Does CBAM apply to hydrogen?

Yes. Hydrogen under CN 2804 10 00 is one of the six in-scope CBAM sectors named in Annex I of Regulation (EU) 2023/956. The definitive period started 1 January 2026 and only the EU importer filing with the EU Registry may import hydrogen into the EU customs territory. Embedded emissions are calculated under Annex IV of Regulation (EU) 2025/2621.

Is there a minimum volume threshold for hydrogen under CBAM?

No. Hydrogen and electricity are the only CBAM sectors excluded from the 50-tonne-per-year de minimis exemption introduced by Regulation (EU) 2025/2083. Article 2(3a) of that regulation makes the carve-out explicit. Every shipment of CN 2804 10 00 triggers a declaration obligation regardless of annual import volume.

Does green hydrogen trigger CBAM costs?

Green hydrogen produced via electrolysis with verified renewable electricity reads €0 under the CBAM definitive phase. The CBAM definitive period covers direct (Scope 1) embedded emissions only for hydrogen under Annex IV, and electrolysis has no direct fossil combustion. The renewable PPA evidence chain must be on file: contract reference, smart metering at both ends, no grid congestion. Without that evidence, the importer falls back to the country default emission factor and pays accordingly.

Is ammonia covered as hydrogen under CBAM?

No. Ammonia (CN 2814) is the dominant hydrogen carrier in practice, but for CBAM purposes it declares under the fertilisers sector with Annex II methodology and its own default values. Pure hydrogen at the EU customs point declares under CN 2804 10 00 and Annex IV. The classification turns on the actual commodity at customs entry, not the upstream feedstock.

What happens when hydrogen is imported under inward processing?

Regulation (EU) 2023/956 Article 2(1) extends CBAM scope to the processed products that result from inward-processed hydrogen — synthetic gases, e-fuels, and other downstream chemicals — even when the downstream CN code is not itself separately listed in Annex I. The declaration obligation transfers to the processed-product output. The inward-processing flag must be set in the XML; missing the flag is one of the more common rejection reasons on the hydrogen scan.

Which countries are exempt from CBAM for hydrogen?

Hydrogen originating in Norway, Iceland, Liechtenstein, and Switzerland is CBAM-exempt because those four EFTA states are linked to the EU Emissions Trading System. No CBAM declaration is required for hydrogen produced in those territories. Hydrogen from every other non-EU origin is in scope, including Oman, Saudi Arabia, Egypt, Morocco, Algeria, Namibia, and Chile.

What default values apply when actual emissions data is unavailable?

Importers without verified actual emissions data use the country × production-route default values published under Regulation (EU) 2025/2621 Annex IV. A statutory markup applies: +10% in 2026, +20% in 2027, +30% from 2028 onwards. Grey hydrogen defaults sit around 9.0 tCO₂e per tonne of H₂ across most non-EU origins; blue hydrogen defaults at 1.5–2.0 tCO₂e per tonne H₂ with a 90% CCS capture assumption; green hydrogen defaults to 0.0 because Annex IV counts direct emissions only.

When is the first CBAM payment for hydrogen imports due?

The first annual CBAM declaration is due 30 September 2027, covering hydrogen imports made during calendar year 2026. Certificate surrender follows the same date. From 1 January 2026, only the EU importer filing with the EU Registry may import hydrogen into the EU customs territory. The certificate-obligation phase-in starts at 2.5% in 2026, ramps to 10% in 2028, and reaches 100% in 2034.

CN 2804 · HYDROGEN

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Default-value markup scheduleArt. 5(3) Reg (EU) 2025/2621

2026 default markupCurrent+10%above verified default

2027 default markup+20%above verified default

2028 default markup+30%above verified default

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Hydrogen

In scope

Hydrogen as an Annex I good from 2026. Default benchmark applies until verified actuals.

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All industries

Emission data · Validation

The published Annex I defaults for this sector, and the rules every XML is checked against before release.

Annex I default emission values

Country	Route	tCO₂e/t	CN
Turkey	GREY	10.82	2804 10 00
India	GREY	14.03	2804 10 00
China	GREY	26.64	2804 10 00
South Korea	GREY	14.03	2804 10 00
Ukraine	GREY	10.82	2804 10 00
Brazil	GREY	10.82	2804 10 00
Egypt	GREY	10.82	2804 10 00
Indonesia	GREY	10.82	2804 10 00

GREY hydrogen route shown. BLUE and GREEN routes pending official publication.

Source: Reg (EU) 2025/2621 Annex I · PDF-verified · carbonmandate.com

Validation rules applied to this sector

HY-01Declared CN code does not match 2804.10 (hydrogen) — verifier will reject.error

HY-02Root reportingPeriod element missing — required for every declaration.error

HY-03Producer EORI does not match member-state format pattern.warning

HY-04Total embedded emissions cannot be zero for declared production volume.error

HY-05calculationMethodId missing — Annex IV requires explicit declaration of method used.error

HY-06productionPathway missing — grey/blue/green pathway is mandatory for hydrogen.error

25 rules total · full rule set applied on every scan

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Sector boundary

Importing ammonia, not pure hydrogen?
Ammonia (CN 2814) sits in the fertilisers sector under Annex II, with its own default values and N₂O reporting rules.
Hydrogen-reduced iron / DRI?
Direct-reduced iron made with hydrogen reductant declares under iron and steel — CN 72 and CN 73, Annex IV.
Norway, Iceland, Liechtenstein, Switzerland?
EFTA states linked to the EU Emissions Trading System are CBAM-exempt. No declaration required for hydrogen originating in those four countries.

Inward processing

Hydrogen imported under inward processing pulls the processed products (synthetic gases, e-fuels) into CBAM scope, even when the downstream CN code is not separately listed. Regulation (EU) 2023/956, Article 2(1).

Regulatory calendar

The dates that move the liability.

Every deadline below is fixed by Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083. Plan verifier bookings, ACD applications, and supplier data collection against the regulatory calendar below — not the financial year.

1 Jan 2026Definitive period started—
31 Mar 2026Late ACD application deadline—
1 Feb 2027CBAM certificate purchasing opens—
30 Sep 2027First annual CBAM declaration due—

Source: Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083

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No 50-tonne exemption for hydrogen.

Hydrogen and electricity are the only CBAM sectors excluded from the de minimis exemption. Every shipment counts, regardless of volume. (Regulation (EU) 2025/2083, Article 2(3a).)