Sectors
Hydrogen
Hydrogen under CBAM at CN 2804 10: SMR vs electrolysis vs partial oxidation, the synthesis-gas carve-out and hydrogen as a precursor.
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Direct answer
Hydrogen falls within CBAM at CN 2804 10. Embedded emissions vary by an order of magnitude across production routes: steam methane reforming (SMR) of natural gas sits at roughly 9-11 tCO2 per tonne of H2; partial oxidation of heavier hydrocarbons higher; coal gasification higher still; electrolysis varies from near zero (renewable power) to grid-average levels depending on the electricity factor. Synthesis gas (syngas) is not in scope as such; only the pure hydrogen line is.
What is covered
Hydrogen in scope is the single CN line 2804 10 00 (hydrogen of Chapter 28). Mixtures with other gases that are not pure hydrogen, including syngas and ammonia synthesis gas streams that have not been separated, are not within this line. The covered goods checker maps a CN code to its scope status.
Hydrogen1
2804Hydrogen1
2804 10Hydrogen1
- 2804 10 00Hydrogen
Hydrogen: process schematic
SourcesAll hydrogen production routes are in scope; emissions depend on feedstock and on the electricity emission factor for electrolysis.
Implementing Regulation (EU) 2023/1773, Annex IV (hydrogen)
Production routes drive the emissions intensity
SMR is the dominant industrial route and the reference for the default value. Autothermal reforming (ATR) and partial oxidation (POX) have similar or higher direct emissions. Coal-gasification hydrogen is higher again. Electrolytic hydrogen carries little direct emissions on site, so the embedded total is driven by the indirect emissions of the electricity input. SMR with CCS lowers the direct factor in proportion to the captured share, subject to verified permanent storage. Methane pyrolysis (turquoise) produces solid carbon and avoids most direct CO2.
Synthesis gas carve-out
Syngas (mixtures of H2 and CO) used as a process intermediate is not listed under CN 2804 10 and is therefore outside CBAM scope as a traded good. When a downstream installation separates pure hydrogen from syngas for sale, the pure hydrogen falls within CN 2804 10 if subsequently imported. The embedded emissions of an ammonia or methanol plant include the upstream syngas step as part of the installation's own boundary.
Hydrogen as a precursor in other CBAM goods
Hydrogen is a precursor in ammonia, methanol-based fertilisers and DRI/HBI steel. The embedded emissions of the hydrogen feedstock flow into the embedded emissions of the downstream good through the installation's attribution methodology. A change of hydrogen route (SMR to electrolysis) at the upstream installation propagates into the downstream fertiliser or steel installation's emissions factor.