EU low-carbon hydrogen: the buyer’s required category comes first

The EU’s final low-carbon-fuels methodology is in force. Regulation 2025/2359 was published on 21 November 2025 and took effect twenty days later. It sets the accounting method for demonstrating the required greenhouse-gas savings, including a 70% minimum threshold.

For a supplier, the commercial question starts with the buyer’s required product category. The Commission says the methodology complements renewable fuels of non-biological origin, or RFNBO, rules and does not determine the renewable share of electrolytic hydrogen. The Renewable Energy Directive governs that separate question.

The distinction already appears in procurement language. TotalEnergies describes separate planned quantities of green and low-carbon hydrogen for its Normandy refinery. For a buyer seeking supply against an RFNBO-specific obligation, the relevant evidence concerns the renewable-qualified product. The fact that different categories can be supplied from one industrial arrangement makes a precise product specification useful at the quotation stage.

The methodology also makes time-resolved input evidence relevant. Under its Annex, each individual accounting interval within an averaging period must meet the minimum 70% savings threshold. For electricity that is not fully renewable, emissions must be attributed using the applicable permitted method. A supplier therefore needs both a suitable product category and the records supporting its emissions calculation.

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