO targets and the broader EU renewable energy goal (Article 3);  

• Conditions under which Member States may reduce the RFNBO target (Article 22a);  

• Overview of the binding sub-target for RFNBOs in the transport sector (Article 25). 

We welcome the European Commission’s guidance on the targets for RFNBO consumption, as it provides much-needed clarity and direction for achieving the implementation goals of the EU’s RED III. We’re pleased with the clarification that the refinery route can contribute to the transport target and appreciate the valuable guidance on accounting for hydrogen consumption in refineries. The clarification on the treatment of derivative imports, aligned with the legal text, is also appreciated, though the potential risk of carbon leakage remains unresolved. However, we regret that some aspects were left unaddressed, especially the implications of Recital 63 concerning the possible exclusion of integrated ammonia plants. 

Overall, these steps are vital in advancing our industry and ensuring that hydrogen plays a central role in the clean energy transition. Achieving the ambitious goals set by RED III will only be possible if the necessary conditions are met, starting with a predictable regulatory framework.  

For more information, on the necessary conditions as well as the implementation routes have a look at Hydrogen Europe’s recommendation in our latest position paper – https://lnkd.in/eKzuBf58 

Additionally, the European Commission also adopted guidance on other aspects of the Renewable Energy Directive, including:  

• Heating and cooling (Articles 15a, 22a, 23, & 24),  

• Energy System Integration (Article 20a), and 

• A recommendation on heating and cooling under the revised Energy Efficiency Directive (Article 26) 

We welcome all the guidance documents. The guidance provided for Article 20a of Directive (EU) 2018/2001 to promote renewable electricity integration, includes provisions to mandate data transparency, smart recharging, and market access for small storage. While it could support green hydrogen through better access to renewable data, the guidance lacks a clear focus on hydrogen’s role in energy storage and system integration, missing a key opportunity to strengthen the sector’s involvement. 

Additional links to the Resources: 
Link to European Commission’s announcement 

Guidance on heating & cooling (RED) 
Guidance on energy system integration (RED) 
Guidance on RFNBOs (RED) 
Guidance on heating & cooling (EED)