Two major pieces of EU legislation that boost the use of hydrogen in transport — the Alternative Fuels Infrastructure Regulation (AFIR) and FuelEU — have today (Friday) become law after being published in the Official Journal of the European Union.

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The AFIR requires the 27 member states to ensure that publicly accessible gaseous H2 filling stations capable of serving both heavy-duty and light vehicles are set up in every “urban node” and every 200km along the core routes of the planned Trans-European Transport Network (TEN-T) by 2030.

The TEN-T core network links “urban nodes” — an EU term for 424 major cities in the bloc with ports, airports and rail terminals — across Europe and is expected to be completed by the start of next decade.

These stations also need to have a minimum capacity of one tonne of H2 per day and a 700-bar dispenser, although a 50% reduction in capacity is allowed if the road has an annual average daily traffic of fewer than 2,000 heavy-duty vehicles and “where the deployment of infrastructure cannot be justified in socio-economic cost-benefit terms”.

Danish hydrogen supplier Everfuel recently shuttered all of its refuelling stations in Denmark—permanently closing three and pausing “until further notice” two — in part due to a lack of compliance with AFIR, and is exploring potential redevelopment of some sites in line with these required capacities and locations.

Member states are required to update their national policy frameworks with a clear indicative target for 2027 towards meeting the scale of refuelling station deployment by the end of 2030.

FuelEU

FuelEU meanwhile aims to drastically reduce the greenhouse gas intensity of ships operating in Europe — both through greater energy efficiency and the use of RFNBOs (renewable fuels of non-biological origin), ie, renewable hydrogen and its derivatives, such as methanol, ammonia, or synthetic fuels.

All ships with a gross tonnage above 5,000, regardless of what flag they fly, will have to cut greenhouse gas emissions by 2% from the start of 2025 against a reference emissions intensity of 91.16 grams of CO2 equivalent per MJ of energy used. This progressively rises to 6% from 2030, 14.5% from 2035, 31% from 2040, 62% from 2045, and finally 80% from 2050.

However, in the calculations of greenhouse gas intensity, vessels will be rewarded for using RFNBOs between the start of 2025 and the end of 2033, allowing the double-counting of their emissions savings from using these fuels.

RFNBOs have 70% lower greenhouse gas emissions compared to fossil equivalents from “well-to-wake”, ie, including energy production, transportation, distribution and use or combustion on board the vessel. And the hydrogen feedstock for these fuels will also have to follow the criteria set out by the EU’s Delegated Acts, which were published into law earlier this year.

If the share of RFNBOs in maritime fuels used in the EU is less than 1% in 2031, the EU will set a target for ships to use 2% of these fuels in annual on-board energy consumption by the beginning of 2034.

This may seem like too small a target to really drive the uptake of hydrogen-based fuels by the maritime industry, particularly given these are unlikely to compete on cost alone.

Even companies that have already invested in new dual-fuel engines that can run on methanol, such as Maersk, have generally opted to run on either fossil-based or biogenic versions of the fuel due to the high cost and lack of availability of green H2 feedstock.

FuelEU’s preamble notes that although RFNBOs “present a high potential to meet decarbonisation needs in the maritime sector, it is possible that other fuels will also present comparable decarbonisation potential”.

As such, the legislation is designed to avoid “unduly discriminating” against ships that reduce emissions to the same level but through other fuels.