Hydrogen regulations: Compliance by design

Hydrogen technology is developing at lightning speed, especially in the automotive sector. However, innovations are regularly delayed or even brought to a halt due to complex and internationally varying regulations. This is particularly true for systems with pressure components or mobile applications, where the requirements differ greatly by region and application. Kiwa expert Leendert van der Marel therefore advocates a clear approach: design hydrogen systems with regulations in mind from the very beginning.

More and more projects, especially those involving pressure components or fuel systems, are being delayed, modified or even cancelled altogether due to non-compliance with regulations. Why is that? Leendert van der Marel: ‘The regulations for hydrogen systems vary not only by region, for example, the EU versus the US, but also by application: there are different standards for on-road vehicles, off-road vehicles and mobile storage units.’

Fragmented regulatory landscape

Hydrogen applications vary greatly in how and where they are used:

  • On-road vehicles must comply with standards such as UN-ECE R134 in the EU and HGV 3.1 in the US.
  • Off-road vehicles operating on private property or in commercial zones may fall under ADR/TPED guidelines in Europe or separate Department of Transportation (DOT) classifications in the US. This may vary per region.
  • Mobile pressure system applications (such as hydrogen trailers) in the US typically fall under the DOT’s ADR/TPED regulations. Standards commonly used here include ISO 11119-3 and EN 12245, although other standards may also apply.

Van der Marel: ‘Some regulatory frameworks, such as the Global Technical Regulation (GTR 13), aim to harmonize requirements, but differences in interpretation and enforcement remain significant, between jurisdictions and even between countries within the same region.’

Different testing methods

Even for something as fundamental as tank testing, requirements can vary greatly:

  • Hydrogen storage for on-road vehicles often requires both hydraulic and pneumatic tests, using real hydrogen, following complex testing procedures.
  • Mobile or off-road systems are sometimes only tested hydraulically under specified pressure and temperature cycles, in accordance with EN or ISO standards.

Van der Marel: ‘If you don’t take these differences into account from the start of a project, costs and delays can quickly add up. Especially for projects aimed at multiple markets.’

Design with legislation in mind

In Kiwa’s view, manufacturers of hydrogen systems should apply the principle of “compliance by design”. ‘Pay close attention, from an early stage in the project, to both the applicable standards and their practical interpretation and testing methods,’ says Van der Marel. ‘Always design with the intended application in mind: a tank that is suitable for a bus is not necessarily suitable for a tank rack. This helps prevent innovations from getting stuck in regulation.’

Kiwa and hydrogen in automotive

With over 25 years of experience and the world’s largest test facility for high and low pressure hydrogen as well as cryogenic hydrogen, Kiwa supports the testing, inspection, and certification of hydrogen systems for all mobility applications, from automotive to aerospace and maritime sectors. On our website, you can read more about Kiwa’s expertise in hydrogen and automotive.

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