Hydrogen powered motor vehicles - summary of contributions
Preliminary draft proposal for a Regulation on hydrogen powered motor vehicles - Summary of Results of Internet Consultation
The Commission has formulated a preliminary draft proposal for a Regulation on hydrogen powered motor vehicles [87 KB] . The objective of the draft is to lay down harmonised testing requirements for the type-approval of hydrogen powered vehicles. As part of the process of finalising the proposal, an internet consultation was carried out in order to gather the views of all interested parties on the Commission's preliminary draft.
A total of 19 replies were received to the request for comment. Of these the breakdown by source is as follows:
- Government 1
- Industry 17
- Academia 1
The summary below only covers some of the main elements identified by the stakeholders. All the contributions received can be found here.
1. General comments
A number of stakeholders expressed general support for the proposal. It was argued that the introduction of hydrogen powered vehicles in the European type-approval framework would clarify the legal situation and encourage the placing of the market of the technology. Some stakeholders mentioned that the present case-by-case approval procedure is cumbersome and imposes high financial burden on the industry. It was also highlighted by some that the draft proposal will increase public confidence in this new innovative technology.
2. Concept of legislation
Many stakeholders commented that it is necessary to set common performance-based requirements in the co-decision proposal that would be applicable to all hydrogen storage forms. The specific testing requirements for liquid and gaseous storage systems should be set in the comitology legislation. They argued that by having a framework Regulation, this approach would enable the facile introduction of requirements relating to future hydrogen storage systems other than gaseous or liquid storage.
Scope of proposal
Some stakeholders thought that there is a discrepancy between the scope (hydrogen powered vehicles) and the requirements (the draft addresses gaseous and liquid hydrogen storage systems) of the draft co-decision proposal. It was argued that the specification of performance requirements for all hydrogen systems in vehicles would solve this problem.
Date of applicability of Regulation
Some responses suggested specifying different application dates of the provisions of the Regulation for M1 and N1 vehicles and M2, N2, M3 and N3 vehicles. One stakeholder suggested 5 year delay for these latter vehicles. One stakeholder said that it is too early to comment on the date of entry into force or applicability at this stage.
Lack of clear definitions and requirements
Some stakeholders commented that the draft proposal lacks some definitions and does not specify clear requirements to fulfil.
Design restrictive requirements
A few consultation responses mentioned that the requirements of the present draft would be design restrictive and would hinder the development of future hydrogen technologies.
One stakeholder suggested introducing a review clause in the co-decision Regulation in order to re-examine the specifications with the continuous development of new technologies of hydrogen systems.
3. Type-approval issues
System approach - Type-approval of components
A number of stakeholders suggested the use of a system approach for type-approval requirements for hydrogen systems instead of specifying tests for single components of the system. This approach would enable the approval of systems (combination of components). They argued that the safety of single components does not ensure the safety of the whole system, i.e. the vehicle.
One stakeholder expressed support for the component-orientated approach.
Small series approval
Some responses suggested allowing for small-scale type-approval in order to facilitate the approval of experimental vehicles.
4. Test requirements
Definition of tests
Some stakeholders requested the definition of detailed testing requirements in the co-decision text, while many others asked for the reduction of technical content. It was also suggested to remove all test requirements applicable for the approval of containers and components from the co-decision text and specify them only in the comitology legislation.
Application of standards
It was suggested by some responses to accept and to refer to applicable standards directly in the co-decision text. It was argued that the applicability of testing requirements for single components (specified in tables in the annexes) are not necessary as the scope of relevant standards specify them.
Some stakeholders argued that the current draft does not allow the consideration of the storage system as a removable tank. It was argued that the possibility of exchangeable fuel tanks should be maintained in the Regulation. Further, it was suggested by some responses to introduce requirements of a removable fuel tank system used in smaller applications.
Classification of containers / hydrogen components
Some stakeholders commented that the various requirements relating to the different types of hydrogen containers and classes of hydrogen components should be specified in the co-decision draft. One stakeholder suggested a different classification of container types and hydrogen components.
A number of stakeholders argued that the draft should not include requirements that relate to the refuelling procedure or refuelling stations (overpressurization, measures to avoid hydrogen leak during refilling, etc.).
It was argued that the requirements of a harmonized refuelling receptacle for all hydrogen powered vehicles should be specified in the Regulation, based on international standards.
5. International harmonisation
It was suggested to harmonise technical requirements of the proposal with existing ISO or SAE standards. One stakeholder underlined that the development of technical requirements and safety concepts in the framework of the UNECE GTR on HFCV should be taken into account in the European Regulation.