Are Hydrogen Refuelling Stations (HRS) within the RFNBO supply chain required to hold ISCC certification? 

Certification for HRS stations depends on national legislation: Where it is mandatory, the station must hold an ISCC certificate under the “Trader” or “Trader with Storage” scope (ISCC EU 203 chapter 3.4.8) and ensure every transfer to third parties is accompanied by a Proof of Sustainability; where it is not, the HRS must still obtain and retain its supplier’s valid ISCC certificate upon delivery. In all cases, the related GHG-emissions calculation, accounting and auditing remain the responsibility of the upstream processing unit (e.g., the electrolyser).  

In the case of Germany, certification is not needed for HRS.