We derive the impedance for the hydrogen electrode in the polymer membrane fuel cell from irreversible thermodynamics. The results predict a surface contribution to the cell impedance that can give two semi-circles in the Nyquist diagram. The equivalent circuit of the impedance is shown. The high-frequency contribution is connected to the oscillation of dipoles consisting of free charges in the surface, while the low-frequency contribution is connected to the electrochemical reaction. This can be explained by a slowly relaxing proton conducting polymer network at the reaction site.