Grey, blue, or green — the CBAM cost of imported hydrogen depends entirely on its production pathway. Grey hydrogen from SMR carries one of the highest emission factors of any traded commodity.
Calculate my CBAM cost →| Type | Production method | Embedded emissions | CBAM impact |
|---|---|---|---|
| Grey H₂ | SMR from natural gas, no CCS | 9 – 12 tCO₂e/t H₂ | High — ~€600–800/t at €67.50/tCO₂ |
| Blue H₂ | SMR + carbon capture (85–95%) | 0.5 – 2 tCO₂e/t H₂ | Low — ~€35–135/t |
| Green H₂ | Electrolysis with renewable electricity | ~0.3 – 0.9 tCO₂e/t H₂ | Very low — ~€20–60/t |
| Turquoise H₂ | Methane pyrolysis (solid carbon by-product) | ~1 – 3 tCO₂e/t H₂ | Low-moderate |
Cost estimates at EU ETS price of €67.50/tCO₂. Actual CBAM costs require verified emission declarations.
Only hydrogen classified under CN 2804 10 is covered. Hydrogen derivatives such as ammonia (CN 2814) and methanol are covered under their own product categories, not as hydrogen derivatives.
Whether the hydrogen is imported as high-pressure compressed gas or as cryogenic liquid hydrogen (LH₂), it falls under CN 2804 10. The CBAM obligation applies to the total mass of H₂ content.
Under EU rules, Renewable Fuels of Non-Biological Origin (RFNBO) certification demonstrates that the hydrogen was produced using renewable electricity. This certification pathway, linked to the Renewable Energy Directive, supports the use of near-zero emission factors for CBAM purposes.
For grey and blue hydrogen, upstream methane leakage from natural gas production and transport must be included in the embedded emission calculation. High-leakage gas supply chains (e.g. from certain Russian or older infrastructure) can add 2–4 tCO₂e/t H₂ to the declared figure.
Grey hydrogen (SMR without CCS) carries approximately 9–12 tCO₂e per tonne of H₂. The EU Commission default is around 10 tCO₂e/t. This is one of the highest emission factors per tonne of any CBAM commodity, reflecting the carbon intensity of the steam methane reforming process.
Yes — all hydrogen under CN 2804 10 is in CBAM scope. However, green hydrogen produced via electrolysis using certified renewable electricity has near-zero embedded emissions (~0.3–0.9 tCO₂e/t for minor process and upstream emissions). Importers can use the verified actual emission factor, making green hydrogen CBAM costs very low.
Blue hydrogen uses CCS to capture 85–95% of CO₂ from the SMR process. The residual 0.5–1.5 tCO₂/t (plus any methane leakage) must still be declared. CCS verification and methane leakage audit are key requirements for demonstrating a low embedded emission factor for blue hydrogen imports.
Hydrogen is covered under CN 2804 10. This is the only CN code for the hydrogen sector in CBAM Annex I. Both compressed and cryogenic liquid hydrogen fall under this classification.
Compare grey vs. blue vs. green scenarios and quantify the CBAM advantage of low-carbon hydrogen sourcing.
Open Hydrogen CBAM Calculator