This report discusses on the implications of the EU's Carbon Border Adjustment Mechanism (CBAM) for imports of PtX products to the EU. PtX means essentially hydrogen based on electrolysis and its derivates. After providing an overview of the CBAM mechanism, its implementation phases and the roles and responsibilities of producers within CBAM, the report provides insights into the calculation of embedded emissions for PtX products, including examples for imported ammonia and crude steel.

This report answers a selection of questions raised by participants of a series of nine online workshops organized on behalf of PtX Hub International by Ecologic Institute, in collaboration with Oeko-Institut and adelphi between March and September 2023. In each workshop, between 20 and 120 stakeholders from the following countries took part: Colombia, Uruguay and Chile, Namibia, South Africa, Kenya, Algeria, Jordan, India and Vietnam. The paper complements our previous briefing 'EU requirements for renewable hydrogen and its derivatives', which provides an in-depth systematic analysis of the contents of these two delegated acts.

In 2023, the EU adopted regulations defining under which conditions green hydrogen is considered as fully renewable and the methodology to determine the GHG intensity of hydrogen and other PtX products. To discuss these requirements with stakeholders from third countries considering to export renewable hydrogen or derivates to the EU, the International PtX Hub organized a workshop series in 2023. Raffaele Piria coordinated the conception of these workshops and gave a presentation on the climate and energy policy context for the EU's hydrogen strategies and policies.

This briefing, co-authored by Raffaele Piria (Ecologic Institute), analyzes the contents of the two Commission Delegated Regulations (CDR, also known as delegated acts) adopted by the European Commission on 10 February 2023 and entered in force in June 2023: CDR 2023/1184 contains detailed rules on the conditions under which electricity used to produce hydrogen may be counted as fully renewable according to European Union (EU) law; CDR 2023/1185specifies a methodology to assess the greenhouse gas (GHG) emissions savings from renewable fuels based on hydrogen (so-called renewable fuels of non-biological origin, RFNBOs) and for recycled carbon fuels (RCFs).

In collaboration with the International PtX Hub, we analyzed the emerging EU and international regimes and develop recommendations on GHG accounting and PtX sustainability. In a series of bilateral online workshops, we provided guidance to policy makers and other stakeholders from Algeria, Chile, Colombia, India, Kenya, Jordan, Namibia, South Africa, Uruguay and Vietnam.