RFNBOs (Renewable Fuels of Non-Biological Origin) are a cornerstone of Europe’s hydrogen strategy. Yet their market ramp-up is increasingly at risk. Geopolitical tensions, volatile energy prices, regulatory uncertainty, and growing international competition are slowing investments and delaying projects. As a result, Europe risks losing industrial capacity, technological expertise, and its leading position in hydrogen value chains.

In response, eight industry associations have jointly called on the European Commission to make targeted changes to the Renewable Hydrogen Delegated Act. In a joint letter, they welcome the Commission’s planned 2026 review of the renewable hydrogen production criteria, viewing it as an important signal that the regulatory framework must better reflect market realities while safeguarding existing investments and commitments.

The associations advocate a focused and accelerated revision of Delegated Regulation (EU) 2023/1184, concentrating on provisions with the greatest impact on project viability. Specifically, they recommend extending the transition period for additionality requirements from 2028 to at least 2035 and postponing the introduction of monthly temporal correlation until at least 2035.

At the same time, the signatories caution against a broad and lengthy overhaul of the regulatory framework. Such a process would create further uncertainty and delay investment decisions. Instead, they call for a narrowly defined amendment process to be completed by the end of 2026, addressing the most critical barriers to hydrogen deployment while maintaining planning security for investors. Read the joint letter here.

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