CBAM by sector

CBAM and Hydrogen

Hydrogen is one of the six sectors covered by the EU Carbon Border Adjustment Mechanism (CBAM). Crucially, hydrogen has no 50-tonne de-minimis exemption: if you import hydrogen at any volume, you are in scope. CBAM counts the direct emissions embedded in producing it. This page explains what is covered and what to do.

Hydrogen

Direct emissions · No exemption

TL;DR

  • Hydrogen is in scope under Regulation (EU) 2023/956, defined by its CN code in Annex I.
  • There is no 50-tonne de-minimis exemption for hydrogen — it is covered at any volume.
  • Embedded emissions for hydrogen are counted as direct emissions from its production.
  • Because there is no threshold, even small hydrogen imports trigger authorisation, declaration and surrender obligations.
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In scope

What CBAM covers for hydrogen

  • Hydrogen (the gas itself), as listed by its CN code in Annex I.

Hydrogen is a single, narrowly defined entry — but unlike the four mass-counted sectors, there is no minimum volume below which you are exempt.

These products are listed in Annex I of Regulation (EU) 2023/956 by their CN code, so you confirm scope by matching your product code, not the product name alone. Use the goods & CN-code reference to check a specific code.

Emissions

How embedded emissions are counted

Emissions are counted as direct emissions. For hydrogen, CBAM counts the direct emissions from production. The carbon intensity depends heavily on the production route — for example, hydrogen made from natural gas without carbon capture has very different embedded emissions from low-carbon routes. Regulation (EU) 2023/956

Actual, verified emissions data is preferred and usually cheaper than the conservative default values. Where you cannot get verified figures, you can fall back to the published default values, which carry a mark-up. See the CBAM default-values reference for the figures and mark-up rates.

The 50-tonne threshold

Does the de-minimis exemption apply?

No exemption: hydrogen is in scope at any volume

CRITICAL: hydrogen has NO 50-tonne exemption. Unlike steel, aluminium, cement and fertilisers, hydrogen is covered at any volume. The cumulative 50-tonne mass threshold does not apply to it at all. 2025 Omnibus, Regulation (EU) 2025/2083

Use the scope checker to confirm your position.

The hard part

The hard part for hydrogen

  • No exemption: there is no minimum volume, so even occasional or small hydrogen imports bring full obligations.
  • Production route matters: embedded emissions vary enormously between conventional and low-carbon hydrogen, so the emissions data you use is decisive for cost.
  • Authorisation lead time: because you are in scope immediately, you need authorised CBAM declarant status before importing — and assessment can take up to 120 days.
  • Obtaining verified production data from suppliers for a product whose footprint is highly route-dependent.

What to do

What to do for hydrogen

  1. Recognise that you are in scope from the first kilogram — there is no 50-tonne grace.
  2. Become an authorised CBAM declarant (or use an indirect customs representative who is) before importing; allow up to 120 days for the National Competent Authority’s assessment.
  3. Establish the production route and gather actual, verified embedded-emissions data, or fall back to the published default values.
  4. File your annual CBAM declaration and surrender certificates by 30 September of the following year.

For the roles and how to apply, see the CBAM declarant guide; for when you need a verifier, see CBAM verification; and for collecting data from suppliers see the supplier data guide.

FAQ

Hydrogen and CBAM: common questions

Does the 50-tonne CBAM threshold apply to hydrogen?
No. Hydrogen has no de-minimis exemption. Unlike steel, aluminium, cement and fertilisers, hydrogen is covered at any volume under Regulation (EU) 2023/956, even after the 2025 Omnibus simplification.
Are indirect emissions counted for hydrogen?
CBAM counts the direct emissions from hydrogen production. The embedded emissions depend strongly on the production route, so the data you provide — actual or default — is what drives your obligation.
Do I need to register as a declarant to import any hydrogen?
Yes. Because there is no volume threshold, importing hydrogen in the definitive period (from 1 January 2026) requires authorised CBAM declarant status. Apply via the CBAM Registry’s Authorisation Management Module and allow up to 120 days for assessment.
When is the first CBAM obligation for hydrogen due?
For 2026 hydrogen imports, the first annual declaration and certificate surrender is due 30 September 2027, the same as the other CBAM sectors.

Get ready for CBAM

Work through the CBAM Readiness Checklist, then explore the tools and guides built for your role.

Get the CBAM Checklist

This is guidance, not legal advice

This is guidance to help you understand how CBAM applies to hydrogen, not legal advice. For decisions specific to your business, confirm with the official sources we link or a qualified adviser. Some details remain subject to pending implementing acts; where the rules are unsettled we say so.

Sources

  1. [1]Regulation (EU) 2023/956, consolidated text including Annex I (EUR-Lex)retrieved 8 Jun 2026
  2. [2]European Commission (DG TAXUD): Carbon Border Adjustment Mechanismretrieved 8 Jun 2026
  3. [3]DG TAXUD: Simplifications for CBAM (Regulation (EU) 2025/2083)retrieved 8 Jun 2026
  4. [4]EUR-Lex: Carbon Border Adjustment Mechanism (summary)retrieved 8 Jun 2026

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