Senseible

What does a CBAM calculation for steam reforming hydrogen look like?

The Commission's example: a steam reformer burning 190,000 tonnes of natural gas and exporting 800 TJ of heat emits 461,765 t CO2 net, over 55,000 t of hydrogen. That is 8.396 t CO2 per tonne. With 2028 free allocation of 4.580, importing 100 tonnes leaves 381.6 certificates.

What is monitored

One production process. The only source stream is natural gas, used as feedstock and fuel. Hydrogen is a simple good, so there are no precursors, and only direct emissions count. Heat exported to the rest of the plant or a district network is subtracted. For heat of unknown origin the default is natural gas at 90% boiler efficiency, which is 62.3 t CO2 per TJ.

Free allocation and the import

Hydrogen has one benchmark whatever the route: 5.089 t CO2 per tonne of hydrogen. The example assumes year 2028, CSCF 1.00 and CBAM factor 90%. Captured CO2 sent to storage could also be deducted, if the receiving site monitors under CBAM.

Steam reforming, hydrogen, import in 2028 (Commission's example)

Figures are the Commission's own worked example in Guidance No. 5b, not a real plant. Your numbers will differ.

What Senseible does here

Senseible reads natural gas invoices into dated, fingerprinted quantities, which is the largest input line in a reformer's calculation. The heat export, free allocation and import steps are done in the Commission's template.

Sources: European Commission, CBAM Guidance No. 5b, hydrogen (14 August 2026), sections 3.1 and 4

Last reviewed 2026-10-25.