Today's hydrogen is a carbon product: SMR emits ≈9–11 t CO2 per tonne H2. CBAM covers hydrogen from day one, EU RFNBO rules define «green», and the delta between grey, blue and green is the whole economics of the energy transition's favourite molecule. For the reporting desk that means: which frameworks bite, which KPI to disclose, and which completed measure to show. Here is the hydrogen production profile.
| Framework | Applies to hydrogen production? |
|---|---|
| EU ETS (if EU site) | Yes — full free-allocation phase-out applies |
| CBAM (if exporting to EU) | Yes |
| SECR (if large UK company) | Yes — energy, Scope 1+2, intensity ratio, efficiency actions |
| ESOS (if large UK undertaking) | Yes — audit by 5 Dec 2027 (Phase 4) + public action plan |
| CSRD / ESRS E1 (if large EU company) | Yes — actions (E1-3), targets (E1-4), energy (E1-5), Scope 1-3 (E1-6) |
| Customer SBTi / CDP requests | Sector-independent — arrives with the RFQ |
The intensity ratio your sector benchmarks against: ≈9–11 t CO2/t H2 (grey SMR; IEA). SECR requires an intensity metric of your choice; ESRS E1-5 wants energy per net revenue; CBAM (where in scope) uses exactly t CO2 per tonne of product. Reporting the same physical KPI everywhere keeps the numbers reconcilable — and auditors happy.
~100% of hydrogen production CO2 is fuel-side — the share efficiency measures can touch. Heat-loss surveys typically recover 2–5% of fuel use, i.e. 2.0–5.0% of this sector's total CO2, at up to-2-year payback. Worked example at a 50,000 t H2/yr site (≈450,000 t CO2/yr at the benchmark intensity): an insulation programme is worth 9,000–22,500 t CO2e/yr — a complete, verifiable entry for SECR disclosure 4, an ESOS progress update, ESRS E1-3 and the tender CRP, plus €696,600+ off the carbon bill where ETS/CBAM applies.
Generate exact figures for your own kW finding: Carbon Savings Certificate → · sector decarbonization pathway: Hydrogen production →
