Sufficient geographical availability and capacity for alternative fuels infrastructure is key for the transition towards a cleaner European road transport. Currently, there is a chicken and egg situation where neither the consumers nor the manufacturers of vehicles are ready to wholeheartedly bet on new drivetrains.

We are strongly convinced that a widely available hydrogen refuelling infrastructure (HRS) will be key to accelerate the rapid decarbonisation of European transport, providing both consumers and European companies with zero-emission options best suited for their respective needs.

The Alternative Fuels Infrastructure Regulation (AFIR) proposal could overturn the chicken and egg predicament by recognising the need for defined and coherent set of rules and targets, without relying on silver bullets for all segments of road transport.

In addition, several studies have shown that a dual infrastructure electric-charging and hydrogen refuelling is cheaper for 100% zero emission fleet than a purely electric infrastructure. A transition to a mix of battery and hydrogen vehicles is likely to be faster, more cost-efficient, and less risky than a transition to either one alone. HRSs could also greatly exploit their interoperability to simultaneously serve existing and future road transport vehicles.

The current proposal clearly recognises the role of hydrogen in road mobility. This is because not all road mobility will be battery electric, for instance, hydrogen fuel cell vehicles (FCEV) in cars and vans segments are particularly well suited for intensive usage, support very high flexibility, and is essential in areas with limited access to electric charging. Vehicles already exist now and many more are under development across cars and vans segments and will be in production in the next 5 years (1).

An early deployment of a reasonable number of HRS suitable to both cars, vans and trucks will mitigate the “usage” risk. A shared hydrogen refuelling infrastructure offers all synergies and cost savings benefits at low additional CAPEX costs.

What is required to unlock the true potential of hydrogen for cars and vans

The industry and the end customers need to see a clear trajectory that would let them safely invest into new zero-emission vehicles. The targets outlined in Article 6 of AFIR must be seen as the bare minimum and should not be watered down – in fact, there is considerable potential for more ambitious and clearer timelines will be needed a total H2 fleet of more than 2 million hydrogen fuel cell electric vehicles, approximately 1700 HRS in 2030 would be needed. This assessment shows that the currently proposed targets, which would result in approximately 800 HRS, barely cover the absolute minimum as a policy signal and more will be needed to stimulate investments.

By 2030, the EU needs to see HRSs at least every 100 kilometres across the entire TEN-T road network, with a minimum 2 tonne/day and 700 bar requirements. This however needs to be led up to by a clear trajectory which would reach half of density by 2025 (at every 200 km). Subsequently, by 2027 the full density of HRS has to be completed on core networks (at every 100 km), in order to match the expected scale up in the rollout by manufacturers by 2027. Lastly, as some HRS operators will store hydrogen in liquid from anyway, meeting the target of one HRS offering liquid hydrogen every 300 km will not be problematic.

In addition, ambitious targets of 2 HRS for each of the 424 European cities (TEN-T nodes) by 2030 will be instrumental in giving more customers the ability to access hydrogen mobility and enhance reliability in Europe’s key multimodal locations.

Mobility as a key component of the French industrial policy on hydrogen

The development of renewable and low-carbon hydrogen is a current trend worldwide becoming a race for leadership on technologies, with more than 30 countries committed to the deployment of hydrogen in their energy system. In the United States, China, India, Australia, or Germany, renewable and low-carbon hydrogen will be used to decarbonize hard-to-abate sectors in complement to electrification.

The transport sector will also use renewable and low-carbon hydrogen to achieve its decarbonisation objectives. Mobility is one of the first and concrete application for hydrogen technologies: in key segments with sufficient technology readiness level (LCVs, taxis, buses), they can already be deployed now to answer transporters and logisticians’ needs for long autonomy, fast recharging time, and intensive uses. As for examples, 3 341 FCEV have been sold in 2021 in California and China has set a goal of using over one million FCEV for commercial purposes by 2030, with a reorientation of its subsidy policy.

France has chosen to invest near 9 billion euros in the deployment of a hydrogen market and has selected 5 main hydrogen transport projects for the Important project of common European interest (IPCEI) currently under preparation for hydrogen technologies. These five industrial chains will generate activities and jobs in France by producing key equipment and components for FCEV in the road sector:

  • Symbio (JV Michelin-Faurecia): R&D followed by a gigafactory for fuel cells for FCEV;
  • Faurecia: R&D followed by a gigafactory for hydrogen tanks for FCEV;
  • Plastic Omnium: R&D followed by a gigafactory for hydrogen tanks for FCEV;
  • Arkema: R&D followed by production of materials and components for hydrogen tanks and fuel cells;
  • Hyvia (JV Renault-Plug Power) development of FCEV and key bricks such as fuel cells and HRS.

To ensure a rapid and efficient deployment of this technology in mobility, it is necessary to have a robust and coherent deployment of HRS over the territory: France Hydrogène considers that up to 1 000 HRS should be deployed by 2030 in France to supply around 160 000 tons of renewable or low-carbon hydrogen to 300 000 light commercial vehicles, 5 000 heavy-duty vehicles, 65 boats and 100 trains (2). Unlike battery, where a domestic socket can be used to recharge a vehicle, the market will not take off without a first network of hydrogen refuelling stations.

The AFIR is an important milestone for the ramp-up of the hydrogen market which, through its ambitions in the deployment of HRS, can accelerate the entire development of the hydrogen industrial sector and provide visibility and certainty to investors, industrials, and project developers.

(1) Hydrogen Council, Roadmap towards zero emissions: The complementary role of BEVs and FCEVs, https://hydrogencouncil.com/wp-content/uploads/2021/10/Transport-Study-Full-Report-Hydrogen-Council-1.pdf

(2) France Hydrogène, A road-map for an ambitious hydrogen strategy. The hydrogen sector’s contribution to implementing the 2030 Hydrogen Strategy, September 2021,
https://s3.production.france-hydrogene.org/uploads/sites/4/2021/11/France_20Hydrog_C3_A8ne_road-map_20for_20an_20ambitious_20H2_EN_final__20Web.pdf