Green hydrogen regulatory compliance: 3.38 kgCO₂eq/kgH₂ answered in 3 seconds.
IgeraIndustria resolves the regulatory complexity of green hydrogen projects: RED III RFNBO thresholds and delegated acts, ISO 22734 electrolyser type approval, GHC and CertifHy certification schemes, ATEX Group IIC zone classification for storage, and ADR Class 2.1 transport requirements — citing the exact article, clause and threshold.
Green hydrogen: the highest regulatory density per megawatt in the energy transition
Electrolyser manufacturers and hydrogen project developers face a regulatory stack unlike any other energy technology: the RED III RFNBO delegated acts, ISO 22734 electrolyser standards, ATEX Group IIC zone requirements, ADR Class 2.1 transport rules and competing green certification schemes — all simultaneously, before a single kilogram of hydrogen is produced.
3.38
kgCO2eq/kgH2 — the RED III RFNBO GHG intensity ceiling. Calculated across the full lifecycle from renewable electricity to compressed hydrogen. Hourly temporal correlation required from January 2030.
IIC T1
Hydrogen ATEX equipment classification — the most stringent gas group. Zone 0/1/2 areas around electrolysers, vents and storage must be mapped and documented under Directive 1999/92/EC.
ISO 22734
2023 edition for water electrolysis systems. Governs PEM and alkaline electrolyser design, FAT/SAT test protocols and integration with the Pressure Equipment Directive 2014/68/EU for CE marking.
IOGP 634
IOGP Report 634 (Hydrogen safety) provides the industry-standard risk assessment framework for hydrogen facilities, cited by insurers and project lenders as due diligence baseline.
Compliance managers spend weeks cross-referencing the RED III delegated act with the GHC certification scheme requirements, or determining whether a specific storage configuration meets ATEX Zone 1 IIC equipment requirements. IgeraIndustria answers these questions in seconds, citing the exact article, standard clause and applicable threshold — so the project team focuses on engineering and permitting, not on regulatory research.
Instant green hydrogen compliance queries — RED III, ISO 22734, ATEX, ADR
IgeraIndustria locates the exact regulation, standard clause or certification requirement that applies to each green hydrogen compliance question and responds with the applicable threshold, methodology or documented evidence required.
RED III RFNBO GHG intensity calculation
Lifecycle GHG methodology from Annex V RED III, the 3.38 kgCO2eq/kgH2 threshold, temporal and geographical correlation requirements for electricity inputs, and how to document compliance for EU Hydrogen Bank auction bids or RFNBO Go guarantee of origin.
ISO 22734 electrolyser type approval
Key clauses for PEM and alkaline electrolyser design (cl.5-6), performance efficiency measurement (cl.7), factory acceptance test (FAT) and site acceptance test (SAT) protocols (cl.9), and how ISO 22734 interfaces with the Pressure Equipment Directive 2014/68/EU for CE marking.
GHC vs CertifHy certification comparison
GHG intensity tiers (green / gold / platinum) under GHC vs the CertifHy Guarantee of Origin system; audit body accreditation requirements; how each scheme maps to RED III RFNBO compliance documentation; and which scheme is preferred by specific offtake markets.
ATEX zone classification for hydrogen storage
Zone 0/1/2 boundary determination around electrolysers, vent outlets, compressors and dispenser connections per IEC 60079-10-1; equipment selection for Group IIC, Temperature Class T1; zone drawing documentation requirements under Directive 1999/92/EC.
ADR Class 2.1 hydrogen transport
UN 1049 packing instructions (P200), cylinder and tube trailer periodic inspection intervals, driver ADR certificate requirements, mixed loading prohibitions with oxidising gases, tunnel restriction code E, and transport document mandatory content.
EU Hydrogen Bank auction eligibility
RFNBO compliance baseline for Innovation Fund auctions, project maturity requirements (FEED, permits, PPA or grid connection), financial eligibility criteria, double-funding restrictions with IPCEI and CEF, and quarterly/annual reporting obligations post-award.
Full support for green hydrogen certification and permitting
From initial RFNBO eligibility assessment to ATEX zone drawing review and ADR documentation, IgeraIndustria supports the compliance team at every stage of a hydrogen project development cycle.
RFNBO eligibility pre-screening
Before investing in certification, IgeraIndustria assesses whether the planned electricity procurement strategy (direct line, PPA, grid with REGOs) meets the RED III additionality, temporal correlation and geographical correlation requirements for RFNBO status.
ISO 22734 FAT/SAT checklist
Factory acceptance test and site acceptance test documentation checklists for PEM and alkaline electrolyser commissioning, aligned with ISO 22734 clause 9 requirements and notified body expectations for CE marking under PED 2014/68/EU.
ATEX explosion protection document (EPD)
Content requirements for the EPD under Directive 1999/92/EC: zone classification drawings, equipment inventory with ATEX certification numbers, ignition risk assessment, inspection programme and competent person appointment.
GHG intensity third-party verification preparation
Documentation required for annual GHG intensity verification by an accredited certification body: electricity metering records, renewable energy certificates (REGOs/GOs), hourly matching data (from 2030), production records and lifecycle calculation worksheets.
Hydrogen safety case and IOGP 634 alignment
Key elements of the hydrogen facility safety case: bow-tie analysis for major accident scenarios, ATEX zone documentation, PSSR written scheme of examination, emergency response plan and DSEAR compliance assessment under COMAH if above threshold quantities.
EU Hydrogen Bank bid documentation
Checklist of technical and financial documentation required for EU Hydrogen Bank auction submissions: RFNBO compliance evidence, project maturity milestones, GHG intensity calculation methodology, monitoring and reporting plan structure.
The 4 critical regulatory pillars of green hydrogen compliance
Green hydrogen projects must simultaneously satisfy production qualification, equipment safety, storage and transport regulations — each with distinct competent authorities, documentation requirements and audit timelines.
RED III Article 27 — RFNBO production qualification
Renewable Fuels of Non-Biological Origin (RFNBOs) must meet the GHG intensity threshold (3.38 kgCO2eq/kgH2), additionality requirement (new renewable capacity installed after 1 January 2021 for direct connection), temporal correlation (hourly matching from January 2030) and geographical correlation (same or adjacent bidding zone). The delegated act (EU) 2023/1184 provides the detailed methodology. Non-compliance invalidates RFNBO status and removes eligibility for EU Hydrogen Bank support, RED III quota counting and CBAM exemptions. Annual third-party verification by an accredited body is mandatory.
ISO 22734:2023 — Electrolyser system safety
ISO 22734 sets design, construction, performance and test requirements for water electrolysis systems. It covers both PEM (proton exchange membrane) and alkaline technologies. The standard is the key reference for CE marking of electrolyser systems under PED 2014/68/EU (pressure vessels) and the Machinery Directive 2006/42/EC (mechanical hazards). Clause 9 test protocols define the mandatory factory acceptance test (FAT) and site acceptance test (SAT) evidence that must be retained. ISO 22734 hydrogen purity requirements align with ISO 14687 Grade D minimum for most stationary applications.
ATEX Directives — Explosive atmosphere classification
Directive 1999/92/EC (minimum requirements for workers) requires employers to classify areas where explosive hydrogen-air mixtures may occur into zones 0, 1 and 2, produce an explosion protection document, and ensure that all equipment installed in those zones is certified to Directive 2014/34/EU for the appropriate category and gas group. Hydrogen is classified in Equipment Group IIC — the highest hazard category — due to its wide flammability range (4-75% LEL-UEL) and very low minimum ignition energy (0.017 mJ). Zone drawings must be reviewed when plant layout or ventilation changes.
ADR 2023 — Dangerous goods road transport
The European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) regulates compressed hydrogen (UN 1049, Class 2.1) transport. Chapter 3.2 table A specifies the requirements: packing instruction P200 for cylinders, portable tank instruction T50 for tube trailers, vehicle type EX/II or EX/III or FL, tunnel restriction code E. Chapter 8 covers driver training and equipment. Updated biennially — the ADR 2023 edition introduced revised pressure vessel inspection intervals and updated emergency response guidance for hydrogen.
How IgeraIndustria works for green hydrogen compliance teams
Five steps from indexing your project documentation to receiving answers with the exact regulation, clause, threshold and required evidence.
Index your hydrogen project documentation
Upload your RFNBO eligibility assessment, ATEX zone drawings, electrolyser technical file, ISO 22734 FAT/SAT reports, GHC certification audit reports and ADR transport documentation. IgeraIndustria processes them alongside RED III delegated acts, ISO 22734, ATEX directives and ADR 2023.
Connect the assistant to your compliance team
Embed in your project management platform, Teams, Slack or as a WhatsApp bot accessible from site. One integration. Compatible with document management systems used in energy project development.
The compliance manager asks in plain English
“Does our hourly-matched PPA from an offshore wind farm meet RED III temporal correlation from 2030?”, “What equipment category is required in the electrolyser room Zone 1?”, “Which ISO 22734 clauses does the notified body verify for CE marking?”
IgeraIndustria searches 2 layers of knowledge
First in your internal project documentation (RFNBO assessments, ATEX zone drawings, certification reports), then in RED III and its delegated acts, ISO 22734:2023, ATEX directives, ADR 2023 and GHC/CertifHy certification scheme documentation, all indexed at article and clause level.
Answer with regulation, article, threshold and evidence required
The response cites the RED III article or ISO 22734 clause, states the applicable threshold or test requirement, identifies the competent authority or accredited body involved, and specifies what documented evidence must be retained for certification or permit applications.
IgeraIndustria in action — RED III RFNBO GHG intensity calculation
A compliance query on temporal correlation requirements for renewable electricity resolved in under 3 seconds, with the exact delegated act article cited.
Hydrogen Compliance Manager
We have a PPA with an offshore wind farm that was commissioned in 2022. Does this meet RED III additionality and temporal correlation for RFNBO status under the delegated act?
IgeraIndustria
RED III RFNBO — Delegated Act (EU) 2023/1184, Articles 4 and 5
- • Additionality: Wind farm commissioned 2022 — MEETS requirement (after 1 Jan 2021 cut-off, Art. 4(1))
- • Temporal correlation: Annual matching allowed until 31 Dec 2029 (Art. 5(2)); hourly matching required from 1 Jan 2030
- • Geographical correlation: Offshore wind must be in the same or adjacent bidding zone as the electrolyser (Art. 4(3)) — verify grid connection bidding zone
- • PPA contractual requirement: Agreement must specify the renewable installation, metered output and generation certificates (REGOs/GOs) transferred to electrolyser operator
⚠ Plan for hourly matching capability by Q3 2029 — metering and certificate registry infrastructure takes 12-18 months to implement.
✓ Delegated Act (EU) 2023/1184 Art. 4-5 · RED III Art. 27 · Confidence: 99.4%
40 MW
PEM electrolyser project
-60%
regulatory research time during permitting
GHC
certification obtained in 4 months
Our compliance team was navigating four different delegated acts simultaneously during the permitting phase of a 40 MW electrolyser project. IgeraIndustria reduced the time spent on regulatory research by 60%. We used it to prepare the ATEX explosion protection document, structure the GHC certification evidence package and answer the notified body’s questions on ISO 22734 FAT protocols. GHC certification was obtained four months ahead of schedule.
*Representative testimonial based on results from real customers
Frequently asked questions — Green Hydrogen Compliance
How is the renewable hydrogen GHG intensity threshold calculated under RED III Article 27?
RED III (Directive 2023/2413/EU) and its Delegated Regulation (EU) 2023/1184 set the GHG intensity threshold for renewable fuels of non-biological origin (RFNBOs), including green hydrogen, at 3.38 kgCO2eq per kgH2 — equivalent to 70% GHG savings compared to the fossil fuel comparator of 94 gCO2eq/MJ. The calculation follows the methodology in Annex V and Article 28 of RED III: lifecycle emissions must be assessed from electricity generation through electrolysis, compression, storage and dispensing. The electricity input must be from renewable sources demonstrably additional, temporally correlated and geographically correlated with the production facility. Temporal correlation requires hourly matching from January 2030 (annual matching allowed until then). If grid electricity is used, the average grid emission factor applies and most grids will not meet the threshold. IgeraIndustria retrieves the applicable calculation methodology, temporal and geographical correlation requirements, and the delegated act provisions that apply to each production pathway.
What are the key clauses of ISO 22734:2023 for electrolyser type approval?
ISO 22734:2023 covers design and safety requirements for water electrolysis systems used to produce hydrogen. Key clauses include: Clause 5 (General requirements) — electrolyser system design, material compatibility with hydrogen and electrolyte, protection against overpressure; Clause 6 (Construction) — cell stack design, membrane/diaphragm requirements for PEM and alkaline technologies, hydrogen/oxygen separation; Clause 7 (Performance) — efficiency measurement methodology (kWh/Nm3), purity requirements (ISO 14687 Grade D or higher for most applications); Clause 9 (Tests) — factory acceptance test (FAT) and site acceptance test (SAT) protocols, leak test procedures, functional safety verification; Clause 10 (Marking and documentation) — nameplate data requirements, installation and operation manual content. ISO 22734 is harmonised for CE marking under the PED (2014/68/EU) for pressure-containing electrolyser components. The standard does not cover the full system balance of plant — piping, compression and storage are addressed by ISO 15649 and EN ISO 15649 respectively.
What is the difference between the GHC Green Hydrogen Certification scheme and CertifHy?
Both are voluntary certification schemes but differ in scope, methodology and market recognition. CertifHy (European) was the first EU scheme, developed under the FCH JU, and issues Guarantees of Origin (GOs) for green and low-carbon hydrogen separately. It defines green hydrogen as produced from renewable electricity with GHG intensity below 36.4 gCO2eq/MJ (equivalent to 60% savings). The GHC (Green Hydrogen Certification) scheme by the Green Hydrogen Organisation is global in scope and aims to become the international reference, aligning closely with the RFNBO definition of RED III (70% GHG savings, 3.38 kgCO2eq/kgH2). Key differences: (1) CertifHy issues transferable GOs traceable via registries; GHC issues certificates linked to specific production batches. (2) GHC includes a graded colour classification (green, gold, platinum) based on GHG intensity tiers. (3) For EU Hydrogen Bank auctions, compliance with the RED III RFNBO delegated act is the compliance baseline — not GHC or CertifHy, though these can facilitate audit evidence. IgeraIndustria maps your production pathway to the applicable scheme requirements and the RED III compliance documentation needed.
How are hydrogen storage areas classified under ATEX Zone 0, 1 and 2?
Hydrogen storage facilities must be classified as explosive atmospheres under Directive 1999/92/EC (ATEX Workplace) and designed to ATEX Directive 2014/34/EU equipment requirements. Zone classification for hydrogen: Zone 0 — inside pressurised vessels, pipelines and electrolyser stacks where hydrogen is continuously present; Zone 1 — areas where explosive hydrogen-air mixtures may be present during normal operation, including the immediate vicinity of vents (typically 1 m radius), flange joints, compressor seals and dispenser connections. Zone 2 — areas where explosive atmospheres are not expected during normal operation but may occur in abnormal conditions, including areas around Zone 1 boundaries (typically extending 1 m to 3 m depending on ventilation). Hydrogen has a lower explosive limit (LEL) of 4% and upper explosive limit (UEL) of 75% — significantly wider than hydrocarbons. IEC 60079-10-1 gas group classification: IIA for propane reference, IIB for ethylene, IIC for hydrogen (most stringent) — equipment for hydrogen must be Group IIC, temperature class T1 or higher. ATEX documents (zone drawings, equipment registers, inspection programme) must be maintained and updated when plant layout changes.
What are the ADR Class 2.1 requirements for road transport of compressed hydrogen?
Compressed hydrogen is classified as a flammable gas under ADR Class 2.1, UN 1049 (hydrogen, compressed). Key transport requirements: Packaging — approved pressure vessels (type 1 to type 4 composite cylinders) or tube trailers conforming to ADR Chapter 6.2 (P200 packing instruction or portable tanks T50). Cylinders must bear ADR marks and undergo periodic inspection (internal inspection every 5 years, hydraulic test every 10 years for most designs). Vehicle requirements — EX/II or EX/III vehicle for total hydrogen quantities above ADR thresholds; FL vehicle for tube trailers. Driver training — ADR Certificate of Training for Drivers (1.3 training minimum; full ADR certificate for quantities above exemption thresholds). Documentation — transport document stating UN number, proper shipping name (HYDROGEN, COMPRESSED), class 2.1, total quantity, consignee and emergency telephone. Tunnel code E applies — restricting certain tunnels. Mixed loading prohibitions: cannot co-load with UN 1072 (oxygen, compressed) or other oxidising gases. IgeraIndustria retrieves the applicable ADR provisions by packing group, quantity and transport unit type.
What are the EU Hydrogen Bank auction eligibility criteria for green hydrogen producers?
The EU Hydrogen Bank (Innovation Fund) auctions for green hydrogen under the RFNBO mechanism require applicants to meet: (1) Compliance with RED III RFNBO delegated act — electricity must be from renewable sources, additive, with temporal correlation (annual matching until 2030, hourly from 2030) and from the same bidding zone or adjacent zone (geographical correlation). (2) GHG intensity threshold — 3.38 kgCO2eq/kgH2 or lower, verified by an accredited third-party certification body. (3) Project maturity — minimum FEED (Front-End Engineering Design) completion, permits obtained or in advanced stage, grid connection agreement or power purchase agreement (PPA) with renewable generator. (4) Financial viability — minimum equity committed, no double funding with other EU schemes (IPCEI, CEF, etc.). (5) Reporting obligations — quarterly production reports, annual third-party verification of GHG intensity and renewable electricity certificates. The support is provided as a fixed premium per kgH2 produced (EUR/kgH2) over the contract duration (typically 10 years). IgeraIndustria can retrieve the published auction terms, eligibility conditions and documentation checklist for submitted bids.
IgeraIndustria Green Hydrogen plans
No long-term commitment. Cancel any time.
Starter
For hydrogen project developers and compliance engineers who need instant access to RED III RFNBO requirements, ISO 22734 clauses and ATEX zone classification rules.
- RED III + delegated acts pre-indexed
- ISO 22734:2023 included
- ATEX IEC 60079-10-1 queries
- 1,000 queries/month
- Widget for compliance team
- Email support
Professional
For electrolyser manufacturers and BESS project developers managing ISO 22734 type approval, GHC/CertifHy certification and multi-regulation compliance.
- RED III + ISO 22734 + ADR 2023
- GHC and CertifHy scheme documentation
- Internal project documentation indexed
- 5,000 queries/month
- Regulatory update alerts
- Priority support
Enterprise
For large hydrogen project developers with multi-site electrolyser deployments, EU Hydrogen Bank auction participation and multi-jurisdiction permitting.
- Multi-project and multi-jurisdiction
- EU Hydrogen Bank auction support
- ATEX + COMAH integrated
- Unlimited queries
- SLA 99.9% uptime
- Dedicated customer success
RED III RFNBO compliance and GHC certification. Start today.
- Free trial — 14 days, no credit card required
- RED III delegated act (EU) 2023/1184 fully indexed from day one — including all RFNBO criteria and calculation methodologies
- Upload your ATEX zone drawings, ISO 22734 technical file and GHC certification reports
- EU Hydrogen Bank auction documentation checklist ready for compliance managers
