Stop diverging priorities, stop disrupting investments.
Supply & Industry
Recent political debate has raised the risk that the EU’s clear decision to phase out combustion engines in 2035 will once again be called into question. We believe this could prove fatal for the future of the European automotive industry.
In opposing this dangerous instability, the Platform for Electromobility is highlighting the importance of creating the enabling conditions to allow clean tech industries to prosper, notably in the transport sectors. Ultimately, this will help achieve the EU’s ambitious decarbonisation goals. As we advance towards zero-emission mobility, we are concerned by recent discussions surrounding the revision of the CO2 standards for cars and vans, which foresee introducing CO2-neutral fuels (such as e-fuels) into the post-2035 regulatory landscape.
This paper outlines the vital importance of supporting the ongoing progress towards the mass adoption of EVs and electromobility. It also highlights the risks of diverting the focus – and the vital investments required for electrification – towards the fictitious solution of e-fuels.
We therefore reiterate our full support for both the 2035 zero-emission targets for cars and vans and the inter-institutional agreement set out in a European Commission statement and confirmed by recital 11 of the CO2 Standards Regulation on the introduction of synthetic fuels beyond this date. If there were to be any role for alternative fuels, it should be minimal, and limited to vehicles running exclusively on 100% climate neutral RFNBOs.
1. Investment certainty for the electromobility ecosystem
Investment in the net-zero industrial ecosystem requires a clear, consistent and properly implemented regulatory framework. European transport industries are committed to, and are building, this ecosystem. EU auto manufacturers have committed around €250 billion to electrification by 2030, while 86 new electric vehicle models will be launched between 2024-26 (58 in segments A, B and C). The EV charging industry is already investing heavily in expanding both public and private charging infrastructure; and – with an average of €33 billion per year invested in our distribution grids over recent years – financing for utilities are continuing to grow to accompany the transition of the grid.
However, adding e-fuels to this regulatory framework will create investment uncertainty. This will ultimately deter stakeholders from fully committing to electric vehicle manufacturing and infrastructure roll-out. Given the combination of increasing competition from non EU countries, rising energy prices and a shortage of qualified EU workers, it is ever-more crucial to focus EU investments on electric vehicles to reach critical mass and help the EU remain globally competitive. A stable regulatory environment remains essential for maintaining Europe’s leadership in sustainable transport and ensuring that investments are directed towards proven, scalable technologies rather than nascent ones such as e-fuels.
2. Strategic prioritisation of proven, sustainable technologies
With limited resources, Europe must prioritise its investments in the technologies most capable of delivering effectively on sustainability and performance. Unlike e-fuels, EV technologies are already proven, energy-efficient and supported by an expanding infrastructure that continues to develop. Allocating resources to establish a separate, parallel infrastructure for e-fuels will only multiply the financial demands and divert away funds that could otherwise be used to enhance EV infrastructure and accelerate the adoption of electric transport.
Decarbonising transport will also necessitate the expansion of rail, public transport and active mobility modes; substantial investments will be essential for scaling up both services and infrastructure to meet these ambitions. The Letta report highlights that “the investment needs associated with realising the TEN-T core network by 2030 are estimated at around €500 billion, with a significant portion still lacking sufficient financial resources”. The Draghi report estimates that completing TEN-T is projected to increase GDP by €467 billion by 2050. For active mobility, Europe would require approximately €40 billion per year to double the number of cycle trips within 10 years.
Europe cannot afford to fragment its investment focus by pursuing less-efficient alternatives, particularly when electromobility is already delivering on its promises for cleaner transport and industrial competitiveness.
3. Enabling the transition to electromobility: skills and innovation
Europe’s transition to electromobility is generating demand for a skilled workforce capable of driving innovation and advancing Europe’s standing in the global clean tech market. Any delays to the transition to electromobility would in turn delay the urgently required shift of the workforce from the fossil fuel industries to the electromobility supply chain and the e-mobility infrastructure ecosystem. Given the current regulatory framework and CO2 standards, jobs in energy production and energy infrastructure in Europe are expected to increase by 128% and 543%, respectively. E-fuels also do not offer the same potential for creating the quality, high-value and future-proof jobs in emerging sectors.
By investing in electromobility, Europe can build a workforce that is properly equipped for the green transition. It will bring skilled employment to local communities and ensure that the transition to clean mobility is supported through jobs with long-term prospects and benefits for European workers. A 2021 BCG study showed almost 80,000 extra operational production workers will be needed in the manufacture of batteries and accumulators, while OEMs will require 30,000 new software and system developers to manufacture electric motor vehicles.
4. Strategic autonomy and energy security
Given the growing need for energy security, electromobility offers Europe the opportunity to establish robust local supply chains based on locally recycled materials and locally produced renewable energy, thus reducing the need for imported fossil fuels. This is important, given that the vast majority of any future e-fuels used in Europe would be imported. As the global market for EVs continues to grow, Europe must concentrate its efforts on bridging the gap to other global leaders.
5. The cost of energy and Europe’s industrial competitiveness
The rising cost of energy is a key factor in the recent difficulties facing Europe’s industries. Developing a transport mode as energy intensive as e-fuels (e-fuels require five times the energy of direct electrification; hydrogen three times) would only drive energy costs higher across Europe.
The production of synthetic fuels is already highly energy intensive; each kilowatt-hour used to produce synthetic fuels is precious energy that cannot provide for other, more efficient, means. Synthetic fuels generated to store electricity during production peaks will be far from sufficient to match Europe’s demand and should be directed to hard-to-abate sectors such as aviation, shipping and energy intensive industries, not road transport for which more energy efficient technologies exist.
With electricity demand continuing to escalate, using synthetic fuels for land transport risks further undermining Europe’s industrial competitiveness by inflating operating costs for manufacturers, reducing the appeal of Europe as a hub for industrial investment. Prioritising energy-efficient, directly electrified transport modes is therefore essential for maintaining energy affordability, supporting industry and ensuring Europe’s long-term economic resilience.
Conclusion
The Platform for Electromobility urges European lawmakers to prioritise investments in clean mobility, and to avoid policies that would instead divert the required critical resources towards inefficient and expensive alternatives. By focusing on electromobility, we can create a sustainable, competitive and resilient transport sector that serves Europe’s citizens, economy and environment.
We consequently reiterate our full support for both the 2035 zero-emission targets for cars and vans and for the inter-institutional agreement – expressed in a European Commission statement1 and confirmed by recital 11 of the CO2 Standards regulation2 – on introducing synthetic fuels past this date. If any future role were to be given to alternative fuels, it should be minimal and restricted to vehicles running exclusively on 100% climate neutral RFNBOs (renewable liquid and gaseous fuels of non-biological origin).
E-fuels: a costly Pandora’s box for European drivers
Vehicles & Markets
The Platform for Electromobility calls on Members of the European Parliament (MEPs) to consider carefully the impact of integrating e-fuels into Europe’s decarbonisation strategy, most notably into the post-2035 regulatory landscape. We advocate for policies that will prioritise energy efficiency, affordability and transparency for consumers; the proposal to expand e-fuel use risks undermining this. As the EU seeks to revise its CO2 standards for cars and vans, MEPs should evaluate how adopting e-fuels will affect Europe’s consumers in terms of increasing costs, creating regulatory ambiguity and ultimately impacting public health and air quality.
1. High costs of e-fuels for consumers
E-fuels are likely to be prohibitively expensive for everyday consumers, increasing the overall cost of mobility in Europe. By 2030, e-fuels are projected to cost consumers 4 times more per kilometre than battery electric vehicles (BEVs).1 While fossil fuel-industry advocates argue that large-scale production will reduce these costs, BEV technologies are also progressing, with prices expected to fall. The comparative cost burden on consumers – particularly low-income families and rural populations who need to cover the greatest distance – would hinder the EU’s ambition of affordable clean mobility accessible for all.
Without strong regulatory guardrails to support and incentivise the transition to electric mobility, drivers may face increased costs for synthetic fuels for internal combustion vehicles. Such a cost will disproportionately impact the most economically vulnerable consumers. These individuals rely on affordable mobility options; advancing high-cost technologies such as e-fuels threaten to exacerbate existing inequalities in accessing transportation. Producing a truly climate-neutral e-fuel will make the cost per kilometre driven significantly higher than any other modes of transports2.
[1]Clean solutions for all: T&E’s car decarbonisation roadmap - Transport & Environment [2] E-Fuels and Their Role in the Transport Sector - Transport & Environment
2. Regulatory instability: impacts on consumer decisions to shift to clean mobility
Inconsistent regulations and enabling conditions delays create uncertainty for consumers, leading to delayed decision-making in purchasing clean vehicles. This in turn is lowering the demand for the clean vehicles that European manufacturers urgently need to reach their decarbonisation targets. If e-fuels are introduced alongside BEVs, it may result in a complex and fragmented regulatory environment, one that is confusing for fleet managers. For example, approximately one-third of new cars in Europe are company vehicles, reflecting corporate fleet purchasing decisions. Companies seeking to decarbonise their fleets are encountering uncertainty over which technologies will ultimately be compliant with EU CO2 emissions standards. As a result, fleet buyers are delaying their decisions to switch to zero-emission vehicles, leading to a detrimental slowdown in clean vehicles market conditions.
Technology-neutral policies that increase regulatory ambiguity risk jeopardising Europe’s decarbonisation targets and lead to delays in adopting proven low-emission vehicles. In committing to a unified and energy-efficient path forward, the EU can provide consumers and companies alike with the certainty needed to make sustainable choices.
3. The Pandora’s box of fraud and ambiguity
Given that transport fuels derived from fossil or renewable energy are chemically identical, the process of monitoring and verifying the environmental benefits of e-fuels is loaded with logistical challenges.
In order to be fully transparent to consumers, fossil and e-fuels should not be blended, and their price should be clearly indicated at petrol stations. Otherwise, consumers committed to choosing clean energy sources for their vehicles may unwittingly purchase fuel that does not deliver the promised environmental benefits.
While control mechanisms are possible, introducing e-fuels alongside existent fossil-fuel pumps would require additional infrastructure investments. Such measures include dedicated e-fuel nozzles, adding additive to e-fuels to tell them apart from fossil fuels, while car makers would have to retrofit vehicles with new onboard sensors to ensure that the vehicle does not drive on fossil fuel. This burden would likely fall on consumers, who may face higher prices and additional maintenance costs. It would be better to invest these resources in more mature and energy-efficient technologies such as battery-electric vehicles. In contrast, BEVs offer transparency, with the energy source directly linked to an increasingly green electric grid, which is increasingly being decarbonised. Allowing e-fuels onto the market without robust consumer protection policies risks misleading consumers and potentially undermining public trust in the EU’s environmental objectives.
4. Impact on air quality and public health
E-fuels produce comparable levels of pollutants – such as nitrogen oxides (NOx) and particulate matter – as traditional fossil fuels. These impact air quality and public health, particularly in urban areas.[1] Europe’s cities already face air quality challenges; introducing e-fuels could further compromise efforts to reduce pollution in densely populated areas. By simply maintaining levels of harmful emissions, e-fuels undermine the EU’s objective of improving public health outcomes through cleaner transportation.
[1] E-Fuels: Current Status and Projections - PIK Potsdam Institute for Climate Impact Research
Policy recommendations for protecting consumers’ interest in the clean mobility transition
- Limit e-fuel use post-2035
Minimise the role of e-fuels in post-2035 vehicle sales, ensuring that only renewable-based e-fuels qualify. This measure will help direct investments to technologies with clear and measurable environmental benefits. We therefore reiterate our full support for both the 2035 zero-emission targets for cars and vans and the inter-institutional agreement set out in a European Commission statement[1] and confirmed by recital 11 of the CO2 Standards Regulation on the introduction of synthetic fuels beyond this date. If there were to be any role for alternative fuels, it should be minimal, and limited to vehicles running exclusively on 100% climate neutral RFNBOs.[2]
- Introduce consumer protections against high costs and misrepresentation
Develop consumer protection policies to mitigate against the high cost of e-fuels, provide transparency around their pricing and use and to prevent misleading claims on their benefits. For example, establishing clear labelling standards and specific nozzles for e-fuels could reduce confusion and help consumers avoid paying premiums for fuels that fail to meet expected environmental standards. In addition, supporting demand for energy-efficient transports (such as BEVs) will create more affordable mobility options.
- Prioritise energy efficiency in mobility investments
Encourage energy efficiency as a guiding principle for all public and private transport investments. By supporting the deployment of proven energy-efficient solutions such as BEVs, the EU can build a more affordable and accessible pathway to clean mobility.
[1] Commission Statement on CO₂ Standards for Light Commercial Vehicles - European Commission [2] Renewable liquid and gaseous fuels of non-biological origin
Conclusion
The Platform for Electromobility calls on MEPs to consider the risks posed by e-fuels. While potentially valuable in hard-to-abate sectors, e-fuels threaten to introduce higher costs, regulatory uncertainty and health risks in the transport sector. By maintaining its focus on energy efficiency and consumer protection, the EU can safeguard the interests of its citizens and ensure a smoother, more-affordable transition to clean mobility.
A strong European recycling ecosystem for electromobility
Fostering a recycling ecosystem in the European electric transportation value chain is crucial for enhancing the region’s strategic autonomy and for reaching its sustainability goals. Currently, Europe relies heavily on third-country producers for critical materials and components essential to the production of electromobility solutions and their infrastructures. By creating conditions for a strong recycling ecosystem within the e-mobility sectors, Europe can reduce this dependency, ensuring a more resilient and self-sufficient supply chain and reduce emissions associated with the use of primary materials. Providing conditions that enable a recycling value chain in the e-mobility ecosystem will not only help mitigate geopolitical risks but will also strengthen Europe’s position in the global market.
As we support the ambitious recycling targets set in the Critical Raw Material Act, it is now key to enable European industry to reach them. With the right legislative framework, significant progress can be made. Indeed, with numerous legislative ‘low-hanging fruits’ up for grabs, the EU can support its local recyclers. The industry is at a crucial juncture as recycling is poised to ramp up and develop rapidly; it is essential that we seize this moment to establish effective frameworks and practices, ensuring that we get a head-start in global competition.
In this paper, we outline the importance of enhancing the recycling industry in Europe and set out a manual for policy makers to use the existing toolkit of legislation to drive forward such a recycling industry. We recognise recycling is only one element of the broader circularity ecosystem that Europe needs to build for a sustainable transport value chain, however this paper focuses solely on recycling.
Box 1/ Benefits of an electromobility value chain supported by recycling practices
Recycing in the emobility value chain enhances Europe’s strategic autonomy by reducing dependency on imported raw (or secondary) materials, particularly for batteries. By fostering domestic recycling and the use of secondary materials, Europe is increasing security of its value chain. It can mitigate supply chain risks, reduce trade imbalances, and strengthen its control over essential resources, supporting resilience and reduce imports of materials.
Recycling of batteries and material recovery from end-of-life vehicles support material efficiency and thus environmental sustainability by minimizing waste and reducing the need for raw material extraction. This can lead to substantial ecological benefits, including lower carbon footprints and less environmental degradation.
Promoting recycling in the e-mobility value chain can also significantly increase the affordability of clean vehicles. By reducing reliance on primary materials through more effective recycling processes, production costs may be lowered in the longer run, making EVs more accessible to a broader range of consumers.
Recycling also fosters innovation, as businesses invest in new technologies and processes to recycle and repurpose materials, driving economic growth and creating new job opportunities within the green economy. Beyond resiliency, Europe can thus be a proactive leader with a prosperous recycling industry in Europe complying with environmental standards, Europe will be able to set its own, highest, international standards.
Our proposal to leveraging existing regulation to create conditions enabling a recycling ecosystem
Regulatory stability is the bottom-line condition for enabling investments to create circular value chains in the emobility ecosystem. Entrepreneurs and investors require a predictable and consistent regulatory environment to confidently commit resources to the development and expansion of circular practices in the electromobility industrial value chain. Safeguarding the clear, long-term policies already agreed by co-legislators will provide the necessary certainty for businesses to innovate and invest in sustainable production and recycling capacities in Europe. This is particularly true for the CO2 Standards for cars and vans’ 2035 zero-emission objective which needs to be maintained to guarantee that EU-based battery production is used in BEVs that will be sold to meet the zero-emission target by 2035.
A slowdown of the EV market as well as of the battery cells production in Europe creates high investment uncertainty for companies ready to invest into recycling on the continent. Feedstock uncertainty is furthermore increased when the shipment rules to destinations outside of the EU are not clear and not ambitiously implemented and controlled.
In the short term, we do not identify the need for new legislative acts but rather the need to effectively implement and enforce the toolkit of legislations already in the hands of European policy makers and to introduce clarifications or improvements where needed. The following suggestions thus focus on optimising and fully utilising existing legislations rather than creating new ones. Our aim is to ensure that the current regulatory framework effectively supports the development of a sustainable and competitive battery recycling industry within the EU. By making targeted improvements, clarifications or by ambitious implementation, we can leverage what is already in place to support European recyclers to reach our targets.
1. Battery Regulation
Secondary acts implementing the Battery Regulation’s provisions on recycling targets and recycled content should acknowledge the current limitations in local recycling capacity, which may necessitate sourcing secondary materials from outside the EU in the short-term. To change this for the mid and long term, it is crucial to focus on developing dedicated local recycling capacity and processing industry within the EU to ensure sustainability and reduce reliance on external sources. EU legislation should incentivise the uptake of needed recycling technology as regulatory frameworks are key drivers for innovation and large-scale solutions. The calculation of the recycling efficiency and material recovery targets as well as of the recycled content (EU Batteries Regulation) are being currently defined in the delegated and implementing acts which need to set the right condition for the development of a competitive and prosperous batteries recycling industry in Europe. Innovation to new recycling solutions needs to be strengthened, and sourcing of secondary materials within Europe facilitated.
An important element of the Secondary acts implementing the Battery Regulation are the ‘Equivalent conditions’. It is essential and we call on the Commission to deliver in 2025 the definition of the criteria for the assessment of the ‘equivalent conditions’ for waste treatment outside the EU as identified in the Batteries Regulation and Waste Shipments Regulation. How Member States assess the fulfilment of equivalent conditions when such documentation is handed to them by the competent authority of destination where the treatment took place also needs to be clarified. The problem with the ‘equivalent conditions’ when there are no clear criteria for assessment, is that it needs to be “demonstrated that the requirements applied in the country of destination ensure a similar level of protection of human health and the environment” (Waste Shipments Regulation Article 56), which leaves room for interpretation and may be implemented differently from MS to MS.
2. List of Waste Legislation
Currently, the List of Waste (LoW) does not adequately address the diverse chemistries of batteries, lacks a consistent definition of battery black mass across EU countries, and results in varied shipment conditions and costs. This not only creates administrative burdens but also distorts the market in the battery recycling sector and suboptimal material recovery. Addressing these gaps through specific measures can streamline processes and enhance the recycling landscape across Europe.
A rapid formal updating of the list of waste codes and its uniform enforcement, including harmonised transport conditions is needed to significantly facilitate intra-EU shipments, establish equivalent recycling conditions both inside and outside the EU. Member States have a great opportunity to support potential EU recycling players in developing activities to capture battery material recovery value in Europe and prevent these materials from being shipped elsewhere. Addressing issues such as the definition of black mass and harmonizing transport conditions are critical steps that could greatly contribute to this goal.
In this context, the Platform for Electromobility welcomes the Commission’s updated List off Waste proposal. Overall, the definition of the new waste codes is expected to improve clarity and will hopefully foster a homogenous use of the waste codes across Member States, which will contribute to clarify intra-EU shipment.
Introducing a definition for black mass is necessary to ensure that no waste material inadvertently becomes classified as a product. A harmonized definition will facilitate easier intra EU shipment of black mass, streamlining European recycling efforts and contributing to a more efficient European recycling industry. The recent Commission’s updated List off Waste proposal classifies black mass as hazardous waste. We welcome this classification which needs to be rigorously and swiftly implemented across Europe to ensure uniformity and compliance with the latest standards.
Classifying black mass as hazardous waste is a significant step towards securing the feedstock of secondary raw materials in Europe as it will help prevent the export of critical minerals outside the Union to non-OECD countries. This is a crucial step forward to a circular economy but these important amendments to the LoW can only be effective if they are thoroughly implemented. The key role here is with Member State market surveillance authorities that need to do effective border controls to ensure that waste shipments and documents fully comply with this new delegated decision. In addition, the EU’s anti-fraud service (OLAF) must be allocated sufficient resources to monitor, investigate, and prevent illegal exports to non-OECD countries.
3. Waste Shipment Regulation
To foster a competitive waste market, it is essential to ensure the successful implementation of the Waste Shipment Regulation (WSR). This includes the deployment of automated, digital authorisation requests from 2026 onward, which will simplify the handling of hazardous waste and significantly reduce the administrative burden on stakeholders involved in waste management and in inter-EU waste shipment.
4. End-of-Life Vehicle Regulation
The ELVR revision needs to effectively address the illegal export of used EVs and therefore prevent material leakage and further help build a recycling ecosystem. Additional measures are required to enable high-quality recycling of a larger array of materials, especially considering the increasing complexity of vehicles. Similarly to the Battery Regulation, the revision should be leveraged to incentivise the use of low-carbon materials and processes. While we support the introduction of targets for producers and public procurement provisions to increase the use of low-carbon materials such as steel and plastics to drive ever more sustainable EVs, those targets should be accompanied with incentives for producers. Beyond the proposed regulation, we would also welcome incentives for consumers to further drive the market to ever more sustainable EVs.
5. Net-Zero Industry Act
By prioritising local manufacturing, we support NZIA provisions that favour local bids and tying EU and national grants to conditions that promote local labour usage. It could be associated to a label encouraging the use of recycled materials of European origin, including for critical materials (in particular for copper recovered from EV recycled engines which is critically exposed to supply risks).
6. Critical Raw Materials Act
It will be key to prioritise the selection of strategic projects under the CRMA in line with the benchmarks set out in the Act, with at least a quarter of selected projects in the recycling sector.
Conclusion
The CRM Act proposed by the European Commission is a much-needed step in securing the supply of raw materials essential to the EU’s economic and strategic interests. The Act acknowledges the increasing demand for critical raw materials, as well as their limited availability, and aims to establish a comprehensive framework for ensuring their sustainable and responsible sourcing.
However, there are some concerns and reservations that need to be addressed to ensure that the Act is fully effective. First, it must balance the need to secure critical raw materials against environmental and social sustainability, as well taking account of ethical considerations. In addition, it is essential to ensure that the implementation of the Act does not lead to trade barriers or lead to unfair competition that could ultimately harm the EU’s industrial competitiveness.
Careful consideration and monitoring are needed to ensure that the implementation of the CRM Act is effective, sustainable and equitable. By addressing these concerns and reservations, the EU can pave the way for a more resilient and sustainable supply chain for critical raw materials, while upholding its values and commitments.
Box 2/ Investment and Market incentives to support local recycling
Looking forward, new policy initiatives and market incentives to support local manufacturing will be instrumental in developing a resilient and sustainable e-mobility value chain. This can be achieved by:
By translating market incentives into consumer incentives, we can accelerate recycling practices and choices and thus drive the market. This can be done through tax breaks and rebates (e.g., offering tax incentives for best-in-class sustainable batteries in EVs), and Green procurements that prioritise best-in-class sustainable battery products or companies that are frontrunners in implementing the Batteries Regulation provisions.
A joint terminology and standards are at the core of scalability and transparency for market actors. In the case of steel, the quality of recycled steel is different for automotive (very high) compared to construction (low). Defining economy-wide quality standards – or a recycling taxonomy – for steel, aluminium and other products will greatly aid both recyclers and end users by creating a clear market.
Beyond legislation, facilitating investment in local battery manufacturing, recycling and material processing businesses is critical element of the puzzle for establishing a circular economy. Today, such technologies and expertise are not yet mature in Europe. Focus on scale and commercialisation are thus critical, with targeted industrial support and consistent prioritisation across all policy fields. This can be achieved by introducing an EU Green Industrial Fund. The Fund could build on the resources of already existing and scalable EU financing instruments: the EU Innovation Fund and the InvestEU Fund.
Accelerating the deployment of the EU Innovation Fund dedicated battery facility is essential and it should be designed to support best-in-class projects in battery production with a spillover effect on the upstream part of the value chain, helping to foster recycling in the EU. Increasing support from the European Investment Bank for exemplary projects that lead the way in sustainable battery manufacturing and recycling is also important.
Prioritising energy efficiency in EU's transport ecosystem
Energy & Infrastructures
The Platform for Electromobility highlights the critical importance of maximising energy efficiency in achieving the EU’s decarbonisation goals. We are collectively worried of the proposal to bring forward the revision of the CO2 Standards for Cars and Vans and the proposal to expand the use of e-fuels, masquerade through a call for “technology-neutrality”. As the European law-makers prepare to review the upcoming amendment to the regulation on CO2 emission performance, we highlight risk such amendment poses to overall energy consumption of the continent.
What is energy efficiency in transport?
Energy efficiency refers to the amount of energy, measured in kilowatt-hours (kWh), required to travel a certain distance (kilometers) per passenger. The more energy-efficient a mode of transport is, the less primary energy is needed to be produced for the vehicle to travel the same distance, regardless of the energy’s source—whether it comes from fossil fuels, nuclear energy, or renewable sources.
2. Why is energy efficiency crucial?
Energy efficiency should be a cornerstone of the EU’s energy transition for transport. As transport remains one of the largest consumers of energy, improving energy efficiency directly supports European energy autonomy and security by reducing Europe’s reliance on imported fossil fuels, particularly from politically unstable regions. According to BloombergNEF, favoring energy-efficient transport could save up to 1.5 million barrels of oil per day, equivalent to over €40 billion annually in reduced imports[1].
In addition to strengthening energy security, energy efficiency has direct economic benefits. As energy costs may continue to rise, more efficient transport solutions can help reduce operational costs for businesses and drivers alike. This would make travel more affordable for citizens and improve the competitiveness of European industries.
Furthermore, a key objective of the EU is to increase the share of renewable energy in its energy mix. However, less energy-efficient transport modes would require a unnecessarily increase in renewable energy production to meet demand. It would increase the risk of “Not-In-My-BackYard” movement against such renewable energy plants, and ultimately Europeans’ resistance against energy transition. Prioritising energy efficiency helps maximize the utility of renewable energy and minimize the impact in Europe.
[1]https://about.bnef.com/blog/electric-cars-have-dented-fuel-demand-by-2040-theyll-slash-it/#:~:text=So%20far%2C%20the%20growing%20fleet,far%20off%2C%20arriving%20in%202027.
Which transport modes are the most energy efficient?
Among all transport modes, trains are by far the most energy-efficient for long distances[1]. 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. We thus support the call to further roll-out of TEN-T as well as plans for an ambitious European high-speed rail network, night train and rail freight. The ecological advantage is especially there for freight transport. On the local level, public passenger transport by metro, tram, bus and urban rail collectively moves large numbers of people, using less energy and emitting less CO2 per passenger-kilometre than private vehicles.[2]
However, passenger cars remain at the center of current political debate. They represent the most widespread form of personal transport and are undergoing major changes amid political debates and upcoming review of the CO2 Standards for cars and vans. When it comes to energy efficiency, not all cars are equal. Energy efficiency among cars varies dramatically, depending on the type of propulsion used. For example, as illustrated by graph 1 above, on the same amount of energy of 15 kWh, similar passenger cars travel very different distances[3]:
- An internal combustion engine vehicle running on synthetic fuels created from renewable energy and climate neutral can travel 20km;
- a hydrogen fuel cell vehicle, running on synthetic fuels created from renewable energy and climate neutral can travel 35km, using the same amount of energy.
- a battery electric vehicle (BEV) can travel 100 km on the same amount of energy, five times more the range of the ICE car.
It is clear that BEVs significantly outperform vehicles powered by e-fuels in terms of energy efficiency.
[1] https://www.iea.org/energy-system/transport/rail [2] In its Urban Mobility Framework (point 2.4), the Commission writes "Public transport such as urban rail, metros, trams, buses, water buses, ferries or cable cars represent the safest, most efficient and sustainable ways for large numbers of people to travel.". There is also a comparison of emissions per mode that includes buses (and coaches) in the EEA Transport and Environment Report 2021 (figure 4.3) [3] Research Center for Energy Networks and Energy Storage
Why are they differences in energy efficiency?
Producing e-fuels requires much more energy than producing fossil fuels or using direct electrification when looking at energy use from production to tank. The main issue with e-fuels is their low efficiency throughout the production process. In order for an e-fuel to truly be carbon-neutral, each step—making hydrogen, capturing carbon, and then synthesizing the fuel— needs to be renewable. However, each of these steps require energy and result in large energy losses. This makes e-fuels less efficient in areas where electrification use is possible, especially since electric motors are far more efficient than combustion engines[1].
While a BEV uses 77% of the primary energy to move its wheels, a vehicle powered by e-fuels converts only 20% of the original energy input into motion[2]. The later would thus need about four times more primary energy than the former to travel same amount of kilometres. This large difference underscores the need to prioritise more efficient technologies. Energy efficiency is not a marginal criteria.
Additionally, such an efficiency gain is without counting on the benefits BEVs can have for the energy system if grid-integrated thanks to smart and bidirectional charging, where their batteries can improve the efficiency of the entire energy system. As the making synthetic fuels in itself is already very energy intensive. Each Kwh used for the production of synthetic fuels is one that cannot serve other, more efficient means.
[1] https://www.spglobal.com/_assets/documents/ratings/research/101595057.pdf [2] https://www.transportenvironment.org/articles/e-fuels-too-inefficient-and-expensive-cars-and-trucks-may-be-part-aviations-climate-solution
Which policies can promote most energy-efficient transport?
To ensure that Europe’s future vehicle fleet is as energy efficient as possible, we recommend the following policy actions:
- No U-turn: Any early review or any U-turn in already agreed policy is detrimental for investment confidence in the energy transition.
- Limit the role of e-fuels in CO2 standards: In the upcoming review of the CO2 standards for cars and vans, we urge policymakers to restrict the use of e-fuels to niche markets that cannot be directly electrified, for emergency services, or vehicles of specific usages such as forestry.
- Focus e-fuels on hard-to-abate sectors: Divert the use of limited e-fuels to other sectors where electrification is still not an option and where so much is needed: aviation, long-haul maritime.
- Introduce differentiated taxation: Vehicle taxation should be tied to energy efficiency. Registration taxes, road taxes, and fuel duties should favour energy-efficient vehicles. For instance, a bonus-malus system could be introduced, where less efficient vehicles face higher taxes, and more efficient options benefit from tax breaks. The revision of the Energy Taxation Directive could be instrumental in this perspective.
- Prioritise energy efficiency in public procurement: Public procurement can be a powerful tool to set an example. Green public procurement criteria should prioritize the energy efficiency of vehicles used in the public sector. By including energy efficiency requirements in public tenders, governments can drive demand for the most efficient technologies. The Net Zero Industrial Act already paves the way in this direction.
Conclusion
Energy efficiency is not just a technical consideration, it is a strategic imperative for Europe’s energy security, economic competitiveness, Europeans’ cost of living, and environmental sustainability. By prioritising the development and use of the most energy-efficient transport modes, the EU can reduce its dependence on imported fossil fuels, lower costs for consumers, and ensure that the shift to renewable energy is as efficient as possible.
We strongly urge you to take decisive action in the upcoming CO2 standards review and to adopt policies that will promote the most energy-efficient transport solutions. This is essential to meeting the EU’s decarbonisation objectives and securing a sustainable future for all Europeans.
Our recommendations to Commissioner for Climate
INDUSTRY - FLEET
The Clean Industrial deal’s success relies on stable legislation on both demand and supply sides
Our recommendations for Wopke Hoekstra
Commissioner-designate for Climate, Net-Zero and Clean Growth
As a new EU mandate begins, the members of the Platform for Electromobility remain dedicated to advancing sustainable transport solutions that drive decarbonisation across all land transport modes in Europe. To achieve this and support Europe in its energy transition, it is crucial to align supply-side policies and strong demand-side measures to ensure a successful decarbonisation of transport; one of the EU’s most polluting sectors. This will require a balanced approach where climate goals are met while addressing the needs of citizens, consumers, and industry. A coordinated effort between the European Green Deal and a Clean Industrial Deal will be key to driving sustainable progress and maintaining Europe’s leadership in clean mobility.
Below, we outline our recommended priorities for the incoming Commissioner for Climate, Net-Zero and Clean Growth for ensuring that European climate policies consider industries and consumers needs while meeting Europe’s long-term climate objectives.
1/ Supply side policies: a steady regulatory framework covering the whole value chain
The Clean Industrial Deal should complement and perfect the European Green Deal, rather than replace it. The two packages must work together to achieve Europe’s climate and industrial goals, particularly as we enter a period of rapid transformation in the transport and mobility sectors. Industrial policy should enable —not dilute— the climate targets that the EU has committed to, ensuring Europe maintains its leadership in clean transportation deployment.
When it comes to decarbonation of transport, legislative clarity and objectives are key. This is particularly true to ensure the successful roll-out of zero-emission vehicles by 2035. We must first safeguard such a flagship target while ensuring that consumers—whether individuals or businesses—are buying-in to the transition and support European car manufacturers in this centurial challenge.
The Platform for Electromobility is very concerned by recent statements calling on the incoming European Commission to reverse the already agreed on CO2 Standards for cars and vans. Today, the 2035 zero emission cars goal is Europe’s most straight-forward EV industrial strategy bringing vital investments to European companies. We thus strongly warn against undermining key EU legislation already agreed by MEPs and EU countries in the last legislative period. Attracting investments to create the net-zero industrial ecosystem for zero-emission mobility is not possible without a consistent, clear regulatory framework. To “hit reverse” now would also significantly penalise all industrial actors, including many of our members, who have already invested in this transition (automotive, batteries, infrastructure, etc.).
More details: Reversing the 2035 zero emission cars goal will harm EU industry (June 2024)
Key Policy Asks:
Ensure the continued implementation of the 2035 zero-emission vehicles target to maintain regulatory certainty and attract investment.
Ensure swift and coherent implementation at national level of other Green Deal measures notably related to charging infrastructures and renewable energies.
The Platform for Electromobility sees the European Green Deal as a long-term strategy to ensure Europe’s global competitiveness and climate leadership. This long-term strategy should now be accompanied by an actionable industrial policy plan. Any such future industrial policy, to be comprehensive, should include a focus on the electromobility manufacturing ecosystem. We underline the need for a holistic approach, covering the entire value chain for clean transport solutions (upstream and downstream) and understanding the particularities of Europe industrial and transport systems. Finally, industrial policy should rely on a stable regulatory framework and reinforced international cooperation.
We advocate for a 360° e-mobility industry strategy that addresses the full value chain—from raw materials to end products—across all modes of sustainable transportation. This includes a focus on upstream (refining) and downstream (recycling) sectors to strengthen Europe’s industrial base. Additionally, we stress the need for policies to address energy-cost disparities and support public procurement that favours European-made products. It is also crucial to support workers in transitioning to new skills required for the green economy.
– More details: Five steps towards a 360° e-mobility industry strategy (March 2024)
– More details: Invest skills for competitive, sustainable, European transport industries (June 2024)
Given the escalating climate investment gap, we propose the creation of a comprehensive Net Zero Investment Plan. This plan should not only focus on innovation but also provide limited-in-time yet predictable support for operating expenses and production. It should consider higher-risk ventures and be structured under the EU Multi Financial Framework and new bond issuance programs. Coordination of state aid measures at the EU level will ensure a level playing field and support Europe’s climate and mobility objectives.
More details: Invest in manufacturing for competitive, sustainable, European transport industries (June 2024)
Robust international cooperation is essential to mitigate geopolitical and dependency risks. The EU should prepare responses to global green industry support programs carefully to avoid a subsidy race. Strengthening cooperation with major economic powers and diversifying sources of green technology will help reduce dependencies and secure supply chains. Furthermore, intra-European cooperation should be encouraged to optimize the procurement of strategic raw materials.
– More details: Strengthening EU’s electromobility ecosystem in the global race. (March 2023)
In the pursuit of the electrification of the mobility sector for the years to come, it is essential to recognise concerns surrounding certain PFAS use cases and their production, use and disposal. Considering that environmental and human health protection are critical, we call next Commissioner to supporting the transition to PFAS-free solutions in the sustainable mobility sector, and call for measures to eliminate all emissions released during the life cycle as soon as viable industrial alternatives are available. Primary collective objective should be to reduce, and where possible, phase out the use of PFAS following the REACH risk management approach across all mobility industries.
– More information: Our statement on PFAS in sustainable e-mobility (April 2024)
Key Policy Asks
Ensure upcoming Clean Industrial Deal considers the whole e-mobility value chain’s competitiveness rather than focusing on a few components or modes.
Financing the energy transition in the long term with a Net Zero Investment Plan
Strengthening international cooperation to avoid trade disruption and diversify sources while ensuring a level-playing field.
Grant appropriate derogation periods necessary for testing alternatives and bringing them to the market and allow for the use of PFAS where no alternative is available while ensuring they are replaced as quickly as possible.
2/ Demand-side measures: a stable framework for consumers to show the way, corporate fleets to pave the way.
The next step in accelerating the transition to electric mobility is to propose a legally binding a corporate fleet mandate, ensuring that companies and large fleet owners, currently lagging behind[1], play their part in electrifying transport. Corporate fleets represent a significant portion of vehicle sales and are pivotal to creating a vibrant second-hand market for EVs. A well-regulated corporate fleet mandate would not only speed up the decarbonization of the transport sector but also ensure that EVs become more affordable for the broader public. We trust the next European Commissioner for Climate will work closely with next European Commissioner for Sustainable Transport in proposing clean corporate fleet initiatives.
– More details: Guidelines for mandating ZEV in corporate and urban fleets (September 2021)
The previous European Commission already laid the groundwork with the public consultation on corporate fleets, and now is the time to build on that momentum. A strong mandate would require companies to transition their vehicle fleets to electric, generating a steady supply of second-hand EVs. Two-third of Europeans purchase their vehicle on the second-hand market. Such measures would particularly benefit lower-income households who might otherwise struggle to afford new electric models and be left aside of the energy transition.
This policy will also support a smoother and more inclusive transition to e-mobility, helping to lower transportation costs for consumers while contributing to the reduction of air pollution and greenhouse gas emissions. To go further, we also invite the European Commission to investigate other potential demand-side measures to be implemented at national level (e.g. social leasing, scrappage schemes, sustainable taxation) to support the transition.
Key policy ask:
Propose a legally-binding corporate fleet mandate to accelerate the electrification of transport and generate a second-hand EV market that broadens access to affordable, zero-emission vehicles.
Investigate the opportunity of other measures to boost the demand of clean mobility solutions.
[1] https://evmarketsreports.com/corporate-ev-adoption-in-eu-lags-behind-private-households-raising-concerns/
Our recommendations to Commissioner for Energy
Energy
Energy policies enabling decarbonised transport, and vice-versa
Our recommendations for Dan Jørgensen
European Commissioner-designate for Energy
As we move into the next five years of the European Parliament mandate, the members of the Platform for Electromobility remain committed to advancing sustainable transport solutions that drive decarbonisation of land transports in Europe. To achieve this, it is essential to create a synergetic ecosystem between energy and transport infrastructures and assets.
Indeed, the emerging ecosystem of sustainable, decarbonized transport sits at the intersection of the energy and transport sectors. The electrification of transport is not just a transport initiative but a crucial energy challenge that requires coordinated efforts across both domains. With transport now a major driver of electricity demand, engagement of next European Commissioner for Energy in electric mobility policy initiatives will be essential to successfully achieving the European Union’s climate and energy goals.
Below, we outline the necessary legislative steps that a seamless, win-win integration between energy and transport ecosystem requires.
1/ Ensuring the implementation of the Green Deal
As you begin your new mandate, we urge you to uphold and fully implement the commitments of the European Green Deal, particularly those within the Regulation on the CO2 standards for new passenger cars and vans, the Renewable Energy Directive (RED) and the 2019 and 2024 Electricity Market Design (EMD) reforms. These legislative files are enablers of Europe’s transition to a sustainable transport system, accelerating renewable energy adoption and creating a more flexible, efficient electricity market. Next European Commissioner for Energy’s leadership will be essential to ensure their timely implementation and to hold Member States accountable for meeting their ambitious targets.
To ensure the success of these ambitious directives and Regulation, it is crucial to pair the Green Deal’s implementation with a robust investment plan. This should include dedicated funding mechanisms to support renewable energy projects, grid modernization, and infrastructure development. By aligning public and private investment with the goals of the Green Deal, Europe can foster innovation, enhance energy security, and create sustainable jobs across Member States.
Key policy asks
Ensure the full and timely transposition of the Renewable Energy Directive (RED) and the Electricity Market Design (EMD) across all Member States. – More details: Our statement on Electricity Market Design.
Uphold the targets already set out in the Regulation on the CO2 standards for new passenger cars and vans.
Support the presentation of a strong Net-Zero Investment Plan to implement the Green Deal. – More details: Investing in energy infrastructure to enable the Green Deal
2/ Upgrading and smartening the electricity grid for e-mobility
The integration of electric vehicles (EVs and eHDVs) into Europe’s electricity grid presents both opportunities and challenges. However, a modern, smart, and flexible power grid across Europe is the key to accommodating the increasing demand for electricity from EVs, ensuring grid stability notably via ancillary flexible services that smart vehicles can deliver. Investments in grid infrastructure, smart technologies, and flexibility services will be essential to managing this transition effectively.
To support this transition, the Platform for Electromobility emphasizes the importance of coordinated action between all stakeholders, including Distribution System Operators (DSOs), Charge Point Operators (CPOs), flexibility service providers, and regulators. A harmonized approach to grid planning, smart charging solutions, and vehicle-to-grid (V2G) technologies will maximize the benefits of EV integration, both for the grid and for consumers.
We encourage you to prioritize the following actions:
Promote the development of national EV charging blueprints and anticipatory grid investments, ensuring that Member States facilitate seamless EV charging infrastructure deployment in alignment with grid capacity.
– More details: The right governance for smooth integration of e-mobility solutions into the grid.Support the reform of grid connection agreements and foster the implementation of smart and bidirectional charging technologies, enabling EVs to contribute to grid stability and flexibility.
– More details: A Comprehensive Roadmap for V2X Integration in Europe
Our recommendations to Commissioner for Transport
Logistics
Towards a Sustainable Logistic Transportation in Europe
Our recommendations for Apostolos Tzitzikostas
European Commissioner-designate for Sustainable Transport
As we move into the next five years of the European Parliament mandate, the members of the Platform for Electromobility remain committed to advancing sustainable transport solutions that drive decarbonisation of the transport of goods in Europe. To achieve this, it is essential to electrify all modes of regional logistic transports, on and off the roads. On road, the electrification of transport is still at the very early days of its development and requires significant and necessary efforts, for large CO2 emission saving potential. Off-roads, the rail and multimodal sectors present opportunities for quicker gains due to their existing capacity. By integrating various modes of transport, we can create efficient, zero-emission logistics networks that reduce reliance on road transport.
Below, we outline the necessary legislative steps required to decarbonize the European logistic system, addressing both vehicles and infrastructure, for transport modes on and off the roads.
1/ On Vehicles: Continuing the work initiated by the first von der Leyen Commission
We urge the next European executive to continue the work initiated by the first von der Leyen Commission. These initiatives are crucial for the deployment and renewal of logistic vehicle fleets, which are a key component of the logistic ecosystem.
- The proper implementation of CO2 standards for trucks and buses is critical for this third pillar. We invite policy-makers to ensure adherence to the regulation as approved by co-legislators in 2023.
- Political initiatives will be essential to encourage the adoption of zero-emission vehicles, therefore we urge a cleaning corporate fleet proposal by the European Commission, after the related consultation, subsidies, tax incentives, and scrappage schemes for older diesel trucks.
- To incentivise the uptake of zero-emission trucks further, we call Member States to engage in an effective review of the Weights and Dimensions Directive, bearing in mind the goal to promote the dissemination of those vehicles. Decarbonising road freight transport is vital, given that it is currently dominated by diesel HDVs (including European Modular Systems where permitted). Zero-emission trucks need adequate weight allowances to accommodate their technology and lawmakers should avoid granting guarantee that their circulation is not unjustly constrained to minimal percentages of the TEN-T core network [1].
- Call on Member States to reach a general approach on the Combined Transport Directive by the end of the year, with a view to promote the use of Zero-Emission Vehicles for short and medium range connections (for which Zero-Emission HDV will be well adapted) and a modal shift towards more energy efficient and highly electrified modes of transport such as rail.
- Given that the average lifespan of rail rolling stock in Europe is approximately 30 years, targeted investments in zero-emission trains will be crucial for phasing out diesel propulsion and advancing rail electrification efforts. Infrastructure managers and operators – particularly in Central and Eastern Europe where rolling stock fleets are older – stand to benefit significantly from investments in new zero-emission rolling stock.
Key policy asks
Implement regulations and incentives for Zero-Emission trucks: Implement robust CO2 standards for trucks and buses, propose a clean corporate fleet initiative, and offer subsidies, tax incentives, and scrappage schemes to accelerate the adoption of zero-emission vehicles and renew outdated diesel fleets.
Enhance legislation to support Zero-Emission Transport: Reach a swift and ambitious general approach on the proposal to revise the Combined Transport Directive and review the Weights and Dimensions Directive to support zero-emission trucks while preventing expanded circulation of heavier diesel vehicles, and invest in the electrification of rail infrastructure, especially in regions with aging rolling stock, to phase out diesel propulsion in rail transport.
2/ On Infrastructure: implement the Green Deal for both above and underground assets.
The second pillar of a sustainable logistic ecosystem is its infrastructure. We believe that the legislation agreed upon under the European Green Deal in recent years is highly relevant and can be effective if properly implemented.
- Ensuring a swift and coherent implementation of the Alternative Fuels Infrastructure Regulation (AFIR) for public charging infrastructure and the national transposition of the Energy Performance of Builidngs Directive (EPBD) for private charging infrastructure is paramount. Member States should develop robust national plans based on AFIR and EPBD targets and on future demand, supporting the deployment of charging infrastructure for eHDVs. We recommend European fundings to still be allocated to the roll out of charging infrastructures for eHDVs via the AFIF.
- To incentivise an impactful decarbonisation of the HDV sector by using more electricity by renewable energy sources, Member States should fast-track the implementation of the Renewable Energy Directive III (REDIII) credit mechanism for EV Chargers in order to be ready for 21st May 2025. The mechanism should be implemented not only for the public accessible chargers but also for the private ones, in order to lower electric HDVs’ Total Cost of Ownership (TCO) and incentivise private actors to deploy chargers and become active in the market, using private resources. By making the most of available credits and financial incentives, this will support business cases for private investments in eHDVs infrastructure.
- The electrification of the Trans-European Transport Network (TEN-T) rail network by 2030, 2040 and 2050 will require substantial investments with priority for three key areas. First, maintenance of existing infrastructure is paramount for ensuring optimal track conditions, enabling higher speeds and improving services. Second, upgrading existing network infrastructure – including implementing the European Rail Traffic Management System (ERTMS) signalisation and addressing bottlenecks – are crucial for enhancing efficiency and capacity.
Underground, the power distribution grid will also need substantive measures to adapt to the decarbonation of logistical transport. We invite next European Commissioner for Transport to :
- nsure that the expansion of the electricity distribution grid keeps pace with the rapidly growing demand for fast chargers for electric heavy-duty vehicles (eHDVs). This requires substantial investment, forward-looking planning, including anticipatory investments, and appropriate mapping on hosting capacity by system operators and streamlined connection procedures to support the necessary infrastructure. We also emphasize the importance of reinforcing the commitments made during the Energy Council in June under the Belgian Presidency, which underscored the need for a coordinated approach to grid development in anticipation of future demand.
- Promoting the deployment of Vehicle-to-Everything (V2X) technology will also be crucial in enhancing grid integration and reducing the total cost of ownership for eHDVs. The development of smart charging systems and bidirectional charging capabilities will support grid stability and renewable energy use. Synergies between eHDVs and eBuses charging infrastructure, like shared depots whenever possible can be sought minimize grid connection requests and optimize public space.
Key policy asks
Accelerate implementation of green infrastructure legislations: Ensure swift and coherent execution of the Alternative Fuels Infrastructure Regulation (AFIR) and Renewable Energy Directive III (REDIII) to expand charging infrastructure for electric heavy-duty vehicles (eHDVs) and integrate more renewable energy sources, lowering the total cost of ownership and incentivizing private investment.
Invest in rail and power grid infrastructure: Prioritize electrification and upgrades of the Trans-European Transport Network (TEN-T) rail network, including maintenance and European Rail Traffic Management System (ERTMS) enhancements, and expand the electricity grid to meet the increasing demand for fast chargers for eHDVs. Encourage the deployment of Vehicle-to-Everything (V2X) technology and smart charging systems to enhance grid stability and support the broader use of renewable energy.
[1] The latest, failed compromise under the Belgian Presidency proposed limiting the circulation of 44-tonne ZETs to 25% of the TEN-T core network by 2030, 50% by 2035, and 100% by 2040 in countries that do not permit 44t trucks internally (e.g., Germany). The Commission's proposal did not include such a restriction, which, as evident, would significantly disadvantage ZETs. If this proposal were adopted, it could also allow Member States like Germany to restrict the circulation of ZETs that already benefit from the existing 2t allowance (i.e., 42t ZETs) to these minimal percentages of the TEN-T core network.
30 investments priorities by 2030 for sustainable mobility
Energy, Infrastructure, Industry
Our recommendations for a “European Net-Zero Infrastructure Investment Plan
Without deployment of high-speed charging infrastructure for electric trucks, a high quality and interoperable rail network as well as integrated recycling facilities, the Green Deal will remain simply a paper tiger.
The Platform for Electromobility supports the overall shift in European policy priorities established the European Green Deal. The Deal acts as a valuable long-term compass, particularly in light of the pending elections and the appointment of a new Commission. In 2023, two pivotal pieces of legislation supporting the shift – the Net Zero Industrial Act and the Critical Raw Materials Act – were enacted. However, while these measures are welcome first steps, they call for a complementary initiative: a robust European Net-Zero Infrastructure Investment Plan.
A comprehensive Net Zero Investment Plan is essential if the EU Green Deal is to be implemented effectively within an appropriate timeframe. European companies and industries will require additional financing in order to transition to net zero, particularly given the support provided by competitors such as the US and China. Whether it is an “Investment Plan for Jobs and Clean Technologies”, an “Investment Plan for the Green Transition”, a “major investment plan to fund green industries and infrastructure” or a “massive investment spending plan for the creation of green jobs and the transformation of industry, transport and energy” – by the European People’s Party, the Party of European Socialists, the European Greens and The Left, respectively, it is clear that investment stands as a cross-partisan priority.
As outlined in our EU election manifesto, a significant investment plan post-elections is essential for ensuring the successful implementation of the Green Deal. This will benefit individuals, the climate and businesses alike, targeting sectors crucial to achieving Net Zero goals. Without deployment of high-speed charging infrastructure for electric trucks, a high quality and interoperable rail network as well as integrated recycling facilities, the Green Deal will remain simply a paper tiger. It is imperative that we make these and other long-term, easily accessible investments. Ensuring legacy of the Green Deal with a large investment plan must take centre stage during the upcoming European elections. It is the democratic moment that would legitimise such a leap forward.
At the Platform for Electromobility, our focus is on identifying priorities for the sustainable transport sectors as a whole, ensuring they work synergistically while avoiding duplication or contradictory expenditure. This document offers an overview of the required investment priorities for the myriad sectors that will constitute tomorrow’s clean mobility ecosystem. We therefore aim to support policy makers in determining the content and priorities of such a cross-partisan investment plan.
Below, 30 investment priorities in seven areas have been identified, in order to respond to three policy imperatives: deploying hard infrastructure, implementing industrial policy and supporting the shift to zero-emissions vehicles. Those priorities are closely intertwined, build on each other and create valuable synergies.
While financial considerations are paramount, they must not be the sole focus. The Green Deal also requires further legislative measures for proper implementation, such as industrial policy reforms, corporate fleet mandates and electricity market design overhauls. We have chosen to refrain from delving into financial arrangements, in order to maintain focus on our area of expertise: sustainable mobility.
30 priorities over seven areas, across three pillars.
Discover the details of the report.
1/ Investing in energy and transport infrastructure to enable the Green Deal
2/ Invest for competitive, sustainable, European transport industries
Methodology - Results are based on a preliminary questionnaire, distributed on a voluntary basis to the members of the Platform for Electromobility. The preliminary findings have been discussed and debated within each of the Platform’s six thematic working groups. The final outcomes have been validated by all members following the Platform’s Memorandum of Understanding validation processes.
A Comprehensive Roadmap for V2X Integration in Europe
Energy & Infrastructures
A Comprehensive Roadmap for V2X Integration in Europe
The paper outlines enablers and barriers concerning bidirectional charging systems, clarifies key barriers, highlights ongoing efforts to mitigate them, and underscores the critical need for concerted and regulatory actions to achieve the transformative potential of V2X integration.
Electric Vehicles (EVs) both pose particular challenges and present promising opportunities for the energy system; they mark a pivotal moment in the evolution of transportation and energy sectors. With the increased adoption of EVs lies the imperative for strategic planning and collaborative action on Vehicle-to-X (V2X), a crucial technology for smartening the road transport sector.[i]
Recently adopted legislation – as part of the European Green Deal – has already paved the way for the roll-out of smart-charging technologies in the electromobility ecosystem.[ii] We welcome these initiatives and will monitor their implementation closely. Smart charging is a fundamental prerequisite for V2X, which will deliver further advantages for people, the climate and European businesses alike.
Recognising this, this document from the Platform for Electromobility seeks to present a comprehensive roadmap on V2X, setting out a series of actionable steps that by Member States (MS) should undertake, along with measures required at the EU level. Stressing the importance of a cross-sectoral approach, our strategy seeks to navigate the complexities of V2X integration in our energy system without delving too deeply into intricate technicalities. The paper outlines enablers and barriers to adopting bidirectional charging systems, clarifies crucial barriers – and highlights ongoing efforts to mitigate them – and underscores the imperative for concerted and regulatory action to realise the transformative potential of V2X integration.
1/ Benefits of bidirectional charging
a/ Benefits for public finances & grid investments
V2X integration offers a multifaceted solution, one with the potential to unlock a wide range of benefits across various domains. Foremost among these, V2X – as with other flexibility resources – complements conventional grid reinforcement measures, helping alleviate the strain on existing infrastructure while enhancing its resilience. We are already starting to see increasing tensions in the grid and the overwhelming need to reinforce it; therefore, the deployment of V2X and the use of EVs as batteries represents a ‘no-brainer’[i] and would effectively smooth the rollout of grid reinforcement, something that usually takes between 5-15 years. V2X integration thus offers access to a realm of ‘low-hanging fruit’ opportunities, allowing the cost-efficient adaptation of the grids to growing electrification.
b/ Benefits for Europe energy autonomy
The integration of V2X will help deploy renewable energy sources (RES), by providing efficient storage solutions. It has the potential to help balance the grid and increase the penetration of renewable electricity (RES-E) into it, thus accelerating the drive to climate neutrality. Indeed, in order to ensure generation adequacy – key for the energy transition – V2X will be pivotal. As intermittent renewable energy becomes increasingly prevalent, maintaining grid stability and meeting demand poses significant challenges. Here, V2X solutions can play a crucial role in balancing supply and demand, enabling dynamic resource adequacy analyses that realise the enormous potential of V2G capabilities.
c/ Benefits for grid operators
From the perspective of the grid operators, there are manifold advantages. For Transmission System Operators (TSOs), V2X is particularly beneficials for Frequency Regulation (FCR) Services, which are pivotal functions for TSOs. In addition to mere savings in battery costs, V2X optimises both standalone and grid-connected storage battery systems. FCR plays a critical role, not only in reducing the necessity for investment in battery storage services but also in minimising the need for grid upgrades. These efficiencies translate into systemic savings, ultimately benefiting electricity consumers. For DSOs, V2X can play a major role in local flexibility markets and congestion solutions providing services to DSOs and representing a valuable flexible resource that can be procured to ease tensions on distribution grids. This requires flexibility mechanisms in which V2X value can be stacked based on related remuneration. To enable even more value of V2X for every DSO, market based procurement of flexibility based on V2X shall be stimulated.
d/ Benefits for users, people and businesses alike
From an end user’s perspective, the benefits of V2X integration will be substantial. Through leveraging V2X capabilities, users will have the opportunity to earn money from feeding energy into the grid, thus enhancing the overall value proposition of electric mobility.[ii] Remuneration mechanisms (such as those based on availability, capacity or time) will trigger further consumers to participate; once they do so, they will naturally generate demand for V2X. V2X integration will not only enhance grid resilience and promote renewable energy uptake but also pave the way for a more sustainable, efficient and adaptive energy ecosystem, one where EVs can equally participate in flex mechanisms.
2. Legislative and Regulatory Principles for V2X Integration
As we call on legislators to begin shaping the regulatory framework for V2X integration, there must be a number of core founding principles that underpin their efforts to foster innovation, interoperability, fairness and trust within the emerging ecosystem.
a/ Consumer trust
Foremost among these principles must be building and maintaining consumer trust. Legislators must prioritise creating a robust system that instils trust among users, system operators and businesses alike. This will entail ensuring transparency and accountability in V2X transactions while also safeguarding consumer rights and interests.
b/ Business models based on use cases
The deployment of V2X infrastructure must be accompanied by corresponding business models, particularly where financed/cofinanced by public entities. As the value of V2X depends on the use case of fleet and chargepoints, there need to be proper business models created that provide an incentive for consumers. Regulators should therefore facilitate mechanisms to support user compensation and fair pricing; these should recognise the pivotal role granular pricing structures play in enabling diverse business models and in incentivising dynamic energy management. The increased volatility in our energy system arising from renewables and negative grid tariffs can further stimulate consumers to engage and participate in V2X initiatives.
c/ Commonly accepted and harmonised standards
The promotion of common standards is paramount for ensuring interoperability and reliability across V2X systems. These should allow the CCS standard to provide smart and bidirectional charging. This should be implemented as early as possible in both charging stations and cars. Any further delay will lead to infrastructure that is not future-proof and will fail to deliver the smart-charging services we will need for the energy transition to succeed. Standardisation bodies should prioritise development and enforcement of standardised protocols for battery efficiency and warranty and for EV charging protocols between both the grid and vehicle. This will bolster consumer confidence and trust in V2X technologies.
d/ Affordability through democratisation
The accessibility and affordability of V2G-capable vehicles must be a priority if access to this transformative technology is to be democratised. By incentivising competition and innovation in the production of V2X-capable chargers and EVs as well as through lowering the barriers detailed below, legislators can drive down costs and promote widespread adoption. This in turn will create economies of scale and lower barriers to entry. With the right regulatory framework in place, recharging costs can theoretically be brought down to zero with bidirectional charging.[i]
e/ Equal treatment for all grid usages
Ensuring equal access, participation, and treatment for all energy usages, including all type of V2X, is fundamental. All grid users should receive equal treatment without discrimination, be they electric vehicles, wind turbines or home appliances. Any exceptions – such as tariff exemptions – should be restricted to emerging user groups, should remain temporary and should be appropriately justified.
f/ Upgradability path
In envisioning the regulatory framework for V2X integration, it is imperative to prioritise establishing future-proof systems capable of evolving alongside advancing technologies and changing needs. Although V2X technology is not as yet fully harmonised across Europe and still faces barriers, its early rollout is needed in order to facilitate improvements. Central to this endeavour is the need for an ‘upgradability path’, embedded within the regulatory framework. Such a path will not only instils trust among consumers and markets but also ensure compliance with future technological advancements and emerging requirements.
g/ Public charging hidden potential
In Europe, a significant proportion of the car fleet lacks access to home charging. As a result, publicly available charging will continue to be necessary in the future. This presents an opportunity to leverage V2X technology at these points also. We therefore encourage public charging points to be V2X-capable; this is provided that the cost-benefit analysis is positive, they are priced similarly, only implemented on slow chargers and do not impede the rollout of charging stations across Europe.
3. Barriers to V2X Deployment
Despite the potential offered by V2X integration, several barriers continue to hinder its widespread deployment. Overcoming regulatory, technical and market hurdles will require concerted efforts.
a/ Implementation of the Electricity Market Design
At the forefront of these challenges are regulatory barriers, most notably the lack of implementation by MS of the 2019 Electricity Market Design, which discriminates and disincentivises the participation of V2X in the electricity markets. To address this, there is an urgent need for MS to accelerate their implementation.
b/ Double Taxation
One of the asks of battery stakeholders (EVs and stationary) is to eliminate double taxation; that is, the taxing again of electricity injected into the grid from a battery. Double taxation[i] remains a persistent concern, particularly in scenarios where energy storage is integrated with other loads. While progress has been made in mitigating double taxation for large-scale storage, challenges persist for small-scale storage assets such as V2X. For example, in Germany, double taxation for stationary storage has been removed, yet remains in place for mobile storage.
c/ Uncoordinated grid requirements
The absence of the anticipated regulations, coupled with limited access to organised markets and revenue streams, poses significant challenges to V2X deployment. Uncoordinated grid requirements and standards between countries are exacerbating these challenges, hindering interoperability and complicating cross-border deployment efforts. Divergent communication standards and disparate smart meter adoption rates – something that is particularly evident in countries such as Germany, which has low penetration rates – underscore the urgent need for harmonisation and standardisation initiatives to realise the full potential of V2X integration.
4. Call for coherence, actions and political ownership at EU level
a/ Coherence across Member States
As the EU navigates the complexities of V2X integration, it is vital to address the prevailing divergences among MS and to foster a cohesive regulatory framework that promotes innovation and harmonisation. Despite incremental progress, no MS has successfully removed all barriers to V2X deployment, underscoring the imperative for EU-level intervention. For V2X for slow public charging, we therefore call for national capacity targets – rather an EU-wide one – because the share of cars without access to off-street parking at home differs significantly between MS.
b/ Coherence across EU legislations and regulations
To advance implementation of V2X and harness its manifold advantages within Europe, it is crucial that the newly installed European institutions adopt a holistic approach to this challenge. All V2X-relevant measures should be in the form a comprehensive regulatory framework, rather than addressing them in isolated discussions, or rather than discussion technologies (AC vs DC). One way of ensuring this seamless integration across diverse legislative frameworks – and avoiding a fragmented approach – is to establish political ownership.
c/ Multilevel coherence on V2X
Cities will, in general, be the key enablers and accelerators of V2X due to the alignment between clean air and decarbonisation strategies (such as growing adoption of zero-emission zones, electrification of heating as an alternative to petrol/gas/wood). V2X should therefore be part of an integrated mobility and energy strategy at all territorial levels. We therefore call upon the EU to adapt the proposed SUMPs/SULPs into SUMEPs/SULEPs (Sustainable Urban Logistics/Mobility and Energy Plan). This will ensure coordinated and integrated planning, helping couple mobility/logistics with energy aspects
d/ Double mandate to jumpstart the market.
Mandating V2X interoperability for all bidirectional-capable vehicles, while at the same time requiring V2X capability for public fleets and buildings would be decisive in kickstarting the market and boosting widespread adoption. It would also ensure flexibility for independent aggregators and promote the use of submeters. Requiring interoperability and encouraging public fleets to lead by example will help jumpstart the market.
Conclusion
Additional measures, including addressing communication standards and issuing non-binding guidelines for MS, will be essential for fostering coherence and facilitating the transition towards a sustainable, interoperable V2X ecosystem. With upcoming revisions to key pieces of legislation now on the horizon, it is an opportune moment for the European Commission to demonstrate leadership and to spearhead concerted action to achieving V2X integration goals. By embracing coherence at an EU level, policymakers can unlock the full potential of V2X technologies and accelerate the shift to a smarter, greener future.
Introduction [i] V2X is an EV bidirectional charging technology encompassing several sub technologies: When the vehicle is plugged and electricity automatically flows from the car back to the grid, this is known as Vehicle-to-Grid (V2G). If the charging and discharging of electricity stored in electric vehicles takes place in buildings, this technology is known as Vehicle-to-Building or Vehicle-to-Home (V2B or V2H). [ii] Notably in the Energy Performance of Buildings Directive, the Renewable Energy Directive and the Alternative Fuels Infrastructures Regulation The benefits of bidirectional charging [i] It has been calculated that V2G can offer 21TWh of upward flexibility, and 24TWh of downward flexibility by 2030, considering 30% of the EVs are charged bidirectionally. Together with other flexibility resources, €11 to €29 billion could be saved in annual savings in distribution grid investments. Source : https ://smarten.eu/wp-content/uploads/2022/09/SmartEN-DSF-benefits-2030-Report_DIGITAL.pdf [ii] In a fleet demo in Denmark, a 10-EV fleet engaging in frequency regulation (FCR) services recorded an average revenue of € 1,860 per car per year[ii]. In a residential V2G project connecting 320 homes in the UK, the V2G units were able to create ‘between £230 and £300 of value per year through the spot electricity market’ and the project team expects that ‘when combined with flexibility services this could grow to £500 per year[ii].’ In the UK, a solution already commercialized proposes the first V2G tariff in the UK where EV drivers would get free charging thanks to their V2G charger and vehicle[ii], providing clear incentives and enhancing the social acceptance of the consumer to opt for bidirectional charging. Source: https://www.ofgem.gov.uk/publications/case-study-uk-electric-vehicle-grid-v2g-charging Legislative and Regulatory Principles for V2X Integration [i] Source: https://smarten.eu/position-paper-why-flexible-consumers-matter-a-contribution-to-eu-elections-2024/, p 9 Barriers to V2X deployment [i] In fact, battery stakeholders face a triple taxation. Once when the energy is taken from the grid, twice when part of the energy is injected into the grid, and a third time when that electricity is used somewhere else. The electricity injected to the grid should not be taxed when taken by the battery nor when injected back into the grid.
Platform's statement: PFAS in sustainable e-mobility
Supply chain
PFAS in sustainable e-mobility
In the pursuit of the electrification of the mobility sector for the years to come, it is essential to recognise concerns surrounding certain PFAS use cases and their production, use and disposal.
The Platform for Electromobility acknowledges the significance and broad presence of Per- and Polyfluoroalkyl Substances (PFAS) in the electromobility ecosystem. PFAS represent a group of artificial/ anthropogenic chemicals with different physical, chemical, and biological properties[1]. PFAS have been widely utilised in most industries for their valuable properties (including resistance to heat, water, and oil) that enhance product performance and safety. However, their production and disposal raise concerns about environment and human exposure[2].
In the context of clean mobility manufacturing, e.g components of electric vehicles of all modes to renewable energy infrastructures, PFAS have played an enabling role. They are used in sustainable transportation, energy systems and components, such as batteries, wiring, and battery thermal management systems.
In the pursuit of the electrification of the mobility sector for the years to come, it is essential to recognise concerns surrounding certain PFAS use cases and their production, use and disposal. Considering that environmental and human health protection are critical, we are committed to supporting the transition to PFAS-free solutions in the sustainable mobility sector, and would support measures to eliminate all emissions released during the life cycle as soon as viable industrial alternatives[3] are available[4]. Our primary collective objective is to reduce, and where possible, phase out the use of PFAS following the REACH risk management approach across all mobility industries. We advocate for continuous innovation to replace such PFAS application in sustainable mobility.
We outline below crucial points for consideration to the Regulators during the whole restriction proposal negotiation process:
1. Minimize uncertainties for investors
While Europe has shown its intention to take a global leading role in environmentally conscious battery production, ongoing uncertainties around PFAS use in the battery industry represents a real threat to this nascent and needed industry for the coming years. The PFAS restriction proposal presented by the four Member States and Norway to ECHA is putting investments in Europe into the mobility sector today at risk, while other parts of the world are actively promoting the development of a domestic e-mobility value chain. Uncertainties regarding the duration of the derogation period pose a potential risk of exposing the sectors to a phase-out without adequate alternatives.
We call upon legislators to take a detailed approach ensuring predictability for battery value chain operators while future-proofing the industry from further restrictions.
2. Allow appropriate, open-ended derogation periods
The proposed phase-out of PFAS, which does not take into account the long lead times for developing alternatives will likely hinder the deployment of ‘made-in-Europe’ essential sustainable mobility solutions, particularly in uses when no viable substitutes exist. Legislators must recognise that, up to date, some components of e-mobility applications cannot work without PFAS[5], because no viable alternative solutions exist on the market or possible alternatives have been ruled as unviable. In order to avoid disastrous consequences for the battery industry and therefore the e-mobility roll-out, the proposed PFAS restriction requires careful and specific consideration:
We call on legislators to grant appropriate derogation periods for as long as necessary for testing alternatives and bringing them to the market[6] and allow for the use of PFAS where no alternative is available.
Encourage continuous and increased research and development to accelerate the testing and research around possible alternatives.
We also support reducing the scope of the current restriction proposal to exclude applications where no significant emissions happen during the whole life cycle, such as for batteries.[7]
3. Consider appropriate tools to increase transparency along the e-mobility supply chain:
Transparency and monitoring requirements could help improve the appropriate capture and destruction of PFAS using complementary abatement technologies and improve depollution standards.
4. Ensure consistent and future-proof legislation
Consistency across various EU legislations is key. Upstream, the issue of PFAS should be addressed within the context of Article 6, which pertains to Substances of Concern in the EU Batteries Regulation. Downstream, matters related to the disposal of materials containing PFAS in electric vehicles are currently under discussion in the End-of-Life Vehicle Regulation proposal.
We urge legislators to pay special attention to the issue of legacy substances under the revision of the EU End-of-Life Vehicles Directive.
Any ban on substances must be applied only on new types of vehicles.
Subsequent set of policies
Following the above-mentioned principles, we call for adopting the following balanced set of policies, which support reducing PFAS use where possible, mitigate their impact on the environment and human health, while supporting the energy transition and path towards climate-neutrality:
Encourage and invest in research and development to identify and promote viable alternatives to currently used PFAS in the electromobility sectors
The derogations which will be defined in the European Commission’s restriction for the use of PFAS substances in MAC (Mobile Air Conditioning) should be the same for all vehicles including EVs and combustion engine vehicles with mechanical compressors;
Ensure legislative predictability and science-based principle in chemicals management so that PFAS restrictions do not unintentionally increase the risk of investment diversion in battery manufacturing, potentially shifting operations from Europe to third countries.
Increase transparency and traceability on PFAS presence across the EV value chain, beyond battery production, notably by merging requested information of the Vehicle passport as proposed in the ELVR and the Battery passport behind a single QR Code.
It is imperative to foster sustainable and viable alternatives to PFAS in a balanced approach to align with the EU’s wider objective of accelerating a sustainable and resilient clean mobility sector.
[1] https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/terminology-per-and-polyfluoroalkyl-substances.pdf [2] The PFOA, a sub-group of PFAS, have notably been included in recent WHO classification as group one carcinogen (IARC Monographs evaluate the carcinogenicity of perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) – IARC (who.int)). Resulting from this, PFOA have been already globally regulated and phased out. They are not in the scope of this document. [3] Industrial viable alternatives are defined as innovations that have been tested, approved and scalable, ready for mass-market applications. [4] Regarding vehicles, only new types should be concerned by the upcoming restrictions. [5] https://rechargebatteries.org/wp-content/uploads/2023/09/FINAL-SECOND-SUBMISSION-.pdf [6] ready for mass-market applications [7] ECOS have decided to dissociate from other members of the Platform for Electromobility and not to support this last specification.