If I buy hydrogen made by electrolysis as an input, what does CBAM need from the supplier?

Hydrogen routes with only electricity emissions give a direct figure of zero, but if you use that hydrogen as a precursor you must still name its production route. Using the zero as an actual value needs the producer's installation to be verified under CBAM rules, though a verifier may simplify the work, for example for hydrogen certified as RFNBO.

Why zero needs proof

For hydrogen as a CBAM good only direct emissions count, and electrolysis has minimal direct emissions. But a buyer who uses that hydrogen as a precursor claims an actual value of zero, and the guidance says that requires verification of the producing installation under CBAM rules.

What to get from the supplier

• The production route, named.
• The producer's verification report for the production year.
• The sector parameters and identity of the installation, as for any precursor.

Simpler verification

Using a risk-based approach, verifiers may simplify the work for hydrogen free of direct emissions. The guidance gives an example: hydrogen certified as a renewable fuel of non-biological origin (RFNBO) under the EU Renewable Energy Directive, a certification needed to import green hydrogen under the EU's renewable energy framework.

Indirect emissions of this hydrogen

If you make ammonia, hydrogen from a separate process such as electrolysis on your site is a precursor listed in Annex II. Its electricity emissions are then left out of the ammonia figure.

Changed since the transitional period

Until 2025, hydrogen certified under Delegated Regulation (EU) 2023/1184 could use a zero electricity factor. In the definitive period hydrogen's electricity emissions are not counted at all.

What Senseible does here

Senseible reads electricity bills and purchase invoices into dated records for a plant that buys or makes hydrogen. It does not issue hydrogen certificates or verify a producer's route.

• Electrolytic hydrogen: direct emissions only
• India green hydrogen and the EU RFNBO threshold
• When a precursor's electricity emissions count

Sources: European Commission, CBAM Guidance No. 5b, hydrogen (14 August 2026), sections 2.3.3.3 and 3.1.3, European Commission, CBAM Guidance No. 3, methods for calculating embedded emissions (14 August 2026), section 4.9.2

Last reviewed 2026-10-25.