When we speak about an energy mix, we usually imagine a diverse combination of technologies working together to meet emission, stability and cost requirements. Logically, a mix should mean choice.

However, European regulation tells a different story.

Not every mix is a real mix. And not every green hydrogen is equally “recognised” as green.

Although I work daily in hydrogen business development, it took me time to fully grasp how strongly regulatory logic differs from technological logic.

Hydrogen “boxes”

Hydrogen can be produced via multiple clean pathways. Yet the EU divides them into rigid categories:

  • RFNBO (most preferred),

  • RED II / RED III hydrogen,

  • other low-carbon technologies.

These categories determine:

  • access to subsidies,

  • quota eligibility,

  • economic feasibility.

RFNBO – the preferred pathway

Strict requirements:

  • additional renewable capacity,

  • temporal correlation,

  • geographical correlation,

  • over 70% emission savings.

In Central Europe, this is technically and economically challenging.

Electrolysers are designed for stable operation. Renewable intermittency creates structural inefficiencies.

RED II / III – broader definition

RED hydrogen can:

  • use biomass and biomethane,

  • operate 24/7,

  • achieve comparable emission savings,

  • reduce costs,

  • support circular economy models.

Technically strong. Economically rational.

Yet often politically marginalised.

The core problem

Hydrogen may be clean, low-carbon and affordable — but if it does not qualify as RFNBO, it does not count toward mandatory targets.

This creates regulatory distortions.

What would help?

Technological neutrality.

Regulation should define emission goals, not prescribe a single pathway.

Hydrogen should become part of a diversified technological mix — just like the broader energy system.

Kristýna Váchalová

Hydrogen Business Development
✉️ info@hyconnect.eu
🌐 www.hyconnect.eu