CEE Bankwatch Network submissions to the 2nd PCI/PMI list consultation

Comments    |    16 May 2025

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The European Commission published the 2nd PCI/PMI candidate list of hydrogen infrastructure projects in November 2024. The public consultations were carried out from February to April in 2025, with the list of confirmed projects expected in November 2025.  

We reviewed 12 candidate PCI hydrogen infrastructure projects across 6 countries in central and eastern Europe: Estonia, Hungary, Latvia, Lithuania, Poland and Romania.  

While varied in context and content, main critiques across the projects follow similar themes – lack of evidence on how the projects will contribute to sustainability and the high risk of stranded assets related to unproven financial and technical viability.  

Despite the undeniably early development phase of renewable hydrogen markets, which is used as the main argument that excuses the current lack of visible feasibility for the pan-European pipeline infrastructure, there lacks a scientific evidence base that warrants the support to such an expensive infrastructure. Instead, the focus should be on localised hydrogen production near the centres of consumption. 

The countries in the region are lacking a clear vision of hydrogen’s future role in their energy mix.¹ This is exemplified in the inconsistency of hydrogen targets and plans across various national strategic documents, further undermining the credibility of proposed PCI projects.  

A few of the proposed projects, such as the Polish section of the Baltic Sea Hydrogen Collector and Hungarian Firefly electrolyser project are not even included in the national strategic documents or the TYNDP.  

In Romania, the new planned hydrogen pipelines would run parallel to existing gas pipelines, which are projected to be repurposed to also accommodate hydrogen by 2040. Two parallel hydrogen pipelines is a financial insanity, and a blatant example of a stranded asset in the theoretical making.   

On the lack of fulfilment of sustainability criteria, multiple projects are vague on issues such as what kind of hydrogen will be carried in the pipelines and stored. This is true for projects in all of the observed countries. For example, the Damasławek Hydrogen Storage project in Poland aims to partially store hydrogen produced from fossil gas, which supports the continued use of fossil fuels and produces significant methane and CO2 emissions, especially due to the inefficiency of carbon capture technologies.  

In Romania’s case, the hydrogen strategy mentions blending hydrogen with fossil gas for the ‘short term’, but it does not provide any further timeline or details on the blending (percentage of the mix). Due to the timeline of building these pipeline projects, it would mean that the pipelines might carry a hydrogen-fossil gas mix beyond the allowed timeline stated in point 1 of Article 31 of the TEN-E Regulation, which states the transitional period for infrastructure to allow hydrogen blended with gas to end on 31 December 2029.   

It is close to impossible to evaluate the true contribution of these projects to greenhouse gas (GHG) emissions reduction due to a lack of publicly available and reliable data.  In the case of Romania’s hydrogen pipelines, there is no publicly available data on quantities of hydrogen transported, proportions and extent of fossil gas blending, capacity and type of connected hydrogen production, and details on offtakers, making it impossible to verify its sustainability. 

In addition, the data supplied by countries, which is the foundation for the PCI/PMI needs assessment, is highly unreliable. For instance, the data provided by the Polish TSO GAZ-SYSTEM for hydrogen demand and production is questionable, with projections based on non-binding market screenings that lack transparency and evidence. The demand estimates are significantly higher than those in Polish strategic documents. 

Evidence of future cross-border trade of hydrogen is also a weak point for the assessed pipeline projects. 

In Poland, there is currently no evidence of hydrogen export potential, challenging the rationale for cross-border interconnections.  In the Hungarian case, the proposal to export domestically produced renewable hydrogen is questionable at minimum as Hungary’s domestic renewable hydrogen needs are not covered by the projected production. Same is true for Estonia and Romania, where renewable hydrogen export potential is looking very unlikely. For all countries, the 2030 renewable hydrogen production targets are looking further and further out of reach, putting incredible pressure on the following decade of 2030-2040 to deliver a rapid increase in expected scale-up in production.