In the previous articles, I focused on the differences between individual categories of “green” hydrogen and how European regulation shapes technological choices. In this issue, I would like to move one step further – to a practical question that industry, mobility and energy sectors are facing today:

Does it make sense to invest in the production and use of hydrogen that is not produced under RFNBO, but complies with RED II / RED III?

The short answer is: Yes – if we think strategically, long-term, and in the context of real decarbonisation.

Decarbonisation does not happen overnight

Large industrial projects – whether in steel, chemicals, energy or transport – are not planned in months, but in years. The same applies to:

  • the construction of production technologies,
  • permitting processes,
  • infrastructure,
  • integration into existing operations.

Waiting for the “ideal” regulatory state often means waiting too long.

While regulations evolve, emissions are generated every single day. And this is exactly where technologies that comply with RED II / RED III come into play – including hydrogen production from biomass, biogenic residues or other low-emission pathways.

What hydrogen beyond RFNBO brings to companies

From the perspective of industry, mobility and municipalities, such projects offer several concrete advantages:

  • real emission reductions already today, not only in the future,
  • higher energy independence,
  • stable production independent of weather conditions,
  • the possibility to integrate circular economy principles,
  • preparation of infrastructure, know-how and operational teams.

Hydrogen produced under RED II / RED III has the same quality and usability – in industry, mobility and energy production. The difference is not in the molecule, but in its regulatory classification.

And what about the disadvantages? It is fair to state them clearly

From today’s legislative perspective, it is necessary to openly acknowledge the downsides:

  • such hydrogen cannot always be counted towards mandatory RFNBO quotas,
  • some companies may face temporary penalties or fees,
  • financial support is less straightforward compared to RFNBO projects.

These are real constraints that cannot be ignored.

But this is exactly where strategic thinking becomes essential.

The prepared are not surprised

If a company today:

  • invests in technology,
  • reduces its emissions,
  • sets up processes,
  • builds infrastructure,

then at the moment when regulation changes or expands (which happens gradually), it will not be at the starting line, but close to the finish.

While others are still designing, permitting and building, prepared companies can:

  • smoothly adapt to new conditions,
  • scale up operations,
  • or complement their technology with additional elements.

Where does financing fit into this?

European instruments such as the Innovation Fund currently strongly emphasise RFNBO, but at the same time:

  • allow support for broader decarbonisation solutions,
  • evaluate the overall emission impact of projects,
  • and gradually respond to technological reality.

This is precisely why it makes sense to prepare projects already now, even if the conditions are not yet ideal.

Conclusion

Hydrogen produced under RED II / RED III is not bypassing decarbonisation. It is a pragmatic way to:

  • reduce emissions,
  • prepare for the future,
  • and avoid losing time waiting for “perfect” regulation.

It is not about going against the rules. It is about being ready when the rules evolve.

And in decarbonisation, more than anywhere else, one principle applies:

Those who are prepared are not surprised.

I focus on the development of hydrogen projects and infrastructure strategies in a European context.

Kristýna Váchalová
Hydrogen Business Development