THE NEED FOR A COMBINED APPROACH TO ZERO-EMISSION TRANSPORT
Battery electric vehicles (BEVs) and hydrogen vehicles (fuel cell electric vehicles (FCEVs) and hydrogen internal combustion vehicles (H2ICE)) are often framed as competing technologies. Instead, they are both contributing to the same objective: decarbonising the entire fleet of fossil fuel-based internal combustion engine (ICE) vehicles.
BEV sales continue to increase - 20.8% of new cars sold in the EU are electrically chargeable (battery electric and plugin hybrid), but they only account for 3.9% of all cars on the road today. Petrol still dominates EU car sales, accounting for 33.3% of all new registrations in 2024.1
Each new BEV and FCEV/H2ICE on the road helps to accelerate the transition to decarbonised transportation, which is still in its infancy.
Hydrogen Europe warmly thanks all the members that contributed to our #NextStopHydrogen campaign.
In a CO2 life cycle assessment, BEVs and FCEVs are similarly beneficial
Apart from energy efficiency, CO2 emissions are obviously a critical factor for technology decisions. BEVs and FCEVs can have similar life cycle emissions (also considering the manufacture of the vehicle and all emissions related to the refuelling/recharging infrastructure).
While BEVs are powered by grid electricity, dedicated renewable or low-carbon hydrogen infrastructure produces hydrogen with very low carbon emissions. Furthermore, transporting hydrogen via ship or pipeline results in low emissions, meaning even the conversion steps between production and usage of hydrogen do not impact the carbon balance materially.
Usage of FCEV especially in high-capacity and high-power applications reduces need for battery minerals as well as grid upgrades.
-> For batteries, supply shortages of Cobalt and Nickel are forecasted as early as 2030. Furthermore, strengthening the electricity grids will need massive amounts of copper in transformers and transmission lines.
-> While the increased demand for platinum and iridium in fuel cells and electrolysers also raises concerns, this can be counteracted with the recycling of combustion engine catalytic converters.
-> In a combined world, demand peaks can be flattened as there is less dependence on single materials. Especially when replacing some large batteries with fuel cells, the effect becomes most noticeable.
Hydrogen mobility: two is better than one
Hydrogen can reduce peak loads and necessary grid upgrades: When it comes to the mobility sector, the only sector whose emissions have not decreased yet, decarbonising the EU road fleet through the deployment of two technologies can reduce risk and would cost less from an infrastructure perspective than if only BEV infrastructure were deployed.
It may seem counterintuitive, but building a hydrogen refuelling network alongside battery charging infrastructure is cheaper than building a charging infrastructure that is powerful enough to cover all use cases, including those with high power demands and little charging capacity. Even if only 10% of EVs are powered with fuel cells, the lower resulting necessary upgrades to the electricity grid in hard-to-serve and high-demand areas delivering tangible cost savings.
-> Cost
- The Clean Hydrogen Partnership found that a 100% BEV ecosystem could cost €3 trillion to €5 trillion more through 2050 from an infrastructure perspective than a combined ecosystem2.
- In a combined world with 90% BEV and 10% FCEV penetration, the cost of additional hydrogen refuelling stations is more than offset by savings in charging equipment and corresponding grid upgrades Replacing hardest-to-abate passenger BEV use cases that rely heavily on public fast charging with FCEV disproportionately reduces grid upgrade needs.
-> Resource scarcity
- The development of multiple technologies can also reduce the risk of resource exhaustion and alleviate other deployment bottlenecks that might arise should only one technology be pursued.
- Last, the availability of both technologies could accelerate the adoption of zero emission solutions as users gain the ability to choose between power trains based on their needs.
In the context of current geopolitical scenarios, the potential of hydrogen to reduce pressure and dependency from global suppliers of critical raw materials, where China is expected to dominate, should not be overlooked.

Figure 1: Source (Hydrogen Council 2021)

Figure 2: Comparison of cumulative investment of supply infrastructure (Source: BMW)

Figure 3: Critical mineral needs for clean energy technologies (Source: IEA)
ROAD
Light duty (below 3.5 tons) and public transport
Next to battery electric solutions, hydrogen vehicles provide further push to decarbonise the urban and peri-urban environment: with faster refuelling times, longer range and zero emission powertrain, they are suitable for intensive use and long range. Within cities, taxi fleets represent an optimal use of such vehicles, but so are buses and urban refuse trucks, as all of them must operate for long periods of time each day.
Battery electric vehicles represent the majority of today’s alternative fuelled fleet, there is no question about that. It is also clear that the hydrogen fleet is growing substantially since early deployment a decade ago, despite the technology still being at demonstration phase at the time:
In those contexts, the priority should not be to arbitrarily pick a powertrain over other, but rather to figure out how to replace current fossil fuelled operations with a zero-emission alternative while guaranteeing the same level of performance and operational availability. Moreover, other variables should be considered, e.g. access to the electricity grid, possibility and cost of installing chargers at depot, local topography, length and timing of routes etc…
As shown in the graph below3, half of European scheduled bus mileage will be challenging to convert to battery electric operations in 2030, with a third still challenging in 2050.
The study shows that while bus operators will decarbonise with battery-electric motors where possible without needing additional assets such as extra vehicles or non-depot charging infrastructure. Where the BEB can either complete a full daily duty in the worst climatic conditions on a single overnight charge (“Straightforward”) or can do so by using vehicle downtime in existing schedules to charge at depot during the day (“Manageable”).
Policymakers and operators expecting to decarbonise local bus networks with BEBs in the 2030s – or even by 2050 – will eventually need to reflect on the large red block marked Challenging: half of European scheduled bus mileage will be challenging to convert to BEB in the 2030, with a third still challenging in 2050.
It should not be forgotten that both batteries and hydrogen come with their own sets of strengths and weaknesses; this does not mean any of the two should be discarded just because challenges exist.
A combination of grids being close to full saturation (as in the case of the Netherlands)4, decarbonisation targets, and demanding operational profiles could lead a public transport operator to pick fuel cell buses over battery electric buses, even if the latter are cheaper and more efficient.

Figure 4: Hydrogen light duty vehicle and public transport fleet (Source: EAFO)

Figure 4: Modelled BEB compatibility with current European bus mileage. (Source: JIVE Mehrlin Project)

Figure 5: Major advantages and challenges for BEVs and FCEVs (Source: EIT Urban Mobility)
The vehicle offer is growing and becoming more articulated to cover as many use cases as possible. Passenger cars from Toyota, Hyundai and (soon) BMW, fuel cell vans from Stellantis, buses from Solaris, Iveco, Hyundai, Mercedes-Benz, Caetano, Rampini, Wrightbus and Arthur Bus. Not to mention companies providing fuel cells and combustion engines for vehicles including, but not limited to, Symbio, Phinia, cellcentric, Cummins, Cespira.
A large vehicle offering allows end users to pick their best configuration to ensure the best possible performance while keeping the total cost of ownership under control. Manufacturers help in that by designing vehicles that run on zero emission drivelines without losing cargo capacity nor payload thanks to efficient solutions.

Figure 6: Current electricity grid transport capacity in the Netherlands (Red = Congestion management offers no or insufficient solution, there is a waiting list and there is no room to offer customers the transport capacity they require)
HEAVY DUTY TRANSPORT
Trucks are the backbone of the European transport sector. However, the demand for road transport services remains such that every improvement, be they related to higher fuel efficiency or alternative fuelled vehicles, is offset. Reversing this trend means making every single solution count - and hydrogen fuel cells and hydrogen-combustion engines are sorely needed.
Also, reversing the trend means realising once more that battery electric vehicles are no silver bullet. A full electric commercial road transport sector would imply that every heavy-duty charging station is equipped with 20 to 50 megawatt charging bays, an energy load comparable to a town of 15,000 inhabitants. In other words, if we wanted to switch all six million trucks in Europe to battery-electric drive, we would need around 350 TWh of green energy per year to charge them. To put the number in context, Germany’s total electricity demand in 2023 was around 500 TWh.
Moreover, battery electric trucks require investment in the power grid, the provision of energy volumes in charging parks, high and medium voltage grids, greater space requirements for charging infrastructure, and the need for active cooling. All of this gets exponentially more complicated and expensive in a full-electrification scenario.
The battery and hydrogen industries should not fight each other. Every extra fossil fuelled heavy-duty vehicle that can be replaced by a zero-emission initiative is a positive. For this sectoral transformation to accelerate, the guiding principle should be the notion of complementarity: the solution is batteries and hydrogen.
Except for Hyundai XCient truck, in series production since 2019, hydrogen heavy-duty vehicles are gradually entering the market with pre-production series and real-life tests. Other companies developing trucks include Daimler, which recently completed a 1047km journey in its hydrogen fuel cell truck without refilling, Volvo, Iveco, MAN, Ford.
The 2020 European Sustainable and Smart Mobility Strategy includes a non-binding milestone of 80 thousand heavy-duty trucks in operation by 2030 to achieve decarbonisation targets. Over time, the number has been reviewed to reflect the urgency of the transition: in 2022, Hydrogen Europe estimated 50 thousand hydrogen trucks in operation by the end of the decade. Two years later, vehicle manufacturer association ACEA stated that a minimum of 400 thousand vehicles, including 70 thousand running on hydrogen, should be on the road to enable the industry to meet the 2030 CO2 emission reduction target:
Hydrogen vehicles offer longer range, shorter refuelling time and smaller payload losses than battery electric trucks which makes them suitable to meet demanding operating conditions of fossil long haul transport operations. It should also not be forgotten that the deployment of hydrogen heavy duty vehicles generates virtuous cycles whose effects are felt by other transport modes:

Figure 7: Comparing medium-sized hydrogen trucks to other propulsion methods. Source: Hylane

Figure 8: The evolution of the EU's hydrogen truck fleet. source: EAFO

Figure 9: CO2 targets: zero emission vehicles and infrastructure needed (Source: ACEA)

Figure 10: Heavy duty fuel cell vehicles will open the door for the scaling of other hydrogen mobility solutions (Source: Hyundai)
ENABLING CONDITIONS
The switch to zero emission transport requires more than just vehicles. Cheap hydrogen must be available in the first place and must be dispatched and distributed from main entry and production points to a widespread refuelling network using pipelines and tube trailers.
Decarbonisation is a puzzle and trucks are just a piece of it, albeit an important one. Work on enabling conditions is underway to make sure all remaining pieces come together as fast as possible.
AFIR revision
The Alternative Fuels Infrastructure Regulation is the EU’s flagship law for the recharging and refuelling of alternative fuel vehicles and covers all transport modes. In force since 2023, the Regulation mandates the deployment of a hydrogen refuelling infrastructure network for road vehicles. It is important to stress that targets set in the Regulation are meant to provide the absolute minimum necessary to support the transition towards zero emission transport.
Article 6 requires Member States to install one HRS every 200km along the TEN-T Core Network with a daily capacity of one tonne, plus an additional tonne of hydrogen to be available at every urban node daily. The Regulation sets an intermediate deployment target in 2027 to ensure consistent ramp up with a view to have a complete refuelling infrastructure network by the end of 2030.
To find out more about position on AFIR, read here.
To find out more about our AFIR HRS mapping, read here.

Sustainable Transport Investment Plan
The Sustainable Transport Investment Plan (STIP) is one of the proposals included in the recent Industrial Action Plan for the Future of the Automotive Sector13, also known as the Automotive Action Plan. To be adopted in the course of 2025, STIP will make additional proposals for actions to remove barriers to scale-up the financing for recharging infrastructure.
CO2 standards
Since 2019, the European Union has set binding emission reduction targets for the automotive sector, both to reduce tailpipe emissions from vehicles and support the uptake of zero emissions solution in the medium to long term. Two separate Regulations are now in force, one for light duty vehicles (cars and vans) and one for heavy-duty vehicles (trucks and buses). The HDV Regulation targets a 90% emission reduction by 2040, with a 100% emission reduction target for urban buses in 2035. The LDV Regulation mandates that all new vehicles sold in the EU should be zero emission from 2035.
To find out more about our position on CO2 Standards for LDVs, read here.
Weights and Dimensions
Alternative fuels powertrains are bigger and heavier than conventional engines. In order for them to be installed in compliance with maximum limits set by EU rules, compromises would be required on payload, with devastating consequences for road transport companies who always operate on very thin margins. To alleviate the pressure and provide an incentive to switch to clean drives, the Weights and Dimensions Directive grants additional length and weight to zero emission HDVs, meaning that trucks and buses can carry the same amount of goods and passengers while running on zero emission solutions.
The revision of the Directive is currently underway, it is crucial that Member States reach an agreement and implement it without delay.
To read more about our position on the Weights and Dimensions Directive, read here.
Funding for hydrogen mobility
When it comes to fighting climate change, Europe is at crossroads; time is running out and climate targets set by the previous Commission are yet to be fully translated into reality. This limbo opens the door for criticism and political backlash. This is especially the case for road transport, a sector that is extremely sensitive politically yet sorely needs support to decarbonize faster. Hydrogen Europe is fully committed to contributing to the transition towards a climate neutral Union and, for this reason, believes that existing financing tools for the decarbonisation of road mobility should be updated and upgraded for targets to materialize. This should be done with instruments like (but not limited to) the Innovation Fund the H2 Bank and the upcoming Sustainable Transport Investment Plan (STIP), with measures focused on OPEX support in the short term.
Figure 12: Cost and revenue evolution of a hypothetical HRS (Source: CEPS)
Also, best practices like the Dutch SWiM programme should be extensively replicated all over Europe.
To read more about our position on funding for hydrogen mobility, read here.