Romania has taken an important step in implementing the EU Renewable Energy Directive – RED III – by introducing binding renewable hydrogen targets together with financial penalties for non-compliance. Law No. 181/2026, published on 28 August and in force since 31 August 2026, amends Romania’s existing hydrogen legislation and introduces a clearer compliance framework for renewable fuels of non-biological origin (RFNBOs) in industry and transport.

For industrial hydrogen consumers, the law directly implements one of the key hydrogen provisions of RED III. At least 42% of hydrogen used for final energy and non-energy purposes in industry must qualify as RFNBO by 2030. The share increases to 60% from 2035. These are the same headline targets established under Article 22a of RED III.

The Romanian legislation also reflects the flexibility mechanism available under RED III. Under specific conditions, the industrial RFNBO targets may be reduced by 20%, potentially lowering them to 33.6% in 2030 and 48% in 2035. This option is linked, among other things, to the country’s progress towards its overall renewable energy contribution and the share of fossil-based hydrogen in national consumption.

What makes the Romanian implementation particularly significant is that the targets are accompanied by an explicit penalty mechanism.

Industrial hydrogen consumers that fail to achieve the required RFNBO share can face a fine of RON 0.17 for every MJ of RFNBO deficit. The total penalty is capped at 1% of the company’s net turnover in the previous financial year. In addition, the missing volume is carried forward and added to the following year’s compliance obligation, meaning that paying the penalty does not simply eliminate the deficit.

The law also introduces reporting and verification requirements. Industrial hydrogen consumers will have to report their hydrogen consumption and eligible RFNBO volumes annually from 2031, while compliance must be supported by sustainability documentation, independent auditing and records in the EU Union Database.

Romania has also introduced RFNBO-related targets for road transport, including a minimum 1% RFNBO share in final transport energy consumption from 2030, preceded by transitional targets for eligible RFNBOs and renewable electricity in 2027–2029.

The Romanian approach is important for the wider European hydrogen market because it moves RED III from a policy objective towards an enforceable demand-creation mechanism. For hydrogen producers and infrastructure developers, this distinction is fundamental: legally binding consumption targets backed by financial penalties can provide a much stronger basis for future offtake agreements and investment decisions than non-binding national hydrogen strategies.