With the AFIR, Europe has created an important framework for the development of hydrogen infrastructure – especially for heavy goods traffic. However, experience from planning and operation shows that AFIR-compliant does not automatically mean practical. A filling station can formally meet all requirements – and still reach its limits during operation, for example in terms of refueling capacity, availability or accessibility for heavy goods vehicles.
This is precisely where the CEP recommendation comes in: The existing targets for the coming years remain an important basis. However, the decisive factor is how infrastructure is technically designed, evaluated and operated. The recommendation builds on the Clean Energy Partnership’s existing technical reference papers on AFIR requirements and the design of high-performance hydrogen refuelling stations for heavy-duty commercial vehicles – and translates this experience into concrete requirements for regulation and implementation.
A central point is the understanding of capacity: for heavy goods traffic, it is not the nominal daily capacity that is decisive, but the actual available delivery capacity in the relevant time window. Infrastructure must be designed in such a way that back-to-back refuelling, stable refuelling profiles and a reliable state of fill are possible under real conditions.
This results in specific requirements for system design and operation – for example with regard to dispenser capacity, storage and compressor design and thermal management.
A differentiated technological approach is also required: 350 bar as an established standard, 700 bar as a central reference point for new applications and liquid hydrogen (LH₂) for high throughputs and long-distance transportation. These options are complementary and must be made interoperable via clear interfaces, protocols and standards.
In addition to the technology, implementation remains a bottleneck: complex approval procedures, inconsistent requirements and a lack of clarity regarding responsibilities are delaying the expansion.
The CEP recommendation bundles this technical and operational experience and shows how the AFIR can be further developed so that infrastructure is not only compliant with regulations, but also functions reliably in real-life use – and thus becomes a viable basis for the decarbonization of heavy goods transport.
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