The regulatory future of renewable hydrogen has returned to the forefront of European debate. A group of 170 companies from across the energy value chain has called on the European Commission to maintain the binding targets and mandates for non-biological renewable fuels (NBRFs) established in the RED III Renewable Energy Directive beyond 2030 .
The letter was addressed to the President of the European Commission, Ursula von der Leyen ; the Executive Vice-President, Teresa Ribera ; and Commissioner Dan Jørgensen , with a specific message: the industry agrees to review and improve the framework, but not to eliminate the mandatory demand signal .
The central argument is economic and related to regulatory confidence. Companies maintain that weakening the targets after 2030 would mean changing the rules when a large part of the investment decisions have already been made based on that framework.
Europe currently has over €15 billion committed to hydrogen applications for the end user , while regional investment grew by around 35% over the past year .
In addition, there are more than 4 GW of electrolysis capacity under construction , a growth that the industry links mainly to the implementation of the Network III transport objectives.
“Weakening renewable hydrogen targets now would mean changing the rules mid-game,” warned Jorgo Chatzimarkakis, executive director of Hydrogen Europe.
According to the sector, achieving the current NETWORK III targets by 2030 could still mobilize between €50 billion and €60 billion of additional investment , as well as avoiding around 30 million tons of CO₂ per year .
The discussion, therefore, is not limited to the volume of hydrogen produced.
For the signatory companies, maintaining binding targets is also a signal of Europe's ability to offer predictability to industrial projects with long-term investment horizons.
The industry acknowledges that the current framework needs adjustments.
Among the demands are improvements in implementation, greater coordination with member states, stronger support mechanisms, and conditions that allow for the achievement of industrial objectives with greater economic viability.
But he differentiates that discussion from a possible elimination of the goals.
“ Europe needs investment. Investment needs certainty. Certainty requires binding RFNBO targets ,” summarized François Paquet, CEO of the Renewable Hydrogen Coalition.
Up to an additional €60 billion depends on the regulatory signal.
The industry's concern stems from the need to maintain a stable benchmark for projects that still face high costs, insufficient infrastructure, and nascent demand.
The companies warn that withdrawing the mandates would not represent regulatory simplification, but could generate a strong disruption to initiatives developed over the last six years.
The fear is that the first projects that took greater technological and commercial risks will be penalized in the face of future investments.
The letter also links hydrogen to other challenges facing the European energy system.
Companies believe this technology can complement direct electrification, provide seasonal storage, grid flexibility and a way to reduce curtailment , as well as supply industrial processes where completely replacing molecules with electricity is more complex.
The industry also argues that the debate should be interpreted in terms of competitiveness.
At a time when Europe is seeking to attract capital for new clean industries, a sudden change in objectives could reinforce precisely one of the problems identified by market players themselves: the lack of predictability for long-term investment decisions.
Ivana Jemelkova, executive director of the Hydrogen Council, argued that maintaining the mandates beyond 2030 would send “ a clear signal that Europe can offer the certainty that investors require .”
The debate thus reaches a sensitive stage for European hydrogen.
With over €15 billion already committed, 4 GW of electrolysis under construction, and up to an additional €60 billion associated with meeting current targets, the discussion on RED III is beginning to define not only post-2030 climate ambition, but also the degree of confidence investors can have in the long-term rules of the game in the European market.
