Europe’s public hydrogen refuelling network is not growing, but shrinking slightly. It is, however, changing shape. The part built for passenger cars is shrinking, while a new generation of dual-pressure stations is carrying 700-bar capability forward into the bus and truck layer. Germany closed 36 first-generation hydrogen refuelling stations during 2025. Twenty-two were small stations explicitly identified with the 700-bar passenger-car market, and another 14 locations followed at the end of the year. H2 Mobility’s explanation was practical rather than ideological. The passenger-car market did not appear at the expected scale, and many early stations could not be economically adapted to the throughput and technical requirements of buses and trucks. At the same time, H2 Mobility and other European operators are commissioning larger stations offering both 350-bar and 700-bar refuelling. Some of that is normal modernization. Small, early stations are being replaced by larger commercial-vehicle infrastructure. The policy issue is that the high-pressure capability justified originally by hydrogen cars is being retained across many of the replacement sites. The station mix shows the pattern clearly. A station-level dataset assembled from European Hydrogen Observatory records shows 108 public H70-only stations in 2023, 50 dual-pressure stations and 20 H35-only stations. By May 2026, H70-only stations had fallen to 32, dual-pressure stations had risen to 129 and H35-only stations stood at 18. The total changed from 178 to 179. The network did not meaningfully expand. It was rebuilt internally. H70 is no longer only a passenger-car standard. Some heavy-truck developers prefer 700 bar because higher pressure stores more hydrogen in a constrained vehicle envelope, but they aren’t delivering trucks. Other truck and bus manufacturers use 350 bar, and Daimler has pursued subcooled liquid hydrogen. That fragmentation makes public infrastructure planning more exposed. A station can be expensive, compliant and still serve too few vehicles, or the wrong vehicles, if the market moves differently. The battery comparison is no longer close. The European Commission’s own market assessment counted more than 15,000 battery-electric trucks in the EU at the end of 2024 and only 170 hydrogen trucks. More than 7,500 battery-electric trucks were registered during that year, compared with 106 hydrogen trucks. The same assessment counted more than 250 public and private hydrogen stations serving about 4,700 cars, 320 vans, 140 trucks and 320 buses, and concluded that the existing hydrogen refuelling network was broadly sufficient for the current vehicle fleet. The bottlenecks were limited vehicle availability and expensive hydrogen, not station coverage. Retaining H70 still has a cost. A 700-bar vehicle cannot be filled quickly and completely by equipment that merely reaches 700 bar. Fast fills require compression and storage substantially above the vehicle’s nominal pressure, as well as chilled hydrogen, specialized components, inspection and maintenance. A dual-pressure station shares hydrogen supply, civil works, safety systems and parts of the compression train, so adding H70 does not double total cost. But it does add a high-pressure storage and dispensing pathway, commonly with boosting, chilling and specialized hardware. The reason that pathway keeps appearing is not mysterious. AFIR requires publicly accessible hydrogen stations along the TEN-T core road network by the end of 2030, no more than 200 km apart. Corridor stations must be designed for at least 1 ton of daily capacity and include at least one 700-bar dispenser. AFIR also requires hydrogen stations at TEN-T urban nodes, and although the explicit H70 requirement applies to corridor sites, grant-funded developers commonly choose dual-pressure designs to maximize eligibility, compatibility and regulatory protection. Grants turn that regulatory signal into assets. ORLEN’s second Polish Clean Cities hydrogen programme has eligible costs of €25.6 million for five stations and an EU grant of €12.8 million. Its third phase includes a production and distribution hub plus 16 public stations offering both 350-bar and 700-bar refuelling, with eligible project costs of €124.6 million and a €62.3 million EU grant. Those stations might support real bus operations and future truck fleets. The question is whether current demand would have financed the same coverage and technical specification without regulation and public support. A screening estimate puts the replacement cycle in the range of about €1 billion to €6 billion, with a central case around €3 billion. The central case assumes roughly 400 new stations or substantial rebuilds averaging €5 million each, plus ten years of operations and maintenance and closure, decommissioning and churn costs. That does not mean the EU budget carries the full amount. The bill will be spread among EU grants, national subsidies, state-owned companies, private capital and users. It also excludes hydrogen production subsidies, distribution equipment, vehicle grants, discounted fuel and operating support for stations whose throughput cannot cover fixed costs. The portion attributable specifically to preserving 700-bar capability cannot be isolated precisely because much of a dual-pressure station is shared. A reasonable engineering range of €0.5 million to €1.5 million in incremental high-pressure compression, storage, chilling, dispensing and integration costs across several hundred stations produces a plausible European H70 premium of roughly €200 million to €700 million. That is not a reported programme total. It is a scale check on a policy choice. There are defensible hydrogen-station projects. A 350-bar station beside a contracted bus fleet can have predictable utilization. A depot or mobile station can serve a bounded commercial use without pretending to be part of a universal public network. A 700-bar dispenser can be justified where a real H70 fleet has been ordered, financed and delivered. Those cases do not require Europe to build a geographically complete public network ahead of proven vehicle demand, pressure-standard convergence or repeat procurement. The 2026 AFIR review should move away from pressure-prescriptive and distance-prescriptive hydrogen rules. Public support should be tied to contracted demand, utilization thresholds, pressure flexibility and staged construction. Infrastructure should follow vehicles that are ordered, delivered and used, not try to summon a vehicle market by building its refuelling system first. Europe already funded one 700-bar network that the market did not use. The next one should have to prove its customers first. Read the full TFIE Strategy Briefing assessment for the station-denominator data, AFIR requirements, grant examples, H70 cost screen and 2026 policy-reset case. Engage Michael Barnard and TFIE Strategy for hydrogen transport due diligence, infrastructure denominator analysis, public-funding review and electrified freight transition strategy.
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