Institutional Bricolage and Interest Groups Preferences: Evolving Regulation of Nascent EU Hydrogen Market

The hydrogen industry—promoted alternately as the “silver bullet” of European decarbonization and a “Trojan horse” for fossil-fuel incumbents—rose to the forefront of EU policy debates under the first Von Der Leyen Commission. This paper examines how the Commission’s attempt to assemble a regulatory framework for a nascent hydrogen market by coupling elements from multiple established sectors became a core source of political contestation among competing interest group coalitions. The unique physical and production characteristics of hydrogen require regulatory components drawn from various pre-existing markets. Consequently, the emerging governance architecture blended features of natural-gas network regulation, electricity-market design, voluntary sustainability schemes for biofuels, and lessons from battery-industry scale-up, and also prompted debate on more dynamic, telecom-style approaches to network development. Yet this institutional bricolage generated new policy dilemmas that activated conflict among stakeholders. Highly contested issues included: preferred hydrogen production pathways; funding and ownership of new infrastructure; the scope and boundaries of the future hydrogen market; interactions between renewable-electricity deployment and clean-hydrogen production; and proposals for dedicated hydrogen regulatory bodies or transmission operators. In resolving these disputes, Commission officials attempted to balance technological neutrality, industrial competitiveness, principles of market liberalization, and the imperative to expand renewable-electricity generation. The resulting policy outputs reflected a series of compromises across these partly incompatible objectives. Clear lines of political conflict emerged. One coalition—comprising natural-gas producers, network operators, and a wide range of industrial users—advocated a seamless transformation of the natural-gas sector into a hydrogen economy, with similar operational structures and continued influence for incumbent gas interests. In contrast, a coalition of renewable-energy producers, climate-advocacy organizations, and several downstream industries sought to confine hydrogen to hard-to-electrify sectors, arguing that an expansive hydrogen mandate would divert scarce renewable electricity away from direct uses and undermine decarbonization efficiency. Tracing the preferences of additional non-energy industries reveals deeper coalition alignments around competing visions of how to balance EU decarbonization goals with industrial competitiveness. The theoretical framework combines institutional bricolage—conceptualizing policy design as the redeployment of existing institutional elements to address new challenges (Carstensen 2011, 2017; Carstensen & Röper 2022; Wilder & Howlett 2014)—with the Advocacy Coalition Framework (Jenkins-Smith & Sabatier 1994; Weible et al. 2009; Rozbicka 2013). Empirically, the study employs automated text analysis of a database of position papers submitted by 243 organizational stakeholders across four hydrogen-specific European Commission consultations conducted between 2020 and 2024.