How ISCC Verifies Renewable Electricity Use in RFNBO Production
As renewable hydrogen and e-fuels move from pilot projects to large-scale deployment, the credibility of their carbon reductions depends on one key factor: proof that the electricity used in production is truly renewable. Under the EU Renewable Energy Directive III (RED III), this verification is mandatory for any Renewable Fuel of Non-Biological Origin (RFNBO) that claims compliance or eligibility for renewable energy credits.
The ISCC EU certification system provides a structured, independent way to demonstrate that electricity used in electrolysis or synthesis meets the EU’s detailed rules for renewable sourcing.
The Context: What RED III Requires
To qualify as an RFNBO, hydrogen or derived fuels must show that the energy used to produce them is renewable and additional—not merely diverted from existing renewable capacity already counted elsewhere.
The European Commission’s Delegated Regulation (EU) 2023/1184 and Implementing Regulation (EU) 2023/1185 define the three main verification conditions:
Additionality:The renewable electricity used must come from new generation capacity that became operational no more than 36 months before the electrolyzer began operation. This ensures hydrogen production drives new renewable investment, not competition for existing capacity. Temporal correlation:
The renewable electricity and hydrogen production must occur in the same time window—currently measured hourly from 2030 onward, though an initial monthly correlation is allowed through 2029. Geographical correlation:
The renewable generation and hydrogen plant must be located within the same bidding zone or a directly interconnected region of the electricity market, ensuring electrons are physically deliverable.
Together, these principles confirm that RFNBOs represent a net addition of renewable energy to the system.
How ISCC Verifies Compliance
ISCC certification audits assess compliance with each of these criteria using documented, auditable evidence.
1. Electricity sourcing documentation
Power Purchase Agreements (PPAs) or direct contracts with renewable energy producers are reviewed for project commissioning dates, capacities, and grid connections. Guarantees of Origin (GOs) are cross-checked to confirm renewable attributes and avoid double counting. In cases where grid electricity is used, auditors verify compliance with the Commission’s rules on renewable matching.2. Plant operation data
Electrolyzer operation logs and production time stamps are compared against renewable generation data to verify temporal correlation. Metered electricity data must show renewable inputs matching hydrogen output intervals.3. Geographic eligibility
Auditors confirm that the renewable source and electrolyzer operate within approved bidding zones or interconnected areas as defined by the relevant transmission system operator (TSO).4. GHG calculations
ISCC’s GHG verification methodology applies Annex V and new RED III parameters to ensure that lifecycle emissions reflect the actual electricity mix used. Auditors confirm that emission factors for renewable sources are applied correctly and that fossil backup electricity, if any, is accounted for.Preparing for Verification
RFNBO producers can streamline certification by integrating data systems early:
Automate metering for electricity, hydrogen, and CO₂ inputs. Maintain synchronized time stamps for electricity supply and hydrogen output. Archive GOs, PPAs, and TSO confirmation letters in standardized digital formats. Conduct internal cross-checks monthly to identify any correlation gaps.Companies that implement these practices ahead of their ISCC audit avoid costly delays and improve data quality for submission to the EU Union Database for Renewable Fuels (UDB) once integration becomes mandatory.
Why It Matters
Renewable electricity verification is more than a compliance requirement—it defines the environmental integrity of the RFNBO concept. Transparent proof of renewable origin ensures that hydrogen and e-fuels deliver genuine decarbonization rather than accounting shifts. It also underpins eligibility for national incentives, carbon credit programs, and voluntary sustainability markets.
How AmSpec Supports RFNBO Verification
AmSpec helps hydrogen and e-fuel producers navigate the technical and regulatory requirements of renewable electricity verification under ISCC EU. Our experts assist with:
Pre-certification readiness reviews for new electrolysis or e-fuel projects Verification of renewable energy contracts and Guarantees of Origin Review of data management systems for additionality, temporal, and geographic compliance ISCC certification audits and GHG verification aligned with RED III Testing and inspection services for fuel quality, traceability, and data validationBy combining technical verification with sustainability certification, AmSpec ensures that your renewable hydrogen and e-fuel production meet both regulatory and market expectations—providing confidence that every megawatt-hour of electricity truly contributes to decarbonization.
