Hydrogen is in CBAM scope from 1 January 2026. This guide explains the CN codes, the distinction between grey, blue, and green hydrogen, and the implications for South African producers.
Hydrogen is one of the five sectors covered by CBAM from 1 January 2026. The inclusion of hydrogen in CBAM reflects the EU's recognition of hydrogen as a critical energy carrier for the clean energy transition — and the importance of ensuring that imported hydrogen meets the same carbon standards as domestically produced hydrogen.
| CN Code | Product Description | CBAM Scope |
|---|---|---|
| 2804.10 | Hydrogen | Yes |
This is a single CN code covering all hydrogen, regardless of production method. The CBAM liability depends on the embedded emissions of the specific hydrogen produced — which varies dramatically between production methods.
| Hydrogen Type | Production Method | Embedded Emissions | CBAM Cost (€65/tCO₂) |
|---|---|---|---|
| Grey | Steam methane reforming (SMR) | ~10–12 tCO₂/t H₂ | €650–€780/t |
| Brown/Black | Coal gasification | ~18–20 tCO₂/t H₂ | €1,170–€1,300/t |
| Blue | SMR + CCS | ~1–3 tCO₂/t H₂ | €65–€195/t |
| Green | Electrolysis (renewable electricity) | ~0.5–1.5 tCO₂/t H₂ | €33–€98/t |
| EU CBAM default | — | 10.9 tCO₂/t | €708.5/t |
The EU default emission value for hydrogen is 10.9 tCO₂/t (with 10% markup) — reflecting the global average, which is dominated by grey hydrogen production.
South Africa is positioning itself as a major green hydrogen exporter, with several large-scale projects under development:
Green hydrogen projects:
Grey/brown hydrogen:
For South African green hydrogen producers, CBAM creates a significant competitive advantage:
This CBAM saving, combined with the green hydrogen premium in EU markets, makes South African green hydrogen highly competitive against grey hydrogen imports.
Use the CBAM Calculator [blocked] to model your specific hydrogen CBAM exposure.