Our Positions
EV charging issues cross many policy areas - Consumer affairs, energy, IT & cyber, automotive, manufacturing, and many more.
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Plug & Charge, ISO 15118, Public Key Infrastructure (PKI), and the Need for Proper Governance
ChargeUp Europe outlines the key aspects of ISO 15118 and how the implementation and governance of this standard will be fundamental to ensure a level playing field for operators and provide choice for EV drivers. If implemented correctly, the services enabled by ISO 15118 can deliver a smoother charging process and bring major benefits to EV drivers and the grid. However, if not governed in a way that enables open and fair competition, EV drivers risk being locked-in to a single provider which then prevents customers from (easily) choosing for access to alternative MSP services and offers. ChargeUp Europe calls for a single legislative instrument which lays out clear market and governance rules which ensure open and fair competition for both Plug & Charge and Smart Charging aspects of the standard. It should address both the vehicle and charger requirements.
Read the paper here.
Joint letter: Demand-side flexibility is a strategic answer to the energy crisis
ChargeUp Europe, together with the European Association for Electromobility (AVERE), Confederation of European Paper Industries (CEPI), the European Association for the Promotion of Cogeneration (COGEN Europe), current, Environmental Coalition on Standards (ECOS), European Federation of Energy Traders (EFET), European Energy Retailers (EER), The European Heat Pump Association (EHPA), European Renewable Energies Federation (EREF), The European association of smart energy solution providers (ESMIG), smartEn, SolarPower Europe and T&D Europe issued a joint letter to Ursula von der Leyen, President of the European Commission; Frans Timmermans, Executive Vice-President for the European Green Deal and Kadri Simson, Energy Commissioner.
In this statement the signatories state that both short and long-term solutions to the current energy crisis is demand side flexibility and to to empower all consumers with decentralised energy resources and allow them to self-consume, adjust and trade their energy consumption, storage and on-site renewable and efficient generation, directly, or through local communities and aggregators.
Read the full statement here.
Statement on EP TRAN Committee adoption of AFIR report
On 3 October, the European Parliament’s TRAN Committee approved MEP Ismail Ertug’s report on the proposal for a Regulation for the Deployment of Alternative Fuels Infrastructure (AFIR), an important step on the journey to a harmonized framework for publicly accessible charging in Europe.
MEPs agreed on ambitious EV charging infrastructure targets, allowing the EU to achieve its decarbonization objectives but are asking for retrofitting of existing AC stations with payment card readers, which would undermine the market for publicly accessible AC charging and would be a significant step backwards.
Read the full statement here.
Statement on the critical role of smart electric transport in addressing the energy crisis
ChargeUp Europe publishes a statement on the critical role of smart electric transport in addressing the energy crisis together with Transport & Environment, AVERE, and SmartEn. The statement contextualises the role of EV charging in the wider context of the worst energy crisis Europe is facing since the 1970s. The statement also calls for a holistic approach that is collective and emphasises the need to explore multiple avenues for engagement.
Read the full statement here.
10-point action plan to make buildings ready for electric mobility
ChargeUp Europe publishes a 10-point action plan together with Transport & Environment, AVERE, and Europe On. The action plan provides a clear guidance for an effective road ahead for calling on the EU institutions to amend the Energy Performance of Building Directive (EPBD) so that EV charging at home or at the workplace becomes easy and accessible for all.
ChargeUp Europe statement on keeping the digital and green transition to e-mobility on track amid an energy crisis
ChargeUp Europe:
Recognises that the European Union is facing the unprecedented, short-term challenge of managing shortages, extreme price volatility and high prices in gas and electricity markets while also confronting the climate crisis and managing the transition to cleaner, more resilient and sustainable energy systems.
Calls for recognition that it is of critical importance that the long-term objective of decarbonization and the digital and green transition to e-mobility are not sacrificed as EU institutions and national governments seek to alleviate short-term pressure.
ChargeUp Europe's response to the Commission's public consultation on Access to Vehicle Data, Functions and Resources
ChargeUp Europe welcomes the European Commission’s public consultation on access to vehicle data, functions, and resources. ChargeUp Europe is convinced that ever-increasing amounts of data will have a significant impact on the transport ecosystem. Therefore, the upcoming initiative comes at a critical time in Europe’s transformation into a smart, digital and sustainable economy.
ChargeUp Europe calls for:
Equal access rights to data, functions and resources including guidelines and requirements on data quality as well as the frequency of communication/data sharing, based on mandatory fair, reasonable and non-discriminatory terms.
The list of vehicle data, functions and resources accessible on a specific model or version of a vehicle would need to be published or otherwise made available by the vehicle’s manufacturers.
Reporting obligations for manufacturers to be introduced, to inform competent authorities (e.g., type-approval authorities and the Commission) about the implementation of such access rights.
Legislation to recognize that access to data in itself is not sufficient, but a successful exchange of data in a seamless, coordinated and timely manner based on existing and open standards is required.
Read the full response here.
EV Charging & VAT - Position Paper of the ChargeUp Europe E-mobility VAT Group
ChargeUp Europe is the voice of the electric vehicle (EV) charging infrastructure industry, working towards an expeditious and effortless rollout of EV charging infrastructure in Europe. Given the challenges and uncertainties of the current EU Value Added Tax (VAT) system for EU cross-border EV charging, ChargeUp Europe set up a new E-mobility VAT Group (EVG) in 2022.
The EVG is a group of business and tax experts covering the whole supply chain of the E-mobility sector, with both ChargeUp Europe members and non-members involved. This group is aligned to actively support and promote the future EU growth of E-mobility and EV charging, in line with the objectives of the European Green Deal. It is a truly European group with participants established in several Member States doing business across Europe.
The aim of the EVG is:
to raise awareness on the topic of VAT and EV charging among key policy stakeholders on an EU and Member State level;
to share and explain the commercial and operational set up of EV charging;
to outline the needs and address the VAT challenges that currently hinder EU cross-border growth as well as the development of a European Single Market for EV charging and
to support providing appropriate solutions that foster future growth.
In this paper ChargeUp Europe’s EVG wants to address key issues related to the VAT treatment of EV charging across the EU - what the root causes are, where they derive from and how they can be resolved – in order to support promoting the sector’s EU cross-border future growth with huge benefits for both businesses and governments and aligned with and critical for Europe’s Green Deal Agenda.
Read the full position paper here.
Making the Case for Private Charging under the Energy Performance of Buildings Directive
Widespread and easy EV charging options will be critical to drive the uptake of electric mobility. The Commission’s Energy Performance of Buildings Directive (EPBD) proposal therefore comes at a critical time to accelerate Europe’s shift towards e-mobility. At the same time, EVs and charging infrastructure can play a critical role in making buildings more energy efficient, managing grid capacity through smart charging and contribute to the EU’s Green Deal objectives.
The Commission’s proposal rightly recognizes the key role of EV charging in decarbonizing the EU building stock and paves the way to ensure the uptake of e-mobility across the European continent.
The Commission’s proposal contains many positive, forward-looking provisions and ChargeUp Europe very much welcomes the inclusion of ambitious EV charging infrastructure targets, the emphasis on smart charging, and the proposed requirements on consumer empowerment to make the installation of EV charging infrastructure in private locations easier and more accessible.
While we welcome the EPBD proposal, there are some key aspects that require further attention to ensure that the complementary benefits from integrating buildings and transport are fully utilized. The following document outlines ChargeUp Europe’s views and recommendations on the EPBD proposal.
Boosting the use of renewable electricity in EU transport - Making the case for EV charging under the Renewable Energy Directive
The revised proposal of the Renewable Energy Directive (REDIII) includes a very welcome focus on the potential of EV charging to contribute to cleaner, more efficient energy systems, and is closely linked to the revision of the Alternative Fuels Infrastructure Regulation (AFIR). Both will play an important role in creating the right framework of EV charging across different uses and locations.
The proposal rightly recognizes the numerous benefits that EV charging offers for the electricity system in terms of flexibility, load balancing and storage opportunities. At the same time, the proposed credit mechanism scheme will play a key role in greening EU transport, as it will boost the use of renewable electricity in the transport sector. To deliver on these opportunities, it will be critical to properly account for the benefits brought by supplying renewable electricity to the transport system and to maximize the potential of e-mobility.
Read the full statement here.
Public tenders guidance note
In this guidance note, we outline the urgent need to address public authorities’ recent designs of public EV infrastructure tenders that put into jeopardy the much-needed private investment flowing into the public infrastructure segment of the EV charging market.
Setting maximum prices and creating excessive financing conditions are not what our sector needs. The EV charging infrastructure sector is a rationally driven business that is best steered through public tenders focused on quality-of-service provisions. Dictating economic terms on how EV charging infrastructure should be run will have a significant impact on the market and affect the speed of the rollout of public EV charging infrastructure in Europe.
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.