EU Type approval for Hydrogen powered vehicles

Helping manufacturers of hydrogen powered vehicles and components gain safe EU market access by closing regulatory gaps 

“To ensure safe market entry for hydrogen vehicles and components, they need to be assessed and tested according to required market regulations. While regulations provide legally binding type approval requirements, the recent withdrawal of Regulation (EC) 79/2009 means that some components (e.g., pressure regulator) will be left without any applicable regulation. In our opinion, the regulatory gap needs to be closed to further ensure safe market entry of hydrogen-powered vehicles.”

Martin Sekura, Hydrogen Business Development Manager, TÜV SÜD

The European Union (EU) requires car emissions for all new vehicles to be cut to zero by 2035. Hydrogen (H2) internal combustion engine vehicles (H2-ICEV), battery-electric vehicles, and FCEV (fuel cell electric vehicles) are therefore key technologies for decarbonising the automotive industry. However, while the industry continues to invest in H2 vehicle development, the European Union (EU) repealed Reg. (EC) 79/2009 on 5th July 2022, which covered the requirements for the type-approval of H2-powered vehicles. 

European type approvals for hydrogen systems and each installed component must now be based on UN Regulation No 134 and parts of Reg. (EU) 2021/535. This leaves a significant regulatory gap for both compressed gaseous hydrogen (CGH2) and liquid hydrogen (LH2), with manufacturers questioning how they can now ensure safe and reliable market access.

REGULATORY GAPS

Many components previously covered by Reg. (EC) 79/2009 are not within the scope of UN Regulation No 134, as it only refers to compressed hydrogen storage systems (CHSS). Also, as UN Regulation No 134 focuses on CGH2, there is no comparable UN or UN/ECE regulation for liquid hydrogen storage systems (LHSS). As the scope of this regulation is more narrow, many components such as pressure regulators, sensors and fittings are left without an applicable type approval framework.

UN Regulation No 134 also does not include requirements regarding the electrical safety of the electric powertrain, post-crash fuel system integrity in the event of a collision, and material compatibility. The Regulation mandates that the maximum service life of hydrogen containers shall not exceed 15 years, whereas Reg. (EC) 79/2009 allowed 20 years.

A preliminary solution to this problem was the introduction of Reg. (EU) 2019/2144 to replace Reg. (EC) 79/2009 (by referencing UN Regulation No 134), as well as including certain testing requirements within Reg. (EU) 2021/535. For LHSS, European type approval is possible via Reg. (EU) 2021/535, while for CHSS components, a double marking according to regulations Reg. (EU) 2021/535 and UN Regulation No 134 is required now.

However, TÜV SÜD believes that a more sophisticated solution is needed to ensure consistency, and it would make sense to combine requirements from Reg. (EC) 79/2009, Reg. (EU) 2021/535 and UN Regulation No 134 for the type approval procedure.

Transitioning from Reg. (EC) 79/2009 with TÜV SÜD

As type approval for certain FCEV hydrogen system components is no longer possible, the legal framework will consider “norms and standards” regarding a manufacturer’s product liability and safety obligations. This means a relevant and applicable standard should be identified, followed and components must be tested for conformity with it. 

In addition to regulatory type approval and certification, most OEMs have specific testing requirements for components, based on typical vehicle use conditions, OEM’s special requirements, and the state of science and technology. Such tests can be performed to meet OEM requirements across the world within TÜV SÜD’s global test laboratory network.

Despite these recent changes, it’s important to note that type approvals granted under Reg. (EC) 79/2009 before 6th July 2022 will not be invalidated and extensions can still be granted, unless the relevant requirements have been modified or new requirements have been added.

Minimise market entry delays

Manufacturers must address product liability issues not only by fulfilling type approval requirements, but also by qualifying their products according to relevant industry norms and standards. The repeal of Reg. (EC) 79/2009 has added a new dimension of complexity. To identify the optimal solution, tailored to their specific products, and to ensure safe and uncomplicated market entry, we recommend manufacturers consult with a notified body such as TÜV SÜD at an early stage.

TÜV SÜD supports its customers along the entire hydrogen vehicle, component and system certification and type approval process. We are helping manufacturers to identify the relevant regulations and standards for their products and target markets. We perform the required certification and approval tests on material, component and system levels in our own global testing laboratories. As our experts take care of the paperwork and other formal requirements, this streamlines the process. This enables our customers to achieve their certification and type approval goals and deliver safe quality hydrogen mobility solutions to the market.

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