Our Positions
EV charging issues cross many policy areas - Consumer affairs, energy, IT & cyber, automotive, manufacturing, and many more.
Search below or use our filters to find our position papers on the topics of interest to you.
Charge Smarter, Not Harder: Unlocking the Potential of Smart EV Charging for European Grids and Consumers
With more and more Electric Vehicles (EVs) on the streets, higher use of electricity in buildings and industry, and increasing electricity production from Variable Renewable Energy Sources (VRES) such as wind and solar, network system operators will need to invest massively to upgrade and modernize the grid to maintain supply and demand in balance and to ensure the grid’s resilience and security.
Smart charging has a key role to play in optimizing the use of the existing grid capacity. It can adapt EV charging to the needs of grids and consumers and distribute electricity to as many cars as possible.
Currently, the full potential of smart charging is untapped due to inadequate regulatory frameworks and the nascent state of bidirectional charging technology. To unlock its full potential, existing barriers must be removed. Recent EU legislation is a step in the right direction, but effective implementation is crucial.
In this paper, ChargeUp Europe highlights the benefits of smart charging in the EV sector and the steps that must be taken to overcome legislative barriers and ensure its effective rollout on both a European and national level.
You can read the full paper on smart charging here.
Access to In-vehicle Data for EV Charging: Consumer and Grid Benefits
ChargeUp Europe strongly supports the upcoming Commission’s proposal on access to in-vehicle data. Significant benefits to both drivers and energy system will be unlocked as a result of fairer and better sharing of vehicle data with third parties. Effective legislation could ensure an improved experience for consumers, and at the same time enable value-added services to help balance the electricity grid and manage energy consumption.
ChargeUp Europe calls the European Commission to:
Establish EU Regulation that creates a level playing field for access to in-vehicle data, improving consumer choice and experience by enabling CPOs and other third parties to offer high-quality charging services.
Consider the devastating disadvantage of a lack of such level playing field to the EU consumers and the electricity grid, resulting in slower uptake of EVs and inefficient grid upgrades.
Read the paper, here.
One Step Closer to an Open and Interoperable EU PKI Ecosystem that Ensures Fairness and a Level Playing Field
The ChargeUp Europe vision:
An open and interoperable EU PKI EcoSystem that ensures fairness and a level playing field.
As Plug&Charge becomes more widely available for EV drivers, it is critical that the Public Key Infrastructure (PKI) security framework underlying these services is developed in a way which ensures the highest level of security, interoperability, and fair competition. The same applies to the EU PKI EcoSystem, and the market rules that should govern it. ChargeUp Europe advocates for EU regulation and governance that ensure that driver choice is prioritised, delivering a level playing field between MSP offers and ensuring that every MSP (third-party, or EV-OEM or CPO-owned) can provide an equal, seamless (in-vehicle) user experience and functionalities for Plug&Charge and no "self-preferencing" occurs whereby the driver is bundled or locked-in to a specific service. Such bundling undermines the ability of EV drivers to choose and can lead to the market being dominated by a small number of large players, reducing competition on innovation, services, and pricing and reducing choice for the driver.
Read the paper here.
“Action Plan to Facilitate Grids Rollout”: The EV Charging Perspective
ChargeUp Europe calls for:
Fixing permitting: EU legislation should establish a dedicated, permanently simplified permitting procedure for EV charging projects, including: a/ a mandatory permitting framework; b/ simplified permitting processes; c/ binding deadlines to public authorities delivering permits; d/ a one-stop shop concept. In addition, a regulatory framework allowing DSO to prioritise grid connection requests coming from some actors (meeting defined climate and social criteria) must be established, reforming the “queue” system by creating a parallel, “fast lane” for them.
Updating governance: Energy governance needs to evolve, with a/ more direct role on steering implementation from the EU level; b/ a High Representative for Electrification and Grid Modernisation in the new Commission; c/ a Joint Office of Transportation and Energy (as in the US); d/ a regulatory framework requiring National Regulatory Authorities (NRAs) to step in to design national solutions.
Designing pragmatic workarounds to alleviate labour shortages: NRAs should provide for the expansion of certified parties (e.g. technicians and electricians) allowed to work independently on grid connected infrastructure, as a stop-gap measure until more staff are available at DSOs to perform technical tasks such as connections.
Why EV charging?
EV charging, even among Distributed Energy Resources (DER), is perhaps the most distributed. Normal and high power charging locations are deployed all over – public parking lots, highway rest areas, hotels and restaurants, homes and apartment buildings, gyms and malls, logistic or sports centres, etc. Unlike even rooftop solar and heat pumps which are connected to a house or construction site which may take a year or two to build, EV charging stations can be installed and connected in far less time (not counting the associated grid connection work). Due to this extremely distributed nature and relatively short project timeline (from the CPO side) the permitting and process needs of EV charging are different from those of energy generation projects and even other DERs. Properly enabling this sector to scale widely and rapidly is essential to the EU meeting its climate targets. This paper outlines recommendations for the “Grid Action Plan” to do just that.
EV Charging Business Fundamentals Factsheet
The expansive EV charging value chain includes a wide range of actors, ranging from component manufacturing to after-market maintenance.
Here is the factsheet that introduces all actors of the value chain:
EV Charging Business Fundamentals
Here are the actor-specific factsheets:
EV Charging Business Fundamentals & Hardware Manufacturers
EV Charging Business Fundamentals & Charge Point Operators
EV Charging Business Fundamentals & Mobility Service Providers
EV Charging Business Fundamentals & Roaming Platforms
EV Charging Business Fundamentals & The After-Market: Maintenance and Circularity
Statement on the calculation of the GHG savings of renewable electricity in transport under the Renewable Energy Directive (RED II) – Expected outcome of trilogue
The signatories to this letter have consistently advocated for an accurate valuation of the carbon savings from electricity as a transport energy vector in the revision of the Renewable Energy Directive (REDII), properly taking into account the GHG emissions reduction from the EV drivetrain due to superior efficiency (higher energy conversion efficiency of renewable electricity versus other drivetrains, i.e., most power used to propel the vehicle not wasted)2, and for a market framework reflecting that technological fact.
The European Parliament and the Council must ensure that both energy and Greenhouse Gas (GHG) based calculation systems recognise this higher efficiency:
For a GHG-based approach, we urge that the fossil electricity reference value of 183gCO2 eq/MJ (as originally proposed by the European Commission) is a minimum floor under which the revised RED should not fall.3
For an energy-based approach, we urge that an appropriate Energy Efficiency Ratio (“multiplier”) of 4 should be retained to provide parity with the GHG approach.
Read the full letter here.
Joint statement ahead of the vote of the European Parliament on the Energy Performance of Buildings Directive (EPBD)
Making sure people can charge at home and at work is critical to boost EV uptake. Ahead of the vote in the European Parliament plenary, we have joined forces with other key stakeholders to support the report of the ITRE committee. The level of ambition must be maintained.
Read the full joint statement here.
Hook Us Up! Simplifying and Accelerating the Grid Connection and Permitting Process for EV Chargers
A successful transition to e-mobility requires a quick deployment of large amount of EV charging infrastructure, for which grid connections represent the single largest bottleneck.
What benchmarks would an efficient and fit for purpose grid connection permitting process look like?
✔ Standardization of steps and procedures
✔ Transparency at all stages
✔ Predictability of outcomes
✔ Harmonisation of the process across Europe
✔ Speed in the time between requesting a permit and realising the connection to the grid
To find out how Charge Point Operators, Distribution System Operators and public authorities can better work towards these objectives while making the best of current limited resources and shrinking timelines, read the paper here.
Recently, we also published an open letter on the same issue, bringing together a coalition of over 20 CPOs from the EU who are united in their voice on the way forward in tackling this single largest bottleneck in rolling out charging infrastructure. Have a look at our campaign page, and if you are a concerned CPO, sign the letter!
Joint Letter: Unlock the demand-side flexibility potential through a consumer-centric EU Electricity Market Design
The revision of the Electricity Market Design (EMD) offers a precious opportunity to address in a structural way the current energy resilience and energy affordability crises, while supporting the clean energy transition with consumers in the lead (from households to energy intensive industries, acting individually or collectively).
Thanks to a wide set of Distributed Energy Resources (DER), including demand management, energy storage, electric vehicles and distributed energy efficient and renewable generation, all consumers can become providers of flexibility. As the electricity system transforms, they will become essential actors in an efficient, digitally-enabled, interoperable and renewables-based power system.
ChargeUp Europe and a broad group of ten other business associations, NGOs and civil society organisations welcome that the importance of active consumers and demand-side flexibility (DSF) is central to the considerations of the European Commission for this revision.
To find out the full list of recommendations, read the letter here.
Plug & Charge, ISO 15118, Public Key Infrastructure (PKI), and the Need for Proper Governance
ChargeUp Europe outlines the key aspects of ISO 15118 and how the implementation and governance of this standard will be fundamental to ensure a level playing field for operators and provide choice for EV drivers. If implemented correctly, the services enabled by ISO 15118 can deliver a smoother charging process and bring major benefits to EV drivers and the grid. However, if not governed in a way that enables open and fair competition, EV drivers risk being locked-in to a single provider which then prevents customers from (easily) choosing for access to alternative MSP services and offers. ChargeUp Europe calls for a single legislative instrument which lays out clear market and governance rules which ensure open and fair competition for both Plug & Charge and Smart Charging aspects of the standard. It should address both the vehicle and charger requirements.
Read the paper here.
Joint letter: Demand-side flexibility is a strategic answer to the energy crisis
ChargeUp Europe, together with the European Association for Electromobility (AVERE), Confederation of European Paper Industries (CEPI), the European Association for the Promotion of Cogeneration (COGEN Europe), current, Environmental Coalition on Standards (ECOS), European Federation of Energy Traders (EFET), European Energy Retailers (EER), The European Heat Pump Association (EHPA), European Renewable Energies Federation (EREF), The European association of smart energy solution providers (ESMIG), smartEn, SolarPower Europe and T&D Europe issued a joint letter to Ursula von der Leyen, President of the European Commission; Frans Timmermans, Executive Vice-President for the European Green Deal and Kadri Simson, Energy Commissioner.
In this statement the signatories state that both short and long-term solutions to the current energy crisis is demand side flexibility and to to empower all consumers with decentralised energy resources and allow them to self-consume, adjust and trade their energy consumption, storage and on-site renewable and efficient generation, directly, or through local communities and aggregators.
Read the full statement here.
Statement on EP TRAN Committee adoption of AFIR report
On 3 October, the European Parliament’s TRAN Committee approved MEP Ismail Ertug’s report on the proposal for a Regulation for the Deployment of Alternative Fuels Infrastructure (AFIR), an important step on the journey to a harmonized framework for publicly accessible charging in Europe.
MEPs agreed on ambitious EV charging infrastructure targets, allowing the EU to achieve its decarbonization objectives but are asking for retrofitting of existing AC stations with payment card readers, which would undermine the market for publicly accessible AC charging and would be a significant step backwards.
Read the full statement here.
Statement on the critical role of smart electric transport in addressing the energy crisis
ChargeUp Europe publishes a statement on the critical role of smart electric transport in addressing the energy crisis together with Transport & Environment, AVERE, and SmartEn. The statement contextualises the role of EV charging in the wider context of the worst energy crisis Europe is facing since the 1970s. The statement also calls for a holistic approach that is collective and emphasises the need to explore multiple avenues for engagement.
Read the full statement here.
10-point action plan to make buildings ready for electric mobility
ChargeUp Europe publishes a 10-point action plan together with Transport & Environment, AVERE, and Europe On. The action plan provides a clear guidance for an effective road ahead for calling on the EU institutions to amend the Energy Performance of Building Directive (EPBD) so that EV charging at home or at the workplace becomes easy and accessible for all.
ChargeUp Europe statement on keeping the digital and green transition to e-mobility on track amid an energy crisis
ChargeUp Europe:
Recognises that the European Union is facing the unprecedented, short-term challenge of managing shortages, extreme price volatility and high prices in gas and electricity markets while also confronting the climate crisis and managing the transition to cleaner, more resilient and sustainable energy systems.
Calls for recognition that it is of critical importance that the long-term objective of decarbonization and the digital and green transition to e-mobility are not sacrificed as EU institutions and national governments seek to alleviate short-term pressure.
ChargeUp Europe's response to the Commission's public consultation on Access to Vehicle Data, Functions and Resources
ChargeUp Europe welcomes the European Commission’s public consultation on access to vehicle data, functions, and resources. ChargeUp Europe is convinced that ever-increasing amounts of data will have a significant impact on the transport ecosystem. Therefore, the upcoming initiative comes at a critical time in Europe’s transformation into a smart, digital and sustainable economy.
ChargeUp Europe calls for:
Equal access rights to data, functions and resources including guidelines and requirements on data quality as well as the frequency of communication/data sharing, based on mandatory fair, reasonable and non-discriminatory terms.
The list of vehicle data, functions and resources accessible on a specific model or version of a vehicle would need to be published or otherwise made available by the vehicle’s manufacturers.
Reporting obligations for manufacturers to be introduced, to inform competent authorities (e.g., type-approval authorities and the Commission) about the implementation of such access rights.
Legislation to recognize that access to data in itself is not sufficient, but a successful exchange of data in a seamless, coordinated and timely manner based on existing and open standards is required.
Read the full response here.
EV Charging & VAT - Position Paper of the ChargeUp Europe E-mobility VAT Group
ChargeUp Europe is the voice of the electric vehicle (EV) charging infrastructure industry, working towards an expeditious and effortless rollout of EV charging infrastructure in Europe. Given the challenges and uncertainties of the current EU Value Added Tax (VAT) system for EU cross-border EV charging, ChargeUp Europe set up a new E-mobility VAT Group (EVG) in 2022.
The EVG is a group of business and tax experts covering the whole supply chain of the E-mobility sector, with both ChargeUp Europe members and non-members involved. This group is aligned to actively support and promote the future EU growth of E-mobility and EV charging, in line with the objectives of the European Green Deal. It is a truly European group with participants established in several Member States doing business across Europe.
The aim of the EVG is:
to raise awareness on the topic of VAT and EV charging among key policy stakeholders on an EU and Member State level;
to share and explain the commercial and operational set up of EV charging;
to outline the needs and address the VAT challenges that currently hinder EU cross-border growth as well as the development of a European Single Market for EV charging and
to support providing appropriate solutions that foster future growth.
In this paper ChargeUp Europe’s EVG wants to address key issues related to the VAT treatment of EV charging across the EU - what the root causes are, where they derive from and how they can be resolved – in order to support promoting the sector’s EU cross-border future growth with huge benefits for both businesses and governments and aligned with and critical for Europe’s Green Deal Agenda.
Read the full position paper here.
Making the Case for Private Charging under the Energy Performance of Buildings Directive
Widespread and easy EV charging options will be critical to drive the uptake of electric mobility. The Commission’s Energy Performance of Buildings Directive (EPBD) proposal therefore comes at a critical time to accelerate Europe’s shift towards e-mobility. At the same time, EVs and charging infrastructure can play a critical role in making buildings more energy efficient, managing grid capacity through smart charging and contribute to the EU’s Green Deal objectives.
The Commission’s proposal rightly recognizes the key role of EV charging in decarbonizing the EU building stock and paves the way to ensure the uptake of e-mobility across the European continent.
The Commission’s proposal contains many positive, forward-looking provisions and ChargeUp Europe very much welcomes the inclusion of ambitious EV charging infrastructure targets, the emphasis on smart charging, and the proposed requirements on consumer empowerment to make the installation of EV charging infrastructure in private locations easier and more accessible.
While we welcome the EPBD proposal, there are some key aspects that require further attention to ensure that the complementary benefits from integrating buildings and transport are fully utilized. The following document outlines ChargeUp Europe’s views and recommendations on the EPBD proposal.
Boosting the use of renewable electricity in EU transport - Making the case for EV charging under the Renewable Energy Directive
The revised proposal of the Renewable Energy Directive (REDIII) includes a very welcome focus on the potential of EV charging to contribute to cleaner, more efficient energy systems, and is closely linked to the revision of the Alternative Fuels Infrastructure Regulation (AFIR). Both will play an important role in creating the right framework of EV charging across different uses and locations.
The proposal rightly recognizes the numerous benefits that EV charging offers for the electricity system in terms of flexibility, load balancing and storage opportunities. At the same time, the proposed credit mechanism scheme will play a key role in greening EU transport, as it will boost the use of renewable electricity in the transport sector. To deliver on these opportunities, it will be critical to properly account for the benefits brought by supplying renewable electricity to the transport system and to maximize the potential of e-mobility.
Read the full statement here.
Public tenders guidance note
In this guidance note, we outline the urgent need to address public authorities’ recent designs of public EV infrastructure tenders that put into jeopardy the much-needed private investment flowing into the public infrastructure segment of the EV charging market.
Setting maximum prices and creating excessive financing conditions are not what our sector needs. The EV charging infrastructure sector is a rationally driven business that is best steered through public tenders focused on quality-of-service provisions. Dictating economic terms on how EV charging infrastructure should be run will have a significant impact on the market and affect the speed of the rollout of public EV charging infrastructure in Europe.