(1)

The Commission established the Hydrogen Mechanism (‘the mechanism’) to support the market development of hydrogen referred to in Article 52 of Regulation (EU) 2024/1789 which is to be implemented under the activities of the European Hydrogen Bank (2). The mechanism was launched in July 2025. The mechanism aims to increase the transparency of hydrogen demand, supply, flows and prices and play a coordination role, connecting, processing, and giving access to information on demand and supply for renewable and low-carbon hydrogen and hydrogen derivatives submitted by off-takers established in the Union and in the Energy Community Contracting Parties and both domestic and international suppliers. The Hydrogen mechanism will be implemented and will operate in accordance with the EU competition rules, in particular Articles 101 and 102 TFEU.

(2)

Hydrogen supply refer to the sale, including resale, of hydrogen, including in the form of liquid organic hydrogen carriers or liquid hydrogen and hydrogen derivatives including ammonia or methanol to customers (3).

(3)

Russia and Belarus produce significant volumes of fossil fuel-based hydrogen and derivatives (such as ammonia). Also, there is potential for substantial sales and supplies of renewable and low-carbon hydrogen and hydrogen derivatives production originating from Russia and Belarus. It is not excluded that some of those hydrogen and hydrogen derivatives volumes would be exported, also to the Union.

(4)

Experience with energy supplies from Russia and Belarus has shown that Russia exploited the Union’s dependence on its energy exports to the Union as a means of exerting coercion and manipulations (4). Russia has systematically abused dependencies to the detriment of the Union’s economy and economic security and used energy supply relationships with partners in the Union to manipulate markets and to weaken the Union’s security of supply (5).

(5)

There is a risk that Russia and Belarus would try to establish similar business relationships and dependencies with regard to exports of renewable and low-carbon hydrogen and hydrogen derivatives to the Union which could be used to manipulate markets.

(6)

Allowing supplies originating in Russia or Belarus to be offered through the mechanism could permit Russia and Belarus to gain a significant foothold in the Union market, thereby facilitating attempts to manipulate the nascent hydrogen market.

(7)

As hydrogen is often used by large industrial customers, and as the hydrogen market is much less liquid than the market for natural gas, establishing new supply dependencies with Russia or Belarus could enable those countries to continue their strategy towards the Union to endanger security of supply by manipulating markets, by interrupting supplies, or by using other form of weaponisation of energy supplies.

(8)

Although these risks are present even in the case of smaller shares in the overall volumes, collecting Russian and Belarusian hydrogen supply offers via the mechanism to support the market development of hydrogen could significantly increase the role and visibility of Russia and Belarus on the Union hydrogen market. This would run counter the Union’s efforts to phase out its dependency on Russian energy imports (6) and avoid new dependencies on energy supplies from those countries (7).

(9)

In view of that geopolitical situation and taking account of the risks resulting from energy deliveries from Russia and Belarus, it is necessary to temporarily exclude offers of hydrogen supplies originating in Russia or Belarus from being collected through the mechanism in order to protect the Union’s essential security interests and security of supply. Pursuant to Article 54(2) of Regulation (EU) 2024/1789, the decision shall be valid for a period of up to one year and may be renewed if justified.

(10)

The temporary exclusion will not unduly disrupt the proper functioning of the internal market for hydrogen and will not undermine the security of supply of the Union or of a Member State, notably because the Union hydrogen market is still nascent with very limited supplies from Russia and Belarus. Furthermore, the temporary exclusion respects the principle of energy solidarity (8), because it is taken in the interest of the Union with regard to the mechanism, without undue impacts on the rights of Member States or their economic operators to trade hydrogen, including renewable and low-carbon, and its derivatives with third countries outside the voluntary mechanism. Moreover, this Decision is taken in accordance with the rights and obligations of the Union or of the Member States with respect to third countries.

(11)

In accordance with Article 54(2) of Regulation (EU) 2024/1789, the Commission has duly informed the European Parliament and the Council about its assessment, and may propose to renew the decision, if justified, also with a view to aligning the measure with other EU policies, such as the RePowerEU Roadmap (9), which aims to further advance the EU’s independence from Russian energy by measures to support the phase out of imports of gas, nuclear, and oil to reduce risks of weaponisation of energy supplies,