Episode 9 of WHySE Creatures Stories
This post first appeared on LinkedIn on 29. June 2026
“Why am I only finding this out now?”
Rat stopped in the middle of the path. She wants to use hydrogen – and had just learnt that, from 2027, she’ll have to provide certified proof of its use.
They were out for a walk. Rat, Snake and Dog. No meeting, no agenda item. Just getting some fresh air. Just having a chat.
Then Rat asked that one question – and the walk turned into a briefing.
Snake – who knows every clause of energy law – explained: “RFNBO.” He looked at Rat. “Renewable Nuels of Non-Biological Origin. Hydrogen produced by water electrolysis is the prime example.” The revised 37th Federal Immission Control Ordinance (BImSchV) transposes the EU Delegated Act on RFNBOs into German law. Anyone using hydrogen produced by water electrolysis will need certified proof from 2027 onwards – via schemes such as CertifHy or ISCC.
Dog added the technical and administrative aspects: production pathway, proof of origin, additionality. That sounds complex. It can be sorted out – if you start in good time and know who to ask.
Rat listened. Nodded. Then said: “Then let’s get started today.”
What to do now:
→ Check whether your H₂ project falls under the RFNBO definition
→ Choose a certification scheme – setting it up takes time
→ Get your documentation in place before the pressure builds
Snake and Dog are here to guide you – legally and technically. If you want to know whether your business is affected, just touch base with me.