The Renewable Energy Directive established the EU’s renewable energy framework back in 2018. Its 2023 revision, often called RED III, defined the role of RFNBO and introduced specific targets for their use in industry and transport. Supplementing regulations (i.e. RFNBO Commission Delegated Regulations) define requirements for renewable electricity sourcing and GHG calculation methodology.
Now, with the regulatory framework in place, the focus has shifted from understanding the provisions to applying them consistently across real-world supply chains, connecting emerging production regions with European demand.
Are you looking for trusted certification support for your own project ? Click here to contact ISCC System
As a trusted, third-party independent certification system, ISCC bridges policy frameworks and the market by translating regulatory provisions into certification requirements, allowing credible sustainability claims. After nearly two years of RFNBO certification, cooperating Certification Bodies have issued over 48 certificates, covering hydrogen, ammonia, methanol, and methane across EU and non-EU supply chains. From this experience, five key takeaways stand out.
1. Electricity sourcing is the first viability consideration
The electricity sourcing scenario determines what evidence is required, so designing compliance is essential. Depending on the pathway, this can include Power Purchase Agreements, Guarantees of Origin, and requirements for additionality, temporal correlation, geographical correlation, and bidding zones.
2. GHG performance must shape supply-chain design
Electricity sourcing modes, carbon inputs, conversion routes, process energy, and logistics affect the fuel’s final carbon intensity, which must demonstrate at least 70% GHG savings. Compliance-ready projects treat emissions performance as an investment criterion from the pre-FEED stage.
Certification alone cannot resolve every challenge. It can, however, provide the common language, traceability, and evidence needed
3. Traceability makes RFNBO claims tradeable
Traceability, mass balance, and Proof of Sustainability and Proof of Compliance handling ensure RFNBO claims are verifiable across supply chains. The well-established traceability and chain-of-custody requirements applied under ISCC EU are now being extended to hydrogen and derivatives.
4. Pre-certification can support bankability
Pre-certification supports project de-risking by identifying possible gaps and demonstrating credible compliance pathways. While it does not replace certification, it can give investors, off-takers, and partners confidence in advance of operational evidence.
5. Real projects shape the frameworks in practice
Thanks to broad stakeholder dialogue and early pilot projects and audits, industry dialogue is helping refine ISCC EU audit approaches for more complex RFNBO pathways, including using RFNBO as intermediates in refinery processes. The same exchange of practical experience is also supporting further guidance on carbon dioxide sourcing and hydrogen-carrier conversion units, expected in October.
The electricity sourcing scenario determines what evidence is required, so designing compliance is essential
Turning ambition into a functioning market
Early experience points to three conditions for success: multistakeholder dialogue, practical implementation guidance, and certification systems that can respond to real-world market structures while safeguarding regulatory integrity.
Certification alone cannot resolve every challenge. It can, however, provide the common language, traceability, and evidence needed to connect EU policy with investment and international markets.
The task ahead is to use implementation experience to develop practical solutions that help the RFNBO market scale credibly and globally, in line with EU climate objectives.
Sign up to The Parliament’s weekly newsletter
Every Friday our editorial team goes behind the headlines to offer insight and analysis on the key stories driving the EU agenda. Subscribe for free here.
