Sourcing AEM electrolyser components is now a question of origin as well as performance. On 19 October 2026, the European Commission selected 77 net-zero technology projects for €3.4 billion from the Innovation Fund and said it is preparing to launch its next calls in early December 2026. The fourth European Hydrogen Bank auction is planned for the same month, and its draft rules require projects to document where their stacks and main electrolyser components come from. For stack builders, integrators and project developers, choosing an AEM membrane supplier, electrodes or a complete stack has become a procurement decision with a paper trail. Here is what the rules say, which components they cover and how to qualify suppliers in time.
What the Commission announced on 19 October
According to the Commission's press release, the call attracted 358 applications requesting €17.5 billion, against a budget of €2.9 billion. Twelve of the selected projects are in clean-tech manufacturing. Together they request almost €895 million and include projects manufacturing clean-tech components such as heat pumps, solar panels, electrolysers and electric-vehicle batteries. The next round will include a €1 billion clean-tech manufacturing topic to de-risk supply chains.
The message for buyers: the EU is funding a European supply chain for electrolysers, and it is tying hydrogen subsidies to a diversified one.
The resilience rule: which AEM electrolyser components count
The IF26 Hydrogen Auction, the fourth auction of the European Hydrogen Bank, is planned to open in December 2026 and close in February 2027, with a proposed budget of up to €500 million. Its draft terms and conditions of 9 July 2026 keep the resilience requirement of the previous auction, aligned with the Net-Zero Industry Act (NZIA):
- At least 75 % of the electrolysers in a project (the individual devices, not the whole plant) must originate in a country other than China.
- For those electrolysers, the stacks must originate outside China.
- No more than two of the main specific components may originate in China. The stack does not count towards these two.
For AEM electrolysers, the main specific components are defined in NZIA Implementing Regulation (EU) 2025/1176, as quoted in the draft terms:
| Main specific component (AEM) | What it covers | Where CENmat fits |
|---|---|---|
| Stacks | Cells, compression hardware, media manifolds | HYScale AEM stacks and systems |
| Membrane electrode assemblies (3-layer) / catalyst-coated membranes | Membrane, ionomer, anode and cathode catalyst layers | AionFLX™ membranes and ionomer, OXYGN and H2GN electrodes |
| Porous transport layers / gas diffusion layers | Porous layers that carry water and gas to the electrodes | Specialist suppliers |
| Bipolar plates and end plates | Flow fields and stack end hardware | Included when you buy a HYScale stack |
Projects prove the claim with a memorandum of understanding (MoU) or letter of intent (LoI) from the electrolyser manufacturer. It must state the origin of the electrolysers and stacks, say whether any of the specific components come from China, and be no more than one year old at application. Projects report intended and actual origin again at financial close and at entry into operation. If the claims are not met, the grant can be reduced or terminated.
In practice, the rule makes stack origin a hard requirement and turns the origin of every main component into a documented, audited claim. Integrators will pass that obligation on to their suppliers. The final terms are still pending, so details may change before the call opens.
Five questions to ask every AEM component supplier
1. Where is it made, and will you confirm it in writing?
Ask for the country of origin of each component and whether the supplier will confirm it in a form your MoU or LoI can reference. A supplier that cannot answer this today is a risk in a bid that closes in February 2027.
2. Are membrane, ionomer and electrodes qualified together?
Many AEM problems start at interfaces: a membrane that swells differently from its binder, or a catalyst layer that delaminates. Components developed as one set reduce that risk and cut the matching work. Electrode architecture matters too. Our CCS vs CCM comparison explains why the EU project NEWELY moved from catalyst-coated membranes to catalyst-coated electrodes.
3. Which data, under which conditions?
Ask for operating hours, degradation rate in µV/h, electrolyte concentration, temperature, current density and active area. Without the conditions, numbers from different suppliers cannot be compared.
4. Which formats, at which scale?
Check sheet sizes, coated areas and batch volumes, and whether performance held from single cell to stack. A component that only exists at 5 cm² is not yet a supply option.
5. What is the regulatory and raw-material exposure?
Fluorinated membranes and ionomers face a broad EU-wide PFAS restriction that the European Chemicals Agency is still evaluating. Iridium and other precious metals are scarce and on the EU list of critical raw materials. PFAS-free membranes and PGM-free electrodes take both questions off your risk register.
Qualifying AEM electrolyser components for a 2027 project? Order a paid sample set of AionFLX™ membrane, ionomer and matched OXYGN/H2GN electrodes and test it in your own cell or stack. Request paid samples – we reply personally with price and availability.
What we supply, from materials to stacks
We work on AEM water electrolysis from materials to stacks and systems, so you can source the MEA materials and the stack along one qualification path. We are a German company, registered at Berge, with our laboratories in Böblingen. All figures below are published on our product pages.
Membranes and ionomer. AionFLX™ anion-exchange membranes are PFAS-free, validated for wet assembly and supplied in sheets validated up to 900 cm². The composite AionFLX™ Plus has run for more than 8,000 h at 1 A/cm² in 1 M KOH at 50 °C, with a degradation rate below 15 µV/h. The standard AionFLX™ membrane has run for more than 4,000 h in 0.1 M KOH at 50 °C, below 30 µV/h. AionFLX™ ionomer is the matched PFAS-free binder from the same material family.
Electrodes. OXYGN anodes and H2GN cathodes are PGM-free and CRM-free. Both come as catalyst powder or as spray-printed coated electrodes of up to 400 cm². With an OXYGN anode and an H2GN cathode, a cell reaches 2.01 V at 2 A/cm² (50 °C, 0.1 M KOH). The electrodes are validated at 400 cm² and in a 6 kW short stack, with the same performance in single cell and stack.
Stacks and systems. Our HYScale AEM electrolyser stacks are built on these materials. A 6 kW short stack with 400 cm² cells is validated. The 100 kW system is built with 900 cm² cells; production is completed and it is now in commissioning. The architecture is designed to scale to the 0.5–1 MW class, and short stacks are available for evaluation and paid pilots.
One materials pack. Membrane, ionomer and matched coated electrodes can be ordered together, so you qualify one set instead of three suppliers. For PEM projects, our OXYGN-M ultra-low iridium catalyst and CCMs work at an anode loading of 0.2 mg Ir/cm².
Tell us which origin information your MoU or LoI needs, and we will tell you what we can confirm.
A realistic timeline for a 2027 bid
If you plan to bid in the IF26 auction, the component decision comes before the MoU, not after it:
- Now to December 2026: order samples and run break-in, polarisation and a first durability test in your own hardware. A 1,000 h test alone takes about six weeks of continuous operation.
- Before the call closes in February 2027: fix your stack and MEA supply and make sure the origin information is in your MoU or LoI.
- After award: scale from short stack to modules with agreed formats, volumes and lead times, and keep the origin records for financial close and entry into operation.
FAQ
What are the main components of an AEM electrolyser?
For EU auction purposes, Implementing Regulation (EU) 2025/1176 lists four for AEM electrolysers: stacks, membrane electrode assemblies or catalyst-coated membranes, porous transport or gas diffusion layers, and bipolar and end plates. Inside the MEA sit the membrane, the ionomer and the anode and cathode catalyst layers.
Do the EU resilience rules ban components from China?
No. Under the draft IF26 terms, at least 75 % of a project's electrolysers must originate outside China. For those, the stack must originate outside China, and no more than two of the other main specific components may come from China. The final terms are still pending.
Are CENmat's AEM components PFAS-free and PGM-free?
Yes. AionFLX™ membranes and ionomers are PFAS-free, and our OXYGN and H2GN electrodes are free of PGMs and other critical raw materials. HYScale stacks are built on these materials.
How do I get samples or a quote for AEM electrolyser components?
Samples are paid and prices are on request. Use our sample request for membranes, ionomer and electrodes, or the quote request for short stacks, pilots and systems. We reply personally.
Next step
Building or buying AEM electrolyser stacks for a European project? Request a quote for HYScale short stacks, pilots and systems, or order paid samples of our matched AEM materials and start qualification now.
Funded by the European Union. HYScale has received funding from the Clean Hydrogen Partnership and its members under grant agreement No 101112055. Views and opinions expressed are those of the author(s) only and do not necessarily reflect those of the European Union or the Clean Hydrogen Partnership.