CN 2804CO₂

Hydrogen

Hydrogen gas and related production processes exported to the EU.

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Emissions scope

Direct only

GHGs covered

CO₂

Functional unit

Tonnes product

Indirect electricity

Excluded — Annex II

What emissions are covered?

Hydrogen exporters must report direct embedded emissions only. The calculation methodology varies significantly by production route — steam methane reforming produces high direct emissions, while electrolysis produces near-zero direct emissions. Indirect electricity emissions are excluded under Annex II.

Included

  • Natural gas combustion for SMR process
  • Process emissions from reforming reactions
  • Fuel combustion for heat generation

Excluded

  • Electricity consumption emissions (Annex II exclusion)
  • Transport and compression emissions

Production Routes

Indicative typical intensities, for comparing routes at an order of magnitude. These are not regulated values and not the EU default values: those are published per country and per CN code in IR (EU) 2026/1740 Annex I, are generally higher, and are the figures a declarant actually uses. Look up the published default for your CN code →

~8.50 tCO₂e/t indicative

Grey hydrogen

Steam Methane Reforming (SMR)

Natural gas reacted with steam to produce hydrogen. Current dominant production method globally. High direct emissions.

~0.50 tCO₂e/t indicative

Green hydrogen

Electrolysis (Green Hydrogen)

Water split using electricity to produce hydrogen. Near-zero direct emissions — electricity excluded from CBAM scope.

~7.50 tCO₂e/t indicative

Blue hydrogen potential

Auto-thermal Reforming (ATR)

Combined reforming process. Similar emissions profile to SMR but more efficient at scale.

Calculate your Hydrogen CBAM exposure

Use the free sector calculator to estimate your CBAM certificate costs based on your production route and export volume.

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The platform

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