Brussels, 15 October 2026 – Relaxing the European Union’s rules on renewable hydrogen could increase electricity prices and greenhouse gas emissions while delivering only modest reductions in hydrogen production costs and doing little to address the range of barriers slowing renewable hydrogen deployment, according to a new study commissioned by Environmental Defense Fund Europe. The findings come as the European Commission is planning to launch a public consultation to review the RFNBO Delegated Act, in advance of its originally scheduled review in 2028. 

The study, ‘Impact of RFNBO Delegated Act Regulatory Variants’, conducted by CLIMACT, University of Liège, and Systemik (UCLouvain), assesses how eight potential regulatory changes to the EU’s renewable fuels of non-biological origin (RFNBO) requirements could have broader systemic impacts for Europe, affecting hydrogen production, renewable energy investment, electricity prices, and greenhouse gas emissions across the European energy system.  

“Europe’s renewable hydrogen policy must be assessed in the context of the entire energy system. This study highlights the risks of weakening safeguards that support renewable electricity investment, potentially shifting costs onto electricity consumers while delivering limited gains in hydrogen production,” said Anna Lóránt, Senior Policy Manager EU, Environmental Defense Fund Europe. “As policymakers consider the future of the RFNBO framework, protecting the integrity of Europe’s energy transition should remain central.”  

Relaxing RFNBO rules could raise electricity prices 

The study finds that the additionality and hourly matching requirements in the current RFNBO framework play an important role in supporting new renewable electricity investment for hydrogen production. Relaxing these safeguards could reduce near-term investment in renewable electricity capacity and increase pressure on the electricity system. In the short term, their simultaneous relaxation could increase already high average marginal electricity prices in the EU by up to 2%. 

The impacts could be more pronounced in some Member States. In 2035, countries including France, Poland and Belgium could experience electricity price increases of more than 4% in certain scenarios, reflecting higher hydrogen production and energy demand linked to hydrogen derivatives. 

These findings highlight the importance of considering the effects of hydrogen policy changes on electricity consumers and the wider energy system. 

Modest cost reductions would not resolve the barriers to hydrogen deployment 

The study finds that relaxing current RFNBO requirements would deliver only modest reductions in the levelised cost of hydrogen (LCOH), estimated at approximately €0.10 to €0.25 per kilogram of hydrogen in the short term, depending on the policy variant. Even a combined relaxation of additionality and temporal correlation requirements would not accelerate the scale of European RFNBO production compared to a scenario in which existing rules remain in place. 

The findings suggest that regulatory requirements are not the dominant factor behind the slow ramp-up of the renewable hydrogen market. Project developers face a broader set of challenges, including policy uncertainty, difficulties securing bankable offtake agreements, the cost gap between renewable and fossil-based hydrogen, high electricity prices, electrolyser capital costs, infrastructure bottlenecks, permitting delays and grid access constraints. 

“Our modelling shows that the effects of RFNBO regulatory changes extend beyond the cost and volume of hydrogen production. Changes to additionality and temporal correlation can negatively impact renewable energy investments, emissions, and electricity prices, with increases as high as 5 eur/mwh in some of the Member States. These interactions are important when assessing potential reforms to the framework,” said Noémie Bidoul, Energy and Climate Change Consultant, CLIMACT. 

Relaxing key safeguards could increase greenhouse gas emissions 

The study also finds that simultaneously relaxing additionality and temporal correlation requirements could lead to more than 15 Mt of additional greenhouse gas emissions in the EU in 2035, even under a modelled net-zero trajectory. That is equivalent to the annual footprint of 1.67 million EU citizens, based on Eurostat data. Lower renewable electricity investment and greater reliance on existing grid electricity, including marginal fossil generation, would increase the carbon intensity of hydrogen production during the transition period. 

The study’s authors note that the emissions impacts are concentrated around 2035 and decline later as electricity systems decarbonise and exemptions begin to apply. Because the modelling assumes a net-zero trajectory, the reported emissions impacts should be interpreted as conservative estimates of the risks associated with relaxing the rules. 

Study recommends maintaining safeguards and addressing wider market barriers 

Based on the findings, the study identifies several policy considerations for EU decisionmakers: 

• Consider wider energy system impacts before changing RFNBO requirements. Policymakers should assess the potential effects of regulatory changes on renewable energy investment and electricity prices, including the risk of shifting costs onto consumers. 
• Preserve the current additionality, temporal and geographic correlation requirements. These safeguards support investment in new renewable capacity, while their relaxation would not deliver a rapid increase in domestic renewable hydrogen production in the short term. 
• Address the wider barriers to renewable hydrogen deployment. Policy measures should include a strong and predictable EU carbon price, legally binding hydrogen uptake targets beyond 2030, support for hydrogen demand as well as production, and accelerated infrastructure development, including electricity grid upgrades. 

The study covers the EU27, Great Britain, Norway and Switzerland, with five-year investment steps through 2050.