# What steps does a gas-based hydrogen plant follow to report its CBAM emissions?

Canonical: https://senseible.earth/answers/cbam-grey-hydrogen-smr-installation-steps

Hydrogen (CN 2804 10 00) is charged on direct emissions only. Measure feed and fuel gas, apply the gas analysis and factor, subtract only CO2 that leaves for permanent storage under the rules, and divide by tonnes of hydrogen produced. Keep metering and lab records for a verifier.

## Steps

- Define the installation and the hydrogen production process inside it.
- Meter feed gas and fuel gas, with gas composition from a lab or online analyser.
- Calculate CO2 from carbon in feed and fuel.
- Deduct captured CO2 only if it goes to recognised permanent storage.
- Divide by tonnes of hydrogen produced in the period.

## What is not charged

Electricity used in the plant is indirect and is not charged for hydrogen under the current rules, but record it, because buyers' footprints may ask.

## No small-importer exemption

Hydrogen is outside the 50 tonne yearly exemption, so even small consignments need a figure.

## What Senseible does here

Senseible reads fuel, power and production records into dated, fingerprinted installation records, the starting point for the actual emissions your EU importer asks for.

- [SMR hydrogen CO2 per kg](https://senseible.earth/answers/smr-hydrogen-co2-per-kg)
- [Hydrogen and the 50 tonne rule](https://senseible.earth/answers/antwerp-hydrogen-imports-cbam-50-tonne-exemption)
- [Electrolytic hydrogen under CBAM](https://senseible.earth/answers/cbam-electrolytic-hydrogen-direct-emissions-only)

Sources: [CBAM Regulation (EU) 2023/956, consolidated](https://eur-lex.europa.eu/eli/reg/2023/956/2025-10-20), [Implementing Regulation (EU) 2023/1773, CBAM reporting rules](https://eur-lex.europa.eu/eli/reg_impl/2023/1773/oj/eng), [Regulation (EU) 2025/2083, CBAM simplification](https://eur-lex.europa.eu/eli/reg/2025/2083/oj)

Last reviewed 2026-10-22.