Europe’s hydrogen strategy has entered a critical phase. A group of Members of the European Parliament (MEPs) has formally urged the European Commission to bring forward the review of the Renewable Fuels of Non-Biological Origin (RFNBO) framework to the first half of 2026.
Their concern: current regulatory requirements may unintentionally delay investment in renewable hydrogen and, by extension, in Power-to-X projects and synthetic fuels.
Why RFNBO Rules Matter for Power-to-X
Power-to-X refers to technologies that convert renewable electricity into hydrogen and further into synthetic fuels such as e-kerosene, e-methanol or e-diesel. These fuels are essential for defossilising hard-to-abate sectors including aviation, shipping and parts of industry. But also road transportation as far as electrification does not come fast enough to achieve the climate goals.
Under the EU Renewable Energy Directive, RFNBO criteria define when hydrogen and derived fuels can be counted as renewable. The framework includes rules on:
- Additionality (electricity must come from newly built renewable plants),
- Temporal correlation (matching electricity production and hydrogen production over time),
- Geographical correlation (location of electricity generation relative to hydrogen production).
According to the MEP letter, several large-scale projects with secured financing and advanced permitting have reportedly stalled because the current RFNBO rules create cost and risk levels that make final investment decisions difficult.
The signatories argue that waiting until 2028 for a formal review could delay Europe’s industrial ramp-up by several years.
Source: Letter from Members of the European Parliament to the European Commission, 18 December 2025 (RFNBO Delegated Acts review request).
The Investment Challenge
For Power-to-X developers, electricity is the dominant cost factor. Strict additionality and hourly matching requirements can:
- Reduce electrolyser operating hours
- Increase hydrogen production costs
- Lower plant utilisation rates
- Increase financing risks
If hydrogen becomes more expensive or uncertain, downstream Power-to-X applications such as e-fuels face even greater economic pressure. Notably, if the same rules were be applied to electricity consumption by BEVs, it is hard to imagine the building up of a sufficient charging stations network. Here, it is clear that different standards were applied.
The MEPs therefore call for:
- A more workable approach to renewable electricity sourcing
- Continued availability of monthly matching as a compliance route
- Cross-border renewable power purchase agreements (PPAs)
- Recognition of hydrogen production that supports grid stability
Their argument is not about weakening climate integrity, but about ensuring that regulation remains aligned with industrial feasibility.
Implications for e-Fuels and Aviation
Synthetic aviation fuels are expected to play a key role under the ReFuelEU Aviation framework. However, e-kerosene (e-SAF) production depends directly on scalable renewable hydrogen supply.
If hydrogen projects are delayed, e-fuel availability may also lag behind policy targets. This could increase reliance on imports or on alternative compliance pathways.
For Power-to-X stakeholders, the current debate highlights a broader policy question:
How can Europe balance environmental robustness with investment realism? This is exactly the same question that is currently dominating the work at SPIN in Switzerland. We recently launched a working group with members of the Federal Offices of Energy, Environment and Civil Aviation to find solutions to the challenges resulting from too strict regulations.
Why This Debate Matters Beyond the EU
Although Switzerland is not an EU Member State, its Power-to-X ecosystem is closely connected to European markets, certification schemes and supply chains.
EU regulatory developments therefore directly influence:
- Market access for synthetic fuels
- Investment decisions
- Technology partnerships
- Long-term industrial planning
Regulatory clarity and investment security remain central prerequisites for scaling Power-to-X technologies across Europe.
Outlook
The European Commission is expected to continue monitoring implementation of the RFNBO Delegated Acts. Whether the formal review timeline will be accelerated remains to be seen.
What is clear, however, is that the success of Power-to-X in Europe will depend not only on technological progress but also on regulatory frameworks that enable projects to move from planning to operation.
The coming months may prove decisive for Europe’s renewable hydrogen and synthetic fuel trajectory.
Read the letter: