In December 2025, the European Commission published the second Projects of Common and Mutual Interest (PCI/PMI) aiming to grant priority status to a record number of cross-border hydrogen infrastructure projects. It includes 108 hydrogen related projects: 59 transmission pipelines, 21 electrolysers, 19 storage facilities and 9 reception terminals. Food & Water Action Europe and Bankwatch CEE analysed all hydrogen projects on the PCI/ list and compiled the alarming findings in this new report: “Hallucinating hydrogen: Why the PCI/PMI process must be overhauled”.
More than two-thirds of the hydrogen pipelines on the list – 42 out of 59 – are likely to transport fossil-fuel-based hydrogen for decades. And seven of them are rebranded gas projects. Few, if any, electrolyser projects are set to include additional renewable electricity capacity; most will rely on grid power, which risks cannibalising existing power generation. Although far from economically viable, hydrogen import terminals aim to receive mostly fossil-fuel-based ammonia. The use of hydrogen derived from fossil fuels will undermine the EU’s current plans to limit dependence on fossil fuel imports.
The scale of the planned hydrogen infrastructure far exceeds the current level of hydrogen economy development in the EU, and is out of touch with realistic forecasts for renewable hydrogen production and demand. This creates a serious risk of stranded assets if these projects are ever built. Even in the best case scenario, it would still mean wasting public funds on expensive feasibility studies and permitting procedures, which could amount to tens of millions of euros, based on recent Connecting Europe Facility (CEF) calls.
Governance flaws in the TEN-E framework are one of the reasons for this outcome. ENTSOG retains control over infrastructure planning, scenario development and cost–benefit analyses, despite its clear conflicts of interest, which have been repeatedly flagged by the EU Agency for the Cooperation of Energy Regulators (ACER), the European Scientific Advisory Board on Climate Change (ESABCC) and civil society. The result is a self-reinforcing cycle in which gas incumbents define ‘system needs’, shape the methodology used to assess candidate projects, and then evaluate projects proposed by their own members.
The Council and Parliament must reject the current Delegated Act on PCIs and PMIs, as it would support an oversized network running on fossil-based hydrogen. Alternatively, it risks creating costly stranded assets.
Upcoming reforms to the TEN-E Regulation must curb the influence of the fossil-fuel industry, ensure democratic oversight, and end public funding for fossil-based hydrogen and related infrastructure. The EU’s hydrogen plans must focus on local and fully renewable production used only in sectors that cannot be directly electrified. Overall, the EU’s energy planning and financing must prioritise electrification and proven renewable technologies, such as interconnections, smart grids, and renewable integration, as the most efficient path to decarbonisation.
Check out the full report for more details!
