Europe is advancing the construction of a network of hydrogen refueling stations for trucks before the existence of a broad market capable of supporting it commercially has been established. Under the Alternative Fuels Infrastructure Regulation (AFIR), stations are supposed to be provided along major motorway corridors at intervals of no more than 200 kilometers by 2030, alongside additional coverage in designated urban nodes. It is estimated that creating a regulation-compliant network could require approximately €2.1 billion in capital investment.
The political logic behind this is clear: it is difficult to persuade truck operators to purchase hydrogen vehicles if they cannot refuel across borders, while investors are reluctant to build stations before customers exist. But South Korea’s experience offers a more mature practical test of this equation and reveals that accelerating infrastructure construction does not guarantee the emergence of a market capable of financing it.
Infrastructure Far Outpaced Demand
By August 2026, South Korea had installed 493 vehicle refueling units, or 74.7% of a target of at least 660 units by 2030. By contrast, only 49,220 hydrogen vehicles were registered, equivalent to 16.4% of a government target of 300,000 vehicles. These figures do not represent direct utilization rates, but they show that the program progressed in building stations much faster than it developed the customer base that was supposed to finance their operation.
The situation is even more significant when the financial data are considered. Of the 258 commercially active stations assessed in the first half of 2026, 208 received government support to cover operating losses, or 80.6%. Several relatively new stations also ceased operations, with weak commercial prospects or financial losses cited among the reasons for their closure. Stations outside the program cannot automatically be considered profitable, because eligibility conditions limit the scope of support; nevertheless, the extensive ongoing reliance on government assistance is difficult to reconcile with the assumption that early infrastructure will automatically become a commercially sustainable network.
Guaranteed Demand Differs from a Station Imposed by the Map
South Korea did not neglect the vehicle side; it combined purchase incentives, support for station construction, coverage of operating losses, and industrial policies to strengthen hydrogen production and infrastructure. Nevertheless, the network’s economics remained heavily dependent on public support after years of coordinated intervention.
Jeonju Pyeonghwa station offers a more positive example, reporting that it reached operational breakeven in 2024 thanks to concentrated demand from hydrogen buses. But the infrastructure was subsidized, and it is unclear whether breakeven included the consumption of capital; moreover, the hydrogen used was derived from fossil fuels. The example therefore shows that hydrogen refueling can approach viability under favorable conditions, not that a motorway station will necessarily succeed simply because it is required by regulation.
Buses return to refueling points predictably and consume large quantities, allowing the station to be designed around known demand. A station imposed to meet a geographic spacing requirement, by contrast, may depend on a truck market that has not yet formed.
Fuel Costs and Competition Multiply the Risks
The economics of hydrogen refueling in South Korea have developed largely around low-cost hydrogen derived from fossil fuels or petrochemical by-products. This helps improve station economics, but weakens the project’s climate rationale. Renewable hydrogen improves life-cycle emissions, but significantly increases fuel costs before transportation, compression, and distribution are added.
Europe faces the same tension; its hydrogen industry still relies overwhelmingly on conventional production, while the cost of renewable hydrogen rises before the costs of transporting, compressing, and distributing it are taken into account. Thus, a station may meet the geographic coverage requirement without demonstrating an attractive commercial price or emissions reduction sufficient to justify the policy.
Battery-electric trucks are also entering service in increasing numbers, and high-power charging solutions for road freight are expanding. Every truck that chooses batteries reduces the potential demand available to recover the fixed costs of hydrogen stations. The network should therefore be assessed against competing technologies over the lifetime of the assets, rather than against the freight market as it existed when the distance requirements were drafted.
What Should Be Tested Before Expansion?
This reading does not call for closing useful existing stations or preventing projects linked to committed fleets. But it questions the continuation of automatic geographic expansion. New stations should be subject to explicit tests covering expected fuel volumes, full capital and operating costs, the amount of public support required, the price and source of the hydrogen, and the climate value of the transport they actually enable.
South Korea’s experience shows that building the network is not evidence that the market exists. It has come close to implementing a substantial portion of its plan, while demand lagged and operating support remained widespread. Europe has an opportunity to use this outcome to review AFIR and distinguish between stations with clearly strategic demand and projects that may become underutilized assets requiring public support after construction grants are forgotten.