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 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.
ChargeUp Europe input into the revision of EU rules on the security of network and information systems
ChargeUp Europe welcomes the European Commission’s initiative to review the EU rules on the security of network and information systems.
The security of network and information systems represents one of the key foundational values of ChargeUp Europe and the revision of the NIS Directive comes at a critical time in Europe’s transformation into a smart and sustainable economy.
The uptake of EVs is developing at a very fast pace. EV drivers need to be guaranteed access to reliable and secure charging infrastructure and it is imperative that their user data is secured. Ensuring more consumer-friendly experience for EV drivers, to boost e-mobility uptake, must go hand in hand with ensuring higher privacy and security standards.
There are numerous steps in the EV charging process which involve communication between networked elements and thus the EV charging value chain should be clearly and coherently covered by the scope of the NIS Directive across Member States.
The priority must be on ensuring that EV drivers feel safe and secure wherever they travel in Europe.
In this respect, EV charging infrastructure should be considered as critical infrastructure and the relevant operators should fall under the category of “operator of essential services” as laid down in Article 5(2) and illustrated in Annex II of the Directive.
In our view, the European Commission’s Impact Assessment should look at:
1.How to ensure a coherent definition of critical infrastructure in Member States. In this sense the European Commission could make recommendations on a list of what is considered as critical infrastructure.
2.How to guarantee multiple certificate issuers and multiple standards, ensure an open market, and combat potential pitfalls of monopolistic behaviors. Market operators should be able to freely choose between different encryption certificates.
3.How to ensure compliance costs will not hurt consumers, both in terms of ease of use and in terms of implementation costs. In the specific case of EV charging infrastructure, drivers will need to be guaranteed a smooth experience with new systems, without waiting for updates or system waiting times when charging their vehicles, and without paying considerable extra costs.
4..The potential benefits of a system of regulatory oversight at EU level to deal with repercussions for value chain players who do not comply with the standards.
See our input here
ChargeUp Europe input into the Roadmap for the Sustainable and Smart Mobility Strategy
ChargeUp Europe is delighted to provide input into the European Commission’s Roadmap for the Sustainable and Smart Mobility Strategy.
The Strategy will play a key role in contributing to the EU’s Green Deal and economic recovery plan.
It must have e-mobility at its heart in order to put the EU’s mobility sector firmly on the path towards climate-neutrality and economic growth and help the EU to deliver on the aims of the Green Deal.
See our detailed input here.
Charge Up Europe input to Renovation Wave Initiative
ChargeUp Europe is delighted to respond to the European Commission’s consultation on a Renovation Wave initiative for both public and private buildings. This initiative can pave the way for upgrading and future proofing existing building stock in a way that enables the benefits of electric vehicles, smart energy systems, renewables and other sustainable technologies to be unlocked.
You can see our contribution here and below.
Renovation Wave
Buildings are central to satisfying the needs of electric vehicle (EV) drivers and play a key role in the shift towards e-mobility. Over 80% of EV charging takes place around buildings – either at home or at the workplace. This highlights the need to equip buildings with EV charging infrastructure which will help to make EVs the preferred choice for families and commuters.
EV charging points at buildings will boost visibility and encourage the switch to EVs.
As the European Commission points out, 80% of today’s buildings will still be in use by 2050 but only 1% (on average) of buildings currently undergo renovations each year. They play a significant role in GHG emissions but also have the potential to be at the forefront of providing flexibility to a clean energy system through the integration of distributed energy sources, storage, and intelligent energy management systems.
To achieve Europe’s 2050 climate goal, a large portion of existing building stock must be upgraded and made energy-efficient. By equipping existing, new, and renovated buildings with future-proof infrastructure, policy makers can help to meet the energy & mobility needs of tomorrow.
Recommendations
Through the Renovation Wave Initiative, a stronger EU commitment on charging requirements in the private and public building stock will provide an opportunity to boost energy system integration and to improve buildings’ energy efficiency.
The following recommendations should be considered through the Renovation Wave:
Revise EV infrastructure ambition in the EPBD: with the expected volumes of EVs entering the market in the coming years, residential and non-residential properties need a strong policy signal.
Increased cabling and ducting requirements need to come with increased ambition for the installation of charging points for the whole building stock which also provide parking spaces.
Introduce a ‘Right to Plug’: EU citizens sometimes find that (regulatory) procedures for requesting or installing charging infrastructure in buildings are lacking. With more than 40% of EU citizens living in apartment buildings, addressing the struggles of this market segment will be key. Establishing a principle of ‘Right to Plug’ for owners and tenants should ensure the facilitation of the installation of a charging station in their parking place in multifamily apartment buildings. It should ensure:
Speedy connection: The time from the initial connection request from an EV user/representative to the DSO for installation of the connection should take no longer than 8 – 12 weeks for AC and 4 - 6 months for DC.
Administrative peace-of-mind: Make it as easy as subscribing to an electricity provider.
Member States or regions should set-up an easily accessible web portal combining services of various building, parking, installer organisations with streamlined permit and installation procedures.
For citizens living in locations without a suitable location to install such infrastructure they should have the right to request the installation of EV charging infrastructure in their neighbourhood. The Renovation Wave should encourage local authorities to put in place policies that allow citizens to request charging infrastructure installation and provide transparent and accountable processes for decisions on whether or not to approve such requests.
Recognize the flexibility potential of EVs: EVs carry huge potential for flexibility services at electricity system, local and consumer level. A proper implementation of the Clean Energy Package will create the market access conditions for demand-side flexibility from EVs in the overall energy management set-up of buildings. From 2024, all new buildings and renovations should include an intelligent energy management system as a minimum requirement which will allow smart charging infrastructure to deliver energy system benefits.
Allocate sufficient EU funding: Electrical infrastructure in existing buildings or near new sites is frequently inadequate for charging infrastructure, requiring upgrading (e.g. from single to three-phase power systems or low- to medium voltage) and additional wiring. Households, SMEs and public sites will benefit from financial support to invest in future-proof charging infrastructure. The proposed Recovery and Resilience Facility under the Next Generation EU plan should dedicate funding to:
grid upgrades in urban areas for multi-user charging hubs at non-residential/commercial buildings
national or local EV charging infrastructure incentives schemes which are accessible for citizens, installers or businesses intending to install charging points (e.g. French ADVENIR scheme & OLEV grant in the UK).
linking EU funds to public procurement criteria with ambitious charging infrastructure requirements.
Position paper on the Revision of Directive 2014/94/EU on the Deployment of Alternative Fuels Infrastructure
Introduction
The revision of the Alternative Fuels Infrastructure Directive (AFID) comes at a critical time in Europe’s shift to a green and sustainable economy. To enable the development and deployment of clean, electric mobility, a wide revision of this legislation is needed. This is necessary to ensure that charging infrastructure can handle the scale of electric vehicles expected to come onto market in the coming years and help the EU achieve its goal of climate neutrality by 2050.
In this position paper, ChargeUp Europe’s outlines 12 key recommendations for the revision of AFID.
12 key recommendations
Replace the Directive with a Regulation to ensure an accelerated, harmonised rollout of EV charging infrastructure across the EU.
Focus the legislation only on zero emission fuels and prioritise only those options with the greatest potential to decarbonise the road transport sector.
Widen the scope to ensure an ambitious and coherent increase for public charging (fast and normal charging), privately owned charging which is accessible to the public and privately owned charging which is not accessible to the public.
Introduce ambitious binding weighted targets for charging infrastructure at Member State level to allow for smart and targeted minimum coverage across the EU.
Improve transparency & market governance to speed up grid connection and enable efficient market access for charging infrastructure companies.
Urge Member States to develop site-allocation strategies for fast charging stations along highways and main traffic corridors and ensure open and transparent tender procedures.
Prioritise interoperability and open networks to facilitate the adoption of open, non-discriminatory and uniform communication protocols (such as OCPP and OCPI) and related standards.
Ensure the necessary conditions for roaming so EV drivers can travel seamlessly across the EU.
Take a consumer-centric approach to make sure the EV driver has quality data on networks and charging locations, price transparency and choice regarding payment systems.
Introduce a “Right to Plug” so that all EU citizens can request the installation of charging points in or near their building of residence or workplace.
Increase focus on electric heavy-duty vehicles to allow HDVs to charge across the EU road network and in urban areas.
Ensure charging infrastructure is future proof and provide a clear definition of smart charging.
Input to the consultation on the EU Climate ambition for 2030
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 climate policy that also takes transportation into account. Below we outline key considerations for the EU’s climate 2030 ambition.
1. ETS and road transport
With regard to the potential extension of the Emission Trading Scheme (ETS) to the road transport sector, ChargeUp Europe would like to stress the following:
Such a proposal will require an adjustment of the CO2 price for the road transport sector to make the measure efficient. Many studies have demonstrated that the current CO2 price would not have a meaningful impact on the reduction of CO2 emissions from the road transport sector since the price gap between conventional technologies and (near) zero-emission technologies is much larger compared with other sectors. A sectoral approach should therefore be envisaged.
Setting up a dedicated CO2 price for some sectors such as road transport could alleviate this but would then lead to a situation where an overlap of measures would create a negative impact on the final consumer. The EU should avoid duplication of regulations as the automotive sector is already regulated through other CO2 reduction measures such as CO2 targets for new vehicles and ETS for manufacturing sites. It would be more effective to ensure these Regulations are implemented properly and the targets are achieved.
In order to assess the effectiveness of carbon pricing in non-ETS sectors (through an ETS extension or other carbon pricing tools), the upcoming European Commission impact assessment needs to look at the number of emissions sources, respective abatement costs, effect on the overall cap and the existing national policies and taxes.
It is also important to consider correction factors to reflect different low carbon fuels due to differences in efficiency between electric motors, fuel cells, and combustion engines.
Recommendation: We encourage the EU to align the existing CO2 emission standards with the Green Deal objectives and ensure proper and effective implementation to make sure targets are achieved rather than extending ETS to road transport.
2. 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 Germany.
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 will give companies that supply electricity to transport the opportunity to qualify for clean fuel credits which they can sell to fuel suppliers (e.g. oil companies or petrol stations). 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.
Recommendation: We encourage European and national authorities to further explore and implement credit mechanisms to leverage the potential of renewable power for road transport as part of the renewable fuels obligations in REDII.
Input to the renovation wave initiative for the building sector
ChargeUp Europe welcomes the European Commission’s initiative to launch a Renovation Wave across Europe for both public and private buildings.
You can see our contribution here and below.
Renovation Wave
Buildings are central to satisfying the needs of electric vehicle (EV) drivers and play a key role in the shift towards e-mobility. Over 80% of EV charging takes place around buildings – either at home or at the workplace. This highlights the need to equip buildings with EV charging infrastructure which will help to make EVs the preferred choice for families and commuters.
At the same time, buildings play a significant role in GHG emissions. To achieve Europe’s 2050 climate goal, a large portion of existing building stock must be upgraded and made energy-efficient. Currently, only a very small number are renovated each year. Buildings have the potential to be at the forefront of providing flexibility to a clean energy system through the integration of distributed energy sources, storage, and intelligent energy management systems. To achieve this, a systemic upgrade is necessary.
By equipping existing, new, and renovated buildings with adequate and future-proof infrastructure, policy makers can help to meet the energy & mobility needs of tomorrow, while increasing property value. EV charging points at buildings boost visibility and encourage the switch to EVs. The ongoing implementation of the Energy Performance of Buildings Directive (EPBD) is a step in the right direction for the uptake of charging infrastructure. However, it is set to have very limited implications due to its exemptions.
A stronger EU commitment on charging requirements in the private building stock and an increase in renovation rates is necessary.
The following recommendations should be considered:
Revise EV infrastructure ambition in the EPBD: with the expected volumes of EVs entering the market in the coming years, residential and non-residential properties need a strong policy signal. Increased cabling and ducting requirements need to come with increased ambition for the installation of charging points for the whole building stock which also provide parking spaces.
Introduce a ‘Right to Plug’: EU citizens sometimes find that (regulatory) procedures for requesting or installing charging infrastructure in buildings are lacking. Establishing a principle of ‘Right to Plug’ for owners and tenants should ensure the facilitation of the installation of a charging station in their parking place in multifamily apartment buildings.
Recognize the flexibility potential of EVs: EVs carry huge potential for flexibility services at electricity system, local and consumer level. A proper implementation of the Clean Energy Package will create the market access conditions for demand-side flexibility from EVs in the overall energy management set-up of buildings. From 2024, all new buildings and renovations should include an intelligent energy management system as a minimum requirement which will allow smart charging infrastructure to deliver energy system benefits.
Allocate sufficient EU funding: Electrical infrastructure in existing buildings or near new sites is frequently inadequate for charging infrastructure, requiring upgrading (e.g. from single to three-phase power systems or low- to medium voltage) and additional wiring. Households, SMEs and public sites will benefit from financial support to invest in future-proof charging infrastructure.
The proposed Recovery and Resilience Facility under the Next Generation EU plan should dedicate funding to:
grid upgrades in urban areas for multi-user charging hubs at non-residential/commercial buildings.
national or local EV charging infrastructure incentives schemes which are accessible for citizens, installers or businesses intending to install charging points (e.g. French ADVENIR scheme & OLEV grant in the UK).
linking EU funds to public procurement criteria with ambitious charging infrastructure requirements.
Input to the clean energy strategy for energy system integration
ChargeUp Europe welcomes the opportunity to input to the roadmap on the EU Clean energy strategy for energy system integration.
To optimize the potential from flexibility offered by EVs, it is vital to deliver a policy framework that embraces a system approach from the generation to transmission, distribution and consumption of electricity.
You can see our contribution here and below:
Clean energy strategy for energy system integration
Most of the time that a private car is parked, it is at home or at work. There is great potential for smart charging at that level provided that the charging station installed is smart, allows communication between the grid and car, the tariff is attractive for drivers to become a supplier of flexibility and the data about the battery state of charge is accessible. These aspects are addressed in different legislation:
Energy Performance of Buildings Directive (EPBD): ambitions to install EV chargers in private buildings (see ChargeUp Europe response to Renovation Wave Roadmap) and roll out of smart charging stations.
Electricity Market Design: enabling flexible electricity tariff at retail level and aggregate response from drivers.
Data access policy.
The current EPBD does not set the right level of ambition to deploy private charging infrastructure (which accounts for 80% of charging for private cars). The smart sector integration strategy should support a more ambitious target to deploy smart chargers in EU in new, renovated and existing buildings. The assessment of local grid capacity and communication with the station needs to be included.
The capacity to manage the load in response to a grid signal to increase the intake of power and avoid congestion is critical as well as the possibility to consider the battery of a car as a form of storage from which power could be re-injected in the distribution grid or the local system (Vehicle-to-everything-V2X).
V2X applications are already technologically feasible and, in some cases, already used. For the wider application of V2X, the issues of storage ownership and associated cost (grid fee to take electricity out and in from the grid) are crucial to make the use case attractive for the driver. In the context of smart energy use, allowing demand management aggregation is crucial, as well as the consumer’s opt-in/out right. The smart sector strategy should include V2X technologies among the storage technologies available.
The potential from load management is also significant at charging depot level, where fleet vehicles typically charge. Based on the schedule patterns of those vehicles, the impact on the local grid can be significantly reduced through load dispatching at the charging station level. Smart devices are needed to enable the communication between vehicles and grid.
The Smart sector integration strategy should coordinate the proper implementation of various legislation addressing consumer’s engagement in energy markets at retail level to leverage the potential for smart load management and/or V2X.
To enable the potential of demand management offered by e-mobility, the digital aspects of the energy system should be addressed. Charging an EV includes the handling of data on charging patterns and technical capabilities of the battery. To charge smartly, communication needs to be established with the car and the grid operator through standardized protocols and access to these data should be guaranteed. The legislation should support the deployment of smart charging stations and support in identifying the requirements of charging stations and the car to enable smart charging, while also guaranteeing safe management of the driver’s data.
The potential of e-mobility to decarbonize the energy system can only be realized if an integrated policy framework combining electricity market design, smart charging networks and adequate digital policies are developed to integrate e-mobility among the other sources of demand side management.
Electric vehicle charging infrastructure: a key pillar of the EU’s green recovery plan
This statement provides an overview of ChargeUp Europe’s views and recommendations for the EU’s post COVID-19 crisis recovery plan.
A clean electrified transport recovery
While the current health crisis is at the very top of the European political agenda, and will be for some time, the economic challenge many sectors will face will be profound. The EU’s response to the COVID-19 crisis must put the union firmly on the path to a truly sustainable, climate-neutral and just economy. The recovery plans that are being developed need to provide stimuli for Europe’s businesses to lead on clean energy, zero-emission mobility and digitalization in order to deliver on the European Green Deal and the EU’s digital strategy.
Electric mobility will play a key role in decarbonising the transport sector, bringing clear environmental benefits by reducing emissions and greatly improving air quality, contributing to the EU’s climate and environment goals and improving the lives and health of all citizens.
It should thus become a key pillar of the EU’s recovery action plan. The EV market is expanding rapidly, and even by conservative estimates, 30% of all registered vehicles in the EU will be EVs by 2030. A combination of well-designed market stimuli programs will trigger and accelerate the much-needed investment leading to faster uptake of EVs and related charging infrastructure. This will maximize the potential of the transport sector in reducing CO2 and other particles emissions in line with the European Green Deal objectives.
In order to achieve this, ChargeUp Europe has the following 10 concrete suggestions for Europe’s recovery plan:
Stimulate the market demand for electric vehicles
Maintain the targets for vehicle CO2 standards and explore the possibility for car manufacturers to receive more super-credits for selling EVs according to the EU 2020/21 Car CO2 regulations.
Establish an EU-wide scrappage scheme to support the sales of zero-emission vehicles by financing the switch from older and combustion engine vehicles to zero-emission vehicles.
Support cities and regions in Europe to invest in electrifying their municipal fleets. With the rapidly improving total cost of ownership (TCO) of electric municipal fleets, an acceleration of the requirements of the implementation of Clean Vehicles Directive should be considered.
Support Member States in extending existing incentive measures for electric vehicle purchase and ownership e.g. registration tax, annual circulation tax and other non-fiscal stimuli. Allowing Member States to temporarily waive VAT on low and zero emission vehicles as recognized in the Revised Clean Vehicles Directive (EU 2019/1161) should also be considered.
Ensure the right investment criteria are in place to accelerate the roll-out of EV charging infrastructure across all domains
Increase the ambition for cabling for both residential and office buildings in order to address EV driver charging needs. A ‘Right to Plug’ should be promoted which will accelerate the relatively slow uptake of EV charging infrastructure in multi-residential buildings.
Earmark EU funds to support Member States and regional authorities in setting up or expanding incentive programs for stimulating private investment by citizens and commercial entities in the roll-out of charging infrastructure.
Investigate the extent to which EV public charging infrastructure is also critical energy infrastructure and steer public funds to prioritize grid preparations and upgrades, in particular for low- to medium-voltage grid upgrades in urban areas, for multi-use (car/bus/van/truck) fast-charging hubs and depots.
Support regional authorities in addressing investment gaps to ensure coverage of remote areas of the TEN-T Comprehensive road network of the EU so that no EU region is left behind on EV-infrastructure.
Promote innovative bidirectional smart charging and energy storage technologies with the goal to integrate mass renewables into the energy system and improve grid efficiency and the overall climate impact.
Encourage Green debt instruments to be launched by the European Investment Bank to grant bonus loans or rate reductions when green performance indicators are met for EV infrastructure projects.
Input to the Inception Impact Assessment of Directive 2014/94/EU on the Deployment of Alternative Fuels Infrastructure
The European Commission is assessing the revision of the AFI Directive.
ChargeUp Europe considers this comes at a critical time in Europe’s shift to a green and sustainable economy.
In order to enable the development and deployment of clean, electric mobility, the impact assessment needs to focus on the policy options that ensure that charging infrastructure can handle the scale of electric vehicles expected to come onto market in the coming years and enable the EU to achieve its goal of climate neutrality by 2050.
You can see our contribution here and below:
Introduction
ChargeUp Europe is an alliance representing the electric vehicle (EV) charging infrastructure industry. It 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, it represents a combined network of over 150,000 charging points in Europe.
ChargeUp Europe welcomes the opportunity to provide input into the Inception Impact Assessment (IIA) of Directive 2014/94/EU on the Deployment of Alternative Fuels Infrastructure (AFID).
Input
The evaluation of AFID comes at a critical time in Europe’s shift to a green and sustainable economy. In order to enable the development and deployment of clean, electric mobility, the impact assessment needs to focus on the policy options that ensure that charging infrastructure can handle the scale of electric vehicles expected to come onto market in the coming years and enable the EU to achieve its goal of climate neutrality by 2050.
PRIORITY: LEGISLATIVE INSTRUMENT
Replace Directive with Regulation. Alternative fuels infrastructure policy should aim to deliver an accelerated rollout of harmonised infrastructure, enlarged in scope for all types of electric vehicle charging across the EU. This will ultimately support investments, and lead to the smooth uptake of e-mobility and a seamless driver experience across the EU, not to mention substantial benefits to the energy system. In order to achieve this, ChargeUp Europe recommends replacing the current Directive with a Regulation which can deliver a faster, more effective and harmonised approach across the EU.
PRIORITY: SCOPE
Focus only on zero emission fuels and examine use cases for different fuel types. If the EU is serious about achieving climate neutrality by 2050, the Directive needs to be revised to prioritise only those options with the greatest potential to decarbonise the road transport sector. The impact assessment should analyse the use-cases of different alternative fuels for different sectors. In this regard, electrification is already proven to be the most sustainable and efficient option for reducing CO2 and other particle emissions across the road transport sector and achieving the European Green Deal objectives.
Public and private charging. The scope of the legislation needs to be widened to harmonise technical requirements and ensure an ambitious and coherent increase for public charging, private charging accessible to the public, and private charging that is not accessible to the public. The impact assessment should assess the need to further define what “publicly accessible” means and the need to include private charging in the scope of the Directive, alongside corresponding distinctive (minimum) requirements for different use cases.
PRIORITY: CHARGING NETWORK COVERAGE AND TARGETS
Ambitious smart targets. The legislation needs to enable smart and targeted minimum coverage across the EU. Binding targets at Member State level should be set and these targets should be further weighted taking into account aspects such as: the specificities of the charging infrastructure (e.g. targets for public charging versus targets for charging on commercial properties which are publicly accessible); regional traffic and housing characteristics and; existing national needs (e.g. home charging may be more common in one Member State and public charging in another). The impact assessment needs to examine regulatory barriers in national housing laws that discourage EV adoption and explore how to build on existing best practices on EV charging and the ‘right to plug’ (installation of charging infrastructure).
Ambitious binding targets will ensure less fragmentation across Member States and lead to more consistent development of the EV market across the EU.
At their core, these targets will encourage private investment in EV charging infrastructure and ensure that public investment is primarily directed towards addressing possible coverage gaps (e.g. in less populated areas or areas where there are no market incentives to invest).
Heavy duty vehicles. The impact assessment should look at how to address the specific requirements of electric heavy-duty vehicles (HDVs, incl. vans and trucks) as their recharging requirements will differ from those of light passenger vehicles. Appropriate coverage for HDVs across the EU road network and in urban areas is key and synergies between the transport and energy sectors need to be promoted. The revision of TEN-T should be linked to TEN-E in order to smartly map out and plan charging infrastructure locations (e.g. rest areas with charging facilities for long haul, multiple uses for different types of charging stations). The current Directive has been successful in harmonising the plug standard for cars and a revision should aim to deliver the same uniform development for heavy duty vehicles.
PRIORITY: INTEROPERABILITY, COMMUNICATION PROTOCOLS AND CONSUMER INFORMATION
Open and interoperable. The development of e-mobility across the single market will depend on open interoperable technology and communication protocols. The impact assessment should look at how to address any existing fragmentation or proprietary network arrangements with regard to standards, communication protocols and product design. Adoption of open, non-discriminatory and uniform communication protocols (such as OCPP and OCPI) and related standards in EV charging infrastructure are fundamental pre-conditions for the acceleration of the installation of charging stations and to facilitate a seamless charging experience for the driver across charging networks and across Member States.
Consumer-centric. The legislation needs to have the consumer at its core. It should ensure that there is:
Quality data for all consumers irrespective of their networks and charging locations
Interoperability and choice with regard to authentication and payment systems and
Price transparency in the networks and via roaming to optimize driver experience.
PRIORITY: SMART CHARGING
Increased focus and clear definition. The legislation should recognise the importance of smart charging for a future renewables-based power system. The impact assessment should assess the need to provide a clear definition of smart charging (e.g.V2X) and set out what this means in terms of functionality to ensure that new charging infrastructure is future-proof and directed to smart, connected charging technology. It should evaluate the potential of the normal charging segment to deliver consumer, environmental and societal energy system benefits.
The future legislation should address the question of battery data access in order to deliver the benefits of smart charging listed above.
PRIORITY: MARKET ACCESS, TRANSPARENCY AND GOVERNANCE
Market access. The impact assessment should assess the current openness of the market and what barriers exist for charging infrastructure players entering the market. It should also examine and clarify the role for Distribution System Operators (DSOs) in the marketplace, which should be limited to addressing specific market gaps (e.g. similar to the procedures outlined in the Electricity Market Design Directive (EU) 2019/944).
Transparency and governance. The impact assessment should also examine transparency and governance issues. In order to ensure the speedy and efficient rollout of EV charging infrastructure and facilitate the growth of the EV market, DSO processes need to be adapted in order to speed up time to connection, permit procedures and provision of information to charging infrastructure businesses.
ChargeUp Europe looks forward to contributing in greater detail to the public consultation on this issue.