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Renewable hydrogen and ERE-R

Hydrogen generates ERE-R when it is demonstrably certified as an RFNBO and supplied to Dutch transport. Calling it 'green hydrogen' is insufficient.

17 September 2026·PYK Power·3 min read
Energy installations and storage

Which hydrogen qualifies?

RFNBO stands for renewable fuel of non-biological origin. Hydrogen made by electrolysis must meet European conditions covering the electricity and production process. These include the electricity source and, depending on the chosen route, the relationship between generation and hydrogen production in time and location.

The fuel must also achieve at least 70% greenhouse gas emissions saving across the full chain. A green electricity contract or a separate guarantee of origin does not prove compliance with all RFNBO requirements. Grey or blue hydrogen does not qualify for this ERE-R route.

The certified supply chain provides proof of renewability. This states the quantity and emissions value used for booking.

From refuelling point to ERE-R

Under the normal refuelling station route, the booking party holds the environmental permit for receiving, storing and selling hydrogen. Each vehicle connection has its own meter. The hydrogen must demonstrably have been supplied to transport in the Netherlands.

The booked quantity cannot exceed the measured supply and must be fully covered by proof of renewability. If 1,000 kg was supplied but only 800 kg is certified, no more than 800 kg can be booked. Equally, a certificate covering more kilograms than the meter records cannot increase the physical supply.

The NEa requires the upstream supply chain to be RFNBO-certified. The booking party operating a refuelling station does not always need its own certification. A party that also produces hydrogen or operates as a certified supply-chain participant must meet the associated mass balance and evidence requirements.

A separate route exists for certified producers delivering hydrogen containers to inland or seagoing vessels. It requires records including the quantity delivered, proof of renewability and vessel details.

The calculation

For hydrogen, the REV uses:

ERE-R = kg hydrogen × 120 × (94 − lifecycle emissions) / 1,000

Lifecycle emissions are stated in grams CO₂-equivalent per MJ on the proof of renewability. The factor 120 is the energy content in MJ per kg. The destination determines whether LRE-R, BRE-R or ZRE-R is generated. There is no fixed number of units per kilogram regardless of production method.

Hydrogen used in a refinery

A Dutch refinery can, under conditions, receive RARE units for RFNBOs used as intermediates in transport fuel production. This is a separate route with its own certification and records.

The same reduction cannot both generate RARE units and lower the calculated lifecycle emissions of the resulting biofuel. Establish the chosen route before booking and ensure the evidence is used only once to generate units.

Sources

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