SECTOR GUIDE
CBAM guide: hydrogen
For producers exporting hydrogen goods to the EU, this page collects how CBAM works in this sector: scope, emission rules, default values and what to monitor at the installation — all grounded in Commission sources.
Last checked: 31 August 2026
Scope: which goods?
1 CN codes/code groupsThe scope is a single code: 2804 10 00 — hydrogen. But that single code has two sharp features. First, the 50-tonne exemption does not apply to hydrogen: the importer’s authorisation obligation holds regardless of quantity. Second, the sector’s default value is by far the highest of the five sectors — the production route determines the result more than anything else.
Look up your own CN code →Which emissions are priced?
For hydrogen only direct emissions are currently priced: hydrogen is on the Annex II list of Regulation (EU) 2023/956 and the indirect column of the default-value table is empty. This is critical for electrolytic hydrogen: the indirect emissions of electrolysis electricity do not enter the CBAM bill today, while direct process emissions (for water electrolysis) are close to none. Hydrogen from steam reforming of natural gas, by contrast, carries its CO₂ entirely as direct emissions, fully priced.
Default values: sample rows
| CN code | Product | Default value (tCO₂e/t) | Route |
|---|---|---|---|
| 2804 10 00 | Hydrogen (Türkiye) | 10.82 | — |
| 2804 10 00 | Hydrogen (other countries) (Other countries*) | 17.74 | — |
Values reflect direct emissions only. Double-digit tCO₂e per tonne shows how expensive declaring with defaults is in this sector — documenting your actual route pays more here than anywhere else.
An importer declaring with default values pays a mark-up on top that rises by year: 10% in 2026, 20% in 2027, 30% in 2028 (1% for fertiliser goods). Source: Implementing Regulation (EU) 2025/2621 (corrected by (EU) 2026/1740).
Cost scale
Rough scale: at the Türkiye default of 10.82 tCO₂e/t and the current certificate price (Q2 2026: 75.28 €/tCO₂e), the implied certificate cost is roughly €815 per tonne — plus the 10% mark-up for 2026. Since actual direct emissions on the electrolysis route can be a small fraction of that, verified actual data is close to a necessity in hydrogen.
Current certificate price →Production routes and precursors
Main routes in the sector
- Steam reforming and partial oxidation
- By-product of steam cracking
- Electrolysis of water and chlor-alkali electrolysis
Hydrogen is a simple good: it has no CBAM-scope precursors (Guidance No. 3, Table 4-2). The technical detail sits in electrolysis: it is a multifunctional process (oxygen as co-product) and emissions are attributed by molar ratios — Methodology Act, Annex III §A.2.1. Hydrogen also enters other sectors’ calculations as a precursor of ammonia, pig iron and DRI: if you sell hydrogen, your customers will ask for your embedded-emissions data for their own CBAM accounting.
What to monitor at your installation
The main items a producer aiming to report verified actual data needs to keep records of:
- On the reforming route: natural gas consumption (fuel + feedstock) with quantity and net calorific value; mass balance of process CO₂.
- On the electrolysis route: documentation of molar-ratio emission attribution with the oxygen co-product.
- Production quantity: hydrogen tonnage per period, split by sales and internal consumption.
- Purification and compression: the fuel/energy consumption of these steps enters the emissions attributed to the process.
Frequently asked
Does the 50-tonne exemption apply to hydrogen?
No. The mass-threshold exemption does not apply to hydrogen or electricity imports — the importer needs authorised CBAM declarant status regardless of quantity.
Is CBAM favourable for green (electrolytic) hydrogen?
Under today’s rules, markedly so: with only direct emissions priced, electrolytic hydrogen carries a very low CBAM burden — the electricity’s emissions do not enter the calculation. But this must be proven with verified actual data; without it, the double-digit default value applies.
I produce ammonia; why am I asked for hydrogen data?
Hydrogen is the precursor of ammonia: your customer’s (or your own plant’s) ammonia embedded-emissions calculation includes the embedded emissions of the hydrogen used. If you buy hydrogen, that data must come from your supplier; if you produce it, from your own process.
Next step
See which value your goods face, produce a first estimate from installation data, and pin down the timeline:
A question specific to your sector?
Let us assess the state of your installation data and your verification readiness through a verifier’s lens.
Get in touch →Sources
Default values: Implementing Regulation (EU) 2025/2621 (corrected by (EU) 2026/1740), Annex I. Direct/indirect rule: Regulation (EU) 2023/956, Art. 7(1) and Annex II. Precursors and routes: Commission Guidance No. 3, Table 4-2. Certificate price: the Commission’s official price page (Q2 2026). This page is informational; work from the current official texts when preparing declarations.
For your product in this sector: check whether your CN code is covered by CBAM, look up your default value or calculate your annual CBAM cost — all free, no registration.