New HySUCCESS Report maps the complex legal landscape of hydrogen safety in Europe and beyond
This publication marks the first of two reports developed under Task 3.1 of the project, contributing to the creation of an ICT tool aimed at supporting hydrogen safety compliance. While this first report focuses on international and European standards, a second report will examine how these frameworks are implemented within the Dutch legal system.
The study highlights the layered and often complex hierarchy of hydrogen safety regulations. At the international level, key standards from organizations such as the International Organization for Standardization (ISO), the United Nations Economic Commission for Europe (UNECE), and the International Electrotechnical Commission (IEC) play a foundational role. Although these standards are not legally binding, they have significantly shaped safety practices and are frequently referenced in licensing procedures across Europe.
At the European level, the report identifies two main categories of regulation. First, binding legal instruments such as the SEVESO III Directive, ATEX Directives, and the Pressure Equipment Directive establish mandatory safety requirements that must be transposed into national law. Second, technical standards developed by organizations like CEN and CENELEC provide detailed guidance for industry, particularly in areas such as hydrogen storage, transport, and fuel cell technologies. While these standards are formally voluntary, compliance becomes essential when referenced in EU legislation.
The research pays particular attention to small-scale hydrogen applications—including storage systems, fuelling stations, and fuel cell technologies—which are currently the most common focus of licensing procedures in the Netherlands. It also highlights the role of the European Industrial Gases Association (EIGA), whose technical documents complement ISO standards at the European level.
A key conclusion of the report is that, despite their voluntary nature, international and European standards effectively shape the regulatory environment for hydrogen. These standards influence licensing decisions, guide industry practices, and serve as the backbone for national regulatory frameworks.
By mapping this complex legal landscape, the report provides valuable insights for policymakers, regulators, and industry stakeholders navigating the rapidly evolving hydrogen sector. The forthcoming second report will build on these findings by examining how these standards are applied in practice within the Netherlands, with particular attention to ambiguities and open norms in national legislation.