The RED Delegated Act on RFNBOs refers to a specific regulatory measure adopted under the Renewable Energy Directive (RED II) of the European Union. It defines the sustainability and greenhouse gas (GHG) emission criteria for Renewable Fuels of Non-Biological Origin (RFNBOs)—a category that includes key e-fuels such as green hydrogen, e-methanol, and e-kerosene.
This delegated act is essential for determining whether RFNBOs can be counted toward renewable energy targets, benefit from regulatory incentives, and be recognized as sustainable within the EU energy system. It is part of the EU’s broader effort to decarbonize transport, industry, and heating, while ensuring transparency, traceability, and environmental integrity.
What are RFNBOs?
Renewable Fuels of Non-Biological Origin (RFNBOs) are fuels that:
- Are produced from renewable electricity, and
- Are not derived from biomass or any biological feedstock.
Examples of RFNBOs include:
- Green hydrogen produced via water electrolysis powered by wind or solar energy
- Synthetic fuels such as e-methanol, e-diesel, or e-kerosene, created by combining green hydrogen with captured carbon dioxide (CO₂)
These fuels are critical to achieving deep decarbonization in hard-to-abate sectors, particularly long-distance transport, aviation, and certain industrial applications.
What is the RED Delegated Act?
The RED Delegated Act is a legally binding regulation under RED II, specifically adopted by the European Commission to clarify how RFNBOs must be produced and documented in order to count towards the EU’s renewable energy targets.
The act provides detailed sustainability criteria, particularly related to:
- Additionality
- Temporal correlation
- Geographical correlation
- GHG emission thresholds
Key sustainability criteria
The RED Delegated Act outlines strict conditions that RFNBOs must meet, including:
- Additionality
The renewable electricity used must come from new generation capacity built specifically for producing RFNBOs. This prevents diverting existing renewable electricity away from the grid. - Temporal correlation
Hydrogen production must be matched with renewable electricity generation within a specific time window (e.g. hourly or monthly), ensuring alignment between production and renewable availability. - Geographical correlation
The renewable energy source and the electrolyzer must be located within the same bidding zone or market region, minimizing energy transmission losses and grid imbalance. - GHG emission savings
RFNBOs must achieve at least 70% GHG savings compared to fossil fuels. This requires full Life Cycle Assessment (LCA) and accurate tracking of carbon inputs and outputs.
Why is this important?
The delegated act sets a clear and uniform regulatory framework for RFNBO producers, investors, and national authorities. Its goals include:
- Ensuring that RFNBO production truly contributes to emissions reduction
- Creating a credible certification system for tracking compliance
- Supporting the development of a robust European hydrogen economy
- Enabling RFNBOs to qualify for EU fuel mandates and quotas, such as those under ReFuelEU Aviation and FuelEU Maritime
For companies in the hydrogen and e-fuel sectors, compliance with the delegated act is crucial for market access, funding eligibility, and long-term competitiveness.
Benefits of the RED Delegated Act on RFNBOs
- Legal certainty: Establishes clear rules and definitions for producers and regulators.
- Market development: Helps standardize e-fuel certification across the EU, building investor confidence.
- Environmental integrity: Ensures that RFNBOs offer real and measurable climate benefits.
- Cross-border trade: Facilitates the integration of hydrogen and synthetic fuel markets within and beyond the EU.
Challenges and criticisms
Despite its intentions, the delegated act has also sparked debate:
- Complexity and administrative burden: Compliance requires sophisticated energy tracking systems, digital monitoring, and third-party audits.
- Concerns about additionality: Critics argue the strict rules may slow hydrogen deployment, especially in early markets where renewable capacity is limited.
- Investment uncertainty: Delays in the act’s adoption and evolving rules have created uncertainty for project developers and investors.
Nevertheless, it is widely acknowledged that some form of harmonized regulatory oversight is essential for ensuring that the EU’s climate ambitions are met without unintended consequences.
