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CN 28041000

Hydrogen

✓ In scope of CBAM Hydrogen

CBAM cost preview

Live ETS price: €78.45/t CO₂. Sample: 1 tonne of CN 28041000 at default factors costs ~€208.99 in CBAM certificates today.

Direct emissions
26.64 t CO₂/t
Indirect emissions
0 t CO₂/t
CBAM cost (1000 t shipment)
€208,991
How is this calculated?

CBAM certificate cost = embedded emissions × ETS price × (1 − free-allocation factor) × phase-in markup.

Phase-in 2026: 10% of full certificate cost. Free allocation assumed 0% in this preview.

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Default embedded emissions

When you cannot collect verified supplier data, the EU lets you use these default values for the Hydrogen sector.

OriginDirect emissionsIndirect emissionsTotal
China26.64—26.64
Albania14.03—14.03
Belarus14.03—14.03
India14.03—14.03
Iran14.03—14.03

t CO₂e per tonne of product. Source: EU Implementing Reg. 2025/2621 Annex IV.

Top exporters into the EU

Eurostat Comext, latest available year. Volumes shown are extra-EU imports (tonnes).

OriginTonnes / yrShare
Norway1,20052%
United Kingdom80034%
United Arab Emirates32014%

Source: Eurostat Comext annual extra-EU trade.

How to comply for this code

Methodology guide -- hydrogen (CN 2804 10)

Hydrogen is the smallest CBAM commodity by volume but the most policy-relevant: the EU is betting on imports of low-carbon hydrogen for industrial decarbonisation.

Step 1: identify the production route. Steam-methane reforming (grey, ~9 t CO2/t H2) vs. SMR with CCS (blue, ~1-2 t CO2/t H2) vs. electrolysis with renewables (green, <0.5 t CO2/t H2). The EU default is calibrated to grey -- almost any verified data improves your position.

Step 2: collect supplier-level data per the EU template. The producer must report scope 1 + scope 2 per tonne H2, the route (SMR / ATR / electrolysis), and -- for blue hydrogen -- the carbon-capture rate.

Step 3: validate certifications carefully. "Renewable hydrogen" claims under EU Delegated Regulation 2023/1184 require additionality, temporal correlation and geographic correlation -- a paper PPA is not enough.

Step 4: monitor the Article 9 deduction. The UK CBAM (in force from 2027) and similar emerging mechanisms create double-counting risks; document carbon prices paid carefully.

Frequently asked questions

Does CBAM apply to ammonia imports as a hydrogen carrier?
Ammonia (CN 2814) is in scope under the fertiliser sector. If the ammonia is intended as a hydrogen carrier (cracking back to H2) the CBAM cost still applies on import -- the use case does not change classification.
How is "green" vs. "blue" hydrogen treated?
CBAM uses the Annex IV default for grey hydrogen (about 9 t CO2/t H2). Verified low-carbon producers can drop to under 1 t CO2/t H2 (electrolysis with renewable electricity) -- the full calculator handles this.
Do I have to use the EU default values?
No. Defaults are a fallback when verified supplier data is unavailable. From 2026 onward you should request actual emissions data from the producer using the EU CBAM communication template -- this is usually cheaper than using defaults, especially for low-carbon producers.
How is the cost adjusted year-on-year?
Phase-in markups apply: 10% of full certificate cost in 2026, 20% in 2027, 30% in 2028, scaling to 100% by 2034. The full calculator at /calculator applies the correct markup for your chosen year.
What about carbon prices already paid in the origin country?
Article 9 of the CBAM Regulation (EU) 2023/956 lets you deduct verifiable carbon prices paid in the country of origin. AutoCBAM Pro automates this; the free preview ignores it.

Get an emissions cost report for this product

Free PDF with sector defaults, top-3 origin countries and an ETS-linked cost forecast for CN 28041000.

Reference data only — confirmed CBAM scope ultimately depends on TARIC declaration and the latest amendments to CBAM Annex I.