From targets to consumer-friendly deployment of publicly accessible charging points for EVs
Our recommendations for a targeted revision on the Alternative Fuel Infrastructures Regulation (AFIR)
ENERGY & INFRASTRUCTURES
A strong infrastructure is Europe’s backbone toward electrified transport. The deployment of both public and private charging infrastructure has made significant progress in recent years, yet the road ahead remains paved with uncertainty.
Charging infrastructure operators are concerned by the doubts raised on the future of the electric shift, which puts their business model at risk and jeopardizes the investments required to sustain the continuous ramp up of Electric Vehicles (EVs). Car makers are concerned as consumers keep citing charging as a key pain point preventing them from going electric. Consumers, on their side, can be tempted to delay EV adoption in front of growing attempts at putting into question the transition itself.
To secure the consolidation of a robust European EV ecosystem and create a healthy market dynamic, EU policymakers must ensure that the conditions are met, adopting a holistic approach to infrastructure deployment, in order to address the needs and business models of all stakeholders, ensuring that public policy choices do not place the financial burden of the transition on any individual sector alone; and to consider AFIR in the broader perspective of the overall charging ecosystem and customers’ charging experience, ensuring consistency and comprehensiveness between AFIR and Energy Performance of Buildings Directive, and electricity grids framework.
First, this requires a facts-based and holistic approach, to objectively review the assumptions on which the current regulatory framework for rolling out the charging infrastructure is built.
Second, adequate measures need to be framed accordingly. Those include: (a) reinforcing investor confidence without jeopardizing the long-term clarity on CO2 emission reduction trajectory to 2035; (b) supporting EV demand and massification to put more EVs on Europe’s roads quicker; (c) incentivise proactive public authorities action to support and create a viable business case for EV charging infrastructure providers; (d) kick-starting the market where demand is still emerging with public investment to bridge the gap allowing the charging market to work as a demand-based market; (e) taking actions to increase consumers’ confidence and familiarity with charging the EV technology and charging at large.
Finaly, beside AFIR review, wide measures will be needed under various EU and national frameworks to further develop charging networks notably in urban areas, in private parking of multi-dwelling buildings, and in less commercially viable locations.
Within this broader framework, the forthcoming review of the AFIR should be seen as an opportunity for more targeted improvements.
It can notably remove some barriers and improve consumer- and grid-friendliness of infrastructures on Europe’s roads, with a specific attention to charging infrastructure for trucks. AFIR can also be instrumental in enhancing the customer experience by supporting reliability, seamless interoperability, and greater choice to reflect the diverse mobility needs of European citizens. AFIR can foster quality and availability of charging points by enabling a competitive and well-functioning market.
Ahead of the review of AFIR in 2026, the members of the Platform for Electromobility put forward 10 targeted recommendations to support a swift, consumer-friendly, and demand-driven deployment of charging infrastructure in Europe.
Objective 1 | From Targets to Deployment
Recommendation 1/Maintain, Expand, and Simplify Funding
Alternative Fuels Infrastructure Fund (AFIF) has been vital for early-stage infrastructure, especially in rural or low-utilisation areas. Funding will likely run out after the June 2025 cut-off, risking a gap in 2026–2027 during a critical growth phase.
We recommend to:
- Keep urban nodes as a central component of Connected Europe Facility (CEF) to ensure finalisation of TEN-T charging infrastructure in cities.
- Include grid connection costs, including smart charging feature and (where suitable) V2G, in eligible funding.
- Simplify access by aligning timelines to match permitting and grid connection processes, allowing flexible site selection and financing models, and reducing administrative burdens.
Recommendation 2/Maintain a Market-Based Approach for Targets
The current kW/BEV approach remains a reliable and market-driven framework for ensuring functional infrastructure deployment. AFIR’s combination of capacity-based and distance-based targets balances market responsiveness with strategic coverage: Capacity-based targets align charging deployment with actual EV adoption, supporting efficient investment and coordinated planning of power grids reinforcements; while distance-based targets ensure network coverage along major corridors providing driver confidence needed to switch to EV and travel confidently throughout Europe.
We recommend to:
- for Light-Duty Vehicles (LDV) charging infrastructure targets, retain the capacity-based approach while
- Monitoring that market-based targets enable the continuation of deployment on both public and private side, including most difficult segment to address such as multi-family homes.
- Monitoring utilization uptake and uptick considering public support when necessary to accompany the EV uptake.
- Regarding the distance-based targets, establish mechanisms to enable the deployment of high-power charging infrastructure in areas where market conditions alone may not ensure sufficient coverage. This will ensure adequate coverage across all the TEN-T network.
- Regarding the distance-based targets for HDVs, support the deployment of high-power charging infrastructure for heavy-duty vehicles along the TEN-T comprehensive network by creating enabling conditions, such as financial incentives, investment support, and mechanisms to de-risk investments.
Recommendation 3/ Concession tendering & permitting for faster and simpler charging deployment
In many Member States, the main barrier to deploying charging points is the lengthy administrative process due to the high number and processing length of required permits. Given the European Commission’s competencies, AFIR should urge Member States to simplify and significantly shorten installation timelines, including those for the necessary electrical infrastructure.
We recommend to:
- Improve coordination with local authorities and with power grids developments to ensure chargers are placed where they provide the greatest value for the final user and the greatest synergy with grid hosting capacity.
- Streamline tendering and permitting processes for both charging stations and related grid infrastructure to speed up deployment.
- Improve tendering rules to avoid risk of monopoly/oligopoly.
- Refer to the STF guidelines for tendering.
Recommendation 4/ A grid-supportive ecosystem
(DSOs for medium voltage and TSOs for high voltage) must be fostered, in terms of location, size, type of electricity connection, services provided, etc. Smart charging features and, where feasible, V2G should be incentivised, as necessary enablers of providing both flexible load and active grid services. Planning coordination and smart charging can increase the grid hosting capacity, avoiding bottlenecks in connection processes and grid congestion which could impair a fully-fledged service to EV drivers.
For the charging sector to play its part in delivering flexibility, charging infrastructure operators must be able to dynamically optimize charging sessions, making the requirement in Article 2 of AFIR for public recharging points to be ‘digitally connected’ a key provision, in terms of services to both EV drivers (real-time information on different charging options ahead) and to grid operators (quasi-real-time information on grid conditions). For charging infrastructure operators, this is an additional leverage for optimising their energy costs and therefore the dynamic tariffs applied to EV drivers, to the benefit of the overall energy-transport integrated ecosystem.
Recommendation 5/ Interoperability to avoid stranded assets
Avoiding stranded charging infrastructure is an important goal. We support consideration of all factors to ensure interoperability between digital systems and physical infrastructure to avoid situations where, if a CPO exits the market, charge points are left unusable. We encourage to utilise common standards also for smart charging in order to enhance the value of charging points for both the transport network and the electricity network.
We recommend to:
- Formalise a standard to ensure interoperability and protect investments. Any such requirements should be phased in and not apply retroactively.
Objective 2 | A truly European ecosystem
Recommendation 6/ Ensure Member States deliver through the AFIR National Policy Framework
Member States are currently preparing their National Policy Frameworks for the development of the market as regards alternative fuels in the transport sector, including all modes, and the deployment of the relevant infrastructure, according to AFIR art. 14. By 31 December 2025, each Member State shall draft its final national policy framework in an easily readable and understandable form and notify it to the Commission. Consequently, the Commission shall assess the draft national policy frameworks and may issue recommendations to Member States.
We recommend:
- the Commission to monitor closely Member States’ elaboration of their Policy Framework to ensure that the obligations and objectives of AFIR art. 14 are respected and fulfilled.
Recommendation 7/ From fragmented National Access Points to coordinated European access
National Access Points (NAPs), first established and mandated in the ITS Directive, were introduced under AFIR as a key mechanism to ensure transparent, accessible, and harmonised EV charging data across Member States. However, their implementation has so far been fragmented, with differing requirements across countries creating usability concerns, compliance costs, and inefficiencies for industry and users. NAPs already exist and should be leveraged during the transition phase to better reflect and support industry needs through a bottom-up approach.
We therefore recommend reinforcing and harmonising NAPs while enhancing coordination at European level by:
- Requiring, as a minimum, that Member States implement fully AFIR requirements and do not create obligations for other/additional data points than those specified in AFIR.
- A clarification by the Commission on the applicability of the penalties considered under the Data Act will be welcomed.
- To avoid redundant reporting and reduce administrative burden for operators, integration between existing national platforms and National Access Points (NAPs) should be allowed and duplications should be avoided.
- Supporting closer coordination between Member States to eliminate compliance costs due to fragmentation.
- Encouraging the European Alternative Fuels Observatory (EAFO) to act as a central reference point, serving as a metadata catalogue that links users with the relevant national data sources.
- Promoting interoperability of existing systems across borders and better integration into EU digital and energy strategies (e.g. the Data Act, smart grid integration).
- Ensuring cooperation with other EU-level initiatives like NAPCORE to gradually build the foundations for a de facto European access layer interlinking all NAPs.
- In the longer term, the system should evolve toward a single European Access Point not merely a gateway to national platforms, but a true one-stop-shop and unified connection point for all CPOs.
Recommendation 8/ Creating truly single market for charging stations equipment
The revised AFIR and corresponding EU legislations[1] should address the persistent national barriers that continue to hinder the sale and installation of charging stations across Member States. These regulatory discrepancies fragment the internal market, slow down infrastructure deployment, and ultimately increase costs for end users. In practice, it can sometimes be easier to sell and install a station designed for the Belgian market in the United-Kingdom than in Germany or France.
- To overcome this, the revision should introduce an equivalence principle ensuring that a charging station compliant with the regulations in one EU country can be sold and installed in any other Member State without additional national requirements, in line with the EU’s mutual recognition framework.
Objective 3 | A consumer-friendly ecosystem
Recommendation 9/ Balanced rules for transparent, consumer-friendly EV charging prices
AFIR Article 5 has introduced price transparency provisions by setting clear rules for pricing display and structures, particularly for ad-hoc charging. However, as EV adoption grows, price transparency is becoming an increasingly sensitive topic.
Addressing transparency issues remains a priority for the EV charging industry. However, it is worth noting that some driver frustration stems from the diversity of business models (e.g., the growing role of EMSPs) in a still nascent industry, a reality that differs fundamentally from the traditional ‘refuelling’. In terms of price transparency, the main concern is inconsistent enforcement at the national level. The challenge lays in the inconsistent and non-harmonised enforcement of existing rules at national level. National regulators should respect AFIR’s legal value as the superseding legislation and refrain from diverging interpretation, rather prioritising harmonized implementation of existing rules rather than introducing additional regulatory burdens.
We support the principle in Article 5(3) allowing differentiated pricing when it is “proportionate and objectively justified.” However, the absence of interpretive guidance has created legal and commercial uncertainty. To improve consistency across Member States, the Commission should continue to provide guidance to clarify how this principle should be applied in the 2026 revision. Ensure necessary clarification to preserve commercial flexibility for CPOs and MSPs, avoid undermining MSP business models, ensure competitive pricing strategies remain viable, and ensure no unjustified price disparities. Non-binding examples or criteria would reduce market risk, foster stronger cooperation between charging providers and EMSPs, and support more cost-effective, user-friendly charging for consumers.
Recommendation 10/ Ad-hoc Payment & Access to ensure simple and reliable EV payments
Transparent and user-friendly payment systems are central to driver trust and convenience.
We recommend to:
- Keep the existing requirement for ad hoc payments at publicly accessible charging points unchanged to maintain legal certainty for operators who have been implementing solutions for AFIR compliance. As required by AFIR before 2027, CPOs are actively responding to AFIR by retrofitting all existing fast-charging points (≥ 50 kW) on the TEN-T network, as well as safe parking areas, with payment terminals or contactless devices.
- For chargers < 50 kW, and in charging point where physical POS retrofits are not mandated, retain flexibility to accept payment using internet connection such as those through QR Code, balancing cost efficiency with user experience.
- CPOs active exclusively in the e-HDV charging segment should be exempted from the ad-hoc payment requirement. All e-HDV charging is conducted by commercial fleets under pre-established contracts, not individual drivers. Unlike the passenger car market, there is no risk of stranded “walk-in” users in the e-HDV sector. Trucks operate under professional contracts, and operators expect and rely on negotiated service agreements.
Recommendation 11/ Roaming & Contract-Based Access
Seamless access to charging is essential for building driver confidence and supporting EV adoption.
This will be crucial also to manage grid capacity constraints and leverage the full potential of EVs as ‘batteries on wheels’. These business models can help optimize grid use, reduce costs for the consumer, and ensure that charging infrastructure is accessible to a wide range of use cases including fleets, service providers, and individual drivers.
We recommend to:
- Ensure subscription-based charging is made possible by mandating the implementation of the protocols which enable inter-network communication.
- Promote Open data protocols for real-time kWh/kW data sharing with Mobility Service Providers in the B2C market.
“In many Member States, the main barrier to deploying charging points is the lengthy administrative process due to the high number and processing length of required permits. Given the European Commission’s competencies, AFIR should urge Member States to simplify and significantly shorten installation timelines, including those for the necessary electrical infrastructure.”
— Sara Linares Calero
IBERDROLA
Circularity and E-Mobility: Supporting a win-win relationship with the CEA
SUPPLY & INDUSTRY
We welcome the announcement of the Circular Economy Act (CEA), a key tool to develop a European Single Recycling market and scale effective recycling across the EU. Transport industries, especially the forward-looking sectors of electric mobility, must be considered as a central part of the CEA and the broader policy discussions surrounding Europe’s transition to a circular economy. Compared to fossil-fueled transport, electromobility practices and industries have the potential to significantly boost resource efficiency, reduce waste, and foster sustainable practices across the continent.
Notably, the CEA represents a timely opportunity to build a truly circular market for electric vehicles (EV) and their batteries in Europe.
With the right regulatory framework, Europe can unlock the full recycling and reuse potential of EVs and batteries, turning them into strategic assets for industrial competitiveness, innovation, and strategic autonomy. Ensuring that end-of-life vehicles and batteries are processed and recycled within Europe will foster high-value circular value chains, create future-oriented jobs, and support the EU’s environmental leadership.
This paper first revisits the essentials of a truly circular economy; then outlines the inherent circular nature of electric mobility; and finally proposes concrete recommendations to enable a circular electric transport system and industry via the CEA
THREE STEPS TO ENABLE A RECYCLING SYSTEM FOR ELECTRIC TRANSPORT.
Scale up Europe’s recycling capacity: The CEA should prioritise the rapid development of industrial-scale pre-processing and high-quality recycling facilities in Europe, particularly for EV batteries, to close the gap between expected waste volumes and current limited capacity.
Increasing the use of recycled materials, with recycled and local content targets: Prioritise incentive-based measures to boost the use of recycled and locally sourced battery materials, going hand in hand with gradually binding local content targets, while allowing exemptions for materials where the recycling market is already functioning well.
Create a true single Recycling Market: Harmonise and simplify intra-EU waste shipment rules, while fostering conditions that favour the processing of strategic waste streams within Europe, to ensure that valuable materials are recovered and reinvested into European clean tech industries.
I. Applying circular thinking to transport and mobility sectors
Firstly, we remind policymakers that a circular economy is one that produces only what is needed, reduces resource consumption, maximises product use through repair, reuse, and refurbishment, and ensures effective recovery notably during the pre-processing stage, which prepares the fractions to be recycled in high-quality recycling processes. This will ensure the successful reintegration of materials into the economy.
This attitude must be embedded in transport industries and mobility practices if Europe is to reach its climate and sustainability goals. To this end, entire systems must be designed with circularity in mind, aiming at building products – such as vehicles and their components – for long lifetimes, and making them repairable, upgradeable, and recyclable, without overburdening manufacturers.
Implementing circular practices like reuse, remanufacturing, and recycling also results in reduced energy consumption and raw material usage in comparison to manufacturing new products, ultimately decreasing the carbon footprint of a product.
Essential parts should be replaceable, and end-of-life processing should be considered from the design stage. The European Union must put in place the enabling conditions and incentives allowing its industry to achieve this objective competitively.
In this context, we welcome the new Circular Economy Act. The CEA will be key to scaling effective recycling across the EU and building up local recycling companies, and must complement and enable implementation of the already adopted Ecodesign for Sustainable Products Regulation (ESPR), which remains a key tool. In parallel, there are opportunities to make up for missed opportunities in the End-of-Life Vehicles Regulation (ELVR), for example by introducing recycled content targets for aluminium and steel from 2030 onwards.
RECYCLING EV BATTERIES: OPPORTUNITIES TO SOURCE MATERIALS LOCALLY AND SUSTAINABLY
Whilst also ensuring Europe’s strategic autonomy in clean tech manufacturing. According to T&E analysis, end-of-Life batteries and scrap from battery gigafactories in Europe have potential to provide 14% of all lithium, 16% of nickel, 17% of manganese, and a quarter of cobalt demand by 2030 already.
These materials will be enough to build between 1.3 and 2.4 million EVs locally in 2030, up to 10 mln in 2035, and up to 15 mln EVs by 2040. Nevertheless, the EU is currently not ready to capitalise on this opportunity. The existing recycling capacity across Europe is 10 times below where it needs to be in 2030, with almost half of Europe’s battery recycling plans at risk. Therefore, Europe will need to significantly scale up its recycling capabilities, and the CEA provides a key lever to create the regulatory space to help scale Europe’s recycling industry.
II. Electromobility is an asset for circularity
Before presenting recommendations for the CEA, it is important to highlight the high circularity potential of electric mobility.
a. Superior energy efficiency of electromobility
Unlike internal combustion engine (ICE) vehicles, which burn fossil fuels and lose energy through heat, battery electric vehicles (BEVs) do not involve irreversible consumption of fossil energy but can rather rely on 100% clean energy. The energy they use can be generated locally from renewable and zero-emission sources. BEVs are also inherently more energy efficient than ICE vehicles[1]. Promoting electric mobility is therefore in itself a resource-saving policy[2].
Beyond individual mobility, trains are by far the most energy-efficient for long distances. Europe is already a global leader in rail transport, and a concerted push to increase modal shift from road to rail could unlock substantial efficiency gains.
b. Second life of EV batteries
EV batteries, after around 15 years of use, retain sufficient capacity for less demanding applications. Their repurposing in stationary storage systems (for example in fast-charging hubs, residential buildings, or industrial facilities) represents a major opportunity to support renewable energy integration. However, while the concept of second-life batteries holds long-term potential, its large-scale deployment remains challenging in the short term, as current priority is – rightfully – given to the recycling and recoverability of critical materials. In the longer run, second-life batteries could become a valuable asset for energy storage, grid management, and flexibility services, complementing renewable energy deployment.
To unlock this potential at scale, batteries should be designed for easy removal, disassembly, repair and repurposing, while reliable data on their state of health must be fully accessible to authorised operators, with implementation best left to industry under existing regulatory frameworks. OEMs and battery manufacturers should ensure that these processes run smoothly, and costs are kept to a minimum, in line with existing regulatory obligations rather than through new legislative measures.
In addition, we call for the swift implementation of the Battery Regulation, especially regarding implementation of the battery passport and availability of standards regarding data on the state of health (SoH) of batteries, key for facilitating reuse and repurposing.
c. High recyclability and material recovery potential
EVs and their batteries are already subject to EU battery regulation requirements on recycling efficiency and recovery targets. Advanced recycling technologies now allow recovery rates of around 90–95% for key battery metals such as cobalt, nickel, and copper[3].
For these reasons, a successful and impactful CEA should support and actively enable the development of electric mobility, by scaling Europe’s recycling capabilities. Doing so will also reinforce Europe’s strategic autonomy in clean transport and green technologies.
III. A circular economy that boosts electric mobility
A well-designed CEA is an act that leverages the potential of electric mobility modes and industries for boosting a competitive and circular European economy. This would be notably possible through the following recommendations:
Boosting circularity in the supply chain
The CEA should boost investment in end-of-life vehicle and battery recycling facilities, support repair and repurposing businesses, and promote cooperation along the value chain, within the limits of EU competition rules. Upskilling support and financial incentives (e.g. tax credits or bonuses) should be offered to companies engaged in repair, refurbishment, and remanufacturing of EV components. While the CRMA has selected strategic projects in recycling, more can be done to ensure recyclers can scale efficiently, faced with significant competition. The EU Innovation Fund, InvestEU, the European Investment Bank (EIB), the future European Competitiveness Fund and national state aid should provide similar Capex and Opex support to recycling and circularity projects as cleantech, focusing on commercialisation and technology gaps (e.g. hydrometallurgical recovery of lithium, graphite and other elements). Ensuring the ramp up of competitive black mass refinement capacities at scale in Europe is especially key. The CEA should also explicitly support second-life applications through clear regulatory pathways and economic incentives.
Furthermore, the development, economic viability, and global competitiveness of European end-of-life and recycling industrial stakeholders relies on the development of a vigorous electromobility industry in Europe, sustained demand for EVs and particularly midstream battery components, and a stable, supporting legislative framework.
Increasing the use of recycled materials
We support the objective of increasing the use of locally recycled materials in batteries. This ambition must be pursued in coherence with the current state of the European recycling value chain, the availability of secondary raw materials, and the need to scale capacity. While we support the introduction of local content requirements, these should be approached with caution, ensuring that targets are aligned with actual supply and processing capabilities. Establishing a solid and competitive European recycling and refining value chain must be prioritised, going hand in hand with incentivising the use of local recycled content supporting the development of the value-chain in the EU.
The CEA could therefore explore mechanisms such as incentive-based approaches to encourage the use of secondary material recycled in Europe. This, in turn, has the potential to incentivise the development of recycling and refining capacity within Europe, rather than increasing reliance on external sourcing..
Where the ELV has so far failed to introduce recycled content targets for steel and aluminium in new cars, the CEA should see these targets being introduced as the Commission is due to finalise its feasibility studies on the aforementioned targets by Q4 2026. This should not, however, be the case for all materials, as for some the market is already very mature.
In conclusion, we call for prioritising or incentive schemes, ensuring they are implemented in line with the development of a resilient European recycling and refining ecosystem.
Harmonising and facilitating intra-EU waste shipment
Classifying battery black mass as hazardous waste has been a welcome step, banning its export to non-OECD countries. However, further steps are needed as one of the main challenges for recyclers remains access to waste. The CEA should ban or significantly limit waste material shipments of black mass, and other materials, outside of the EU. Progress so far has been a one-off; we need a systematic EU waste code structure to avoid exports of aluminium, steel, etc. as well as their final end-of-life products.
Additional measures should be taken to facilitate intra-EU shipments of black mass with harmonised criteria, allowing smooth transportation between pre-processing facilities and material recovery plants. Importantly, this waste criteria harmonisation should not encourage the export of black mass outside the EU. Finally, the forthcoming Green Listing Initiative should explicitly include waste batteries among its priority materials, ensuring that the recycling of strategic resources remains within the EU value chain.
At present, the complex and fragmented rules under the Waste Shipment Regulation act as a barrier to the circular economy. A harmonised set of rules for the transport of end-of-life batteries and related waste across Member States is urgently needed. Companies co-operating across the EU should be able to collaborate more easily: for example, when one company is handling collection, another refining, and another repurposing, they are facing administrative hurdles. Consideration should be given to treating such cross-border collaborations as a single entity for regulatory purposes. While the introduction of pre-consented statuses and fast-track notification for intra-EU waste shipments is a good start, more needs to be done to overcome national fragmentation. To this end, ensuring the automatic recognition of such pre-consented statuses among all EU Member States is key, as is the efficient use of ‘tacit consent’ to enable capable facilities to quickly receive and send battery waste.
The current classification and nomenclature for various waste streams is overly complex and inconsistent across Member States. It comes on top of the current restrictions and administrative burden, including lots of paperwork, associated with their shipment between EU member states under the Waste Shipment Directive. A revision of these provisions would improve coordination, simplify compliance, and encourage more businesses to engage in recycling and repurposing operations. Waste transportation rules should be modernised to reflect the collaborative, cross-border nature of the emerging circular battery economy creating a true European single recycling market.
Creating standardised recycled products
Different industries need varying quality standards for use of recycled products, e.g. lower grades of scrap steel are required in the construction industry often compared to the higher purity grades needed in many automotive applications. No differentiation of recycling grades based on quality standards, or “nomenclature” (e.g. in terms of contamination thresholds, etc) exist currently as it is assumed that all grades should be free of significant contamination. In practice, contamination levels vary, including copper contamination, which creates uncertainty as to the quality of the scrap. Creating such a nomenclature with clear thresholds on copper content for instance could allow recyclers to specialise and create better partnerships with the downstream industry, e.g. carmakers, to design recycled products based on specifications while achieving the necessary scale.
Therefore, the CEA should put in place quality standards for secondary materials to ease scaling and investment. Simpler recycling quality standards, as well as a more harmonised end of waste criteria, is needed to drive scale and cost-effectiveness for a few materials, such as steel and aluminium. By creating 2-3 categories (largely based on the levels of copper contamination), with the most pure being for automotive, recyclers can specialise and create standardised products, simplifying the process.
A FOCUS ON COPPER
On recycled content target, copper’s intrinsic value drives market demand for secondary copper, and there is no need for additional regulatory measures to increase demand.
For copper, purity standards are not needed, as high-quality recycling facilities, such as smelters and refiners, can recycle copper scrap to a purity of 99.9935% (copper grade A cathode), regardless of the purity of the scrap they receive, ensuring material quality equivalent to that of primary production.
"To support Europe’s strategic autonomy and climate goals, we must keep strategic raw materials like copper in the loop. The Circular Economy Act is an opportunity to remove barriers to high-quality recycling, simplify material flows, and fully align circularity with the EU’s green transition."
— Rikarnto Bountis, Senior Policy Manager
International Copper Association Europe
Conclusion:
A win-win relationship between circularity and e-mobility
Just as renewable energy development and electrification go hand in hand, electric mobility and circular economy objectives are mutually reinforcing. The high recyclability and reusability of EV components can support the growth of circular value chains in Europe, while circular policies can strengthen Europe’s industrial leadership in clean transport.
However, we are faced with a key moment to ensure the scaling of effective recycling across the EU, building up local recycling companies and getting volumes and actual recycling production going, in the face of significant competition.
A strong Circular Economy Act must therefore focus on creating a single European recycling market, whilst acknowledging and supporting the electrification of transport as both a driver and a beneficiary of circularity.
[1] Negri, M., & Bieker, G. (2025). Life-cycle greenhouse gas emissions from passenger cars in the European Union: A 2025 update and key factors to consider (ICCT Report). International Council on Clean Transportation. [2] Platform for Electromobility. (2024, November 27). Prioritising energy efficiency in EU’s transport ecosystem. [3] Agoro, H. (2025, March). Comparative Study of EV and Internal Combustion Engine (ICE) Vehicles. University of Ibadan
Boosting Europe's competitiveness with an ambitious MFF for clean transport
Ad-hoc group
The transition to electric mobility is one of Europe’s most strategic industrial and societal projects. It delivers on climate neutrality, strengthens energy independence, and secures competitiveness in a rapidly changing global market. As the European Commission presents its proposal for the next Multiannual Financial Framework (MFF), the Platform for Electromobility calls for a budget that is fully aligned with Europe’s long-term policy objectives and capable of unlocking the massive investments required for deployment.
1. Guaranteeing stability and predictability
The upcoming MFF must send a strong signal of regulatory and investment stability. Investors and industry require clarity, not only on the rules of the game but also on the tools available to deliver on them. A stable framework with appropriate tools and budgets adapted to the new geopolitical realities and priorities will maintain Europe’s attractiveness as a destination for clean tech investment in the face of global competition.
Any deviation from the agreed implementation path would generate uncertainty, reduce the credibility of the EU’s climate framework, and jeopardise our ability to meet emissions reduction targets.
2. From strategy to delivery: aligning policies and funding
The EU has already put in place a clear regulatory framework for the decarbonisation of transport, with milestones such as the CO₂ standards for vehicles, the TEN-T Regulation, AFIR and the Batteries Regulation. To make sure instruments are deployed timely to successfully reach the 2035 CO2 reduction ambitions, the new MFF must now match this ambition with financial instruments that accelerate the deployment of clean infrastructure and technologies across the value chain. Strategic policy without corresponding financial planning risks creating uncertainty and slowing down investment. Therefore, the transition to electric mobility should be a priority area under the main headings of the MFF.
3. Unlocking investment needs through smart financial tools
Europe’s e-mobility ecosystem requires unprecedented levels of investment in sustainable infrastructure, railway electrification, clean transport assets technologies, charging infrastructure, battery production, and research & innovation. Key programmes such as Horizon Europe, the European Competitiveness Fund (including the InvestEU fund), and the Connecting Europe Facility should provide targeted support in these areas and key enabling and interoperable digital technologies across all transport modes. In this regard, we welcome the focus of the proposed CEF on railway infrastructure and call for additional dedicated, easily accessible instruments to prolong AFIF, ensuring continuity and predictability for investors. Beyond grant funding, the next MFF should place emphasis on instruments that crowd in private capital (e.g. loans, guarantees, risk-sharing mechanisms, etc).
4. A partnership approach through national and regional plans
National and regional partnership plans (NRPPs) must become genuine drivers of deployment. They should prioritise projects that deliver the highest value for decarbonisation, energy security, and industrial competitiveness. Coordination with local authorities will be crucial to ensure that funding is channelled towards projects with real impact while ensuring synergies with investments under CEF and ECF.
5. Funding conditionality as a driver of implementation
Access to EU funds should be firmly linked to the correct and timely implementation of existing EU legislation. Conditionality will help ensure a level playing field across Member States, reward frontrunners, and avoid undermining Europe’s collective progress toward climate and industrial goals. Co-legislators should align the respective indicators within the performance framework and other horizontal rules for the Union programmes and activities the respective indicators with the sector’s concerns These indicators will determine the effectiveness of the National and Regional Partnerships. The indicators must be aligned with legal requirements, should be future-proof (with a 2035 horizon), and use definitions that are commonly used in the sector.
6. Defining clean tech industries
To ensure that EU funding instruments effectively strengthen Europe’s strategic autonomy, the next MFF should establish a clear definition and criteria for what constitutes clean technology industries. This will provide clarity, avoid dispersing resources, and prevent clean technologies from being placed in direct competition with unrelated sectors within instruments such as the Competitiveness Fund. Establishing such a framework will ensure that financial support is directed towards industries that demonstrably contribute to Europe’s energy independence, decarbonisation, and long-term competitiveness.
Conclusion:Level of ambition must be maintained or strengthened during the negotiations
The next MFF represents a unique opportunity to transform Europe’s climate and industrial ambitions into reality. By aligning financial planning with strategic objectives, ensuring dedicated and predictable support for deployment, and maintaining conditionality and regulatory stability, the EU can secure its trajectory towards 2050 and its leadership in the global race for e-mobility, all modes considered. The Platform for Electromobility stands ready to work with institutions and Member States to make this vision a reality.
"Europe has already set ambitious climate and mobility targets. The next EU budget must provide the tools to deliver them. With stable, predictable and well-targeted financial instruments, Europe can turn its strategic vision for clean mobility into a global competitive advantage."
— Xavier Sol, Director Sustainable Finance, T&E
ETS 2: Staying the course for an effective and fair transition to e-mobility
Vehicles & Markets
The Platform for Electromobility, representing a broad coalition of industries committed to the decarbonisation of transport, reiterates its firm support for the timely implementation of the ETS 2 (Emissions Trading System for road transport and buildings) as scheduled in the previous mandate, in line with the vote of the European Parliament on April 18, 2023.
1. Uphold ETS 2 to unlock investments
Rolling back or delaying the ETS 2 would undermine investor confidence and reduce the available financial tools to accelerate the uptake of electric vehicles, the development of alternative and collective mobility modes, and related infrastructures. The new system is not only a pillar of the Fit for 55 package, it is also a key driver for directing public and private capital towards the clean transition ecosystem and industries.
Any deviation from the agreed implementation path would generate uncertainty, reduce the credibility of the EU’s climate framework, and jeopardise our ability to meet emissions reduction targets.
2. Timely transposition: a key step for fair and effective implementation
As of today, only 10 Member States have transposed the ETS 2 directive into national law. Accelerating transposition is essential to ensure a coherent and effective rollout of the system across the EU. It will provide legal certainty, enable better coordination among stakeholders, and help deliver the expected climate and social benefits in a timely manner. Encouraging swift action from all Member States will also strengthen the credibility and impact of ETS 2 as a key pillar of the EU’s climate policy.
Moreover, citizens and businesses need a clear price signal. A stable and well-communicated carbon price will encourage behavioural change, spur investment in energy efficiency and zero-emission solutions, and support long-term planning across the value chain.
3. Ensuring ETS 2 is effective and socially fair
To guarantee that ETS 2 delivers both environmental and social outcomes, we recommend the following measures:
- Reinvest 100% of ETS 2 revenues into decarbonisation and targeted social support. We call to ensure transparency and additionality of Member State spending, so EU funds do not replace existing national support schemes.
- Strengthen complementary policy tools: ETS 2 must work alongside a robust regulatory framework. This includes preserving the CO₂ reduction ambitions for cars and heavy-duty vehicles, supporting the Clean Corporate Vehicles initiative, and ensuring the rollout of charging and multimodal infrastructure.
- Frontload ETS 2 revenues. We must accelerate investment to protect vulnerable groups from the impact of rising carbon prices and to deliver visible benefits early in the transition.
- Reinforce the Social Climate Plans (SCPs): push Member States to increase the co-financing rate above 25% to ensure meaningful national action.
- End fossil fuel subsidies: Use ETS 2 as an opportunity to rebalance taxation in favour of electrification, including reducing the tax burden on electricity and removing outdated exemptions for fossil fuels.
- Early auctions should be launched in 2026. Early auctions would help market participants form their view on expected prices. It would be a market friendly move to enhance transparency and ensure a smoother transition into full system operation.
Conclusion
"ETS 2 is not only about cars – it is also key to decarbonising heavy-duty transport. By sending a predictable price signal, the system will support investment in zero-emission trucks, strengthen the CO₂ standards for heavy-duty vehicles, and accelerate the rollout of charging and refuelling infrastructure needed for long-haul freight."
— Koen Noyens, Head of Public Affairs, MILENCE
ETS 2 is a cornerstone of Europe’s decarbonisation strategy. It must be implemented as planned to send a clear signal to markets, enable effective carbon pricing, and channel investments into clean mobility. Our coalition of industries stands ready to support this effort and ensure that ETS 2 is both socially just and economically effective.
Words of Members - Video series
Video series
In our video series "Words of Members", Platform members provide their perspectives on the coalition and vision for the electric mobility ecosystem
Platform members include EU-based industries and environmental NGOs across the whole value chain of electric mobility, across all land transport modes.
1/ Ivo Cré (POLIS) on the role of local authorities in the electric mobility transition.
Polis is an association of cities and regions working on urban mobility innovation. We’ve been with the platform from the start, also one of the founding members. We are, as a network, involved in the full cycle of electromobility innovation on the research side through our involvement in the 2zero platform, but also in the deployment side.
Cities and regions are essential stakeholders in the electromobility deployment. We buy a lot of vehicles. We set regulations for vehicles in our cities. We also are parking managers and parking means charging.
The Platform offers a unique environment to discuss policies on electromobility to make sure that electromobility does not lose its momentum in European policy. We are also convinced that the Platform is the right ecosystem to really keep electromobility in focus as a transformational technology.
We believe electromobility is a transformational technology because we don’t want a one-on-one replacement of one car by an electric car. We are interested to see the whole mobility system change. We look at shared mobility, at new forms of logistics in cities, at new forms of car use and car ownership.
Electromobility can be an essential part of that system overhaul and system change.
We will fight with the Platform to keep the 2035 deadline in European legislation. And a lot will have to happen to make that policy objective a reality. And we think that we as cities and regions, as procurers, as regulators,as asset owners also, we can really make a contribution to that mission.
2/ Nicolas Erb (Alstom) on Regulatory Stability Matters for European railway industry
Alstom is the European leader for railway equipment, trains from tramways to high speed, signalling, infrastructure and we deliver projects all around the globe thanks to our 85,000 colleagues.
Rail is the best in class in terms of environmental performance of all collective transport modes. And there is no way Europe will achieve its decarbonization targets without increasing the modal share of railway, be it for freight transport or passenger transport.
We call for regulatory stability because in our sector, projects have a very long life cycle. They take years to be prepared and several years to execute.
So any change in the regulatory framework that impacts ongoing projects creates a risk of additional cost, additional delays, which are ultimately detrimental for everyone.
This is why we have to make sure that our regulatory framework changes less frequently, and especially, and this is most important, that new regulatory requirements apply to new projects only.
Statement on the CO2 Standards ahead of the Strategic Dialogue with automotive industry
Statement
European clean transport industries urge EU to
stay the course on 2035 zero-emission car target
The members of the Platform for Electromobility reaffirm their strong support for the 2035 zero-emission targets for cars and vans, as adopted in 2023, ahead of the Strategic Dialogue with the automotive industry of the 12 September 2025 which might cover this legislation. We call for their persistent, robust and timely implementation for both Europe’s competitiveness in global competition and Europeans’ access to clean transport solutions.
Electrification is a global race. Europe cannot afford to fall behind. A clear and consistent regulatory path is vital to maintaining the competitiveness of Europe’s automotive industry and whole electromobility value chain, ensuring its ability to export high-value, future-proof technologies in a rapidly evolving global market.
A stable and effective regulatory framework is essential.
Europe’s clean tech industrial development needs long-term legal certainty. The current CO₂ Standards for cars and vans are not only instrumental in driving down emissions in line with climate targets, they also represent a cornerstone of the EU’s industrial policy. Stability in legislation is key to attract investment in the scale-up of clean technologies, the creation and expansion of manufacturing capacity, and the reskilling and upskilling of Europe’s workforce. Let’s not send a counterproductive signal to markets and investors at a critical time for Europe’s competitiveness.
Building a zero-emission transport system will require smart and diversified use of multiple transport modes. An unstable regulatory framework hampers long-term investment in multimodal solutions and infrastructure. Clear and ambitious targets provide certainty for investors and industry, helping the automotive and e-mobility value chain to plan ahead, scale production, and remain globally competitive while the transition to clean transport is accelerating worldwide.
BEVs are the driver of efficient and competitive decarbonisation.
Electric vehicles are the most energy-efficient individual transport mode. Energy efficiency in transport should be a central pillar of the EU’s energy transition, as it strengthens energy security, cuts costs for businesses and citizens, and reduces pressure on renewable energy deployment compared to alternative fuels solutions.
We strongly urge European lawmakers to reject the introduction of alternative fuels for cars and vans due to their inefficiency, high costs, and negative impact on industrial competitiveness, consumer protection, and air quality.
Let’s stay focused on the enablers of electrification.
Today, European policy should focus on the key drivers of electrification, rather than weakening existing legislation. These include: an ambitious Clean Corporate Fleet Regulation to be proposed later this year, which can further stimulate demand and set clear signals to the market; the implementation of AFIR as a key enablers for EV uptake for European consumers the mobilisation of EU funds to finance demand-side support mechanisms in Member States; coordination between automotive and energy sectors; and a broader policy framework to ensure affordable and clean energy for industries and consumers alike. On the production side, fostering innovation through smart regulation streamlining and setting the conditions to produce in Europe efficient and affordable EVs (such as by incentivising battery cells/modules made in Europe by rewarding each kWh produced) is key to powering the continent’s EV shift.
We trust that the Strategic Dialogue will serve to reinforce confidence in the EU’s regulatory direction and to support the full deployment of zero-emission mobility across the Union. The Dialogue is an opportunity to solve the genuine challenges our members face on the road to the 2035 target and to explore how to best seize the opportunities it offers.
“The Platform for Electromobility’s call is clear: stop disrupting investments by creating uncertainty and focus on the enabling conditions for industrial leadership along the e-mobility ecosystem to allow European clean tech industries to prosper – such as batteries. A stable regulatory framework is essential, as are concrete effective actions to support Europe’s electromobility value chain."
— Kinga Timaru-Kast, Chair of the Platform for Electromobility