Japan
Automobile
Manufacturers
Association, Inc.

Issue No. 5, 2006

JAMA’s vision for hydrogen-powered automobiles

The European Commission’s draft proposal for a Regulation on Hydrogen-Powered Motor Vehicles

In the latter part of 2007 the European Commission, the European Union’s executive branch, is expected to propose a new law relating to motor vehicles using liquid or compressed gaseous hydrogen.

The objective of the proposed law is "to lay down harmonised testing requirements" for the type approval of hydrogen-powered motor vehicles in the M and N categories through the establishment of "safety requirements for the hydrogen storage system of these vehicles".

The proposed law is thus expected to permit the approval and market entry of vehicles using hydrogen.  With these measures, the Commission hopes to build consumer confidence in this new technology.

JAMA position on hydrogen-powered motor vehicles

JAMA engaged with the Commission during the drafting of this new regulation and has presented a set of key messages which it hopes will be taken into consideration.

These key messages focus on the importance of coordinating the Commission’s research and development work with other similar initiatives in UN/ECE WP29, on an HFCV global technical regulation, and in ISO and SAE, on international standards for HFCVs.

The UN/ECE group is currently drafting a gtr for HFCVs and studying measures to ensure their safety.  WP29 is expected to need a further six months to collect the necessary information on technical requirements for the introduction of HFCVs.  Such being the case, it is JAMA’s view that the Commission should not finalise its own proposal until it has fully assessed the findings of WP29.  This view echoes calls by the European Commissioner for Enterprise and Industry, GŁnter Verheugen, to coordinate discussions at the EU level and those within the WP29 framework.

Moreover, in order to avoid discrepancies with other international standards for the high-pressure hydrogen containers and hydrogen components of HFCVs, the Commission should in its draft Regulation reflect the ISO and SAE standards already established in this regard.  This will prevent manufacturers from having to comply with two sets of standards, which would prolong vehicle development and increase vehicle cost.

JAMA also believes that it is essential to recognise the difference between the regulation of LPG/CNG vehicles and HFCV regulation.  LPG/CNG regulation is drawn from retrofit vehicles based on models already in the market.  In JAMA’s opinion, this is an incorrect basis on which to draft a new regulation for HFCVs, as the percentage of retrofit HFCVs will be very limited.

In addition, although the draft Regulation on Hydrogen-Powered Motor Vehicles identifies three classes of hydrogen components in its Annex I, JAMA requests the Commission to clarify at the earliest opportunity how the provisions of the proposed new law will be applied to those three classes of components.

With HFCV technological development still at an early stage, innovation must be encouraged.  JAMA therefore urges the Commission to make HFCV performance specification, rather than HFCV parts and materials specification, the target of the new law.  The latter approach—which would require detailed specifications for each part in terms of structure, materials, and design—would clearly risk delaying the innovation of new technologies.

Safety aspects of the proposed Regulation

Specific safety provisions are needed for vehicles that will be equipped with a high-pressure hydrogen container.  Contrary to the Commission’s approach in its draft proposal, which is to focus on type-approval requirements for individual parts, JAMA believes that the safety of the hydrogen storage system as a whole must be assured.

JAMA does, however, suggest introducing type-approval requirements for the parts directly involved in the event of a significant quantity of hydrogen escaping from the high-pressure hydrogen container.  Further, JAMA supports the introduction of a hydrogen-safety management system capable of detecting leaks in the first place and preventing any further leakage.

Finally, JAMA recommends developing a concept for the safety of HFCVs as whole units, not just of their hydrogen storage system.  JAMA believes the proposed Regulation contains a number of requirements that are ambiguous (that is, neither objective nor quantitative), and that it therefore runs the risk of further complicating compliance judgements when its final version enters into force.