The global hydrogen economy is rapidly evolving, with cross-border trade emerging as a critical enabler for scaling up hydrogen as a clean energy carrier. Regulatory frameworks governing international hydrogen trade are still in development, with regions like the European Union, Asia, and North America taking divergent approaches to customs, safety, and environmental compliance. Harmonizing these frameworks remains a challenge, yet progress is being made to establish standardized rules that facilitate secure and efficient hydrogen trade while mitigating risks.

Customs and trade regulations for hydrogen vary significantly across regions due to differences in classification and handling requirements. The European Union has been proactive in defining hydrogen under customs codes, particularly for liquid hydrogen and hydrogen carriers like ammonia and liquid organic hydrogen carriers (LOHCs). The EU’s Combined Nomenclature system includes specific codes for hydrogen, enabling streamlined customs procedures. However, inconsistencies arise when hydrogen is transported via different carriers, as ammonia and LOHCs fall under separate classifications. Asia, particularly Japan and South Korea, has implemented specialized import-export procedures for hydrogen, often tied to long-term decarbonization strategies. Japan’s Green Growth Strategy includes provisions for hydrogen imports, with customs prioritizing safety inspections for cryogenic and compressed hydrogen shipments. North America lacks a unified approach, with the U.S. and Canada treating hydrogen under broader chemical categories, leading to delays in cross-border shipments. Mexico, however, is aligning more closely with U.S. safety standards for hydrogen transport by truck and rail.

Safety regulations present another layer of complexity, as hydrogen’s flammability and low-density properties necessitate stringent handling protocols. The EU adheres to the ATEX Directive and the Pressure Equipment Directive (PED), which set rigorous standards for hydrogen storage and transport equipment. Germany and the Netherlands have additional national regulations for pipeline and maritime hydrogen transport, reflecting their leadership in hydrogen infrastructure. In Asia, Japan’s High-Pressure Gas Safety Act and South Korea’s Industrial Safety Act govern hydrogen handling, with strict certification requirements for storage tanks and transport vessels. China has recently updated its safety codes to include hydrogen refueling stations and long-distance pipelines, though enforcement remains inconsistent. North America relies on a mix of Department of Transportation (DOT) regulations in the U.S. and the Transport of Dangerous Goods Act in Canada. The U.S. lacks specific federal standards for hydrogen pipelines, relying instead on state-level guidelines, which complicates interstate and international trade.

Environmental compliance is increasingly shaping hydrogen trade policies, particularly as nations prioritize low-carbon hydrogen. The EU’s Carbon Border Adjustment Mechanism (CBAM) will eventually include hydrogen, requiring exporters to report emissions associated with production. Renewable hydrogen, certified under the EU’s Delegated Acts on Renewable Fuels of Non-Biological Origin (RFNBOs), will receive preferential treatment. Asia’s approach is fragmented: Japan accepts blue hydrogen with carbon capture under its Basic Hydrogen Strategy, while South Korea mandates renewable hydrogen for certain imports. Australia, a key exporter, aligns with the EU’s emissions accounting methods to meet future demand. North America lacks a unified emissions standard, though the U.S. is developing a Clean Hydrogen Production Standard to differentiate between grey, blue, and green hydrogen. Canada’s federal carbon pricing system indirectly influences hydrogen trade by incentivizing low-carbon production.

Efforts toward harmonization are gaining momentum, driven by international organizations and bilateral agreements. The International Partnership for Hydrogen and Fuel Cells in the Economy (IPHE) is working on global safety standards, while the ISO Technical Committee 197 focuses on hydrogen technologies. The EU and Japan have established a Green Alliance to align certification schemes, and the U.S. is engaging in similar dialogues under the Indo-Pacific Economic Framework. However, gaps persist in areas like cross-border pipeline regulations, uniform emissions accounting, and emergency response protocols. The lack of a global hydrogen certification system creates market inefficiencies, as exporters must navigate multiple regional standards.

Future policy needs include the development of a unified customs classification for hydrogen and its carriers, possibly under the World Customs Organization’s Harmonized System. Safety regulations must converge on international best practices, particularly for maritime transport of liquid hydrogen and ammonia. Environmental policies should adopt transparent life-cycle assessment methodologies to ensure consistency in carbon accounting. Strengthening international collaboration through platforms like the G7 Hydrogen Action Pact will be crucial for aligning regulatory frameworks and accelerating the growth of cross-border hydrogen trade.

In conclusion, while regional disparities in hydrogen trade regulations pose challenges, the push for harmonization is underway. The EU leads in structured policy development, Asia focuses on strategic import-export frameworks, and North America lags in cohesion but shows potential for alignment. Addressing gaps in customs, safety, and environmental compliance will be essential for unlocking the full potential of a global hydrogen market.