Rules forcing EU truck and bus manufacturers to produce zero-emission vehicles (ZEVs) as part of a phase-out of fossil fuels in the transport sector could be undermined by a loophole allowing the use of gray hydrogen, although it could be more effective, Hydrogen has learned. Insight is that it is more polluting than diesel.
The new Heavy Vehicle Standards (HDVS) rules, approved by the European Commission (EC) but not yet finalized, require car manufacturers to reduce the total emissions from the heavy vehicles they produce, starting with a 45% reduction in 2030 compared to 2019, 65% by 2035 and 90% by 2040.
To meet the goals, truck and bus manufacturers will have to produce enough ZEVS to meet emissions reductions, and equip them with technology such as batteries, hydrogen fuel cells or hydrogen internal combustion engines.
The remaining 10% of emissions not covered by 2040 will be reserved for sectors that are very difficult to decarbonise, such as vehicles used in forestry or agriculture, so in practice, carmakers are likely to produce almost 100% of trucks And buses. With ZEV technology by 2040.
But since the rules don’t hold manufacturers responsible for the lifetime emissions of the fuel ultimately used in the vehicle — only tailpipe emissions calculated through a range of criteria including driving styles and component performance — it means ZEVs could run on gray, synthetic hydrogen. Of gray hydrogen. Fossil fuels are still counted toward the phase-out of fossil fuels.
“The responsibility for meeting targets under HDV standards legislation lies with manufacturers,” an EU spokesperson told Hydrogen Insight. “It will be up to them to decide which technologies they use to achieve these goals, such as electricity, hydrogen fuel cells or hydrogen in internal combustion vehicles.
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“(The use of gray hydrogen will be allowed) because carbon dioxide emissions from the tailpipe of a hydrogen fuel cell vehicle are zero, regardless of the hydrogen fuel source.”
Based on data from the International Energy Agency (IEA) and the UK Forest Research Agency, gray hydrogen made from gas through steam methane reforming has a life cycle emissions intensity of between 0.23 kg and 0.33 kg CO2/kWh , compared to 0.27 kg/kWh. For diesel, according to Hydrogen Insight calculations.
This means that a car running on gray hydrogen in the name of phasing out fossil fuels in the EU could be more polluting than diesel, depending on the emissions intensity at the source.
The EU regulates fuel emissions separately, both through its carbon market, the Emissions Trading Scheme (ETS), and the newly drafted Renewable Energy Directive (RED III), which the European Commission told Hydrogen Insight will “make sure that… Carbon from hydrogen used gradually.”
However, it is not clear how this will be achieved, because in each case the targets do not match those set in the heavy vehicle targets – which could allow gray hydrogen to be used as fuel.
The new ETS 2, which specifically covers emissions from buildings and road transport, caps emissions from fuel sold by suppliers at 42% by 2030 compared to 2005 emissions (in contrast to the heavy vehicle standard of 2019 is its base year). However, as of now, there is no target beyond 2030.
In addition, the emissions-trading nature of the targets means that if there is not enough low-carbon hydrogen, fuel suppliers are able to sell gray hydrogen anyway, and pay EU carbon allowances to cover the additional emissions.
The effect of RED III on H2 gray use is more ambiguous. Rather than targeting emissions reductions, the legislation envisages increasing the share of renewables in primary energy consumption by 42.5% by 2030 (as part of the overall EU emissions reduction target of 55% by 2030), with transport expected to contribute either a 29% share % of renewable energy, including electricity, or a reduction in greenhouse gas intensity (rather than a real reduction in emissions) of at least 14.5%.
The hydrogen mandate in RED III stipulates that only 1% of the total fuel supplied to the transport sector, including shipping and aviation, be renewable fuel of non-biological origin (RFNBO) – the EU term for green hydrogen and its derivatives, such as ammonia or methanol. – By 2030.
These two targets appear to be insufficient to ensure that green hydrogen is used in heavy trucking rather than gray polluting, negating some of the benefits of phasing out fossil fuels in this sector.
However, it will ultimately depend on how vehicle manufacturers choose to meet HDVS targets, which will be determined by the needs of their customers. If there is an influx of hydrogen-powered buses and trucks, it will be difficult to find enough low-carbon hydrogen to meet expected targets – especially without tougher targets for fuel suppliers – resulting in more gray hydrogen being used.
