Framework Conditions for Hydrogen Valleys in the EU: Understanding Legal Barriers to Cross-Sectoral Regulation

The European Union's commitment to climate neutrality by 2050 has positioned hydrogen as a cornerstone technology for decarbonising hard-to-abate sectors and enabling energy system integration. Central to this transition are hydrogen valleys, integrated ‘ecosystems’ that connect the hydrogen value chain within geographically concentrated areas. Despite their strategic importance as building blocks for the hydrogen economy, hydrogen valleys face regulatory and governance barriers that may impede their development and scaling. This article addresses gaps in the emerging literature by mapping the evolution of hydrogen valleys from hydrogen territories to multi-sectoral ecosystems, while identifying key regulatory impediments to their deployment, revealing the absence of a coherent legislative definition that creates legal uncertainty and constitutes a barrier to hydrogen valley development. The analysis identifies five further primary barriers: (i) complex and fragmented funding mechanisms; (ii) the EU's strong policy preference for renewable hydrogen; (iii) fragmented permitting processes lacking streamlined valley-scale procedures; (iv) underutilisation of hydrogen's ‘nodal’ potential for system integration; and (v) a disconnect between the critical raw materials/hydrogen nexus. The article proposes regulatory solutions including establishing legislative parameters to define hydrogen valleys; implementing streamlined permitting procedures; adopting technologically neutral and coherent funding mechanisms; and emphasising hydrogen's role in energy storage and system flexibility. These reforms represent necessary conditions for transforming hydrogen valleys from promising concepts into operational cornerstones of the EU's hydrogen economy.