CBAM Hydrogen Default Values: 5.28 tCO2/t and the Route-Specific Reality
The CBAM default value for hydrogen is approximately 5.28 tCO2e per tonne — a number that sits awkwardly between the actual emissions of grey hydrogen (which are higher) and the actual emissions of blue or green hydrogen (which are dramatically lower). This makes the hydrogen default unique in CBAM: it can either save or cost producers depending on their actual production route.
What the Hydrogen Default Costs
Cost per tonne of hydrogen imported at the 5.28 default:
| ETS price (EUR/tCO2) | CBAM cost per tonne of hydrogen |
|---|---|
| EUR 50 | EUR 264 |
| EUR 65 | EUR 343 |
| EUR 80 | EUR 422 |
| EUR 100 | EUR 528 |
Hydrogen trade volumes are small today but growing as Europe pursues hydrogen import strategies. The CBAM cost differential between routes determines which exporters win those import contracts.
The Hydrogen Default is the Wrong Number for Most Producers
Unique to hydrogen: the default is genuinely between the dominant production route (grey, ~10 tCO2e/t) and the strategic-future routes (blue at 2.5, green at 0.3). This means:
- Grey hydrogen producers who document actual values truthfully will face higher CBAM costs than under the default. Many will simply not document and pay the default.
- Blue and green hydrogen producers who document actuals will face far lower CBAM costs than the default. The CBAM economics are a strategic argument for the route shift.
This creates an unusual moral hazard: the default lets dirty producers off lightly. The EU Commission is aware of this and the hydrogen default is among the most likely to be adjusted downward as the regulation matures.
Replacing the Default for Green and Blue
For producers in the favourable position (blue or green), the path is the same as other sectors:
- Calculate per Annex III, including the hourly renewable matching for green hydrogen claims. See the CBAM hydrogen calculation guide.
- Verify with an ISO 14065 accredited body that has experience with hydrogen-specific calculations.
- Store the verified record. The vault URL is what your EU buyer cites in their CBAM declaration. Store your record.
Frequently Asked Questions
What is the CBAM default value for hydrogen?
Approximately 5.28 tCO2e per tonne under CN code 2804. The exact published value should be checked in the latest Implementing Regulation 2023/1773 amendment.
What does the hydrogen default cost per tonne in EUR?
At the current EU ETS price band (~EUR 65/tCO2), approximately EUR 343 per tonne of hydrogen. At EUR 100/tCO2, EUR 528 per tonne.
Why is the hydrogen default lower than grey hydrogen actuals?
The default is the global production weighted average across grey (dominant), blue, and green. Most grey hydrogen plants emit 9–11 tCO2e/t, well above the 5.28 default. The default lets grey producers off lightly relative to their actual emissions.
Is the hydrogen default likely to be revised?
Yes — it is among the most likely to be adjusted as the CBAM regulation matures and as the EU pursues stricter hydrogen import standards aligned with the Renewable Energy Directive (RED III) and Hydrogen and Decarbonised Gas Markets Package.
Does CBAM accept third-party hydrogen certification schemes (e.g. CertifHy)?
Third-party certification schemes can support the verification but do not replace the CBAM-specific calculation and ISO 14065 accredited verification requirement. Producers should plan for both: their certification scheme for marketing claims, and a CBAM-specific verification for customs declarations.
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