Illustration of three vehicles on a light-colored background: excavator, forklift, tractor (from left)

The increasing use of hydrogen as an energy carrier in various areas beyond road transportation poses new challenges for the refuelling infrastructure. A current CEP white paper “Safe refueling with hydrogen for special applications at public and non-public hydrogen refueling stations” addresses this development and offers solutions for the technical and regulatory issues involved in refueling special hydrogen applications.


The focus is on applications such as mobile energy supply systems, construction machinery, agricultural equipment and mobile hydrogen filling stations. The authors conclude that refueling these special applications is technically feasible, but requires a clear regulatory framework that has not yet been comprehensively defined.


A key challenge lies in the different certification and testing requirements for special applications compared to road-approved vehicles. While the latter are approved in accordance with UN/ECE regulations or EU regulations, special applications are often subject to the Machinery Directive or the Pressure Equipment Directive.


To close this regulatory gap, the white paper provides a detailed gap analysis of the technical requirements. This analysis supports manufacturers and operators in identifying and implementing the necessary safety standards for safe refueling.

The core recommendations of the white paper include:

  1. Component qualification according to UN/ECE R134 and EU 2021/535 as the basis for safe refueling
  2. Flexible verification for non-certified components by combining relevant standards
  3. Consideration of specific requirements for different application types
  4. Two-stage approval process: manufacturer documentation and operator approval


In addition, practical safety measures such as anti-roll bars and earthing during refueling are recommended.


For further information on the white paper “Safe refueling with hydrogen for special applications at public and non-public hydrogen refueling stations”, please contact:

Clean Energy Partnership
Marcus Merkel, marcus.merkel@cep.expert

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