Verifying Green Hydrogen Emissions for CBAM: Certification Requirements for SA Producers

Verifying Green Hydrogen Emissions for CBAM

For South African green hydrogen producers to benefit from the CBAM advantage of low embedded emissions, they must be able to demonstrate — through verified certification — that their hydrogen has the claimed low carbon footprint. Without verification, the EU default emission value of 10.9 tCO₂/t applies.

The Verification Requirement

Article 4 of Regulation (EU) 2023/956 requires that embedded emissions be calculated using either:

1. Actual verified emissions — calculated and verified according to the methodology in Implementing Regulation (EU) 2023/1773
2. EU default values — published by the European Commission for each product category

For green hydrogen, the actual emissions approach is strongly preferable, as actual emissions (0.5–1.5 tCO₂/t) are dramatically lower than the default (10.9 tCO₂/t).

The EU RFNBO Standard

The EU's Delegated Regulation on Renewable Fuels of Non-Biological Origin (RFNBO) defines what counts as "renewable hydrogen" for EU purposes. Key requirements:

1. Additionality: The renewable electricity used for electrolysis must come from new renewable capacity (not existing renewable generation)
2. Temporal correlation: The renewable electricity must be produced in the same hour as the electrolysis (or within the same month in some cases)
3. Geographic correlation: The renewable electricity must be produced in the same bidding zone or adjacent zone as the electrolysis
4. Greenhouse gas threshold: The hydrogen must have lifecycle emissions below 3.38 kgCO₂e/kgH₂ (3.38 tCO₂/t H₂)

South African green hydrogen projects must comply with these requirements to qualify as RFNBO hydrogen for EU markets.

Accredited Verifiers for Green Hydrogen

Third-party verification of green hydrogen emissions must be conducted by accredited verifiers. In South Africa, relevant verifiers include:

• Bureau Veritas — ISO 14064-3 accredited, experience with renewable energy projects
• SGS South Africa — experience with energy and emissions verification
• DNV South Africa — experience with hydrogen and offshore projects
• TÜV Rheinland South Africa — experience with renewable energy certification

International verifiers with SA presence:

• CertifHy — EU-based green hydrogen certification scheme
• IRENA's Green Hydrogen Certification — international standard

The Certification Process

1. Project design: Design the green hydrogen production system to meet RFNBO requirements
2. Monitoring plan: Implement metering and monitoring systems for electricity consumption, electrolyser efficiency, and emissions
3. Data collection: Collect production data over the certification period
4. Third-party audit: Commission an accredited verifier to audit the data and production process
5. Certificate issuance: Receive a certificate of compliance with the RFNBO standard
6. CBAM declaration: Provide the certificate to the EU importer for their CBAM declaration

The Cost of Certification

Certification costs for green hydrogen projects are typically:

• Initial certification: R500,000–R2,000,000 (depending on project scale)
• Annual renewal: R200,000–R500,000

These costs are modest relative to the CBAM savings from verified low emissions:

• At 10,000 t H₂/year exported to EU: CBAM saving = (10.9 - 1.0) × €65 × 10,000 = €6.435 million/year
• Certification cost: R1,000,000/year (€50,000/year)
• Net saving: €6.385 million/year

Use the CBAM Calculator [blocked] to model your specific green hydrogen CBAM exposure.