An October 2026 compilation of 2025 trade figures recorded about 6.8 million euros in extra-EU imports under the relevant hydrogen code, against 111.23 billion euros in total trade under Carbon Border Adjustment Mechanism (CBAM) codes. Hydrogen accounted for only a fraction of that recorded market, but its customs value does not measure its potential importance to Europe’s industrial decarbonisation strategy and should not be extrapolated into a forecast for later this decade.
Hydrogen is a future-oriented CBAM intelligence category, not a current-volume market comparable with steel or aluminium. It is used in refining and chemical processes, notably ammonia production, and could feature in future low-emissions iron and steel production routes. Much of Europe’s current supply is produced and consumed near industrial sites, limiting what cross-border customs statistics show. Those data also do not reveal where imported hydrogen is ultimately consumed.
Import chains and emissions evidence
Prospective import infrastructure and new derivatives could change the trade picture. Ammonia and other products must be assessed under their own classification and regulatory treatment; they are not automatically counted as imported hydrogen. The 50-tonne annual mass-based CBAM exemption does not apply to hydrogen, so even a small commercial shipment can require appropriate declarant status and emissions documentation.
Imported hydrogen’s production emissions can vary substantially depending on whether it is made through unabated fossil-fuel reforming, carbon capture or electrolysis, and on the electricity used. A direct importer could be an industrial gas company, chemical producer or other industrial off-taker; a refinery, fertiliser producer or manufacturer seeking lower-carbon process inputs could be the final beneficiary.
Commercial diligence needs to establish the installation, production pathway, imported form, contractual chain, carbon evidence and buyer’s specifications. Monitoring indicators include production capacity emerging outside the EU, infrastructure access, customer offtake agreements, certification methods and industrial sites able to switch feedstocks. The 6.8 million euros recorded for 2025 is not a basis for estimating the market that may develop later this decade.
