They argue that overly rigid rules on additionality, spatial and temporal correlation are stalling projects, causing cancellations, and putting Europe at risk of missing its hydrogen deployment targets while global competitors surge ahead.
EU rules for renewable fuels of non-biological origin (RFNBO) require electrolyser operators, from 2028, to use new renewable assets in the same grid region and match their output with power generation on an hourly basis.
Ahead of the EU’s Omnibus Regulation and review of the RFNBO Delegated Act, the letter stressed that RFNBO must remain central to EU strategy, but with a revised additionality principle and extended exemptions, retention of the grandfathering clause, and eased matching rules.
These changes, it said, should stimulate demand through full implementation of the Renewable Energy Directive (RED III).
The signatories also urged the bloc’s ongoing study of the RFNBO Act to assess the liquidity of the renewable PPA market before tightening matching requirements, and to consider adopting weekly, monthly, or daily matching instead of strictly hourly.
“If RFNBO hydrogen is to reach meaningful scale, the stringent rules around additionality, spatial, and temporal correlation must be simplified,” the letter stated.
“If these rules remain unchanged, only a handful of small projects will reach final investment decision (FID).
“The reality today: Europe has failed to hit its target for 6GW of installed electrolysis by 2024. [Meanwhile] the electrolyser industry has deployed less than 1GW in installed projects, even though we have delivered on our commitment to increase manufacturing capacity tenfold – from 1GW to 10GW per year.”
Addressed to Commission President Ursula von der Leyen and DG Energy, which is reviewing RFNBO rules, the letter was signed by leading industry executives, including Siemens Energy’s Anne-Laure de Chammard, Bosch’s Stefan Hartung, and ITM’s Dennis Schulz.
Previously, the European Parliament has warned that the current rules may be holding back green hydrogen scale-up and keeping costs high.
However, others argue that loosening the framework could undermine projects that rely on its clarity and stringency.