27.03.2026
The hydrogen sector for Ukraine is gradually transitioning from the level of a general strategy to the practical preparation of the future market. To participate in the European hydrogen market, the country needs not only political signals and technical solutions, but also a clear regulatory framework, coordinated approaches to infrastructure and hydrogen circulation, as well as legal certainty for business and investors.
In an interview with the Energy Club media department, Oleksiy Hnatenko, a partner in the dispute resolution practice of the law firm Juscutum and member of the Supervisory Board of the East European Association for the Development of the Hydrogen Economy, spoke about the role of hydrogen in Ukraine’s industrial transformation, the prospects of H₂-ICE for heavy transport and special equipment, as well as the key steps of the state and business for the practical implementation of hydrogen technologies in the country.
— “The hydrogen internal combustion engine is not a universal answer to the entire spectrum of issues in the transition period from ICE to engines using alternative technologies,” Oleksiy noted. “Its main advantage is not its efficiency over battery-powered transport, but the fact that it gives mechanical engineering a chance to undergo decarbonization without a complete dismantling of the existing industrial base, especially in heavy transport, special equipment, and off-road applications, where cruising range, fast refueling, and operation under high load are critical. That is why today H₂-ICE should be evaluated not as a competitor to all technologies at once, but as a separate industrial niche with a clear economy, infrastructure, and legal prerequisites.”
— Mr. Oleksiy, currently, global engineering leaders are increasingly paying attention to hydrogen internal combustion engines (H₂-ICE). But the world is also actively investing in battery electric vehicles (BEVs) and hydrogen fuel cells. What is the main economic and technological advantage of H₂-ICE over BEVs and Fuel Cells?
— The main advantage of H₂-ICE is not maximum energy efficiency, because by this criterion, battery platforms, as well as fuel cells, generally look stronger. The advantage of H₂-ICE is that it allows the use of existing engine platforms, factories, mechanical processing, service networks, engineering skills, and a significant part of the supply chain. Cummins explicitly speaks about a common platform architecture for diesel, gas, and hydrogen engines, as well as the fact that hydrogen engines can be mass-produced through the same supply chains and factories as traditional ICEs. For heavy transport, this is especially important because refueling time, load, and continuity of operation often matter more than the absolute efficiency of the power plant. At the same time, for urban transport, BEV is a technologically more mature solution today.
— It is believed that H₂-ICE allows automakers to preserve jobs, factories, and established supply chains. How much does the production of a hydrogen ICE realistically differ from a classic diesel one? What percentage of parts do they share?
— To speak correctly, H₂-ICE is not simply an adapted diesel. The fuel system, hydrogen storage, combustion management, ignition, calibration, safety, and, depending on the architecture, solutions regarding NOx emissions require a different approach. But at the level of the basic engine platform, the degree of commonality is indeed high. Cummins notes that below the cylinder head, components largely match, and their hydrogen engines have a lot in common with existing diesel and gas ones. DEUTZ explicitly states in its materials that their TCG 7.8 H2 is approximately 75% based on an established diesel platform. Therefore, the market benchmark today, when it comes to close platforms, is about 75–80% commonality specifically for the engine as a product, but not for the entire vehicle as a whole.
— What is the TCO logic for diesel and H₂-ICE today and in 2030? When will the technology become commercially viable without major subsidies?
— As of today, H₂-ICE almost nowhere beats diesel on a fully market-based TCO in the broad freight transport segment. The reason is simple: the deciding factor remains not only the price of the vehicle, but the price of hydrogen at gas stations, the availability of refueling, and the scale of the series. JRC notes that the key condition for the transition is precisely achieving TCO parity, and for heavy transport, cruising range and refueling speed are especially important. The DOE in the US sets a target for the wholesale price of hydrogen for heavy-duty at $7/kg by 2028, and the cost of hydrogen production at $1/kg by 2031. According to JRC estimates, for hydrogen solutions, parity with diesel begins to look more realistic where hydrogen approaches the level of about 5 € /kg, but this does not yet mean automatic parity specifically for H₂-ICE in all segments. The forecast is as follows: without substantial subsidies, H₂-ICE can become commercially justified by 2030 only in niches with high utilization, fixed routes, proprietary or contract refueling, and a high cost of equipment downtime. For the mass market of open transport, this is most likely a horizon already beyond 2030. But this is a conclusion drawn from current DOE targets and European TCO estimates, not a market guarantee.
— Which Ukrainian enterprises or related industries already have the basis for transitioning to components for hydrogen equipment?
— I would look not at a single Ukrainian H₂-ICE manufacturer, but at the cooperation of several related industrial blocks. First, this is engine building and precision mechanical processing, where Motor Sich has the closest technological affinity. Second, this is turbo engineering, compressor, testing, and assembly culture, where Ukrainian Energy Machines demonstrate a strong base. Third, this is a pipe, metalworking, and engineering base, where Interpipe has relevant competencies in seamless pipes, solutions for mechanical engineering, and precision applications. Fourth, this is the integration of chassis, bodies, and specialized transport, where it is logical to look at Bogdan and the Kryukiv Railway Car Building Works as platforms for cooperation in special equipment, municipal transport, or heavy platforms. This does not mean that they will start mass-producing hydrogen equipment tomorrow, but from publicly available data, it is these enterprises and sectors that have the potential and appear closest to the future localization chain.
— How can Ukraine avoid losing to Poland, Hungary, or Slovakia in the fight for AVL, Cummins, or Toyota factories?
— Ukraine will not win this competition with cheap labor. You can only win with the speed of industrial launch, the quality of the industrial package, and a clearly defined regulatory and legal framework for the industry. Five things are important for such companies: predictable law, quick connection to networks, a preferential industrial site, predictable demand, and a local supply chain. Ukraine already has the tools of industrial parks with compensation for connection to networks, infrastructure co-financing, a 10-year corporate tax exemption subject to reinvestment, privileges on the import of new equipment, and simplified customs procedures. But this is not enough without anchor demand: pilot procurements, localization of service, testing grounds, war risk insurance, and a clear regulatory route. The behavior of Toyota and Cummins shows that global players enter not just a country with cheaper costs, but an ecosystem where there is simultaneously production, infrastructure, and an application market. That is why Ukraine, after the war, needs to sell not labor, but the speed of cluster deployment.
— If you had carte blanche and funding, what would be the first pilot project for the implementation of H₂-ICE you would launch in Ukraine tomorrow? Would it be municipal transport, agricultural machinery, or freight transport?
— I would not start with the passenger car segment and would not start with a dispersed network of gas stations. As a first pilot, I would create a closed corridor for heavy freight transport or municipal special equipment in a single industrial hub, where the equipment returns to base, has a stable daily mileage, and can be refueled at a single point. The best logic for a start, in my opinion, is 15–30 heavy vehicles in a depot-based operation model, rather than an urban bus fleet, because for the urban and regional segment, BEV already looks more mature. For hydrogen solutions, the JRC explicitly points to their greater relevance in more energy-intensive, heavier, or off-road applications, and the DOE is working on fast refueling infrastructure specifically for heavy-duty.
— Hydrogen transport will not run without hydrogen refueling stations. Who should build this infrastructure in Ukraine first: the state, private gas station networks, or hydrogen producers themselves in partnership with transport companies?
— Not the state by itself, not private gas stations by themselves, and not hydrogen producers separate from the carrier. Only a consortium model works: a hydrogen producer or supplier, a transport fleet operator, a refueling infrastructure operator, and the state as a co-financier of the regulatory and capital parts at the start. The European logic of AFIR shows that without a planned approach, infrastructure does not appear on its own, and American DOE materials confirm that hydrogen refueling is a complex of delivery, storage, and dispensing. The fact that Toyota is investing in FirstElement Fuel also demonstrates a simple market truth: the OEM does not wait for someone else to build the infrastructure, but enters into a partnership where it wants to create demand. For Ukraine, this means that the first wave of HRS should grow around transport fleets, and not around an abstract network for everyone.
— Green hydrogen requires enormous RES capacities, which are currently insufficient even for the basic needs of the grid. How should the development of hydrogen transport be synchronized with the development of decentralized generation in Ukraine?
— Ukraine cannot afford a scenario in which transport hydrogen begins to compete for electricity with the basic stability of the system. The government already explicitly defines the development of decentralized generation as a strategic task, and the Ministry of Energy reports 762 MW of new gas generation commissioned in 2025, and 1.4 GW since the beginning of the full-scale invasion. Therefore, hydrogen transport needs to be tied to new local nodes of generation and consumption: industrial parks, logistics centers, port and municipal depots, where there is or will be proprietary generation, a controlled consumption schedule, and predictable demand. The IEA proposes precisely a phased scenario for Ukraine with planning, regulatory preparation, and pilots, rather than a forced nationwide rollout.
— Can future hydrogen production facilities for transport become an effective tool for balancing the Ukrainian energy system during periods of surplus solar or wind energy?
— Yes, they can, but not as a replacement for batteries and not as a panacea for all imbalances. The IEA explicitly notes that hydrogen can work as a form of energy storage, and electrolyzers can act as a dispatchable load, reducing consumption when the residual load in the system is high, and absorbing the surplus at other times. At the same time, it is emphasized there that batteries are usually better suited for daily cycles of solar generation, while hydrogen is stronger in longer horizons and in more complex flexibility profiles. Therefore, for Ukraine, hydrogen transport makes sense as part of a broader system integration model, and not as a separate transport project unlinked to the electricity market.
— What are the first three steps the Government and Parliament must take this year for the successful integration of hydrogen technologies into the Ukrainian industrial landscape, so that it does not remain just a document on paper?
— The first step – to assemble a comprehensive legal package for hydrogen transport: type approval of design, requirements for HRS, safety, fire regulations, metrology, land allocation, operation, and technical control, and moreover, immediately in the logic of approximation with European rules.
The second step – to launch 2–3 pilot “lighthouse” projects with state support, but only where there is already or rapidly emerging guaranteed demand and local generation.
The third step – to make an industrial offer for component manufacturers: industrial parks, connections, tax and customs incentives, R&D centers, and a clear localization regime. It is exactly this sequence – first regulatory certainty, then pilot projects, then scaling. This logic is proposed by the IEA for Ukraine and one cannot disagree with it.
— Are Ukrainian legislation and technical regulations adapted today to the use of hydrogen as a fuel on public roads? What needs to be changed in the first place?
— Partially, but not systematically. Ukraine has a basic law on alternative fuels, valid as amended on July 5, 2025, and there is also a general architecture for vehicle type approval and accession to the 1958 Geneva Agreement concerning the Adoption of Uniform Technical Prescriptions for Wheeled Vehicles. The problem is that from publicly available acts, a comprehensive, separately assembled regime for hydrogen transport and hydrogen refueling stations following a logic similar to the European AFIR is not visible. That is why the primary need is not simply to add the word “hydrogen” to a few acts, but to assemble the complete route from type approval and technical control to the construction, launch, and supervision of HRS. The IEA explicitly calls regulatory clarity a priority for Ukraine’s hydrogen development.
In this context, the activities of the Working Group on the Development and Implementation of the Hydrogen Reform in Ukraine, created within the framework of the Ukraine Energy Initiative of the UN Global Compact in Ukraine, are indicative. At the official level, its goal is defined as the development of regulatory, institutional, and economic solutions for the implementation of the hydrogen reform, taking into account the legislation of Ukraine, EU standards and policies, as well as the practices of OECD countries. For us, this is not an abstract discussion, but practical work to ensure that hydrogen in Ukraine does not remain just a topic of strategies, but receives an applied legal framework for transport, industry, infrastructure, and investments. It is also particularly important that Juscutum is one of the initiators of the creation of this working group and is its active participant.
— What could the transport and energy landscape of Ukraine be like in 10 years if we use this technological window of opportunity?
— In ten years, Ukraine may become not a country of mass hydrogen passenger transport, but a country of heavy hydrogen specialization. A realistic scenario is a network of several industrial and logistical hydrogen hubs, or as it is customary to say now – Hydrogen Valleys, connected with decentralized generation, local electrolyzers, a limited but highly utilized HRS network, as well as with the localized production of individual components: engine elements, pipe solutions, compressor and power equipment, and special machinery. In such a model, hydrogen works simultaneously as a transport fuel, a tool for energy system flexibility, and part of a new industrial policy. If this is not done, Ukraine risks remaining merely an importer of foreign technologies and foreign standards. The IEA directly sees a long-term role for Ukraine through the phased development of assets, regulation, financing, and international cooperation, and the Ukrainian course towards decentralized generation creates the energy basis for this.
Looking soberly, H₂-ICE for Ukraine is a real chance to preserve and restart a part of mechanical engineering through heavy transport, special equipment, and industrial clusters. The question is no longer whether hydrogen has a technical future. The question is whether Ukraine will be able to create a legal basis, infrastructure, and industrial cooperation for it in time.
Hydrogen for Ukraine is not just a strategic prospect, but a real opportunity for a phased industrial and energy transformation. As Oleksiy Hnatenko emphasizes, the development of H₂-ICE and hydrogen infrastructure allows for preserving production capacities, adapting existing supply chains, and creating competitive industrial clusters. The key factor of success is the synchrony of actions between the state, business, and international partners: a clear regulatory framework, pilot projects, and the localization of production will become the foundation for the implementation of hydrogen technologies.
In such a model, hydrogen becomes not merely an energy resource, but an instrument of energy system flexibility, a driver of industrial development, and a foundation for Ukraine’s integration into the European market. Expert cooperation, public-private initiatives, and clear legal frameworks are precisely the components that allow hydrogen to be transformed from a promise into an applied, economically justified reality for the country.
