Brussels, July 2026
ERGaR has co-signed a joint letter to the European Commission together with CO2 Value Europe, eFuel Alliance, eNG Coalition, Eurogas, Hydrogen Europe, Methanol Institute and VDMA. The signatories call for swift action on the targeted revision of Delegated Regulation (EU) 2023/1184 on RFNBO production criteria.
Renewable hydrogen and RFNBO projects are not scaling at the pace Europe needs. At the same time, regulatory uncertainty is delaying investment decisions. For first-mover projects, clear and workable rules are essential to move from planning to final investment decisions.
The joint letter calls on the European Commission to:
- Extend the transition period for additionality requirements until at least 2035;
- Postpone the move to stricter temporal correlation requirements, keeping the monthly approach until at least 2035;
- Provide robust grandfathering and investment protection for first-mover projects;
- Launch and complete a targeted amendment process by the end of 2026.
From ERGaR’s certification perspective, Delegated Regulation (EU) 2023/1184 and the GHG methodology set out in Delegated Regulation (EU) 2023/1185 should be treated as closely connected elements of the same implementation framework. Any change to RFNBO production criteria can have practical implications for greenhouse gas accounting, certification and verification. ERGaR therefore supports a targeted revision that offers legal certainty, reduces regulatory risk and enables renewable gases and RFNBOs to contribute effectively to Europe’s decarbonisation objectives.
Read the joint letter below.