Special applications – White paper on filling athydrogen refuelling stations

Featured image Special refueling

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

Whitepaper as PDF for viewing and downloading:


The focus is on applications such as mobile energy supply systems, construction machinery, agricultural equipment and mobile hydrogen filling stations. The authors conclude that refuelling 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 helps manufacturers and operators identify and implement the necessary safety standards for safe refuelling.

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 refuelling
  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 roll-away locks and grounding during refuelling are recommended.


For further information on the white paper “Safe hydrogen refuelling for special applications at public and non-public hydrogen refuelling stations”, please contact:
Clean Energy Partnership
Marcus Merkel, marcus.merkel@cep.expert

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