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.
Towards zero-emission transport
Joint industry call for the right policy framework to kick-start the transition.
Decarbonising road transport is one of the key challenges of the European Green Deal. Moving towards carbon neutral mobility by 2050 will require a strong and concerted set of actions from different industry sectors, policy makers and society. We, as representatives of the key industries involved in the decarbonisation of road transport, take our role seriously. We are committed to play our part in paving the road to climate neutrality. Indeed, our sectors are already delivering a number of solutions: from zero- and low-carbon power generation and distribution, to smart grid solutions, to zero-emission vehicles. But we need a strong signal from policy makers that we will not steer the drive to decarbonisation alone.
Read the full statement here.
The need to remove PIN-pad obligations for EV charging payments
ChargeUp Europe, Avere, bdew, Doet, Euroelectric and Inspire welcome the publication of the Alternative Fuel Infrastructure Regulation (AFIR), a key pillar of the “Fit for 55” legislative package.
As industry stakeholders from across the globe representing the whole electric charging eco-system, we believe in the importance of the transport sector’s contribution to sustainable energy and the ambition of climate neutrality. We are cooperating closely as industry and with government and civil society to achieve these important goals. In that context, we also support efforts to take a consumer-focused approach to make driving and charging electric vehicles (EVs) more convenient and reliable.
How consumers pay for charging EVs is an important element in their charging experience and ensuring the availability of widely used payment methods will increase the acceptability and accessibility of EVs. However, it is our collective view and concern that the AFIR proposals obligation for direct payment card functionality on public charging stations is overestimating the positive impact for customers and underestimating the negative consequences on overall EV infrastructure and availability of charging.
The importance of including EVroaming in AFIR
The Alternative Fuels Infrastructure Regulation (AFIR) will shape public electric vehicle charging in Europe for the next decade. It offers the opportunity to create a driver centric EV charging framework that ensures widespread charging availability across the EU and promotes innovation and energy system integration. It can empower drivers to control their charging behaviour and optimise their energy consumption in a way that costs the least and is the most environmentally and energy efficient. This also contributes to some of the key efficiency goals of the Renewable Energy Directive (RED) recast.
To deliver on this opportunity it is critical that the legislation enables solutions that maximise the potential of EV charging in terms of consumer and environmental benefits, and broad energy system integration. In this regard, one of the key solutions is the EV charging subscription and roaming model, which is today a popular solution for payment for charging sessions all over Europe.
The case for open, non-prescriptive payment technology requirements in AFIR
The European Commission proposal for an Alternative Fuels Infrastructure Regulation (AFIR) can pave the way towards sustainable transport, driven by electrification and digitalisation.
One of the key aspects of the proposal relates to ad-hoc charging payments at fully publicly accessible stations. ChargeUp Europe strongly supports the goals of the AFIR proposal to make EV driving more accessible and user-friendly for EU citizens. Ad-hoc charging is very important in accelerating the transition towards e-mobility and should be available at all fully publicly accessible stations.
To increase the accessibility and reliability of the EV charging network it is vital to install more chargers at more locations so that every EV user has a place to reliably recharge. This is why ChargeUp Europe supports the calls for binding infrastructure targets at the member state level. However, we are extremely concerned that the approach taken with regard to payment technologies would have numerous unintended negative consequences delaying the energy transition. Mandating payment card readers would on publicly accessible charging infrastructure, with additional retrofit obligations, will slow down the deployment of infrastructure, reduce options or increase prices for customers.
For the EV driver, ad hoc charging options are widely available today. For payment and authentication, they use methods including web-based payments and mobile applications. EV drivers are well served by these methods. At the same time consumer behaviour and payment technologies are evolving rapidly. Mandating specific payment methods and technologies, especially ones which may soon be outdated is not future-proof and does not reflect the market and consumer payment trends for EV charging.
Therefore, it is critical for the AFIR proposal to maintain an open, future-proof approach to authentication and payments and avoid the mandating of card terminals on publicly accessible stations.
A vision for Public Key Infrastructure (PKI) for EV Charging
ChargeUp Europe has been formed to accelerate the switch to zero emission mobility and ensure a seamless driver experience with access to high quality, readily available charging infrastructure across Europe.
This paper outlines the importance of public key infrastructure (PKI) for EV charging. As e-mobility becomes mainstream the security of communications and transactions is ever more critical. To ensure the widespread rollout of EVs and EV charging around the globe, ChargeUp Europe calls for the development of a common global governance for EV charging PKI.
See the full paper here
For Consumers and Climate - ChargeUp Europe’s position on the Alternative Fuels Infrastructure Regulation(AFIR), Renewable Energy Directive (REDIII) and CO2 Standards for light duty vehicles proposals
ChargeUp Europe would like to applaud the European Commission on delivering an ambitious and forward-looking “Fit for 55” Climate & Energy Package.
The following paper outlines ChargeUp Europe’s views and recommendations on the proposal for an Alternative Fuels Infrastructure Regulation, a Renewable Energy Directive (REDIII), and the revision of the performance standards for CO2 emissions for cars and vans.
ChargeUp Europe calls for more ambitious e-mobility requirements under the EPBD
Europe has seen an e-mobility boom in recent years, with Electric Vehicle (EV) sales rising rapidly across the continent: in 2020, around 1.4 million passenger EVs were registered in Europe. That number is expected to grow at least 40% annually over the next decade, resulting in over 42 million passenger EVs on the road by 2030. Widespread and easy EV charging options will be critical to drive the uptake of electric mobility.
The revision of the Energy Performance of Buildings Directive (EPBD) therefore comes at a critical time to accelerate Europe’s shift towards e-mobility. Buildings, as a primary charging location, are central to satisfying the needs of EV drivers. At the same time, EVs and charging infrastructure can play a critical role in making buildings more energy efficient and contribute to the EU’s Green Deal objectives. Given that over 75% of EV charging takes place at home or at work, the EPBD will be a key instrument in enabling the development and deployment of EV charging infrastructure. Nevertheless, numerous administrative and regulatory barriers are currently halting the roll out of charging infrastructure in residential and non-residential buildings.
In this paper, ChargeUp Europe outlines key recommendations for the ongoing revision of the EPBD and calls for the introduction of a dedicated chapter on e-mobility which includes ambitious minimum requirements on cabling, as well as capacity-based targets for all non-publicly accessible charging stations (at residential and non-residential parking locations). These non-publicly accessible charging stations should also support smart charging functionalities.
For Consumers and Climate ChargeUp Europe’s position on the Alternative Fuels Infrastructure Regulation (AFIR) proposal
ChargeUp Europe, the voice of the European electric vehicle infrastructure sector, has published its response to the European Commission proposal for an Alternative Fuels Infrastructure Regulation (AFIR).
ChargeUp Europe welcomes the overall ambition of the proposals as an important step in the right direction, while also highlighting important issues that require further attention. AFIR comes at a critical time. It will set the framework for how we roll out EV charging infrastructure in Europe and how we harness the full potential of electromobility for decarbonization and energy system integration between now and 2030.
Targets have an important role to play during the early phase of market adoption and especially in lesser developed markets and where ambition is lower. With the support of our knowledge partner Arthur D Little, ChargeUp Europe analysed the European Commission’s proposed targets in light of market realities. We propose that targets are connected to the level of electrification of the total fleet in a given market, and that higher targets are needed when Member States are at an earlier stage, to help kickstart their development. These targets should continue on a decreasing scale until a Member State hits a share of 7.5% of battery-electric vehicles (BEVs) on their market and which point they can be phased out entirely.
According to Christopher Burghardt, President of ChargeUp Europe, “It is important to avoid a two speed Europe situation. New rules should give the right boost to underserved regions, while allowing the market to take over when targets are no longer needed. Higher targets that phase out as the EV fleet increases should provide an incentive for national governments to support infrastructure deployment and reassure citizens they can go electric regardless of where they live.”
ChargeUp Europe wholeheartedly supports the goals of the AFIR proposal to make EV driving and charging more accessible and user-friendly for all. There are two main business models which enable publicly accessible charging today - ad hoc and subscription based - with the subscription-based model accounting for the vast majority of public charging sessions.
ChargeUp Europe feels strongly that AFIR needs to better recognize and promote the key role of the subscription-based model. Well-designed E-mobility subscriptions provide many benefits to EV drivers such as lower prices, tailored offers, the ability to plug & charge, and more. Crucially, they also enable smart charging and thereby drive emissions reduction and energy system integration.
EV drivers need to be able to benefit from these advantages at as many charging stations as possible across Europe. AFIR should therefore ensure that all publicly accessible EV charging stations are capable of e-roaming.
At the same time, we believe it is necessary to maintain a technology neutral approach regarding how payments for ad-hoc and subscription model type charging are made. Mandating specific payment technologies as the current proposal foresees does not reflect the reality in the market today and how most payments on EV charging infrastructure are carried out. The current proposal does not leave sufficient room for market operators to react to market and fintech developments and thus runs counter to consumer interest and preferences.
“The ad hoc model and the subscription model are complementary to each other and should be treated on an equal footing under AFIR” said Christopher Burghardt, President of ChargeUp Europe. “Laws we adopt today have to stand the test of time. We need forward looking rules that harness the potential of new fuelling models to empower citizens and accelerate the decarbonisation of mobility and energy systems in Europe over the next ten years and beyond.”
Please see here our full position paper.
Please see here the detailed methodology developed by ChargeUp Europe and Arthur D Little for light duty vehicle charging infrastructure targets within Alternative Fuels Infrastructure Regulation proposal (AFIR).
ChargeUp Europe input to the Consultation on the Climate, Energy and Environmental Protection Aid Guidelines (CEEAG)
ChargeUp Europe congratulates the Commission’s efforts to include EV charging infrastructure under the scope of the CEEAG and welcomes the opportunity to provide feedback on the draft guidelines.
Read our input to the CEEAG consultation here.
Charging up Europe through binding capacity targets for publicly accessible charging infrastructure and Member State action plans
In this paper, developed with its knowledge partner Arthur D Little, ChargeUp Europe outlines the minimum capacity targets for publicly accessible EV infrastructure required at European and national level to serve the charging needs of EV passenger vehicles for 2025 and 2030. The paper also outlines the key components of Member States Charging Action Plans that should underpin these targets as well as stressing the need for a regulation in order to create a single European market for EV charging infrastructure. The paper also provides clear definitions for what constitutes as: fully publicly accessible, limited accessibility and private charging
See the full position paper here:
See the link below for the detailed overview of the methodology:
ChargeUp Europe calls for European Commission clarification on applicability of Measuring Instruments Directive (MID) to active AC and DC electrical energy meters
Why is the application of the MID currently a hurdle for the e-mobility?
E-Mobility will play a critical role in the decarbonisation of Europe’s transport sector and in reaching the EU Green Deal aim of carbon neutrality by 2050. To make this a reality, it is vital that a harmonised EV charging infrastructure market is created in Europe which makes driving and charging seamless across Europe.
In 2004, when MID was passed, there were almost no charging stations erected in Europe. The market started with mainly AC charging stations that partly contained MID meters known from household appliances, meaning that those AC chargers were manufactured and certified under MID.
A decade later, in 2014, the Alternative Fuels Infrastructure Directive was passed and Member States started applying metrology law to the meters inside the EV chargers and the chargers themselves, e.g. Germany in 2015. Fast charging was evolving but commercial DC meters designed for fast chargers were not available back then.
Today, there currently exists discrepancies and a lack of clarity regarding certain rules and technical requirements for EV charging, including in the area of metering and the application of MID to both AC and DC electrical energy meters.
ChargeUp Europe - Position paper on VAT for EV charging
In this paper ChargeUp Europe wants to point out some of the main issues the EV charging infrastructure industry is currently facing with regard to VAT and wants to bring the issue forward for debate in order to elaborate possible strategies to remedy the current situation.
VAT law has been found to be crucial for the development of a European Single Market for EV charging infrastructure. When it comes to cross-border transactions, the industry is confronted with many uncertainties regarding the correct interpretation of EU and national VAT law. On top of this, the existing VAT regime has turned out to be a major obstacle to the development of an integrated European EV charging infrastructure market.
In our paper, we highlight some of the main issues the EV charging infrastructure industry is currently facing with regard to VAT and we put forward 6 key recommendations for next steps.
See the full position paper here.
ChargeUp Europe input to Consultation on Revision of TEN-T
The revision of the TEN-T needs to take place in the broader context of the ongoing revision of AFID and EPBD. This is a critical time in the transition to zero emission transport. The decarbonization of road transport is an achievable mid-term goal and can be accomplished with e-mobility at its core. A comprehensive EU wide governance regime for e-mobility should be developed to deliver a comprehensive and harmonized approach to EV charging rollout through coordinated revision of TEN-T, AFID, EPBD and TEN-E. This can provide the framework for EV charging infrastructure rollout at all levels - private, public and cross-border level and for different use cases.
For the TEN-T revision specifically, a number of key factors must be taken into account in order to deliver the most widespread, harmonized and effective EV charging rollout across the European road network which makes the transition to zero emission transport successful and doesn’t leave any regions behind.
Check our recommendations here.
ChargeUp Europe Letter - call for standalone Regulation for EV Charging Infrastructure
Europe needs a new standalone Regulation for EV charging infrastructure
ChargeUp Europe, the voice of the electric vehicles (EV) charging infrastructure industry, today issued an open call to EU leaders to come forward with a dedicated Regulation on EV charging infrastructure in Europe – separated out from existing rules on alternative fuels - or risk losing momentum in the fight against climate change.
Check out our letter here.
ChargeUp Europe: The building blocks for an open market for EV charging infrastructure in the EU
ChargeUp Europe is publishing an ‘open market building blocks’ series to highlight a number of areas where the principles of an open market model are not in place at present, and we believe policy intervention is needed.
This particular paper, cosigned with AVERE, examines the issue of fast charging concessions on highways and main traffic corridors and the need for coordinated, open and non-discriminatory concessions. This paper can also act as guidance for the European Commission recommendations on planning and permitting processes on alternative fuels infrastructure, announced in the Sustainable and Smart Mobility Strategy.
See our paper here!
ChargeUp Europe criteria for funding under the EU Recovery & Resilience Facility
ChargeUp Europe whole-heartedly supports the focus on EV charging infrastructure in the recharge and refuel flagship initiative, and we fully endorse the need to include this flagship initiative in Member State national investment and recovery plans.
Please find here our paper outlining 5 key criteria to inform the deployment of public funding for EV charging infrastructure under the Recovery and Resilience Facility.
Integrated approach for national recovery plans
Addressing market gaps
Interoperability
Future proofing & harmonization
Open and transparent tender procedures
We encourage the European Commission to take into account the criteria listed in this document to ensure that the assessment and delivery of projects under the Recovery and Resilience Facility enable the EV sector to maximize its contribution to the EU’s economic and climate ambitions.
ChargeUp Europe input into the EU roadmap on the inception impact assessment for the revision of the Renewables Directive.
Introduction
ChargeUp Europe is an industry alliance acting as the voice of the electric vehicle (EV) charging infrastructure industry. ChargeUp Europe has been formed to accelerate the switch to zero emission mobility and ensure that people can have a seamless driver experience with access to high quality, readily available charging infrastructure across Europe.
As of today, our member companies – Allego, ChargePoint, EDP, EVBox, evway, Fastned, GreenWay and has.to.be - represent over 175.000 charging points in all 27 EU Member States.
Our member companies provide the hardware and the software infrastructure to charge all types of electric vehicles at all power levels. E-mobility will be instrumental in supporting the decarbonization of the transport sector in Europe. It is therefore crucial for Europe to develop an integrated policy framework to enable this transition and meet EU’s climate 2030 ambition.
Renewables Directive
The Renewables Directive is an instrumental piece of legislation to support the electrification of the transport sector and to power electric vehicles with renewable energy. For this reason, ChargeUp Europe supports the overall objective described in the Impact Assessment to “ensure that renewable energy sufficiently contributes to the achievement of a higher EU Climate ambition (…)” and the subsequent need to “ensure synergies with other legislation”.
The current Directive already sets mandatory targets for Member States to have a share of renewable fuels for transportation including renewable energy. The reality has however demonstrated that very few Member States actually take into account the share of renewable electricity used in transportation. While the Renewables Directive sets the right goals, it is still failing in providing the effective instrument to support widescale and fast electrification of transport through green electricity.
In that regard, ChargeUp Europe members recommend:
Keep and increase binding targets for Member States to have a share of renewable electricity for transportation.
Prioritize electricity over other green fuels in the reporting calculation methodology. Electrification of transportation is not only already happening but has demonstrated to be the fastest and most sustainable way to reduce GHG emissions for transport1
Propose a harmonized way of integrating electricity in fuels markets through for example national crediting schemes where CO2 emissions savings certificates /clean fuels credits could be traded between electricity suppliers, aggregators, charging point operators/owners of publicly available charging stations and fuel suppliers. Such a mechanism would put electricity on the same level of other fuels to compete to green the transport sector but also create a financial resource for electromobility service companies to set up the EV charging network of tomorrow, reducing reliance of public funding.
Renewable power credit scheme for EVs
Decarbonizing the energy system goes hand in hand with increasing the share of renewable energy to power electric vehicles. While the Renewables Directive set targets for Member States to use renewables sources for transport, we believe that there is an opportunity to better leverage the role that electricity from green sources could play.
In RED II, renewable electricity used directly in transport can count towards the 7% advanced fuels target. Renewable electricity is subject to multipliers (1 energy unit of renewable electricity used in road transport can count 4 times towards the target), whereas renewable electricity used in rail transport can count 1.5 times (the latter is voluntary). Countries must use the share of renewables in the national grid to claim the share of renewable electricity used in transport.
In the case where the charging installation is directly connected to a renewable energy generation facility, 100% of the renewable electricity can be counted. In many countries, the compliance mechanism for the RED target rewards only the use of liquid renewable alternatives - mainly biofuels. To reward the use of renewable electricity in transport, such a mechanism would allow for a technology-neutral and cost-effective implementation of the advanced target and would include and treat all renewable energy forms in an equal manner.
So far, the majority of EU countries have not incentivised the use of electricity in the same way they do with biofuels. Through the implementation of the new RED for the period 2021 to 2030, Member States have the opportunity to include renewable electricity in their compliance mechanism to reach a target for renewable advanced fuels.
California, Netherlands and Germany are three examples showing that such a system will diversify the options available to the RED obligated parties - fuel suppliers - for meeting their targets and allow them to use other options beyond biofuels. It will also generate new financial resources to support the decarbonisation of transport and energy systems. It will encourage the uptake of renewable electricity and provide an additional private financing route for the roll-out of electric charging infrastructure or targeted rebate programmes for purchasing EVs. The system could generate up to €5.9 billion of credit value in 2030 at EU level or up to €1.2 billion for a country like Germany2.
A crediting system is a key tool for creating a level-playing field between renewable electricity supplied to EVs and blended biofuels, enabling the most cost-effective compliance with RED II for fuel suppliers.
Unfortunately, EU rules do not propose a harmonised way of integrating electricity in fuel markets, but Member States have the possibility to set a dedicated crediting system in place. Such a national system would give companies that supply electricity to transport, aggregators or charging point operators/owners the opportunity to qualify for clean fuel credits which they can sell to fuel suppliers. On top of diversifying compliance options, this is an opportunity to implement the “polluter pays principle”: Fuel suppliers that deliver final transport fuels will need to purchase renewable electricity credits to reduce their GHG footprint, when in most cases these fuel suppliers don’t invest themselves in electric mobility or in the production of electricity as a transport fuel. At the same time, the system can create a direct financial flow to entities taking part in building electromobility services, without using public money.
HOW TO ENABLE SUCH SCHEMES?
Who is entitled to generate the credits? In the Dutch system, companies that deliver electricity to road vehicles and that have connections to the electricity grid exclusively for that purpose are entitled to credits. This means that in reality only a small share of very large charge point operators benefit (smaller ones have not opted for the system and are excluded by the system). The way the system is applied in California is different as it is centralized through the California Air Resources Board (CARB) who provides credits based on estimates for all entities delivering power to EVs (incl. private charging).
For non-residential areas, several entities such as EV fleet operators, charging point operators and car makers (e.g. through metered information on board the vehicle), can opt into the system and generate their own credits. This system applies not only to electric cars, but also to electricity used by buses, trucks, rail lines and forklifts. In Germany, fuel suppliers pool with utilities, which provide electricity for EVs in public (certified consumption) and private charging points (estimated consumption basis).
Functioning of the crediting system: Electricity can be traded as a renewable unit (as in the Netherlands) and is then subject to the RED multiplier or, as it is applied in California, where there is a carbon intensity target set for the fuel supplier which extends the scope of the system to all low carbon fuels (not only renewables). Companies can also demonstrate ‘carbon free’ charging (e.g. solar panels on charging sites) which increases the electricity credits they receive. In Germany, only utilities can sell their renewable electricity credits to fuel suppliers. Charge point operators, electro-mobility platforms, car manufacturers and individuals that own an EV cannot participate, which is a real burden to the system.
Allocation of the revenue: It is desirable that the revenue generated from such schemes would be allocated to the deployment of charging infrastructure and would at the same time decrease the need for public finance intervention for such networks. In Germany, the revenue from selling the credits stays with the utilities. The German scheme does not include any earmarking of revenues for promoting EVs. In the Netherlands there is no re-allocation of the funds to e-mobility projects. There is no provision in the legislation – national and EU - to do so. In California though, the revenue from selling credits is earmarked by utilities for rebate programmes including providing point-of-sale rebates to EV buyers or payments to customers owning an EV.
Ensure consistency with other EU legislation such as the “Energy Performance of Building Directive” and the upcoming “Renovation Wave”. As a large part of private EV cars charging is taking place at home or at work, it is of crucial importance to ensure the deployment of an EV charging networks in buildings. The current Renewables Directive already makes reference to the Energy Efficiency Directive in its art.15 “Art.15. “Administrative procedures, regulations and codes” and we encourage the addition of a specific reference to EU legislation (existing or coming) related to an obligation to pre-cable or install EV chargers in new or renovated building in Europe. We take this opportunity to also reiterate our previous recommendations that EU should also mandate EV charging infrastructure in existing buildings.
CONCLUSION
In conclusion, based on the EU Roadmap published for the Revision of the Renewables Directive, ChargeUp Europe recommends to opt for Option 4 “Amend RED II to translate into legal measures the actions in other energy strategies of the EGD”.
This legislation can support the electrification of the transport sector – through renewable power- which will be vital for the EU to reach its EU climate ambition but also overall to contribute to a better quality environment for all EU citizens and at the same time support the transition of the automotive industry in Europe.
See our input here.