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 by production route. Indirect electricity emissions are excluded under Annex II. The single mass-based threshold that exempts small importers does not apply to hydrogen: Article 2a of Regulation (EU) 2023/956 shall not apply to imports of electricity or hydrogen (Art. 2a(4), inserted by Regulation (EU) 2025/2083), so any imported volume brings the obligation with it.

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

Look up the published default for your CN code →

Grey hydrogen

Steam Methane Reforming (SMR)

Natural gas reacted with steam to produce hydrogen.

Electrolysis

Electrolysis (Green Hydrogen)

Water split using electricity to produce hydrogen. Emissions from the electricity are outside CBAM scope for hydrogen.

Reforming

Auto-thermal Reforming (ATR)

Combined reforming process.

Calculate your Hydrogen CBAM exposure

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The platform

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