The reactions from the electric mobility ecosystem on Net Zero Industry Act

Green Deal Industrial Plan:
the reactions from the electric mobility ecosystem on Net Zero Industry Act and State Aid framework.

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The Platform for electromobility welcomes the European Commission’s Net Zero Industrial Act (NZIA) and Temporary Crisis and Transition State aid Framework (TCTF) for accelerating the transition of the EU’s net zero industrial sectors towards climate neutrality by 2050. As currently proposed, the NZIA is a positive start for a necessary holistic and long-term strategic plan, detailing specific financial and regulatory support measures for addressing all global current and future challenges, securing an EU-built industrial ecosystem of sustainable transport and ensuring bespoke strategic autonomy for every key sector identified.

We understand and welcome the package of both NZIA and TCTF as a tool for accelerating clean-tech industries with proposed non-financial regulatory measures. In this paper, we outline how the narrow scope of the proposed NZIA may fail in its aim of supporting European specificities. In addition, certain financial measures should also be included; without these, the NZIA may fall short of achieving its intended goals and fail to provide the required support for European clean industries.


Given the importance of reducing greenhouse gas emissions from the transport sector and industries, and the fact that Europe’s transport systems make up part of its critical infrastructure, we consider that mobility industries that provide zero-emission vehicles (ZEV) – all transport modes considered – as well as charging stations, software and other ZEV enabling tech, should be considered part of the ‘Clean Tech’ sector.

We welcome the inclusion of battery, charging infrastructures and grid technologies in the Annexes as Strategic Net Zero Technologies, yet we remain concerned about the lack of recognition for the entire EV value chain in the proposal. Net Zero Technologies should be extended to include other EV enabling technologies, including smart and bidirectional charging as well as component manufacturers.

A more flexible approach to those sectors that will be key for the EU’s future competitiveness should be adopted. Downstream industries, such as ZEV manufacturers, should be better considered and included in the scope of the Regulation to secure economic opportunities for supported upstream industries, such as cell manufacturing. Considering the NZIA as a non-financial tool, extending the scope to other sectors of the energy transition would increase Europe’s ability to be competitive in strategic sectors for the decarbonisation of transport, without undermining the support of already-included sectors such as battery manufacturing.

Non-financial measures

To create the enabling conditions for the European clean transport industry to prosper, several issues must be urgently tackled.

Financial measures

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CO2 Standards for trucks and buses: our reaction

Recommendation paper of the Platform on the revision of the HDV CO2 emission standards following the Commission’s proposal

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The Platform for electromobility very much welcomes the proposal by the European Commission for revision of the CO2 standards for heavy-duty vehicles (HDV) and sees the regulation as a fundamental tool to electrify trucks and buses and thus advance the rapid roll out of zero emission vehicles (ZEV) in the road heavy transport sector. Currently, trucks and buses together make about 27% of the EU road transport emissions and trucks make up more than three quarters those. The proposal of the Commission for the revision of HDV CO2 standards falls short to align the CO2 targets for the sector with the EU’s overall -55% GHG reduction target in 2030 and the climate neutrality target of 2050.

In order to transition the road freight sector to zero emission, more ambitious standards are needed to set the right pace and a clear trajectory for manufacturers, logistics operators as well as for the supply chains in the electromobility and automotive industry. Scaling effects in production and technology development in the e-mobility and transport sector contribute to making electric HDVs more competitive and widespread.

Uniting ambitious green supply-side policy making with investments into cleantech industries, as done with the Net Zero Industrial Act, allows Europe to remain a climate leader whilst paving the way for thriving industries. The Platform calls on the European Parliament and Member States to notably strengthen the targets of the HDV CO2 standards, reducing emission, air pollution levels and setting pace for a greening road transport sector.

     The ambitious charging infrastructure targets as finally adopted in the AFIR enabler a successful rollout of ZEVs. Additional private as well as public investments are needed to ensure higher grid capacity to serve the growing trucks and buses charging demand. The revenues from excess emission premiums should be channeled back into the sector for the roll out of the infrastructure network.

Investing in reskilling of workers is essential for both, those currently employed in the HDV manufacturing and therefore see a conversion of current skills, and new ones who will be increasingly specialized in new production value-chain. It can reduce social risk and increase labour resiliency. Other measures such as job-search assistance to jobseekers and income and early retirement support could make the transition more “just”.

The positive effects of electrifying trucks and buses are far-reaching and go beyond reducing Europe’s GHG emissions – accelerating the zero emission HDVs roll out also allows to drastically improve noise and air pollution. The high increase of energy efficiency in the case of BETs is particularly beneficial when road transport accounts for 29% of the EU’s final energy consumption[1]. The Platform for electromobility also wants to highlight that the transition to electric trucks and buses is a considerable opportunity for the European e-mobility value chain and the competitiveness of the economy. Ambitious targets would make Europe a leader in zero emission HDVs and thus further unlock the potential of the e-mobility value chain.


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Weight & Dimensions Directive: the hidden milestone for e-trucks

Six points to make the Weights & Dimensions Directive
better incentivize zero emission trucks and buses

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The Heavy Duty Vehicle (HDV) segment needs to accelerate its decarbonisation. In 2022, battery electric heavy trucks made up only 0.6% of new truck registrations in Europe. Diesel  represented 96.6%[1].

Buses are decarbonising much faster, as new urban bus sales in 2022 saw a higher share of zero emission vehicles – 30%. Diesel buses represented 67.3% of the new sales in Europe[2].

While the CO2 standards for trucks and buses are important in setting decarbonization targets for the HDV sector, they will not solve the issue of incentivizing Zero Emission (ZE) trucks and buses.

ZE trucks will be able to benefit from mandatory toll discounts under the Eurovignette directive and the expansion of ETS to road transport. Currently, ZE trucks benefit from a minimum tax on diesel, and a weight allowance of 2 tonnes more than a diesel truck. As zero emission vehicles weigh more than diesel-powered vehicles due e.g. to the battery weight, the additional weight allowance is a must-have measure for decarbonizing the HDV segment.

Even though the additional weight allowance of 2 tonnes is a good starting point, there are additional measures that can help the uptake of ZEHDVs, which has so far been limited. The proposed revision of the Weights & Dimensions Directive (WDD) provides an excellent opportunity for non-monetary incentives for zero emission trucks and buses in Europe. The European Commission should focus on the following measures:

  • Implement clear cross-border rules
  • Modify the methodology governing the additional weight allowance
  • For long-range ZE trucks, permit one further tonne, linked to range, to a max of 3t
  • Allow ZEHDVs a time-limited increase in the maximum authorised drive axle weight
  • European Modular System (EMS) should be zero-emission by 2028
  • Set explicit time limits for WDD transposition and type-approval

  • Implement clear cross-border rules

As it stands now, the WDD enables the additional weight allowance only at border crossings of 13 EU Member States as the weight allowance only applies at borders of countries that have the lowest authorised vehicle weight. Furthermore, it does not provide an incentive for ZE HDV activities at the national level.

The current WDD has led to disputes between Member States on the allowed weight of HDVs on border crossings. In order to avoid any new disputes and remove the existing ones, the EC should develop rules that apply to the entire EU and not to selected border crossings.

The Benelux countries have done exactly that in 2022[3]. Although Benelux countries have different authorised weight allowances, when freight vehicles cross borders, the lowest weight limit in both countries is applicable. And for zero-emission vehicles, the additional weight allowance is automatically added.

Therefore, the European Commission should expand the scope of the WDD and clearly define that:

  1. The lowest authorised weight limit at border crossings is equal to the lowest authorised weight limit between two adjoining Member States;
  2. That the additional weight allowance for ZE HDVs is automatically added to the lower authorised weight limit;
  3. The additional weight allowance applies also for national transport.
  • Modify the methodology governing the additional weight allowance

In practice, the current system requires the vehicle-maker to present a diesel comparator, with up to 2 additional tonnes then allowed above the weight of the comparator vehicle.

This system causes issues for new ZE vehicle-makers, which by definition, don’t have comparator vehicles to reference.

The WDD revision should grant some flexibility to new entrants by saying that the relevant authorities must have due regard to the position of new entrants in the selection and assessment of comparator vehicles.

  • For long-range ZE trucks, permit one further tonne, linked to range, to a max of 3t

Up to ranges of approximately 400km, the additional 2t already granted is sufficient. Beyond this range, however, the allowance should be increased according to greater range provided. We suggest 2.5kg per km of ZE certified range above 400km to a maximum of 3t (i.e. the maximum is reached at 800km).

  • Allow ZEHDVs a time-limited increase in the maximum authorised drive axle weight

The change most sought by truck and bus-makers is an increase in the maximum authorised axle weight placed on the axle connected to the zero emission powertrain, more commonly known as the drive axle. Today the weight limit applied to the drive axle is 11.5t, and due to the higher weight of ZE powertrains (e.g. batteries), truck and bus-makers ask that this limit be raised to 12t. This ask concerns two-axle tractor units and buses in the EU, which are the most-sold configurations.

On the one hand, such a change would boost the pace and scale at which zero-emission trucks and buses are deployed. On the other hand, without safeguards and phase-down dates, it could increase road wear.

Therefore, we advocate considering this change on the basis of a number of safeguards covering:

  1. tyre configuration and maintenance;
  2. the speed at which such vehicles can take off from a stopped position (“acceleration from rest”); and
  3. timeframe, namely that ZE truck & bus-makers can deploy 12t drive axles – under certain conditions – until a certain year (2029 for trucks).

Taking each of these in turn, for a qualifying vehicle, it would be necessary to deploy:


  • On the steer (front) axle, wide base high-efficiency tyres
  • On the drive (rear) axle, dual tyre configuration (assembly) using high-efficiency tyres
  • A Tyre Pressure Monitoring system that alerts the driver to a loss of pressure any greater than 0.5 bar, and with a duty to restore pressure to recommended levels at the nearest available facility having regard to the direction of travel

Acceleration limiter

  • Ensuring take-off-from-rest is between 1 and 1.2m/s2


  • 4×2 ZE trucks registered from entry into force [in ~2026] to 1.1.2029 can carry 12t on the drive axle – once the above conditions are met
  • More flexibility on the end date could be considered for buses (and coaches) given their smaller sales numbers.
  • European Modular System (EMS) should be zero-emission by 2028

There are calls across the trucking sector for more opportunities to use EMS. However, it can only be guaranteed that EMS will reduce emissions if the trucks are ZE. Therefore if proposals are made to permit cross border EMS, it can only be by ZE trucks, and where each route is checked and approved by the relevant authorities for road safety (i.e. that approach roads used to access the highway are suitable for EMS movement) and freight modality (coherence with overall freight policy goals).

  • Set explicit time limits for WDD transposition and type-approval

The WDD does not have a formal time limit for transposing the existing 2 tonnes weight allowance into national law. This needs to be done as soon as possible as the business case for long-range zero emission HDVs depends on clear rules across Member States.

As the previous transposition of weights and dimensions rules to type approval law took four years, it is important to set a stricter deadline. This will enable manufacturers to achieve the recently proposed HDV CO2 reduction targets.

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Critical Raw Materials Act: Reaction paper of the Platform for electromobility

Critical Raw Materials Act :

Reaction paper of the Platform for electromobility

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The European Commission’s proposed Critical Raw Materials Act is a much-needed initiative in today’s world. Demand for critical raw materials (CRMs) will continue to increase, in order to underpin a sustainable transport system in the near future. Indeed, the proposed Act aims to ensure the sustainable supply of those CRMs essential for electric mobility-enabling sectors, electric cars themselves and renewable energy technologies. We particularly welcome the Act’s efforts to balance resilience, security of supply and environmental protection with the new focus on refining and remining, which are crucial steps in producing and securing CRMs. ‘Refining’ refers to the process of purifying raw materials, which can reduce the waste and environmental impact of their extraction. ‘Remining’, meanwhile, involves the extraction of raw materials from the waste or by-products generated during the production process or from legacy mining sites.

Furthermore, the Act also stresses the importance of the responsible extraction and processing of CRMs. This includes promoting the use of new and innovative technologies for reducing the environmental impact of extraction and processing activities. By adopting these measures, the European Union (EU) can lead the way in sustainable mining practices, while also ensuring the ongoing availability of critical raw materials for the production of high-tech products. These measures will also help reduce the dependency of the EU on raw materials sourced from outside its borders, thereby ensuring a stable, sustainable and secure supply of these much-needed CRMs.

For these reasons, the CRMs Act proposed by the European Commission is a generally welcome initiative, one which can help ensure the sustainable supply of critical raw materials. However, the following addition improvements, proposed by all members of the Platform for electromobility, from NGOs to industries, should be considered by co-legislators:


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.

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Strengthening EU’s electromobility ecosystem in the global race.

Strengthening EU’s electromobility ecosystem in the global race.

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The investment in manufacturing technologies required to develop the net-zero, clean technologies and renewable energies is urgently needed at European and global levels. The Platform for electromobility therefore welcomes the ambition shown in the European Commission’s Green Deal Industrial Plan, which is designed to improve a number of European policies in response to the new industrial ‘Inflation Reduction Act’ (IRA) in the United States.

Given the importance of reducing greenhouse gas emissions from the transport sector, and the fact that Europe’s transport systems are part of its critical infrastructure, we believe that mobility industries providing zero-emission vehicles – all transport modes considered – should be considered part of the ‘Clean Tech’ sector. This should also extended in order to include charging stations, software and other EV enabling tech, given their important manufacturing footprint in Europe. This way, it will help anchor the manufacturing facilities for EV chargers on our continent.

An effective European response should go further than the IRA, and rapidly ensure the resilience of European industries against a backdrop of growing geoeconomic challenges. These have already seen both the United States and China invest heavily to try to secure the control of the electric mobility industrial value-chain.

Together, the IRA and the Made in China 2025 (MIC) plan should be treated as a wake-up call and a trigger for a robust European response. Indeed, Europe needs a holistic and long-term strategy that sets out the specific financial and regulatory support to address all the global current and future challenges. This should be capable of securing an EU-built industrial ecosystem of sustainable transport, and should ensure bespoke strategic autonomy for each key sector identified.

Importantly, the EU response should be prepared with care, in order to avoid provoking a global subsidy race. The goal should be to create an international level playing field between all economies, aimed at reaching Paris Agreement climate targets (COP21) together.

Disregarding trans-Atlantic subsidies schemes, the European industrial strategy should define a long term-strategic ambition which, as a priority, should support the zero-emissions mobility, along its entire value chain and through all sustainable transport modes.

The Platform for electromobility is willing to bring its expertise and ecosystem perspective to the democratic debate by drafting detailed proposals that would lead way to a) short-term non-financial measures, such as regulatory certainty, bureaucratic delays, energy taxation, European research and shipment rules; b) State Aid rules and European Sovereignty Fund; and c) financial support.

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Where the Critical Raw Material Act should critically act

Where the Critical Raw Material Act should critically act

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The vital transition away from fossil fuels to cleaner technologies such as electric transportation – cars, trucks, buses, trains and public transport – will drive the demand for raw materials. Lithium, nickel, copper and cobalt will all be required in varying amounts depending on the technologies and applications.

Whilst certain Critical Raw Materials (CRMs) are accessible on the EU territory, Europe remains largely dependent on third countries for mining, processing, refining and recycling. This dependency has been accentuated by current geopolitical events and supply chain tensions, which have led to volatility, increasing prices and uncertainties over global supply. For this reason, we strongly welcome the principle of today’s Commission’s CRM Act, and we will shortly publish a detailed assessment from the perspective of the electromobility ecosystem.

Three clear flaws for Europe on CRMs

In light of the urgently required transition to e-mobility, and the need to ramp up a domestic Electric Vehicle (EV) value chain in Europe, there is a clear flaw; the EU is primarily deficient in domestic capacity beyond that of battery manufacturing. It lacks access to resources to extract, and – critically – the capacity to refine and process, as well as to recycle. Such processes are still undertaken almost entirely in resource-rich, more experienced and more competitive third countries. This is endangering both Europe’s autonomy in CRMs and the respect of the upmost environmental standards.

It is therefore vital that Europe builds its own processing and refining capacity for battery materials, using existing domestic sources of valuable materials. Europe must also increase its recycling capability and competitiveness in order to reduce the EU’s dependence on primary raw materials.

The second flaw is the excessive hurdles to the permitting. In particular, the range of mining codes that exist in Europe creates incoherence and differences in the levels of ambition between Member States, which in some cases may threaten safeguards to social and/or environmental protection. The processes for granting permits becomes excessively lengthy when multiple permits are needed for both renewable energy production and for sustainable mineral extraction projects.

The third flaw is the limited availability of sustainably sourced, highest quality materials, in no small part due to incomplete and limited mapping of geological and remining potentials. There are also barriers to the reuse and repurposing of EV parts, which could extend the lifespan of CRMs prior to recycling, thereby reducing the overall demand for CRMs. Member States lack the expert capacity to ensure the efficient, robust and timely evaluation of Environmental Impact Assessments and Area Assessments.

Consequently, the Platform for electromobility wishes to highlight the need for the EU’s Critical Raw Materials Act (the Act) to consider to the following 12 areas:

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Ten truths about electric trucks and buses

Lice-cycle GHG emissions

Battery electric trucks have the lowest life-cycle GHG emissions

This is true from 16-40t trucks, according to a study by Ricardo Research (2020), which compared emissions of the differing drivetrain technologies based on a WTW approach. The emission-saving potential of electric vehicles (EVs) increase when entirely powered by renewable energy (up to 81%) compared to a fossil-powered alternative as shown by study ICCT (2021) undertaken in passenger cars. As battery-eletric trucks (BETs) have outstanding energy efficiency, lifecycle emissions decrease with every additional kilometre driven, meaning that long-distance trucks have particularly high emission-saving potential.

Ricardo Research (2020)IICCT (2021)
Traffic jam
car energy efficiency
Energy efficiency

Battery electric trucks offer a dramatic improvement of energy efficiency

BETs offer a dramatic improvement of energy efficiency, i.e. the ability to drive a greater number of kilometres on the same amount of energy. The JRC, EUCAR and Concawe (2020) have updated their joint evaluation of the WTW energy use and Greenhouse gas (GHG) emissions for a wide range of powertrain options. Considering only zero-emission technologies on Wheel-to-Well (WTW) basis, BETs using green electricity - both regional and long-haul - are 2.6 times more energy efficient than the green hydrogen-powered fuel cell equivalent. Although synthetic fuels were evaluated for cars rather than trucks, as an indication a battery electric car using green electricity is 6.9 times more energy efficient than a combustion vehicle using e-fuel.

JRC, EUCAR and Concawe (2020)

GHGs and air pollutant

Battery electric buses do not produce local GHGs and air pollutant emissions

Battery-electric buses (BEBs) do not produce local GHGs and air pollutant emissions, providing considerable health benefits, particularly in cities. Because they are powered by electricity, the higher powertrain efficiency means that BEBs emit 73% less CO2 equivalent than diesels, rising to 90% if powered by 100% renewable sources. In contrast (according to ICCT (2022)),Compressed Natural Gas (CNG) CO2 emissions are nearly 30% lower than a diesel, but its higher energy consumption - 24-50% per kilometre - reduces this advantage. In addition, methane is a potent GHG with a global warming potential more than 80 times greater than CO2 over a 20-year period; unintended leakages during extraction and transport further exacerbate the situation.

ICCT (2022)
bus in charge
canal amsterdam

BETs will contribute to the further greening of intermodal transport

BETs will contribute to the further greening of intermodal transport, as well as improving the overall energy efficiency of freight logistics. Synergies between rail, road transport and inland waterways are crucial to the logistics system. These offer benefits for the whole supply chain, as intermodal transport helps reduce congestion in urban areas while potentially increasing capacity in and around cities. Tangible examples of intermodal links have been successfully deployed in Paris’ metropolitan area. Companies such as IKEA and Franprix supply stores in Paris are using a combination of electric ships and electric road transport solutions for the last-mile segment.

Electricity grid

With smart grid technologies, the grid would need little adaptation for BETs and BEBs.

With smart grid technologies, the grid would need little adaptation for BETs and BEBs. Uni- and bi-directional charging enables a double optimization of the load at the depot. Optimising the grid connection and allowing the monetisation of the vehicles' flexibility capabilities makes them valuable assets, even when parked: it also provides the grid with supplementary battery capacity. Vehicle-to-grid (V2G) is performed at much lower power levels than in regenerative braking or fast charging.

battery storage
truck manager

By 2030, 99.6% of new BETs will be cheaper to own and run than diesel trucks

By 2030, 99.6% of new BETs will be cheaper to own and run than diesel trucks while carrying the same weight of goods over the same distance and journey time, according to a study by TNO (2022). This study is based on the total cost of ownership (TCO), the most important economic indicator for a truck. It covers those deployed in urban and regional delivery over distances of 300 km as well as long-distance trucks travelling 800km/day. Due to the savings from using electricity rather than diesel, the cost-saving potential of BETs increases with every additional kilometre driven, meaning that by 2035, long-distance trucks will be the most cost-efficient solution in Europe.

study by TNO (2022)

Investment costs of battery elecric buses

Higher investment costs of BEBs offset by lower electricity consumption and maintenance costs.

Similarly, the higher investment costs of BEBs are offset by their lower electricity consumption and maintenance costs (in Spain and Latin America in 2021 and in Italy, US and UK by 2023). Bocconi University and Enel Foundation (2021) integrated well-known TCO (the initial investment in purchasing vehicles and the charging infrastructure, plus the operational and maintenance costs) with peculiar to BEBs circular economy revenue streams, by the second life of batteries and V2G. This explains why buses are now the fastest-growing zero-emission vehicle segment, making up 23% of new city buses in 2021, up from 16% in 2020. Considering the revenues from V2G and second life, BEBs are more cost effective than diesel and CNG buses.

Bocconi University and Enel Foundation (2021)

Urban and regional trucks can already have as much payload capacity as their diesel counterparts

Urban and regional trucks can already have as much payload capacity as their diesel counterparts today, according to a recent study by TNO. While the battery of an electric long-haul truck currently may weigh several tonnes, depending on its size, the so-called 'ZEV weight allowance' grants an additional two tonnes to zero emission trucks on European roads. This, along with improving vehicle energy efficiency and battery energy density, will eliminate any payload loss by the end of the decade, even for long-distance trucks with 800km range.

TNO (2022)


BETs already have more than sufficient range to cover freight transport routes in Europe

BETs already have more than sufficient range to cover freight transport routes in Europe, something that will continue to improve. With the compulsory 45-minute break every 4.5 hours, and given that they have a maximum permitted speed of 90km/h, trucks will never drive more than 400 km without having to stop. Tesla has begun deliveries of the ‘Tesla Semi’, a clean-sheet design BET with a real-world range of 800km when fully loaded. The EU’s Weights & Dimensions Directive allows ZETs to be increased by two tonnes over that of diesel trucks. This allowance alone already increases the payload-neutral range of electric trucks by over 300km.

road landscape europe
truck in snow
Extreme conditions

BETs are as competent as diesel trucks in extreme cold.

BETs are as competent as diesel trucks in extreme cold. In February 2021, Volvo Trucks, ABB and Vattenfall - together with a local mining company - ran a trial on replacing the diesel transport of iron ore with BETs. The ore is taken from a North Sweden mine to the railway transfer station, in temperatures of -30C°. The BETs were used for the journey from the mine to the transfer station where they could unload the cargo while recharging batteries following a 280km round trip normally undertaken by diesel-powered vehicles. The Polar Winter Project proved the feasibility of electric transportation in extreme conditions. The BETs were able to drive the entire distance - including 140km with 14t of ore on board, at temperatures as low as -32C° - while taking the same amount of time as the diesel trucks.

BET       Battery Electric Truck

GHG      Greenhouse Gas

EV         Electric Vehicle

WTW    Wheel-to-Well

BEB       Battery Electric Bus

CNG      Compressed Natural Gas

V2G       Vehicle-to-Grid

HDV      Heavy-Duty Vehicle

LFP        Lithium iron phosphate

TCO       Total Cost of Ownership

ZEV       Zero-Emission Vehicle

ZET        Zero-Emission Truck

JRC        Joint Research Center

EPBD: 3 Pillars to ensure the private charging of EVs

3 Pillars to ensure the private charging of EVs

As 90% of all charging takes place at home or in the workplace and 80% of the EU’s current building stock will still be in use by 2050, private charging is key to the growth of electromobility. Only an ambitious revision of the EPBD (Art. 12) can make it happen.

Importance of private charging
for multifamily dwellings


If a building is not pre-cabled in the construction or major renovation phase, it can be 9 times more expensive to install cables in the latter stage. It'd lead to highly cumbersome discussions with project developers which can take over 6 months in problematic cases to install a charging station. The pre-cabling should cover both technical and electrical installations for the seamless future installation of recharging points.

for users and grid

Smart functionalities

Smart charging (uni- and bi-directional) can reduce one-third of the EV users' electricity bill. Moreover, it would facilitate the integration of the renewable energies into the grid, reduce the electricity consumption during peak hours and provide flexibility services to the system.

For existing buildings


Those advantages would not be reached without removing administrative barriers to installing a charging station, especially the delays in multifamily buildings. Time between application and installation should not exceed 3 months.

EU Year of skills: making the Green Deal works for everyone

EU Year of Skills
Our recommendations to make Green Deal works for everyone

A 2021 study undertaken by the BCG looked into the opportunities and challenges  created by the transition of the automotive industry towards electrification. The study shows that shift to EVs will have only a minor net impact on jobs through to 2030.

The relatively small net impact should not, however, obscure the massive structural changes resulting from electrification. Changes in production will modify both the skills requirements and distribution of labour. Over the next decade, direct employment in carmakers and ICE-focused suppliers will decrease by 5%, while the workforce in adjacent industries’ will increase by 34%. On top of this large transfer from core automotive industries to adjacent industries, a further 40k jobs will be created each year in construction and civil works for adapting energy production and distribution infrastructures needed for electrification.

By 2030, the job profile of 2.4mn positions will change, with different degrees of training needs to prepare them for future job demands, which means 42% of all employees in the core automotive and adjacent industries will have dedicated training needs. Specifically, 1.6mnwill require retraining, while remaining in their current position; another 610k will need requalification while remaining in the same industry cluster; and 225k people will need support to requalify for work in other industries outside the automotive ecosystem. Some regions – those more dependent on the traditional automotive sector – will feel this impact more acutely, so it is vital that governments provide policies and support to help those regions adapt to the coming change.

The right political and regulatory choices will help workers fully grab the upskilling opportunity created by the transition to electromobility. To support workers during this transition: the EU, governments and companies should prioritise programmes that invest in the education, training, upskilling and reskilling of the labour force to capitalise on new opportunities, raising the bar on employment conditions, to ensure no one is left behind.

The social changes triggered by the Fit for 55 should be tackled with similar levels of ambition by empowering companies, governments and regional authorities to equip the workforce with new skillsets.

Workers in the automotive sector should benefit from a policy framework similar to the Just Transition Fund, Just Transition Platform and Just Transition Mechanism for the energy-intensive industries and assist industrial stakeholders, local, regional and national authorities to:

For industrial stakeholders, support will be needed to design requalification and upskilling programmes and hiring as well as restructuring programmes. Rapid growth of adjacent industries (like battery manufacturing and charging stations operations and production) should be underpinned by ambitious requalification and upskilling and targets. Support should be provided, particularly for SMEs and fast-growing enterprises, as they will lack the analytics and training resources of bigger companies.

Relocations should be avoided where possible by adapting existing production plants, and training for new skills where they are needed. Via their industrial, attractiveness and educations competences, local and regional authorities will play a key role in addressing the knowledge gaps in the workforce. The new ESF+ should be an instrument for supporting local and regional authorities.

Governments need to perform ‘whole-of-economy’ workforce planning in close cooperation with regional and local authorities and industrial stakeholders to:

  • Help employers and employees manage their transitions.
  • Tailor educational curricula towards new automotive technologies.
  • Build new career and employment platforms to help workers navigate to jobs and training opportunities.
  • Increase student seats at universities in new automotive technologies and production/process engineering.

Critical Raw Materials Act: Our response to the EC's consultation.

Critical Raw Materials Act
Our feedbacks to the European Commission

The vital transition away from fossil fuels towards cleaner technologies for transport  will drive, depending on the technology, the demand for raw materials like lithium, nickel. Whilst some CRMs are available in the EU, Europe is largely dependent on third countries for mining, processing, refining and recycling, even more so in the case of batteries needed for EVs and considering the current geostrategic tensions. We would therefore strongly welcome a CRM package beginning of 2023 to tackle our three concerns:

With the e-mobility transition, the EU is lacking an EV value chain beyond battery manufacturing – i.e. extraction, refining, processing, and recycling, which today is located in third countries – and a coherent approach of using existing EU sources of battery materials.

Hurdles to permitting is due to a) the plurality of mining codes in Europe bringing different levels of ambition and lack of coherence across Member States. This leads to, in some cases, not having any safeguards in relation to social or environmental protection; b) lengthy permitting processes when multiple permits are required for both renewable energy production and sustainable mineral extraction projects; c) lack of expert capacity to ensure the efficient, robust and timely evaluation of Environmental Impact Assessments and Area Assessments.

Limited amounts of sustainably sourced materials, notably due to limited geological mapping of available resources. Barriers also exist to the reuse and repurposing of EV parts that could extend the lifecycle of CRMs before recycling.

Critical Raw Materials Act should therefore:

Include a single strategy on raw materials that defines expected needs, challenges, priorities and key lines of action with specific objectives of reducing the need of primary CRMs, with efficient reuse and recycle.

Assess the need of stockpiling mechanisms.

Provide financial, political support (e.g. tax reductions) to economic actors meeting the highest existing environmental and social standards. For EU-sourced material, the initiative would then work in relation with the package of environmental policies that control impacts from its domestic mining and refining operations and the high EU social standards.

Incentivise keeping valuable battery material in Europe, available for domestic recyclers, justifying their investments in EU today and incentivise the recycling of production scrap and blackmass/BAMM in EU.

Ensure the sustainability of CRMs by addressing adverse environmental and social impacts of their production or recycling. For imports, supply should come from responsible sources with robust certification, due diligence rules setting legal requirements for suppliers to control risk across their supply chains.

Support geological surveys to determine accessibility of domestic resources, including waste.

Mandate specific marking for any product containing CRMs to facilitate their recovery and recycling.

Streamline robust permitting processes without undermining existing environmental laws and in compliance of ESG criteria.

Support permitting authorities with additional expert capacities.

Digitalize permitting processes to ensure transparency and full engagement from project developers to local communities.

Support financially the development of recycling capacities as all recycling activities are not financially viable today due to the low cost of some primary resources. Support for the development of recycling capacities is indeed crucial to the circularity and sustainability aspect of CRM sourcing.

 Ensure consistency across different pieces of legislation – notably the proposed lithium salts classification – and make sense of the needs of the CRM demand sector.

Give the ERMAlliance the overall view of EU levers and make it a driving force behind the implementation of the strategy.