In order to meet the ambitious hydrogen targets of the EU’s Renewable Energy Directive III (RED III), the Netherlands is introducing a bill that includes an annual obligation for all operators of industrial plants whose annual hydrogen consumption exceeds a certain threshold to ensure that a certain percentage of their annual consumption is met by renewable fuels from non-biological sources (RFNBOs, an obligation known as the Annual Obligation).
The Act is expected to take effect on January 1, 2026, however, this will be a challenge for some hydrogen users as compliance will require the actual delivery of hydrogen. Some users will not be able to connect to the Dutch hydrogen grid until 2027 at the earliest, which means that they will not be able to fulfill this obligation. The Act also provides temporary exemptions for these users, as described in more detail below.
