Energy and Utilities

Draft regulations on the quality requirements for hydrogen have been published

Published on 6th Sep 2022

This information is important for the producers of hydrogen to be used to fuel vehicles and for laboratories planning to obtain certification for hydrogen quality testing.

At the end of last August, the Ministry of Climate and Environment has published the expected draft ordinances on hydrogen quality requirements and hydrogen quality testing methods. 

The proposed ordinances supplement regulations resulting from the amendment of the Act of 25 August 2006 on the Fuel Quality Monitoring and Controlling System (amendment of 11.08.2021). 


Pursuant to this amendment, as of 1.01.2023, hydrogen used to fuel vehicles will be covered by a fuel quality monitoring and control system, provided for under said Act. The producers - before selling hydrogen - will have to issue the so-called hydrogen quality certificate, confirming that the hydrogen they produce meets the quality requirements allowing it to be used to fuel cars. 

The basis for issuing the quality certificate for hydrogen by its producer will be the quality tests performed during the hydrogen production process - flow-through tests carried out daily as well as tests performed at least once a month in an accredited laboratory. 

Compliance with the requirements for quality testing of hydrogen by its producers will be subject to review by the State Trade Inspectorate.

In summary, after 1.01.2023, Polish hydrogen producers will not be allowed to sell the hydrogen they produce (e.g. to petrol station operators) unless it has been properly tested and certified for hydrogen quality.

The draft ordinances published in August describe the hydrogen quality control system in more detail, specifying:

  • Quality requirements to be met by hydrogen to be used to fuel vehicles, including the maximum concentration of specific impurities - according to the rationale of the draft ordinance, these requirements are based on EN 17124:2018 and ISO 14687:2019 standards, and they apply to both gaseous and liquid hydrogen;
  • Methods for hydrogen quality testing performed by the accredited laboratory - the draft ordinance refers to selected methods specified in ISO 21087:2019; however, it also allows the use of other methods for hydrogen quality testing, not mentioned in the draft (including non-standardised methods) - provided that such methods are in line with the scientific and technical progress and best practice, and they meet the additional requirements specified in the draft; 
  • Hydrogen sampling method to be used by the accredited laboratory - according to the draft ordinance, hydrogen samples for quality testing should be taken in accordance with the state of the art and best practice, in particular as outlined in ISO 19880-1:2020 and ISO 21087:2019; importantly, samples can only be taken by an employee of the accredited laboratory.

The proposed regulations are expected to come into force on 1.01.2023. 

The draft ordinances are available on the website of the Government Legislation Centre (legislacja.rcl. 

The drafts have been subject to consultation, and thus their content may change. Given the extent of changes in hydrogen quality control that will come into effect on 1.01.2023, it is advisable to follow regulations in this area and prepare oneself for what the new year will bring. 

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* This article is current as of the date of its publication and does not necessarily reflect the present state of the law or relevant regulation.

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