How SMAP, FuelEU RFNBO, and the ETS zero-factor stack on a hydrogen voyage

What each layer actually is: the ETS saving is not a subsidy — under the proposal, compliant hydrogen has a zero combustion emission factor under Annex IV, so no allowances are surrendered for it regardless of upstream emissions; that's why the ETS bar doesn't move when you change hydrogen's intensity below. FuelEU is different: it runs on well-to-wake life-cycle intensity, where hydrogen is not zero — it carries the 20 gCO₂eq/MJ assumption set above. Only the gap it closes versus the 91.16 gCO₂eq/MJ fossil reference counts as avoided CO2eq, and RFNBO's ×2 reward factor (to 31 Dec 2033) doubles how much of that gets credited. It's priced here at a market compliance rate (default €200/tCO2, roughly where inter-ship pooling has cleared) rather than the €2,400/t VLSFOeq statutory penalty ceiling — the ceiling is a worst-case deterrent, not what avoiding a shortfall is typically worth in practice. SMAP (Art. 3gaa) is the only genuine top-up: it reimburses 90% (RFNBO) or 80% (low-carbon H2) of the remaining price gap, subject to EU/linked-country origin rules and to the 110M-allowance pool not being oversubscribed in a given year — if demand exceeds supply, allocations are pro-rated down.

This is an illustrative simplification for exploring how the mechanisms interact, built from the draft text of COM(2026) 616. It is not a compliance calculation — verify against the Commission's published reference prices and your own MRV/FuelEU figures once the delegated acts are adopted.