The leaked RED IV assessment: what it means for RFNBO quotas after 2030

A draft of the Commission impact assessment for the EU renewable energy framework after 2030, the future RED IV, is dated 8 September 2026 and has not been published. The press reported it as the end of the EU hydrogen quota. The document says nothing of the kind: Commission staff score 32 measures, recommend two and propose no law.

We read the draft against the national laws already in force. The 13-page report below sets out which options exist, where binding RFNBO demand sits today, how likely each change is and what a tonne of e-methanol is worth under each rule.

Five findings

1. Nothing changes before 2031. The draft covers only the years after 2030. A Commission proposal, two years of negotiation, adoption and transposition by 27 national legislatures still lie ahead. The national quotas follow a separate procedure.
2. Twelve member states have an RFNBO quota in law, and three publish the penalty for missing it. Germany charges 120 euro per gigajoule missed, the highest in the EU. Czechia charges about 82 euro and Finland 40 euro.
3. The industry target reached national law in six member states and binds no company anywhere. Article 22a requires 42 percent renewable industrial hydrogen by 2030 and 60 percent by 2035.
4. ICODOS estimates a 70 percent probability that the EU sets a binding RFNBO share for the years after 2030. Since 2021 Parliament and Council have set a reserved share for e-fuels three times and have never deleted one.
5. ICODOS estimates a 75 percent probability that the list of eligible fuels widens. Nuclear based and low carbon hydrogen would then count. German law protects most of the value: the factor 3 credit in the 37. BImSchV runs until 2036, is worth 1,200 to 2,400 euro a tonne at 2026 quota prices and is tied to RFNBO status in national law.

The two options Commission staff recommend

Six of the 32 measures decide the RFNBO market. Staff recommend option L2, which would replace the binding national industry targets with one EU target of 8 million tonnes of renewable hydrogen, backed by financing and credits. They also recommend option K2, which keeps the duty on fuel suppliers and leaves its level with the member states. A staff recommendation carries no legal force, and the Commission may set it aside before it adopts a proposal.

Who the report is for

• RFNBO producers taking investment decisions before 2030.
• Buyers signing offtake terms that extend beyond 2030, in particular under German law.
• Policy and public affairs teams preparing comments for the eight week feedback period on the Commission proposal, expected in Q4 2026.

Read the full report

The leaked RED IV assessment: options, likelihood and price effect for RFNBO producers and buyers

PDF · 13 pages · 7.7 MB · English · Version 1, 21 September 2026

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Published by ICODOS GmbH, Mannheim, on 21 September 2026. Probabilities are ICODOS estimates; the method is set out on page 13. This report is not legal advice. Comments and corrections are welcome via our contact form.