Green Hydrogen & RFNBO Criteria
Today I took a closer look at a new EWI study: “Green hydrogen production under RFNBO criteria – Analyzing the system and business case perspective” (2025).
✅ Key Takeaways:
This analysis examines the impact of the RFNBO criteria on green hydrogen production from system and business perspectives, with particular attention to how the criteria affect costs, capacity expansion, and the need for system flexibility.
📌 From a system perspective:
- Implementing all RFNBO criteria increases electrolysis capacity by over 3% across Europe to meet predefined demand, while average full-load hours decline by around 200 hours.
- Applying all RFNBO criteria with hourly matching increases average hydrogen supply costs by around 10 EUR/MWh (+8%) across Europe, driven primarily by additionality requirements and the shift from daily to hourly matching.
- In Germany, expected to be the largest hydrogen offtaker in Europe, the impact on marginal hydrogen costs is higher than the EU average (+16%).
- These effects highlight distributional impacts between sectors: while marginal electricity costs decline due to surplus renewables entering the market, additional system costs remain within the hydrogen sector. This implies a cost shift from electricity consumers to hydrogen producers.
- Average EU electricity costs fall by around 5%, and marginal CO₂ certificate costs by around 2%.
- Applying all RFNBO criteria adds over 25 GWel of additional RES capacity across Europe. In Germany, total installed RES capacity increases by 17%.
- Adding RFNBO criteria reallocates capacities from the electricity market to hydrogen production.
- With stricter temporal correlation requirements, hydrogen production increasingly relies on RES with high full-load hours (onshore and offshore wind), leaving more volatile solar generation to the electricity market.
📌 From a business perspective:
- Tighter matching requirements push portfolios toward dedicated renewables and short-term flexibility.
- Under Hourly Matching and a baseload supply profile, PV is often combined with large batteries; adding hydrogen storage can shift flexibility from the electricity sector to the hydrogen sector.
- Results show that LCOH are more sensitive to constraints from the business perspective: in the baseline, they rise from around 150 EUR/MWh (No Criteria) to almost 180 EUR/MWh (Hourly Matching), an increase of +19%, with the largest jump occurring between Daily and Hourly Matching.
- Sensitivity analyses reveal a much stronger impact than in the system perspective, especially under Hourly Matching, where LCOH range from about 170 EUR/MWh up to 370 EUR/MWh.
- The difference between Monthly and Hourly Matching spans from roughly 15 EUR/MWh to over 90 EUR/MWh.
