Why do RFNBOs Matter?
With the European Union’s Renewable Energy Directive (RED) setting stringent targets for emissions reduction and renewable energy adoption, the role of renewable fuels of non-biological origin (RFNBOs) is growing. These fuels are essential for decarbonising industries, reducing reliance on fossil fuels, and strengthening long-term energy security. Whether you’re an energy provider, a producer of hydrogen, or an industrial user, understanding RFNBO regulations and the certification processes is crucial.
Key Takeaway
RFNBOs, such as renewable hydrogen and e-fuels, must meet strict EU sustainability criteria. These criteria include a thorough documentation and tracking, to demonstrate significant CO₂ reductions compared to fossil alternatives. Certification requires accurate GHG emissions calculations to verify compliance and to ensure that the fuel qualifies as renewable under the regulations. Understanding the requirements in the early stages helps businesses navigate the certification process with confidence and avoid compliance risks.
What is an RFNBO?
RFNBOs are liquid or gaseous fuels produced using renewable energy sources other than biomass. This includes hydrogen produced via electrolysis powered by wind or solar energy. The EU’s Renewable Energy Directive (RED III) defines RFNBOs and sets stringent conditions for their certification, ensuring that only truly sustainable fuels contribute to climate goals.
To be classified as an RFNBO, a fuel must:
- Be produced using 100% renewable electricity.
- Meet a minimum of 70% greenhouse gas (GHG) emissions savings compared to fossil alternatives.
- Comply with mass balance and sustainability traceability requirements.
What do businesses need to know?
1. Certification
The EU has introduced strict certification requirements to ensure that RFNBOs meet certain sustainability criteria. Companies producing or using these fuels must demonstrate compliance through a voluntary certification scheme such as ISCC, CertifHy, or REDcert, which have been officially recognised by the European Commission.
2. Electricity requirements for RFNBO production
The electricity used for the production of the RFNBO fuel must be fully renewable. The EU provides three pathways for compliance with this requirement:
- Direct connection: the production site is connected to a dedicated renewable energy source (e.g. a wind park or solar panels).
- Grid connection with a power purchase agreement (PPA): the electricity is sourced from the grid, but backed by a PPA with a renewable electricity provider. This is supported by Guarantees of Origin.
- Grid mix: this is only applicable in regions where the renewable share in the electricity mix exceeds 90%, therefore no sourcing of renewable electricity is needed.
From 2030 onwards, there will be an additional requirement of tracking the correlation between production and renewable electricity generation on an hourly basis. The aim is to produce the RFNBOs at times when renewable electricity is available.
3. Greenhouse Gas emissions savings
A key requirement for RFNBO certification is achieving at least 70% greenhouse gas (GHG) emissions savings compared to fossil fuel alternatives. This calculation follows a life-cycle approach, covering emissions from energy inputs, production processes, transport, and end-use combustion. RFNBO emissions are measured against standard pre-defined fossil fuel comparators. Factors such as the carbon intensity of electricity used in production, the origin of feedstock, and potential CO₂ capture or storage are all considered. If electricity from the grid is used, its renewable share and time of consumption impact emissions calculations, reinforcing the need for precise accounting and traceability.
4. Mass Balance and sustainability proof
RFNBOs must be fully traceable along the supply chain. This is done through a mass balance system and Proof of Sustainability (PoS) documentation. Companies must also report transactions in the EU Union Database, ensuring transparency and preventing double counting.
Want to know more?
Our team has in-depth knowledge of life-cycle assessment (LCA) methodologies, emission accounting frameworks, and key voluntary certification schemes such as ISCC, CertifHy, and REDcert. We assist companies in accurately assessing the carbon intensity of their RFNBO production, ensuring that the required 70% GHG reduction threshold is met.
If you would like to discuss working with Ecomatters on your RFNBO certification, please contact us or schedule a call with one of our experts.
Our experts
Mieke de Jager
