1) The European Hydrogen Association welcomes the European Commission's initiative to develop a regulation for the type-approval of hydrogen vehicles. A unified European regulation will help build local expertise and infrastructure for hydrogen vehicles and fueling by 2015. 2) The transition to hydrogen vehicles will require public funding and support for adapting existing fueling infrastructure, which differs by Member State. Regulations should include vehicles using hydrogen-natural gas mixtures to avoid competitive disadvantages between countries. 3) Regulations should also cover detachable hydrogen containers for small vehicles like scooters. Certification is important to facilitate the market introduction of hydrogen vehicles and a second-hand market.

1. European Hydrogen Association
Gulledelle 98 - B 1200 Brussels - Belgium
tel. +32 2 7759077 - fax. +32 2 7725044 - www.h2euro.org - info@h2euro.org
EHA Contribution to the consultation
on the hydrogen proposal
Brussels, September, 2006
The European Hydrogen Association (EHA) welcomes the initiative of the
Directorate General Enterprise and Industry to prepare a Preliminary draft
proposal for a Regulation of the European Parliament and the Council, relating to
the type-approval of hydrogen powered motor vehicles. As car manufacturers are
getting ready for the commercial production of hydrogen vehicles by 2015, local
expertise with hydrogen vehicles and hydrogen refueling installations needs to be
built up in a relatively short time. The European Regulation will allow local
authorities to obtain local experiences with hydrogen vehicles on their streets and
facilitate the involvement of local industries to develop innovative solutions
adapted to a specific location. A European Regulation will also send a strong
signal to international investors that Europe is serious about the development of
the necessary regulatory framework for a hydrogen infrastructure. Last but not
least a European Regulation will ensure the consumer that hydrogen vehicles are
a safe and clean alternative contributing to a cleaner European transportation
system .
The EHA, with its unique membership structure of the main Hydrogen producers
and distributors plus national member associations, has been active in European
initiatives as the European Hydrogen and Fuel cell Technology Platform, to
ensure that European developments are translated to local levels and vice versa.
We would therefore like to offer some suggestions to ensure that the Regulation
will be effectively implemented at national level and will enhance local initiatives
that have been successfully started throughout Europe:
1. The transition to a hydrogen based transport fuel supply will not happen
overnight and not without public financial support. As the fuel supply
infrastructure differs from Member State to Member State the
development of a hydrogen refueling infrastructure will be different in each
country. Public funding will tend to support measures that adapt the
existing refueling infrastructures to hydrogen transport applications. In
addition the local availability of different types of hydrogen vehicles, as
fuel cell powered vehicles or vehicles that use hydrogen to power
conventional engines, will determine the choice for different hydrogen

2. European Hydrogen Association
Gulledelle 98 - B 1200 Brussels - Belgium
tel. +32 2 7759077 - fax. +32 2 7725044 - www.h2euro.org - info@h2euro.org
supply solutions. Recently the use of a mixture of hydrogen and natural
gas in areas with an existing gas refueling infrastructure is being looked at
as a transition solution towards a sustainable hydrogen infrastructure. On
Member State level authorization of vehicles that are using this mixture
has not been dealt with in a consistent manner; in some countries they are
simply authorized when the percentage of hydrogen is up to a certain level
in others authorization is more difficult. The EHA therefore suggests to
include the regulation of vehicles that are using hydrogen/natural mixtures
up to 30% in the Regulation to avoid unnecessary competitive advantages
resulting from these national differences.
2. For smaller vehicles as scooters detachable hydrogen containers that
could be changed with a fast click-on operation are being developed (EU
supported Hychain project). The EHA suggests to include regulation of
these solutions for smaller transport applications..
3. To facilitate a smooth market introduction of hydrogen vehicles
Certification is an important aspect to allow for example the development
of a transparent second hand market. The EHA urges the European
Commission to actively pursue the certification of hydrogen vehicles.