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

~8.50 tCO₂e/t

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

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

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

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