May 2024

eFuels: Navigating the EU’s complex

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regulatory landscape
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Content 1. Introduction to Ramboll

2. Requirements and certification of eFuels

3. Funding options

4. Needed and expected developments

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 Anna Pekala Kamil Raad
Market Director Consultant
Ramboll Management Consulting Ramboll Management Consulting
ap@ramboll.com klrd@ramboll.com

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 RAMBOL
L

About Ramboll
We work in multidisciplinary teams
across seven markets:

We are an independent engineering, architecture, and consultancy company

founded in Denmark in 1945.
Across the world, Ramboll combines local experience with global knowledgebase
to create sustainable businesses and societies. Environment
Buildings
& Health
We combine insights with the power to drive positive change to our clients, in
the form of ideas that can be realised and implemented.

We call it: Bright ideas. Sustainable change. Management

Water
Consulting

300 18,000 2.25 B Energy Energy

Global offices in Employees Global revenue, in 2020

35 countries across all markets

Architecture
& Landscape
Supporting the energy transition is at the core of Ramboll’s
strategic ambitions

We work on accelerating
the Green Energy
Transition: Renewables
and new technologies

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Ramboll offers a unique mix of technological, commercial and global
expertise within PtX and eFuels
We know the
technology
• Ramboll is a world-leading advisor in the
green fuels sector and energy transition
• Deep technical knowledge of systems
and technologies within green fuels
• At the forefront of the development of
current and future technologies
• Deep understanding of the green transition
and the potential measures (incl. their
limitations)
• We provide future-fit and highly accurate
recommendations
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We work across the entire
value chain
• We work across the entire value chain of
sustainable fuels production
• We cover sourcing of biomass and
renewable power, logistics, process and
operation, to value creation and end-use
• We work as a trusted technical and strategic
advisor for various stakeholders including
various governmental bodies and regulators
• We can advise on how to best plan, procure
and manage the implementation and
operations of alternative fuels
We understand all the commercial
and environmental aspects
• 500+ specialised management consultants
collaborating closely with technical experts
• We know energy markets, incl. trends,
drivers, challenges, business models, and
prerequisites for operational excellence
• We also understand and have insights on the
regulatory environment (globally and locally)
and how it impacts projects commercially
• Environmental experts support clients with
multimedia and multi-agency permitting and
compliance support
Our experience is
global
• Ramboll has global expertise combined with
in-depth market insights and understanding
through our strong local presence
• Our global footprint gives us in-depth
knowledge about market conditions, sector
connections and local industry dynamics
and practices (incl. business cultural
dimensions)
• We use this to provide geographic and
industry-specific recommendations
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Requirements for
eFuels

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Broadly, alternative fuels can be grouped under two
categories
Today’s focus

eFuels are fuels that are produced from renewable or

decarbonised electricity. Through electrolysis, water is
split into hydrogen and oxygen using electricity.
Depending on the desired end-product, nitrogen or
POWER-TO-X carbon dioxide can be added in a synthesis to produce
products in either gas or liquid form.
POWER-TO-X

Green
fuels
Biofuels are any fuels that are made from biomass –
BIO-TO-X
known as the feedstock. The feedstocks are feed into a
BIO-TO-X WASTE-TO-X bioenergy conversion to form biogas from anaerobic
digestion, fermentation, gasification or other.

WASTE-TO-X

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The drive to decarbonise hard-to-abate sectors using
eFuels requires a clear legislative framework
Three key legislations provide some clarity in the EU…
Renewable Energy Directive (RED)
• Sets the EU’s renewable energy
target at 42.5% by 2030
• Defines transport and industry sector
targets for the adoption of eFuels
• Defines eFuels requirements in
Delegated Acts
• Defines eFuels as renewable fuels
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Hydrogen and Decarbonised Gas Market
Package
• Facilitates integration of eFuels into
framework for gas networks
• Covers eFuels made from non-
renewable energy
• Details are pending the release of
related Delegated Acts
• Defines eFuels as “low-carbon fuels”
…but some pieces are missing, and complexity exists on a global level
EU Taxonomy
• Enables sustainable investments by
defining sustainable activities
• Drives financing in sustainable
activities aligned with its
requirements
• Imposes requirements on the
manufacture of hydrogen and its
derivatives
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Who and when will be subject to diverse regulatory and
policy frameworks within eFuels?
PRODUCERS
• Producers should prepare to meet the EU’s
production criteria, such that the eFuels can
be certified
• While offering regulatory compliance,
certificates can also increase the
attractiveness of the fuel in the market
• Funding and subsidy schemes will be
connected to the production of eFuels that
meet regulatory criteria
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INVESTORS
• As investors seek to align with various
regulatory and policy frameworks, they
will seek to invest in activities that align
with underlying regulation and comply
with production requirements set by the
EU Taxonomy
• To gain access to funding, producers will
need to ensure the manufacturing of
eFuels is also EU Taxonomy aligned
OFF-TAKERS
• To comply with sector specific regulation,
off-takers will need to prove eFuels meet
the sustainability criteria, i.e. they will
need to document certifications that
meet regulatory criteria
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The uptake of eFuels across sectors is driven by the key
legislation through targets and requirements
Manufacturing Transport Power & Heat

Industry Aviation Maritime Road Utilities

Renewable Energy Directive (RED)

Hydrogen and Decarbonised Gas Market Package

EU Taxonomy

ReFuel EU Aviation Fuel EU Maritime

Players across sectors may also need to
consider and align with other standards such as
the GHG Protocol

Other sector-specific
legislation also drives uptake

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Production can align with one of the three key Based on the framework you want to align
with, different requirements must be met
pieces of legislation based on strategic
ambitions:

Hydrogen and Decarbonised Gas Energy source H2 Derivatives, GHG threshold

1
Market Package
1 2 3 1 2 3

Non-
Renewable electricity Source 28 gCO2e/MJ 28 gCO2e/MJ 28 gCO2e/MJ
renewable
and specific source requirements agnostic (70%) (70%) (70%)
sources
Renewable Energy Directive
2
(RED)
Oxygen Nitrogen
Electrolysis Synthesis
O2 N2 NH3

Ammonia
3 EU Taxonomy

CH3
CxHy
OH
Production criteria define requirements which Methanol Kerosene
H2
need to be met for eFuels to fall under a (jet fuel)
certain category Excess heat Excess heat

Water (H2O) Hydrogen, GHG threshold1 CO 2

1 2 3 1 2 3 1 2 3

Awaiting Identify & 28 gCO2e/MJ 28 gCO2e/MJ 25 gCO2e/MJ Awaiting

final N/A address (70%) (70%) (73.4%) N/A2 N/A
final reqs.
reqs. risks

Ramboll Notes: 1Thresholds do not refer to input hydrogen but to hydrogen as a final product; 2Source of CO2 will impact GHG calculation 12
RED aligned eFuels | To classify as renewable, fuels need to
meet source and GHG requirements
Definition
RED aligned eFuels are labelled under Article 2(36) of RED as ‘liquid and gaseous
fuels […] derived from renewable sources other than biomass’ (RFNBOs).
Regulation status
Regulation is active and the RFNBO DAs were adopted on June
14, 2023. Fuels can be produced according to the requirements.

Source requirements GHG requirements

Where electricity is sourced from a directly connected GHG emissions over the lifecycle of the RFNBO need to be under 28.2
installation: gCO2e/MJ1
- The connected installation came into place within 36
months of the fuel production facility
- It is connected by a direct line or takes place in the same H2 NH3
installation
CH3 CxH
OH
Where electricity is taken from the grid: Y

- The bidding zone the production facility is in, had over

90% renewable electricity the previous year Transport and
Input Processing Combustion
- The bidding zone’s emission intensity is below 18 distribution
emissions emissions emissions
gCO2e/MJ and a renewables PPA is signed emissions
- Or, the electricity is consumed during an imbalance
settlement period with conditions met
- Or, a PPA is signed and additionality, geographical and Input CO2 can impact
temporal correlation requirements are met – exemptions Captured carbon that is geologically
emissions calculation
apply to operations beginning before 1 January 2027 stored throughout the lifecycle

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eFuels Certification | As the regulatory basis comes into
place, producers will have to certify their fuels
Regulatory basis
1 2 3

Gas Market Package RED EU Taxonomy

Certification scheme Member

Recognise,
supervise States
National
Accreditation
Board
Scheme rules Scheme Operator

Train, accept, Supervise &

& supervise monitor

Certification bodies (Auditors)

Issue certification

Fuel producer

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eFuels Certification | Approval of a voluntary scheme is still
pending in the EU
Current status of certification Voluntary schemes

• Voluntary schemes are schemes developed independently but recognised by The European Commission

The European Commission has not yet approved a • The European Commission can recognise them as compliant with Renewable Energy Directive.
certification scheme for eFuels.

Voluntary schemes on the market Status

This causes several challenges
ISCC (extension of the scope to also RFNBOs and
Producers are unable to gear up to supply certified Applied
RCF)
RFNBOs

CertifHy (RFNBOs) Applied

Several countries developing their own temporary

solutions REDcert (RFNBOs) Applied

KZR INiG System (extension of the scope to also

Increased uncertainty in the market caused by each Applied
RFNBOs and RCF)
country implementing its own rules
CCEE Hydrogen and Derivatives Certification System
Applied
(RFNBO)
While applications are pending, National
Schemes are acting as placeholders such
as the Danish GO scheme
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Funding

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Several funding options are available to The complexity of the funding
support the deployment of eFuels landscape requires good preparation

Two major mechanisms

Map your current project,
1 planned design and strategic
targets
Scope Budget Dates

RFNBO Pilot: 720 mEUR awarded Pilot results released Assess options, requirements
Hydrogen Bank
Hydrogen 2nd round: 2.2 bnEUR 2nd round Q4 2024 2 and any restrictions that exist

Net-zero Call for proposal Review requirements in detail,

Innovation Fund 4 bnEUR 3 engage with EU bodies and
Technologies closed 9th of April
begin to prepare submission

Multiple options exists beyond these such as the Horizon Europe Clean
Hydrogen Partnership, free allowances under the EU ETS, among others…

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Needed & expected
developments

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Expected developments in 2024

Development Description Timing

Hydrogen and Decarbonised Gas

Market Package Delegated Act
• Finalises details and requirements on the outstanding fuels category Q4

Certification scheme approval

• Better understanding of methodologies and certainty on requirements
• Harmonisation of rules to encourage cross-border trading Q3

US and global requirements

• Final version of the US requirements for green hydrogen
• Alignment with EU certifications and standards will afford cross-border trade Q3

• The results of the Pilot auction for the Hydrogen Bank were released on the 30th of
Upcoming auctions April 2024 and contracts should be signed by November 2024
• The second round of the Hydrogen Bank will be launched by the end of the year
Q4

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Our advice

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Our advice to all eFuel stakeholders

Prepare

Embrace

Stay updated

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