CLEPA feedback on the EC roadmap for the “EU Hydrogen Strategy”

The Association of the Automotive Suppliers’ industry in Europe has provided feedback on the roadmap for an EU Climate Law.


CLEPA represents over 3.000 companies supplying state-of-the-art components and innovative technology for safe, smart and sustainable mobility, investing over 25 billion euro yearly in research and development and employing overall nearly five million people across the continent.


The automotive suppliers’ industry in Europe is a driving force behind the transformation to sustainable, safe, and smart mobility. We support the Paris agreement and are ready to contribute to a reliable, technology-open, and ambitious regulatory framework to achieve its objectives. To achieve this we have argued consistently in favour of a pragmatic regulatory and policy approach, which defines ambitious targets but stays technology open.


In road transport all efficient and low or zero carbon solutions will be necessary and have to be effective in new vehicles but also the existing fleet. Europe needs battery electric vehicles, different degrees of hybridization, from mild to plug-in, fuel cells and efficient combustion engines, along with the necessary charging infrastructure and availability of renewable energy, but also refuelling infrastructure and availability of renewable fuels, e-fuels, and hydrogen.


Against this background we welcome the intention of the European Commission to put forward a hydrogen strategy; that the roadmap mentions the need to deploy hydrogen in, amongst others, the mobility sector and confirm that an appropriate mix of policy and regulation will be necessary to achieve this.


The strategy should explore the options inherent to the use of hydrogen in both gaseous as well as liquid form, for example as synthetic fuels, to enable the use of a variety of technology options, depending on use case and to manage the gradual transition towards the most effective solutions in the market.


For example, fuel cell technology is expected to play a role in long-haul transport of goods. Creating the necessary infrastructure for refuelling of trucks will take time but, in this segment, can start with a focus on long haul transport corridors in a first step.


For individual mobility, synthetic fuels may be better suited as “drop-in” solution in existing, mature technology, without an immediate need for broad availability of refuelling stations and allow for reduction of carbon emissions in the entire fleet, not only through the use of new (electric) vehicles.


Road transport and individual mobility constitute a significant market for hydrogen as element or bound in molecules of synthetic fuels and thereby promises the necessary scale and stability of demand for rapid industrialisation of production and distribution at comparatively lower cost.


The political framework should support the necessary investments, for example through the introduction of a quota for sustainable renewable fuels in the revision of the Renewable Energy Directive; reducing the taxation of sustainable renewable fuels in the Energy Taxation Directive; the introduction of a voluntary crediting scheme in the CO2 fleet regulation; and more ambitious targets for hydrogen infrastructure in the revision of the Alternative Fuels Infrastructure Directive.


We welcome that the Commission is currently examining the potential contribution of Life-Cycle-Assessment (LCA) to regulating carbon emissions in transport. We underline, that the Well-to-Wheel approach may provide a less complex alternative to LCA while both create incentives for all technologies to reduce emissions and increase efficiency whilst avoiding that emission reductions are offset at other parts of the value chain.



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