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A push for technology neutrality in transport decarbonisation has emerged from the Hydrogen Energy Association (HEA), which is urging the UK government to avoid picking winners and instead let all low‑carbon solutions compete on an equal footing. The call, made public on March 20, 2025, warns that current regulatory frameworks heavily favour battery‑electric vehicles (BEVs), potentially stifling the development of hydrogen fuel cells, e‑fuels, and other alternative technologies that could be critical for hard‑to‑electrify sectors like heavy‑duty trucking and aviation.
The core ask: level the playing field
The HEA argues that a truly neutral approach would allow the market to determine the most efficient and cost‑effective pathways for reducing emissions across all transport modes. In a recently published position paper, the association highlights that while BEVs are well suited for light‑duty passenger cars, heavy goods vehicles, shipping, and off‑road machinery face range, weight, and infrastructure constraints that hydrogen can address. “Mandating one technology risks locking in suboptimal solutions for entire fleets,” the paper states.
This position comes as the UK’s Zero Emission Vehicle (ZEV) mandate—which sets annual BEV sales targets—faces criticism from multiple industry groups. The HEA is not alone: the UK’s Committee on Climate Change has also noted that a portfolio of technologies will be needed to meet net‑zero by 2050.
Exclusive angle: Lessons from US policy debates
While the HEA’s plea is directed at Westminster, the same tension plays out in the United States. The EPA’s 2023 greenhouse gas standards for heavy‑duty vehicles effectively favour BEVs over hydrogen, sparking pushback from truck manufacturers and hydrogen producers. A senior analyst at the American Council for an Energy‑Efficient Economy (ACEEE) told us: “The US is grappling with the same question—whether to set performance standards or to mandate a specific powertrain. The HEA’s argument adds weight to the case for fuel‑neutral regulations that reward low carbon intensity regardless of the energy carrier.”
In a January 2025 regulatory filing, the US Department of Energy (DOE) acknowledged that hydrogen fuel cells could provide “critical complementarity” to BEVs in long‑haul trucking, but noted that infrastructure investment remains a major hurdle. The HEA’s UK call, therefore, resonates on both sides of the Atlantic, where fuel producers, automakers, and environmental groups are locked in debate over the optimal policy mix.
Why technology neutrality matters for decarbonisation
Proponents argue that a technology‑neutral framework encourages innovation by allowing multiple solutions to mature simultaneously. Hydrogen fuel cells offer higher energy density and faster refuelling times compared to batteries—advantages for fleets that operate under tight schedules. E‑fuels, produced from captured CO₂ and renewable hydrogen, can be used in existing internal combustion engines without modification, providing a potential retrofit solution for legacy vehicles.
On the other hand, critics warn that neutrality can be a smokescreen for delaying electrification. The International Council on Clean Transportation (ICCT) has cautioned that without clear phase‑out deadlines, incumbents may prolong the use of fossil‑fuel vehicles under the guise of “alternative fuels.” The HEA responds by insisting that its proposal includes binding carbon intensity targets that tighten over time, ensuring that all technologies must demonstrably reduce emissions.
The UK context: ZEV mandate under review
The UK’s Transport Department is currently conducting a post‑implementation review of the ZEV mandate, which requires 80% of new cars and 70% of new vans to be zero‑emission by 2030, with 100% for both by 2035. The HEA’s intervention is timed to influence this review. The association suggests replacing the strict BEV quota with a “low‑carbon intensity obligation” that would credit any vehicle achieving a tail‑pipe emissions threshold, regardless of whether it is battery‑electric, hydrogen fuel cell, or plug‑in hybrid running on low‑carbon fuel.
Industry reactions have been mixed. The UK’s Society of Motor Manufacturers and Traders (SMMT) expressed cautious support for “technology‑open standards,” while environmental groups like Transport & Environment warned that such flexibility could weaken the mandate’s force. “We need to maintain regulatory certainty to attract investment,” said a spokesperson for the green transport campaign.
What US readers should watch
For American observers, the UK debate serves as a bellwether. If the UK pivots toward technology neutrality, it could influence EPA rulemaking and EU regulatory reviews. The HEA’s push also aligns with the recent “Clean Fuels Standard” proposals in several US states, which use a carbon‑intensity scoring system rather than vehicle‑type mandates. California’s Low Carbon Fuel Standard (LCFS) already operates on this principle, rewarding fuels based on their lifecycle emissions.
The key question for both countries: Can performance‑based regulation achieve deep decarbonisation without forcing a single technology? The HEA believes yes, provided the targets are strong enough. As the UK government weighs its next steps, the US will be watching closely—and the HEA’s paper provides a detailed blueprint for a debate that is far from settled.
Background: The Hydrogen Energy Association
The HEA is a UK‑based trade body representing companies across the hydrogen value chain, from production to end‑use. Its members include BP, ITM Power, and Toyota Europe. The association has long advocated for hydrogen as a complement to electrification, and its latest report, “Neutral by Design,” provides technical analysis of how a technology‑neutral framework could be implemented in practice, including infrastructure cost modelling and emissions accounting methodologies.









