Russian and Belarusian hydrogen excluded from EU market: what changes for energy companies in 2026

Key data

If your company buys or sells hydrogen in the European market, this decision affects you directly from 9 July 2026. The European Commission has renewed, through Commission Implementing Decision (EU) 2026/1551, the temporary exclusion that prevents hydrogen originating from the Russian Federation and the Republic of Belarus from participating in the European hydrogen market development support mechanism, regulated by Regulation (EU) 2024/1789.

This is not a new measure: it is a renewal of an exclusion already in force, which confirms that EU policy in this area remains firm with no signs of reversal in the short term. Companies that have not yet adapted their supply chain are at risk of non-compliance.

What does this regulation establish?

Implementing Decision 2026/1551 establishes the implementing provisions of Regulation (EU) 2024/1789 regarding the renewal of the temporary exclusion applicable to the collection of hydrogen supply offers from Russia and Belarus through the European hydrogen market support mechanism.

In practical terms, this means:

• Russian and Belarusian suppliers cannot submit offers in auctions or European green hydrogen procurement mechanisms.
• Hydrogen originating from both countries is excluded from any procurement process covered by the European market support mechanism.
• The measure responds directly to sanctions and restrictions arising from the conflict in Ukraine.
• The exclusion reinforces the EU's policy of energy diversification and strategic autonomy in the hydrogen sector.

The regulation is directly applicable in all Member States from its entry into force on 9 July 2026, without requiring national transposition.

Economic and operational impact

The most immediate impact is operational: any company with active contracts or ongoing negotiations with Russian or Belarusian hydrogen suppliers must halt those processes if they are linked to the European market support mechanism.

From a strategic perspective, the renewal of this exclusion has three direct business consequences:

• Price pressure: As the number of eligible suppliers decreases, competition in European auctions diminishes, which can translate into higher prices for hydrogen buyers in the short and medium term.
• Urgent need for diversification: Purchasing companies must identify and qualify alternative suppliers in non-sanctioned third countries to guarantee supply.
• Compliance risk: Participating in European procurement mechanisms with hydrogen of Russian or Belarusian origin exposes the company to sanctions for violation of the exclusion regime.

The measure is part of the broader EU policy of energy strategic autonomy, which seeks to reduce dependence on suppliers from countries with which there are geopolitical conflicts or active sanctions.

Who does it affect?

• Hydrogen producing companies that operate or wish to operate in the European market.
• Industrial hydrogen buyers (chemical industry, refining, mobility, steel) that participate in European auctions or procurement mechanisms.
• Traders and intermediaries in the European energy market that manage hydrogen supply contracts.
• Infrastructure operators (pipelines, terminals) that transport or store hydrogen of Russian or Belarusian origin.
• Legal and compliance advisors that manage energy contracts with an international component.
• CFOs and procurement directors of energy companies with exposure to suppliers from Eastern Europe.

Practical example

Imagine a Spanish chemical company that until now received hydrogen supply offers from a Russian supplier through the European hydrogen market support mechanism, covered by Regulation (EU) 2024/1789.

With the renewal of the exclusion established by Decision 2026/1551, that Russian supplier can no longer submit offers in any auction or procurement process linked to that mechanism. If the chemical company attempts to formalize a supply contract with that supplier within the mechanism, it would be in breach of current European regulations.

The company must act immediately: review its current contracts, identify if any active supplier has Russian or Belarusian origin, and seek alternatives in non-sanctioned countries (for example, green hydrogen suppliers from North Africa, Norway or Gulf countries) to guarantee supply without compliance risk.

What should companies do now?

1. Audit the hydrogen supply chain: Identify all current and potential suppliers, verifying if any have Russian or Belarusian origin. This review must be done urgently given that the regulation is already in force from 9 July 2026.
2. Review active contracts: Check if there are hydrogen supply contracts linked to the European market support mechanism that involve suppliers from Russia or Belarus, and consult with legal advisors about their validity and potential risks.
3. Identify alternative suppliers: Initiate qualification processes for new suppliers in non-sanctioned third countries to guarantee supply continuity without regulatory compliance risk.
4. Update compliance procedures: Incorporate verification of hydrogen origin as a mandatory step in energy procurement and contracting processes.
5. Monitor future renewals: The exclusion is temporary but has already been renewed. Establish regulatory alerts to detect any changes in the scope or duration of the measure.

Official source

Consult full regulation at official source

Notice: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202601551