O GHG inventory for e-methanol gained centrality with the entry into force of EU delegated acts for RFNBOs (renewable fuels of non-biological origin) and the consolidation of the ISCC EU scope to certify hydrogen and e-fuel chains with traceability and independent verification. In the industrial context, e-methanol depends on three methodological pillars: (1) prove that electricity is renewable (additionality, temporal and geographic correlation), (2) apply the specific emissions calculation methodology for RFNBOs, e (3) maintain auditable accounting and chain of custody as per ISCC.
What the EU requires for RFNBOs (and where ISCC comes in)
A Delegated Regulation (EU) 2023/1184 defines life cycle emissions methodology for RFNBOs and carbon recyclates (RCFs), with the result expressed in Co.₂e/MJ of final fuel. It operationalizes RED II/III requirements and establishes the rules for accounting for emissions per stage and the conditions for using electricity from the grid as renewable when specific criteria are met.. In parallel, the ISCC structured documents dedicated to RFNBOs — notably ISCC EU 202-6 (RFNBO & RCF) e ISCC EU 205-1 (GHG de RFNBO/RCF) — that translate regulatory requirements into audit checklists, evidence trails and calculation formulas.
The EU also detailed the verification of renewable electricity with three key conditions: additionality (new assets or PPAs without legacy subsidy), temporal correlation (hourly/monthly window depending on phase) e geographic correlation (same interconnected supply zone). These criteria tie green H₂ production to the renewable generation profile, avoiding “washing” of emissions via intensive grid.
e-methanol process boundary and data
E-methanol is produced, typically, by the catalytic synthesis of H₂ via electrolysis with CO₂ caught (biogenic, DAC or eligible process). No GHG inventory for e-methanol, the border covers (i) renewable electricity generation/contracting, (ii) production and compression of H₂, (iii) capture, CO₂ purification and compression, (iv) synthesis and purification of e-methanol, (v) utilities (vapor, cooling, compressed ar, water/effluent), in addition to packaging and shipping when applicable. O ISCC 205-1 prescribes that the result be reported in gCO₂e/MJ and that each emission portion be divided by the energy of the final fuel.
When there are emission factors (FE) listed no Implementing Regulation (EU) 2022/996, they must be applied; alternative sources only come into play in the absence of applicable FE. This hierarchy guarantees comparability between operators and reduces arbitrariness in estimates.
Inventory step by step (auditor-oriented)
- Set the boundary and period: cradle-at-gate (or gate-to-gate, if that's the case), with 12 months and lines/assets covered by certificate ISCC EU.
- Map critical flows: renewable kWh (PPA, self-consumption, certificates), MWh de calor, Nm³ of H₂, t of CO₂ captured, chemical inputs and utilities. Record loads and losses (compression, blow-down, purges, torch).
- Check out renewable electricity: evidence of additionality, correl. temporal (hour/month according to transition phase) e correl. geographical (same bidding zone/interconnected area). Save contracts, guarantees of origin and hourly measurements.
- Apply the RFNBO methodology: calculate emissions per module (electricity → H₂; CO₂ → I prepare; synthesis → utilities) according to 2023/1184 e ISCC 205-1; normalize to gCO₂e/MJ of e-methanol.
- Use correct FE/LHV: prioritize 2022/996 for FE and calorific values; document versions and dates. For gaps, cite secondary bases and justifications.
- Integrate chain of custody: if there is physical mixing (p. ex., grid + PPA, CO₂ from multiple sources), adopt mass balance in line with ISCC 202-6 and reflect this in sustainability statements.
- Relate e audite: generate reports with calculation tables, sources, hypotheses and reconciliations. The verifier will follow the script of ISCC docs and EU acts.
Technical levers that most change the result
- Carbon intensity of electricity: is the biggest driver of GHG inventory for e-methanol; Dedicated wind/solar and self-consumption PPAs reduce footprint. Simultaneous fulfillment of additionality + temporal and geographic correlation is decisive for eligibility as RFNBO.
- Electrolyzer Efficiency: lower kWh/Nm³-H₂ dilutes emissions; record real performance per hour/day to audit different energy harvests.
- Source and preparation of CO₂: Biogenic CO₂ or DAC tends to be the best metric, as long as the capture/compression energy balance is optimized. Purity documents, compressor, electrical consumption and possible solvents.
- Thermal integration: synthesis heat recovery and utility optimization (vapor, ice water) reduce the process modulus in the LCA.
Chain of custody (mass balance) and allegations
For RFNBOs, traceability needs to match bookkeeping of inputs/outputs with declarations ISCC. O ISCC 202-6 describes how to operate mass balance (periods, losses, transfers) and how to issue Sustainability Declarations consistent with the inventory; any commercial claim (ex.: “renewable e-methanol”) must accurately reflect the certified attributes and applicable correlation rules.
Brazil: opportunities and adherence
E-methanol projects in Brazil target exports to the EU and maritime markets, where acceptance as RFNBO depends on compliance with acts 2023/1184/1185 and chain certification via ISCC EU. Proof of electricity renewability (Dedicated PPAs, own parks) under additionality and correlation criteria is the key point for eligibility — and for competitive GHG performance in audit.
Frequent errors (and how to avoid them)
- Use “generic” FE when there is FE of the 2022/996: the regulation is clear — if there is an applicable FE, it must be used.
- Confusing guarantee of origin with additionality: GOs alone do not meet the rule; a contractual relationship with nova renewable capacity and fulfill temporal/geographic correlation.
- Report only annual averages: verification may require hourly/monthly granularity to check temporal correlation; organize data from the day 1.
- Bookkeeping inconsistente: divergences between the energy balance and the “mass balance” break the ISCC track; reconcile inflows/outflows/losses by period.
Readiness checklist
- PPA/renewable generation additional contracted and measured with appropriate granularity.
- Plane of temporal and geographic correlation formalized (includes bidding zones and time window schedule).
- Primary data inventory (kWh, Nm³ H₂, tCO₂, utilities, inputs) e FE 2022/996 mapped.
- ISCC procedures for mass balance and emissions (ISCC 202-6 e 205-1) deployed.
- PCF/LCA reports in Co.₂e/MJ with attached memories and evidence, ready for the auditor.
Conclusion
To compete in the European market, e-fuels projects need GHG inventory for e-methanol consistent, married to additionality e correlations of electricity, official factors (2022/996) and chain of custody ISCC. Who organizes primary data from the project design and integrates mass balance, energy contracts and methodology 2023/1184/ISCC 205-1 arrives at the audit with comparable numbers and claims defensible — turning regulatory requirements into commercial advantage. Our consultants lead GHG inventories for e-methanol (RFNBO) from end to end, integrating requirements ISCC EU (2023/1184/1185), chain of custody by mass balance, verification of additionality e temporal/geographic correlation of electricity, and rigorous use of Official FE/LHV (2022/996). We structure the bookkeeping for audit, we calculate the result in Co.₂e/MJ with an evidence trail and align the PCF to recognized standards (ISO 14067 / GHG Protocol). We deliver comparable numbers, claims defensible and independent auditor-ready documentation — from project design to final report.
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