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.
Charging Up Europe’s Corporate Fleets
The future is electric, and the EV charging infrastructure industry is at the forefront of developing the solutions to not only support, but also drive the shift to electric road transports.
Maturity levels within the market for corporate fleets vary: policy initiatives must take this into account, while ensuring that electrification stays on track and accelerates where it is possible and desirable.
Love Me (Public) Tender: Input on Sustainable Transport Forum TF7 Work
Several years ago the EU developed a practical tool (“handbook”) for public authorities on how to design tenders for e-charging infrastructure. This practical tool is currently being revised by the “Sustainable Transport Forum” (STF), a body gathering industry and public authorities under the aegis of the European Commission.
A “short” version of the handbook will be released in April 2024, accompanying the application of the Alternative Fuel Infrastructure Regulation (AFIR). As a member of the STF, ChargeUp Europe has gathered information from its members on their experience with tender processes to influence this process and shape the next wave of public tenders across the EU.
Read our latest paper, where we discuss a set of obstacles and provide recommendations for public authorities to prepare fair, effective and balanced public tenders to deploy EV charging infrastructure across the EU.
Find the full version 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
Call from the Economy to the Grid: The New Highways of Europe
The EU economy is moving towards electrification across systems and sectors, from energy to industry, transport, heating and cooling or the built environment. Markets for electric vehicles (cars, vans, trucks and buses), as well as heat pumps (residential and industrial) and the renewables that will power them are growing at an unprecedented pace. Clean tech is becoming the bedrock of Europe’s economy.
As a cross-industry alliance of associations, we call for a High Representative for Smart Electrification and Grid Modernisation in the European Commission.
Read the joint letter from ACEA, AVERE, EHPA, SolarPower Europe, smarten, EUBAC & ChargeUp Europe here.
Revision of PSDII: Enable easy EV charging!
In light of the the Commission’s proposal on the revision of PSD II, ChargeUp Europe recommends to:
Exempt EV charging sessions from the SCA requirement, aligning it with payments for public parking & public transport.
Ensure coherence between payment requirement in AFIR and the revised PSD.
Expand the definition of payment services according to Annex 1 of PSD II, to include the new forms of payments that have become widely available across the EU in the last years.
To read the full paper, find it here.
European Commission clarifies the application of Measurement Instruments Directive (MID) to EV charging stations
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 (AFID) 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.
In order to ensure a harmonized application of MID across the EU and prevent the introduction of non-harmonized requirements for active electrical meters across the Member States, ChargeUp Europe sent a letter to the European Commission, in support of the work done by DG GROW’s Working Group Measuring Instruments (E01349). The letter sought a confirmation that active electrical energy meters are within the scope of MID, regardless of whether AC or DC is used. The European Commission has replied confirming that ‘the Directive neither excludes DC meters nor restricts the scope to AC meters’.
Read the full letter sent by ChargeUp Europe here and the European Commission’s reply here.
Cyber Resilience Act: Ensure the cybersecurity of EV charging!
ChargeUp Europe welcomes the proposal and the intention behind the Cyber Resilience Act (CRA). We share the objective of making our products more resilient and secure, not only physically but also digitally level.
The Commission's proposal could further discuss some points that would be critical to ensuring the correct and effective implementation also in the EV charging sector. As the CRA’s ultimate purpose is to ensure a high level of cybersecurity of all products entering the EU market, it is necessary to consider a broader of scope of actors working on this topic.
In light of the ongoing discussions on the Cyber Resilience Act (CRA), ChargeUp Europe recommends to:
Enable manufacturers to indicate the expected product lifetime and ensure a differential treatment B2B and B2C products.
Make more and better use of standards from compliance purposes, especially critical products.
Ensure coherence with other digital legislation for the reporting obligations.
Download the full paper here.
EV Charging Infrastructure: An agenda for the next European Commission
The European Union has set out the be the first climate-neutral continent by mid-century, with an ambitious decarbonisation pathway by 2030. The transport sector, the second sector responsible for GHG
emissions in the EU, is on course to transform rapidly to contribute to these objectives.
ChargeUp Europe calls for shifting the EU policy focus from EV charging infrastructure targets to enabling conditions, by:
Leveraging the growth-inducing power of the single market, by introducing a type- approval for EV chargers and implementing a regulatory simplification effort (“refit 2.0” for the twin green and digital transitions).
Building an EU grid fit for the electrification agenda, supporting investments in grids and fully leveraging the benefits of smart charging to accelerate the integration of the energy, transport and digital sectors.
Integrating widely accepted open, EU-industry led standards and protocols OCPP and OCPI into EU legal frameworks, emulating the US.
Alleviating pressure on staff shortages by implementing an ambitious standardisation and regulatory simplification agenda to maximise efficiency gains along the value chain.
Supporting system integration (in particular energy, digital and transport) with a reformed institutional set-up, building on the successful US example of the US Joint Office of Transportation and Energy.
Read the full paper here.
Public Key Infrastructure Market Principles
This paper outlines the key market rules that should be implemented to deliver an open, interoperable and competitive public key infrastructure (PKI) for EV charging. Ultimately, this will play an important part in ensuring that in Europe, any EV-Driver can charge in any EV, on any (publicly accessible) charging station using any service provider. It follows up on previous ChargeUp Europe papers on public key infrastructure and also the relationship between PKI and ISO15118.
Read the full paper here.
Life is a Highway: Driving the Electrification of Heavy Duty Vehicles
At a glance
Availability of space to build charging sites (including fast permitting and planning procedures), access to sufficient power supply in a timely manner, the actual charging demand from a growing number of electric trucks and software standards are the critical enablers that can make or break electrification of HDVs.
Tags: HDV, Public Charging, Girds.
Read the paper here.
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.
Renewable Energy Directive Trilogues: EU legislators must ensure market conditions to best enable electrification of transport to meet climate targets
The Renewable Energy Directive trilogues present a unique opportunity to design market conditions to accelerate the uptake of emobility and EV charging in Europe. Electric vehicles already account for over 10% of new passenger cars and market share is growing.
The directive should recognise the superior energy conversion efficiency of renewable electricity vs fuels and properly value it.
Fuel-neutral credit trading should include private EV charging, (workplaces, depots, and private homes), as well, as this accounts for 70% of passenger EVs and 99% of electrified public transport.
This also incentivizes market players to install charging infrastructure and bring electricity into the system, and gives member states more tools to reach their targets with.
Read our joint statement with Eurelectric, AVERE and Transport & Environment here.
Invest Now & Save Later: Advancing building energy efficiency and e-mobility via EPBD
Making sure people can charge at home and at work is why the EPBD is so important to facilitate the transition towards e-mobility. Further, more, smart EV charging can contribute to building energy efficiency by making the building an active, productive participant in the energy system, consuming energy when it’s best to do so, supporting the integration of renewable energy, and even providing clean energy to the building.
Our top asks in one glance:
Ensure pre-cabling requirements to accelerate EV uptake.
A strong right to plug as a standard that guarantees the accessibility of EV charging.
Private charging stations should be digitally connected and smart charging capable.
Read the full paper here.
The Green Deal Industrial Plan: How a thriving, EV manufacturing sector can support the EU's green & digital economy
ChargeUp Europe calls for:
Centering the e-mobility value chain in the Green Deal Industrial Plan: charging stations, software, and other EV enabling tech,should be explicitly recognised as “clean tech”;
Including EV charging infrastructures amongst the sectors that will be benefit from simplified and accelerated permitting processes, integrating the guidance from the Sustainable Transport Forum;
Avoiding distortion of the single market by complementing action on public subsidies with an EU-wide instrument; as EV charging is a rational, market-driven sector, funding should target the "enablers" of the transition e.g. grid capacity & smartness, training and re-skilling;
Bringing a sharper focus on building a single market and the benefits derived from leaner, simpler regulatory frameworks. The Net Zero Act should identify clean tech products that would benefit from the introduction of type approval, such as EV chargers.
Read the full paper 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.