CBAM for hydrogen: proof beats colour
Hydrogen is one of the six CBAM sectors and is excluded from the 50-tonne threshold, so every tonne is declared. With no Türkiye-specific value, imports without actual data fall back to the 'other countries' default.
No de minimis
Like electricity, hydrogen is excluded from the annual 50-tonne threshold. Even small volumes need a declaration and certificates.
Direct emissions only
For hydrogen, CBAM counts direct emissions only; electricity used for electrolysis is not included for now.
A very high default
Without a Türkiye-specific value, 17.740 tCO₂e/t applies, plus a mark-up of 10 % in 2026 and 30 % from 2028. Grey hydrogen from steam reforming is usually well below that.
Your sector in numbers
CBAM cost per tonne for goods from Türkiye, based on the EU default value and benchmark at the Q3 2026 certificate price (€82.32/tCO₂e).
| Indicator | Value |
|---|---|
| EU default value (Türkiye) | 17.740 tCO₂e / tonne |
| with the 10 % mark-up in 2026 | 19.514 tCO₂e / tonne |
| Benchmark | 5.089 tCO₂e / tonne |
| Cost per tonne in 2026 | €1,197.94 |
| Cost per tonne in 2030 | €1,682.72 |
| Cost per tonne once free allocation ends (2034) | €1,898.46 |
Worked example
An importer buying 1,000 tonnes of hydrogen a year from a steam reforming plant in Türkiye.
Where do the emissions come from?
Hydrogen is often produced inside ammonia, refinery or methanol plants; the calculation must be separated by unit.
- Natural gas as feedstock and fuel in steam methane reforming
- Combustion emissions of reformer furnaces
- Process CO₂ released in the water gas shift
- Captured and permanently stored CO₂ (deductible if documented under the rules)
- Electricity for electrolysis (not counted under CBAM for now)
What CO₂ Manager and our team do
Unit-level values
Separates hydrogen from ammonia, refinery and methanol production and calculates embedded emissions per tonne.
Proof instead of colour
Documents grey, blue and green production and keeps source records for renewable hydrogen.
Hydrogen as a precursor
Carries the emissions of hydrogen used in ammonia and fertilisers into the right product.
Audit-ready trail
ISO 14064-1 inventory and CBAM data from the same dataset.
Frequently asked questions
Is green hydrogen counted as zero?
Electricity used for electrolysis is not counted under CBAM for now, so the direct emissions of electrolytic hydrogen are very low. This only counts with actual, verified data.
We use hydrogen to make ammonia. Does CBAM apply?
In that case hydrogen is a precursor; its emissions are added to the embedded emissions of the ammonia, which is covered as a fertiliser.
Why is there no Turkish default value?
The Commission uses the 'other countries' value where country data was insufficient. As this value is high, declaring with actual data makes a large difference.
First your obligations, then your costs
Find out in two minutes whether EU ETS or CBAM applies to you, then calculate the carbon cost for your product and volume. We help you replace estimates with real data.
Sources: Regulation (EU) 2023/956; Implementing Regulations (EU) 2025/2620, 2025/2621 and 2026/1740; European Commission CBAM certificate price (Q3 2026); Directive 2003/87/EC (EU ETS). All figures are indicative. European Commission: CBAM · European Commission: EU ETS