· Hydrogen Shipping Regulations

Hydrogen Fills the Gaps Electrification Cannot — And Maritime Is the Hardest Gap of All

Jorgo Chatzimarkakis of Hydrogen Europe argues clean hydrogen addresses three specific failures of direct electrification: seasonal energy storage, hard-to-abate industrial sectors, and long-haul transport. For shipping, all three arguments converge — and the EU's new Ports Strategy and FuelEU Maritime are starting to close the policy gap, though Hydrogen Europe says not fast enough.

Hydrogen Fills the Gaps Electrification Cannot — And Maritime Is the Hardest Gap of All
Liquid hydrogen transportation and storage pathways. Image: Lloyd's Register

The argument for hydrogen in the energy transition is not that it is better than electricity — it is that it is necessary where electricity is not sufficient. Jorgo Chatzimarkakis, CEO of Hydrogen Europe, sets out three specific failures of direct electrification that clean hydrogen can address: seasonal energy storage, decarbonisation of hard-to-abate industrial sectors, and long-haul transport where energy density rules out batteries. For shipping, all three arguments apply simultaneously, and the EU’s new Ports and Maritime Strategy adopted in March 2026 is beginning to build the regulatory scaffolding — even as Hydrogen Europe argues the ambition still falls short where it matters most.

⚡ TL;DR

  • Thesis: Clean hydrogen addresses gaps where electrification fails — seasonal storage, hard-to-abate sectors, and long-haul transport. Maritime is the sector where all three failures coincide.
  • Policy: EU Ports Strategy (March 2026) positions ports as multi-fuel energy hubs and mandates the Renewable and Low-Carbon Fuels Alliance to assess hydrogen infrastructure capacity by end 2026.
  • FuelEU Maritime: First compliance year data (2025) was reported in January 2026; GHG intensity targets run from −2% (2025) to −80% (2050), with hydrogen-derived fuels central to achieving the steeper post-2030 reductions.
  • Gap: Hydrogen Europe criticises the Ports Strategy for excluding a minimum supply obligation for Sustainable Maritime Fuels — reducing policy ambition at the moment it matters most.
  • Watch for: The Fuels Alliance infrastructure capacity assessment (end 2026) and IMO's mid-century GHG strategy implementation — these will determine the investment signal for green ammonia and methanol supply chains.

The Three Gaps: Why Hydrogen Is Not Optional

The standard critique of hydrogen is that it is an inefficient energy carrier — and that critique is correct in contexts where direct electrification is viable. Round-trip efficiency for hydrogen via electrolysis and fuel cell is typically 30–40%, compared with 85–90% for battery charge-discharge cycles. Where you can plug in, batteries win on physics.

The argument Chatzimarkakis makes — and it is one that the European Commission’s energy modelling increasingly supports — is that there are three categories of energy demand where direct electrification is not viable at scale, and where hydrogen or hydrogen-derived fuels therefore become necessary rather than merely preferable:

Gap 1: Seasonal Energy Storage

A fully renewable electricity grid faces a structural imbalance: solar and wind generate peak power in summer and day-time windows, while heating and industrial demand peak in winter. Battery storage handles daily and weekly balancing adequately, but storing energy across seasons — six to eight months — at the scale required for Northern European industrial demand is beyond what any plausible battery deployment can achieve.

Hydrogen can be produced by surplus renewable electricity in summer, stored in underground caverns (salt caverns, depleted gas fields), and reconverted to electricity or fed directly to industrial consumers in winter. This seasonal storage function is system-level infrastructure, not a vehicle or ship application — but it matters for maritime because the same electrolysers and hydrogen storage systems that balance the grid are the upstream production base for ship fuel supply chains.

Gap 2: Hard-to-Abate Industrial Sectors

Steel production via direct reduced iron (DRI) requires hydrogen as a reducing agent — there is no electrical substitute that operates at commercial scale today. Ammonia synthesis (Haber-Bosch) requires hydrogen as feedstock. Cement production, certain chemical processes, and high-temperature industrial heat above 1,000°C cannot be economically electrified with current technology.

These sectors collectively represent a large fraction of European industrial CO₂ emissions. Their decarbonisation pathway runs through hydrogen, which means the hydrogen production capacity built for industry is the same capacity base that can supply maritime fuel production.

Gap 3: Long-Haul Transport — The Maritime Case

Aviation and maritime are the canonical hard-to-decarbonise transport sectors. Both require energy storage at high volumetric and gravimetric density over long operating periods. Batteries do not meet those requirements at commercial scale for intercontinental flight or deep-sea shipping.

For maritime specifically, the numbers are stark. Deep-sea vessels — those operating on international routes above approximately 5,000 GT — account for roughly 80% of total shipping emissions. The energy required for a single voyage from Rotterdam to Singapore in a large container ship represents a power demand that no foreseeable battery technology can supply in the volume available. Hydrogen-derived fuels — green ammonia, green methanol, and synthetic e-fuels — are the decarbonisation pathway for this segment.

Together, aviation and maritime account for approximately 10% of global greenhouse gas emissions. Both sectors are outside the scope of the EU ETS for non-EU route segments; both are under increasing IMO pressure; and both are explicitly named in the FuelEU Maritime framework as the target for mandatory GHG intensity reductions.


The EU Regulatory Frame: Ports Strategy and FuelEU Maritime

On 4 March 2026, the European Commission adopted two linked strategies: the EU Industrial Maritime Strategy and the EU Ports Strategy. Together they represent the Commission’s most detailed articulation yet of how Europe’s port infrastructure is expected to adapt to the clean energy transition.

The key maritime-hydrogen provisions:

Policy instrument Hydrogen-relevant measure Timeline
EU Ports Strategy Ports to become multi-fuel energy hubs, including hydrogen import infrastructure Ongoing
Renewable & Low-Carbon Fuels Alliance Assess port infrastructure capacity and future needs for renewable fuels End 2026
Clean Energy Ministerial hydrogen global ports coalition Commission to fund a study to support the coalition’s port hydrogen activities Early 2026
FuelEU Maritime GHG intensity limits: −2% (2025), −6% (2030), −14.5% (2035), escalating to −80% (2050) 2025 onwards
FuelEU Maritime — first report 2025 compliance year data submitted to verifiers January 31, 2026
FuelEU Maritime — RFNBO sub-target Hydrogen-based fuels sub-target within the GHG intensity trajectory 2030 onwards

The FuelEU Maritime regulation is already in force. The first compliance year (2025) has passed, and reporting obligations are being met. The regulation’s GHG intensity trajectory — a modest −2% reduction in 2025, tightening progressively to −80% by 2050 — is designed so that the initial steps can be met with conventional fuel switching (LNG, biofuels), while the post-2035 targets structurally require hydrogen-derived fuels. No combination of fossil LNG and currently available biofuels can meet an 80% GHG intensity reduction.

The Ports Strategy’s recognition of ports as multi-fuel energy hubs is significant for infrastructure investment. It signals that EU funding instruments — the Connecting Europe Facility, the Innovation Fund, and the European Investment Bank — should treat hydrogen import terminals at major ports as eligible core infrastructure, not as experimental projects. That classification matters for project finance.

Liquid hydrogen transportation and storage pathways
Hydrogen transportation and storage options — the choice of pathway determines cost, boil-off, and compatibility with port infrastructure. Image: Lloyd's Register

Where the Strategy Falls Short: Hydrogen Europe’s Critique

Hydrogen Europe welcomed the multi-fuel port designation but delivered a pointed criticism of what the strategy omits: there is no minimum supply obligation for Sustainable Maritime Fuels (SMF) in the Ports Strategy.

The distinction matters. A policy that says ports can become hydrogen hubs does not create the same investment signal as a policy that says ports must ensure a minimum volume of clean fuel is available. Without a supply obligation, the buildout of hydrogen import infrastructure at ports is contingent on voluntary commercial decisions — and those decisions are currently constrained by the absence of contracted offtake at sufficient volume and price.

Hydrogen Europe’s position is that the Commission should:

  • Strengthen binding RFNBO (Renewable Fuels of Non-Biological Origin) targets under FuelEU Maritime to create assured demand for green hydrogen-based fuels
  • Lead ambitiously at the IMO rather than accepting weaker global standards that could undercut EU investment
  • Avoid double regulation that would allow ships calling at EU ports to meet a lower international standard while EU operators face the full FuelEU requirement

The critique reflects a structural challenge in maritime fuel policy: ships are mobile assets that call at ports across multiple jurisdictions. An EU-only supply obligation creates investment incentive for EU ports while leaving the question of what happens outside EU waters — on the 50% of a Rotterdam-Singapore voyage that is outside EU ETS scope — unresolved.


The Production Competition: Ships vs. the Power Sector

One dimension of the three-gaps argument that is underappreciated in maritime planning is that the sectors compete for the same hydrogen production capacity.

An electrolyser producing green hydrogen for seasonal grid storage and an electrolyser producing green hydrogen for green ammonia synthesis are the same asset class. In the early years of the hydrogen economy — roughly 2025–2035 — production capacity will be the binding constraint. Industrial decarbonisation (steel, chemicals), grid storage, and maritime fuel production will all be drawing on a limited pool of electrolysis capacity and green power purchase agreements.

This competition has implications for maritime fuel pricing and availability. Green ammonia and green methanol production requires dedicated long-term supply agreements; spot market purchasing will be unreliable when the production base is constrained. Ship operators that want hydrogen-derived fuels available in the early 2030s need to be participating in offtake agreements today — the same timeline logic that applies to LNG terminal investment.

The supply chain projects hydrogenshipbuilding.com has been tracking — Gen2 Energy’s Mosjøen facility in Norway, the EcoLog Amsterdam terminal, the Hamburg JDA between Daimler, MB Energy, and Kawasaki — are exactly the kind of upstream-to-terminal projects that lock in production capacity for specific end markets. The projects that secure committed supply now will have fuel available when the FuelEU Maritime trajectory forces the transition.


The Fuel Choice: Ammonia, Methanol, or LH2?

Within the maritime sector, the hydrogen-derived fuel choice is not settled. Three pathways are currently in commercial development:

Fuel Energy density (MJ/kg) Maritime readiness Main challenge
Green ammonia 18.8 Engine conversions underway; MAN and WinGD developing NH₃ two-stroke engines Toxicity; NOx emissions; combustion stability
Green methanol 19.7 Commercial deployments underway (Maersk Ane Mærsk-class) Carbon source for e-methanol; biogenic CO₂
Liquid hydrogen 120 (but low volumetric density) Early commercial stage; Viking Libra 2026 Cryogenic storage at −253°C; boil-off; volume
E-ammonia via LOHC Variable Pre-commercial Dehydrogenation energy requirement

The Chatzimarkakis thesis does not prescribe which fuel wins — it argues that hydrogen underpins all of them as feedstock or as the fuel itself. Green ammonia is hydrogen plus nitrogen (Haber-Bosch). Green methanol is hydrogen plus CO₂ (direct synthesis). LH2 is hydrogen, liquefied. The maritime sector’s fuel diversity is, at its root, a set of different packaging solutions for the same upstream molecule.

What this means from a port infrastructure perspective is that a hydrogen import terminal and a green ammonia terminal are not independent investments — they are part of a hydrogen value chain that should be planned as a system. The EU Ports Strategy’s multi-fuel hub concept is directionally correct; the question is whether project financing and permitting frameworks are aligned to allow integrated planning rather than piecemeal development.


Why This Matters

The Chatzimarkakis article is worth reading for maritime professionals not because it contains shipping-specific analysis, but because it frames hydrogen’s role in the energy system from the perspective of a sector that has to live with the consequences of policy decisions made at the energy system level.

For those of us designing and operating hydrogen-capable vessels, the energy system context is directly relevant:

  • Electrolyser buildout for grid balancing is the same capital that produces ship fuel — understanding system-level hydrogen demand forecasts informs fuel availability projections.
  • Industrial hydrogen demand (steel, chemicals) in Northern Europe’s industrial clusters is co-located with major port infrastructure — hydrogen pipelines serving those clusters can also supply port bunkering.
  • The policy trajectory that Hydrogen Europe is trying to steepen — binding RFNBO targets, supply obligations, IMO ambition — directly determines the rate at which the fuel cost gap between green and fossil narrows.

The hydrogen-powered ships database currently contains vessels that are already operating on hydrogen in coastal and short-sea trades. The expansion of that database into deep-sea shipping is a function of supply chain development that is now, finally, being addressed at the policy and project level simultaneously.

Challenges and Open Questions

  • Supply obligation gap: Without a mandated minimum supply of SMF at EU ports, the market signal for hydrogen import infrastructure investment remains weaker than it should be for a 2030-target technology.
  • IMO vs. EU standard divergence: If the IMO’s GHG targets for international shipping remain below the FuelEU Maritime trajectory, EU-flagged and EU-calling ships face competitive disadvantage relative to operators not subject to the EU regime.
  • Production competition: Green hydrogen demand from the power sector (seasonal storage) and from heavy industry may crowd out maritime supply chains in the 2025–2032 period when production capacity is most constrained.
  • Fuel technology convergence: The maritime sector is currently developing parallel fuel pathways (ammonia, methanol, LH2). Port infrastructure designed for one pathway may not serve another — and the fuel that achieves cost-competitive scale first may strand investment in the alternatives.
  • Carbon accounting for e-methanol: Green methanol requires a carbon source; biogenic CO₂ is the current primary option, but supply is limited and contested. RFNBO-compliant e-methanol requires atmospheric or captured industrial CO₂, adding cost and supply chain complexity.

Sources

Source: Enlit World / Hydrogen Europe / European Commission