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RCS Database

Hydrogen Refueling Stations

Safe refuelling due to high standards

Hydrogen refuelling stations (HRS) are filling stations for refuelling vehicles with hydrogen. The basic regulations for HRS are defined internationally by ISO and CEN. By applying the established standards, appropriate safety measures and interoperability are ensured and potential damage during refuelling can be prevented.

Two pressure levels have become established for refuelling with gaseous hydrogen (GH2): 35 MPa (350 bar) for heavy commercial vehicles and 70 MPa (700 bar) for passenger cars. Refuelling with liquid (LH2) or cryo-compressed hydrogen (CcH2) is not currently carried out in Germany. HRS also differ in terms of their accessibility. HRS can be publicly accessible (classic refuelling station) or non-public, e.g. refuelling stations for depots. Furthermore, refuelling stations can be stationary or mobile.

The central international series of standards for refuelling gaseous hydrogen at HRS is ISO 19880-1 through 19880-10. Other important technical and legal regulations include AFIR, UN ECE-R134, DIN EN 17127, BetrSichV, GefStoffV, TRBS+TRGS, ÜAnlG, BImSchG/BImSchV.

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AFIR

Stationary HRS

Mobile HRS

Refuelling

Taxation

Transport

Targets in the area of hydrogen refuelling and charging infrastructure

Approval and important standardisation

Approval and installation at a new location

Nozzle, hydrogen quality and fuelling protocol

Basic regulation and taxation of H2 combustion vehicles

H2 transport via pipeline, trailer, train and ship

AFIR

Alternative Fuel Infrastructure Regulation

The Alternative Fuels Infrastructure Regulation (AFIR) is an EU regulation that replaces the Alternative Fuels Infrastructure Directive (AFID). It is immediately compulsory for all EU member states.

The AFIR sets targets in the area of hydrogen refuelling and charging infrastructure, shore-side power supply for maritime and inland waterway transport and ground power supply (i.e. in aviation). The AFIR also contains regulations regarding market surveillance, common standards, reporting obligations and obligations for infrastructure operators.

For hydrogen infrastructure, this means hydrogen refuelling stations must be installend along the Trans-European Transport Network (TEN-T) at a maximum distance of 200 km and in urban nodes by 2031. These must enable 700-bar refuelling and have a capacity of at least one tonne of hydrogen per day. ‘Along’ the TEN-T network means that the HRS must not exceed a distance of 10 km from the TEN-T network.

Certain standards are laid down in the AFIR, with which compliance is mandatory. Of significance in the area of hydrogen infrastructure is the EN 17124, which sets out requirements for hydrogen quality for refuelling on the road; the EN 17127, which sets out specifications for HRS; and the EN 17268, which specifies the refuelling nozzle.

The AFIR reporting obligation requires member states to produce a National Strategy Framework (NSR). In this paper, the member states are to submit their implementation strategy for achieving AFIR targets to the EU Commission. This must be submitted to the EU Commission by the end of 2025.

Stationary HRS

Approval

NOW GmbH has published a guide to inform about the approval process for hydrogen refuelling stations (HRS). This guide was developed in collaboration with the relevant authorities and industry partners.

At the heart of the brochure is the permit guide, which is based on the approval procedure according to §18 of the German Ordinance on Industrial Safety and Health (BetrSichV). It contains in-depth information and best practice experiences. Additionally, the guide features checklists of standard documents and expert reports, details of key stakeholders, and an example diagram outlining the approval process. While not a regulatory framework, the publication is intended to support and provide orientation for approval procedures related to hydrogen refuelling stations.

It is primarily aimed at investors, station operators, authorities and inspection organisations. It is also intended to support investors, developers and operators of HRS facilities, as well as regional and local authorities, throughout the approval process. In doing so, it considers technical, safety-related and regulatory aspects.

It covers HRS stations for road vehicles and publicly accessible refuelling stations with a maximum H₂ storage tank volume of less than three tonnes. The legal requirements for the continued operation of HRS delivery vehicles are not included in the guide. Similarly, the filling process of the HRS low-pressure tank is not included.

The guide takes into account the current national regulations applicable in the Federal Republic of Germany. Differences in regulations between the individual federal states are not addressed.

ISO 19880 Series
The central standard for hydrogen refueling stations (HRS) is the ISO 19880: ISO 19880-1 to ISO 19880-10. It includes a general part, ISO 19880-1, which forms the basis for the other, more specific parts. ISO 19880-2 to ISO 19880-7 describe various components of HRS, such as the dispensing system (ISO 19880-2) or shut-off devices (ISO 19880-3). For the components described or their individual parts, there are usually separate standards referenced within the ISO 19880 series. ISO 19880-8 and ISO 19880-9 are standards for the correct determination of hydrogen quality at refueling stations. These standards reference ISO 14687, which defines the different grades of hydrogen quality. For fuel cell applications, Grade D (H2 purity of 99.97%) is recommended according to ISO 14687, as this ensures hydrogen gas is largely sulfur-free. This quality grade is also specified in the DIN EN 17124 standard. DIN EN 17124 is the European standard for hydrogen as a fuel and has been established in the AFIR and the BImSchV. As a result, only hydrogen of fuel cell quality may be dispensed at public hydrogen refueling stations in Europe.

Mobile HRS

Approval

A mobile hydrogen refuelling station (mobile HRS) is a transportable HRS. In addition to the requirements for stationary HRS, the Ordinance on Transportable Pressure Equipment (ODV) also applies. The ODV implements the EU directive “Transportable Pressure Equipment Directive” (TPED).

Furthermore, the transport of hydrogen and the approval of vehicles are adressed in the Ordinance on the Transport of Dangerous Goods by Road, Rail and Inland Waterways (GGVSEB), which is based on the Agreement concerning the International Carriage of Dangerous Goods by Road (ADR).

In the field of mobile HRS, the technical rules TRBS 3151/TRGS 751 are also of importance. These rules specify the German Ordinance on Industrial Safety(BetrSichV) and the Ordinance on Hazardous Substances (GefStoffV), and include an annex containing technical rules specifically for mobile HRS.

A standard for mobile HRS, ISO 19880-10, is currently under development. It is intended to include various technical specifications as well as information on safety, inspection, and testing of mobile HRS.

Currently, mobile HRS are manufactured and offered by only a few providers. In most cases, the manufacturers also offer support during installation and for the approval process.

Installation of a mobile HRS at a new location

The defining characteristic of a mobile hydrogen refueling station (mobile HRS) is its transportability. When relocating a mobile HRS to a new site, a full approval process does not have to be repeated. However, a wide range of conditions must still be met, which limits its mobility.

A mobile HRS may only be put into operation after a certificate has been issued by an approved inspection body (as defined in the Ordinance on Industrial Safety – BetrSichV). It must also be verified that the requirements of the Ordinance on Industrial Safety (BetrSichV), the Ordinance on Hazardous Substances (GefStoffV), and the Federal Immission Control Act (BImSchG) continue to be fulfilled. In addition, compliance with the Act on Installations Requiring Supervision (ÜAnlG) and the specifications outlined in the DEKRA inspection report is mandatory.

Furthermore, the local responsible authorities should be informed, and an on-site appointment should be made possible. In addition, the mobile HRS must be secured with a designated collision protection system in accordance with VdTÜV 965 Parts 1–3.

Refueling

Nozzle

Gaseous hydrogen must be dispensed at an H35 and/or H70 filling unit (350 bar or 700 bar) using appropriately rated components, with the dispensing nozzle being compatible with the vehicle. It must comply with EN ISO 17268, which is also mandated by the AFIR. A unified standard for the filling nozzle for LH2 is currently under development as ISO 25578.

In addition, a standard for a heavy-duty nozzle for compressed gaseous hydrogen (CGH2) is being developed  (ISO 17268-2), and a nozzle for cryo-compressed hydrogen (CcH2) is being planned (ISO 17268-3).

Quality

The hydrogen quality at the dispensing nozzle for use in fuel cell electric vehicles (FCEVs) with PEM fuel cells must be sulfur-free and must comply with the requirements of EN 17124 according to the Alternative Fuels Infrastructure Regulation (AFIR). This corresponds to Grade D in ISO 14687, while for hydrogen combustion engines, both Grade D and Grade F, as described in the annex of ISO 14687, could be used.

Fuelling protocol

Requirements for the dispensing of gaseous hydrogen are defined in ISO 19880-1 and, at the European level, in DIN EN 17127. This standard establishes the basic conditions for the actual fueling protocols, which are described in ISO 19885-1. ISO 19880-1 prescribes various pre-tests, malfunction tests, response tests, capacity tests, and optional implementation tests.

ISO 19885-1 enables fueling rates of up to 120 g/s and filling volumes of up to 10 kg for nearly all vehicle types. To allow for higher fueling speeds and volumes in the heavy-duty (HD) vehicle sector, a specific HD fueling protocol is currently being developed by ISO/TC 197/WG 24 as ISO 19885-3. This protocol builds upon ISO 19885-1, prior work from the PRHYDE project, and SAE J 2601/5. ISO 19885-3 is also intended to be compatible with the already established standards to ensure interoperability and avoid mismatches between all requirements.

The heavy-duty protocol is designed to enable a maximum refueling rate of 300 g/s and 200 kg per refueling event for HD vehicles.

ISO series: ISO 19885-1, ISO 19885-2, and ISO 19885-3

  • ISO 19885-1 serves the general definition and development of a fueling protocol and has already been published.

  • ISO 19885-2 defines the communication interface between the vehicle and the HRS.

  • ISO 19885-3 defines the HD refueling protocol.

The refueling process for liquid hydrogen must be carried out in accordance with ISO 13984. A standard for fueling cryo-compressed hydrogen (CcH₂), ISO 24925, is currently under development.

Taxation

The basis for hydrogen taxation is the European Energy Taxation Directive (ETD), which is implemented nationally through the German Energy Tax Act (EnergieStG).

When hydrogen is used as an energy carrier for the generation of mechanical energy in a combustion engine, it is defined as a fuel under the Energy Tax Act and must therefore be taxed equivalently to natural gas (equivalence principle). According to the Energy Tax Act, the tax debtor in the case of refueling for combustion engines is the invoice issuer. Hydrogen is also subject to the Energy Tax Act when used to operate turbines, as this also involves a conversion into mechanical energy.

Currently, no tax is applied when refueling a fuel cell electric vehicle (FCEV), due to a lack of specific definition in the Energy Tax Act. However, this may change with a planned revision of the ETD.

The tax differences between FCEVs and internal combustion engine vehicles (ICEs) were highlighted in a study by the German Hydrogen and Fuel Cell Association (DWV).

Hydrogen Transport

The efficient Europe-wide distribution of produced or imported green hydrogen is one of the key tasks in the expansion of the hydrogen infrastructure. In the future, various distribution technologies and different physical states of hydrogen are expected to be used.

While the transport of compressed or liquefied hydrogen primarily involves regulations concerning pressure and cryogenic containers (e.g. Pressure Equipment Directive (PED), Transportable Pressure Equipment Directive (TPED), German Ordinance on Industrial Safety and Health (BetrSichV), and the ATEX Directive), the transport of hydrogen in the form of chemical derivatives such as LOHC or NH₃ is subject to chemical safety regulations (e.g. REACH, the German Ordinance on Hazardous Substances – GefStoffV). An important standard in the field of hydrogen transport is EN 17339, which defines the requirements for transportable gas cylinders for hydrogen.

For transport purposes, the physical state of hydrogen is a crucial factor. Depending on its state, the method of storage varies significantly. As a result, different sets of standards must be observed depending on the type of storage used.

Pipeline

Transporting hydrogen and its derivatives via pipeline is the most cost-effective method in the long term for distributing large quantities of hydrogen over long distances. However, a pipeline network involves very high investment costs and will not pay off in the short term. In this context, it would be advantageous to convert the existing natural gas pipeline network—which is gradually being phased out as part of the energy transition—to hydrogen or its derivatives. Corresponding ISO standards are currently under development.

When converting the pipeline network, attention must be paid to the hydrogen quality. In this regard, Annex D of DVGW G260 can be applied. The technical conditions are specified in DVGW G 463 and DIN EN 1594. From a legal perspective, the Energy Industry Act (EnWG), the Ordinance on High-Pressure Gas Pipelines (GasHDrLtgV), and the Incentive Regulation Ordinance (ARegV) are highly relevant to the conversion of the pipeline network. For pipeline safety issues, reference can be made to ISO 15916. Currently, there is an ongoing discussion among European member states regarding the purity level to be targeted across the entire network. A possible target value is a purity of 99.5%.

A scenario for the initial expansion phase of the hydrogen core network has been established in the EnWG. The hydrogen core network approval foresees an H₂ network with a length of 9,700 km, of which 40% will be newly laid pipelines and 60% converted natural gas pipelines. The investment costs are expected to amount to approximately 18.9 billion euros.

The German Energy Agency (dena) and NOW have jointly developed a study investigating the supply of hydrogen refueling station infrastructure in Germany via a pipeline network. As a result of this study, supplying hydrogen refueling stations (HRS) by truck from an H₂ hub connected to the hydrogen core network was assessed as particularly advantageous from a technical and economic perspective. The study also includes important recommendations for action regarding the expansion of the hydrogen pipeline and HRS infrastructure.

Trailer and Rail

The transport of gaseous and liquid hydrogen by trailer on roads and railways is subject to the German Ordinance on Transportable Pressure Equipment (ODV), as well as the EU-level Transportable Pressure Equipment Directive (TPED), and national dangerous goods legislation. The German Regulation on the Transport of Dangerous Goods by Road, Rail, and Inland Waterways (GGVSEB) specifies the provisions of the Dangerous Goods Transportation Act (GGBefG). These laws incorporate the Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) and the Regulations concerning the International Carriage of Dangerous Goods by Rail (RID) into national law.

A key area for development is the interoperability between road (ADR), rail (RID), inland waterways (ADN), and maritime transport (IMDG Code). It is necessary to define how a smooth regulatory transition between different modes of transport can be ensured in order to enable uninterrupted hydrogen transport.

The approval of fuel cell electric vehicles (FCEVs) for the transport of dangerous goods—including hydrogen—will be permitted starting January 1, 2025, for dangerous goods classes FL and AT. Battery electric vehicles (BEVs) have already been eligible for approval for the transport of dangerous goods since 2023.

Maritime Transport

In addition to the Ordinance on Transportable Pressure Equipment (ODV), the transport of dangerous goods by sea is governed by the German Maritime Dangerous Goods Ordinance (GGVSee), which implements the international IMDG Code. The GGVSee also specifies the provisions of the Dangerous Goods Transportation Act. For inland waterways, on the other hand, the Regulation on the Transport of Dangerous Goods by Road, Rail, and Inland Waterways (GGVSEB) applies, which implements the requirements of the European Agreement concerning the International Carriage of Dangerous Goods by Inland Waterways (ADN).

In the field of maritime transport, the transport of liquid hydrogen (LH₂) is of particular importance for the future. The global fleet of hydrogen tankers currently consists of only a few initial vessels. One example is the hydrogen tanker Suiso Frontier by Kawasaki Heavy Industries. For the transport of liquid hydrogen by ship, the International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code) is especially relevant.

RCS is the abbreviation for Regulations, Codes and Standards. The goal of standardization is the planned unification of tangible and intangible objects, carried out jointly by interest groups, for the benefit of the general public.

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