An October 2026 compilation of 2025 trade figures put extra-EU imports under the relevant hydrogen code at about 6.8 million euros, compared with 111.23 billion euros in total trade under Carbon Border Adjustment Mechanism (CBAM) codes. Hydrogen therefore represented only a fraction of the recorded CBAM-code import market, but the customs value does not measure its potential importance to Europe’s industrial decarbonisation strategy.
The 2025 figure should not be extrapolated into a forecast for the market that may develop later this decade. Hydrogen is a future-oriented CBAM intelligence category, rather than a current-volume market comparable with steel or aluminium.
Customs data and hydrogen use
Much of Europe’s current hydrogen supply is produced and consumed near industrial sites, limiting the significance of cross-border customs statistics. Hydrogen is used in refining and chemical processes, notably ammonia production, and could be used in future low-emissions iron and steel production routes.
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. Even a small commercial shipment can therefore require appropriate declarant status and emissions documentation.
Import chains and emissions evidence
Production emissions can vary substantially depending on whether hydrogen is made through unabated fossil-fuel reforming, carbon capture, or electrolysis, and on the electricity supplying the process. A direct importer could be an industrial gas company, a chemical producer or another industrial off-taker. The final beneficiary could be a refinery, fertiliser producer or manufacturer seeking lower-carbon process inputs.
Customs data do not disclose the eventual consumption site. Commercial diligence needs to establish the installation, production pathway and imported form, as well as the contractual chain, carbon evidence and buyer’s specifications.
Monitoring indicators include emerging production capacity outside the EU, infrastructure access, customer offtake agreements, certification methods and industrial sites capable of switching feedstocks.
