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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

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

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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 21^st 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.

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.

Our manifesto | 2024-2029: Five Years to Make the E-mobility Transition a Success

Five steps towards a 360° e-mobility industry strategy

EU Industrial Strategy

Our recommendations for a “Green Deal Industrial Plan”

Any “Green Deal Industrial Plan” would not be complete without a strong chapter on the electromobilities manufacturing ecosystem.

https://www.platformelectromobility.eu/wp-content/uploads/2024/07/For-a-360-degrees-EU-industrial-strategy-for-emobility-1.mp4

In the context of the forthcoming EU legislative mandate, the Platform for electromobility endorses the overall shift in European policy priorities set by the European Green Deal as a welcome long-term compass. Recent institutional declarations[1] aligned with Platform’s EU Election Manifesto[2] support the development of a robust industrial policy. This is essential to ensure Europe’s competitiveness, resilience in a rapidly evolving global landscape, and maintain its leadership in climate change mitigation. Any “Green Deal Industrial Plan” would not be complete without a strong chapter on the electromobilities manufacturing ecosystem. To achieve these goals, we propose a multifaceted approach that considers the entire value chain’s competitiveness in green transport solutions while revitalizing their financial support. Such policies must be implemented within a framework of regulatory stability and close international cooperation with other regions.

We will set out these proposals below under 5 headings:

Ensuring regulatory stability for industries and investors
Enhancing value chain competitiveness and resilience
Financing the transition in the short term: the “low hanging fruits”
Financing the transition in the long term: Net Zero Investment Plan
Strengthening international cooperation

We welcome questions and cooperation with the Platform for Electromobility on our proposals.

1. Ensuring regulatory stability for industries and investors

A stable regulatory system is crucial. Attracting investment to create the net-zero industrial ecosystem for electromobility will be facilitated by maintaining a consistent, clear regulatory framework and climate objectives. This means first and foremost ensuring that the European Green Deal legislations as voted in the 2019-2024 mandate remain steady over time. We strongly warn against disruption of the Green Deal and their long-term planning notably by limiting the scope of major reviews. At a more granular level, we call for stability in the regulatory frameworks of all transport modes. It is a key element for successful risk management. A consistent, clear regulatory framework secondly means performing sound impact assessments before proposing new legislation. Potential legislations should be in line with the direction taken by the Green Deal as voted during this mandate. Thirdly, regulatory stability means focus on proper implementation through the swift adoption of all necessary complementary acts In a nutshell, implementing before reviewing.

2. Enhancing value chain competitiveness and resilience

a. A 360° e-mobility industry strategy

While recent European industrial policy initiatives, such as the Net Zero Industry Act (NZIA), have focused on key components and sub-systems[1], we have observed that an emphasis and consideration of full value chain competitiveness is lacking. It is crucial that these policies take into account the comprehensive nature of mobility industry value chains across sectors and support their global competitiveness as they navigate the green transitions. We call for a 360° e-mobility industry strategy, widening the focus from specific components to a more comprehensive approach, spanning from raw materials to end products and from individual to all modes of sustainable transportation.

B. Upstream and downstream

While the presence of gigafactories is fundamental for the development of green industries in Europe, with production capacity on some parts of the value chain (so far mostly focused on end products), it is important to highlight that they alone do not guarantee a competitive and non-dependant industry[2]. Indeed future industrial policy should go beyond the end-product and also consider upstream (refining) and downstream (recycling), both sectors being, so far, not located in Europe. A European industrial network of innovative companies from all sizes would help securing all stages of e-mobility value chains for the manufacturing and recycling of key components. The EU should channel purchases toward “made in Europe” products and increase production chains within Europe. Given the high demand for strategic raw material to manufacture electric vehicles, securing the value chains also includes a strong focus on security of supply of such materials and other available alternative technologies, as well as the recyclability of engines and batteries. The creation of new industrial hubs in Europe should go hand-in-hand with this strategy.

c. Energy-cost efficient strategy

Energy costs play an integral part of manufacturing competitive transport solutions. The availability of affordable, decarbonised energy is paramount to maintaining Europe’s competitiveness in the global low-carbon technology competition. We ask policymakers to work urgently on mitigating electricity prices disparities between the Union, China and the US, which are severely disadvantaging EU manufacturers. We endorse other calls[3] for the introduction of incentives that reward low-carbon technology producers favouring local materials and components.

d. Public procurement driven sectors

Similarly, for mobility sectors where investment decisions are predominantly the responsibility of public authorities, such as rail, the relevant EU legal framework must be properly enforced. That starts with public procurement, ensuring that tender evaluation criteria set the right focus on the sustainability of the selected solutions but also include all available tools to ensure fair competition, such as the foreign subsidy regulation. We strongly support the NZIA’s non-price criteria proposal in public procurement supporting sustainable development and resilient European industries. Those criteria will help favour European industries in public auctions and ultimately promote technologies produced in Europe.

e. Accompany workers and employers in skills transition

Industrial sectors must be supported in their skills development and employment policies for a successful decarbonisation of its values chains. For this purpose, EU institutions and Member States should undertake a mapping of skills shortages. This should consider both traditional and new skills. That way, we can assess the needs for jobs and skills in each sector, developing tools to identify and publicise available training, and highlight those that need to be created. Based on the identified needs, measures should be undertaken by the EU – such as NZIA’s initiative for “Net-Zero Academy” – and the Member States to support existing training structures in Member States as well as to ensure that the trainings are conducted by practitioners from companies.

3. Financing the transition in the short term: The “low hanging fruits”

Existing EU funds can already serve as valuable assets if they are distributed efficiently and intelligently, notably by streamlining access to finance, particularly for net-zero industries, through instruments such as the Innovation Fund and InvestEU. To do so, we have identified five “low-hanging fruits” measures that can be taken without further delay:

Low hanging fruit 1: Guarantees. As a matter of priority, public investment tools should crowd in private investments by increasingly making use of instruments like guarantees. Firstly, the InvestEU Fund should be further mobilised in support of a 360° e-mobility industry strategy. Secondly, the European Investment Bank (EIB) Group should strengthen the provision of commercial bank guarantees for investments by companies across the EV value chain, replicating the recently announced €5 billion guarantee facility for the wind sector[1].

Low hanging fruit 2: Innovation Fund. We welcome the recent initiative under the Innovation Fund to dedicate €3 billion to the EV battery value chain. This new mechanism needs to focus on the most sustainable EU battery and components manufacturers[2]. A robust mechanism needs to be built, including for channelling increased funding from Member States to match EU funding.

Low hanging fruit 3: Capacity building. To enhance accessibility, we propose that EU or national administrations train and appoints specific staff to provide advisory services to both applicants and national authorities responsible for distributing EU funds. A substantial portion of these funds, especially in the case of Recovery funding, may remain unallocated due to the constrained administrative capacity of Member States[3] to prepare projects or process applications. Supporting project preparation and speeding up authorization procedures at the national level would thus benefit both the applicants and the authorities involved.

Low hanging fruit 4: Mid-term MFF revision. The mid-term revision of the MFF is the opportunity for European institutions and Member States to significantly raise funds of strategic programmes (STEP but also CEF) to provide appropriate financing instruments to support a competitive decarbonisation of the EU industry and support investments in clean, sustainable mobility solutions.

3. Financing the transition in the long term: Net Zero Investment Plan

a. Why a Net Zero Investment Plan now?

The climate investment gap is deepening by the day and the way to fill the gap will be a major challenge for decision-makers in the coming years. European elections are the democratic the window of opportunity to set priorities about where EU funds should flow and the level of support that EU will provide to shift the continent to clean mobility. 2024 is thus a milestone year for the green transition. The STEP platform is, although welcomed, unfortunately far from the pan-European response to global competition on cleantech that the EU needs. Therefore, we support the creation of a major Net-Zero Investment Plan after the EU elections.

b. Predictable and upfront support for op-ex

The EU should ensure that financial instruments do not exclusively prioritise innovation but also consider the importance of providing strategic support for operating expenses and production, for a limited duration. We highlight the fact that operational expenses (op-ex) are not covered by the current InvestEU funding framework. This means that in addition to promoting innovation, financial support should be directed towards sustaining and optimizing day-to-day operations and the production processes of net-zero industries, thereby creating a more balanced approach to funding allocation. Beyond deciding the level of support that will be provided to the green and digital transition of the transport sectors, upfront predictability and certainty about possible funding should also be provided. A rulebook for financing should make sure op-ex support is both predictable and upfront.

c. Consider ventures with higher risk profiles

To complement this new approach and move closer to a truly comprehensive funding allocation, it’s essential to also consider ventures with higher risk profiles. For instance, when it comes to the Alternative Fuels Infrastructure Fund, the current financing terms are notably stringent. These terms often exclude high-risk endeavours, as they require a minimum of 50% funding from national banks or partners, effectively limiting opportunities for investment in riskier projects. This, in turn, disproportionately affects emerging industries and initiatives in Central and Eastern Europe. To address this issue, the European Investment Bank (EIB) should explore investments in riskier ventures, and InvestEU should be equipped to provide loans and equity for such undertakings. The InvestEU Program, designed to offer guarantees to both public and private banks, can play a pivotal role in enabling them to take more substantial risks in their lending and equity operations. This approach can facilitate the inclusion of ‘investments in riskier ventures’ and contribute to a more diverse and dynamic investment landscape.

d. How to finance a Net Zero Investment Plan?

This Net-Zero Investment Plan should be structured under the EU Multi Financial Framework on the one hand, and via new bond issuance programme replacing the Next Generation EU programme on the other hand. In addition, this broader investment plan should ensure that sufficient European and national funding resources, leveraging private sector investment, are available to achieve Europe’s objectives as set in the Climate Law and in the Smart and Sustainable Mobility Strategy. On top of the achievement of dedicated programs such as the TEN-T, it should include a dedicated Green Industry fund. State Aid measures should be re-designed and local supports coordinated at EU level to ensure a level playing field at European level,. The future State Aid regime should mandate EU governments to integrate environmental and social considerations to their support schemes, so that only best-in-class projects benefit from public support at regional and national level.

5. Strengthening international cooperation

Stability also requires robust international cooperation. Strengthening ties with diverse regions would diversify sources, reduce geopolitical risks and uncertainties, ensure a secure supply chain, enhance global industrial collaborations, and uphold a fair competitive environment for all clean transport industries.

Proactively setting a Level Playing Field

The EU response to other regions’ recent green industry support program should be prepared with care, 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 and aligned on WTO rules. For certain industries, level playing field can only be reached by matching competitors’ support: for examples, for battery manufacturing, the US IRA provides a significant op-ex support per kWh produced; for reskilling workers, massive support for training automotive workers is proposed. We call for EU policymakers to match such support in some manner to help its European battery industry compete on more equal terms. Without such matching, there can be no global level-playing-field for e-mobility related manufacturing.

Cooperation to avoid trade disruption

With several studies by the OECD[1] highlighting the challenges faced by European railway producers in the Chinese market, as well as the public assistance received by their companies, the question of China’s undisclosed subsidies benefiting its products is not new for the railway industry. Cooperations should be reinforced to ensure there are no such practices risking unbalancing global competition.

Cooperation to diversify sources

Dependence on one single third country for green transport technologies is tangible^[2] and should also be mitigated. China dominates the production of solar panels, batteries for EVs and part of the world trade in wind turbines. To diversify sources, we support proposals to form a green technology partnership between governments and businesses of the major economic powers to reduce strategic dependencies. Such partnership would be intended to complement, not replace, existing supply chain. Beyond cooperation with third countries, cooperation should also be within European countries and industrial partnerships to multiply joint purchases and thus secure supply of strategic raw materials at advantageous prices.

[1] President von der Leyen’s State of the Union, European Commission’s Work Programme. Executive Vice President Sefcovic’s speech at Environment Council. [2] “2024-2029: Five years to make e-mobility transition a success”, Platform for electromobility, September 2023.

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[1] A "sub-system" refers to a specialized and interconnected set of components that collectively perform a specific function within the overall system.

[2] “How to Meet the Industrial Challenge of Electric Mobility in France and in Europe?”, Notes de l’Ifri, Ifri, November 2023.

[3] “Call for EU Clean Industrial Deal and urgent actions to keep Europe in the world’s clean technology race”, Eurofer, October 2023.

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[1] Press Release, EIB, December 2023

[2] Press Release, European Commission, December 2023

[3] “How Europe should answer the US Inflation Reduction Act”, Bruegel, February 2023

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[1] “Measuring distortions in international markets: The rolling-stock value chain”, OECD, February 2023

[2] “De-risking and decarbonising: a green tech partnership to reduce reliance on China”, Bruegel, October 2023.

Our five recommendations to CO2 Standards for trucks and buses trilogue negotiators

CO2 Standards for HDVs
Our recommendations to trilogue negotiators

The members of the Platform for Electromobility welcome the position adopted in November by the European Parliament on the revision of the CO2 Standards for trucks and buses Regulation. Welcomed overall, the text provides a robust and ambitious yet realistic and business-friendly path toward decarbonisation of road transport in Europe. Ahead of trilogue negotiations, we hereby highlight key elements that negotiators should keep in mind to safeguard the Regulation’s added value

First and foremost, we urge negotiators to reach a conclusion before March 2024 to avoid losing one year in our collective fight against climate change. Considering the deadline of the text, a late agreement would delay its application by a full year, hence jeopardising our joint effort to reduce CO2 emissions and reach net-zero society in 2050. A timely resolution is paramount to providing certainty to the truck and bus industries, its customers as well as adjacent infrastructures and energy industries, enabling them to plan and invest in the necessary innovations for compliance.

Industrial certainty and environmental progress are also jeopardised by a potential loophole that could open the way for unrealistic use and expectation of e-fuels and biofuels. Both alternative fuels solutions are inherently inefficient[1] and should remain out of the CO2 standards. Renewable and low carbon fuels and, most notably, e-fuels will not be carbon-neutral in time to decarbonize the road transport sector and meet our climate targets, and as a result should be limited where direct electrification is not feasible, namely in maritime and aviation sectors. These fuels are scarce resources sorely needed to reduce greenhouse gas emissions in the aviation and shipping sectors, whereas the road transport sector is well-suited for electrification. They do not provide a viable alternative to existing zero-emission solutions. In addition, e-fuels aren’t currently produced at commercial volumes. Scaling up additional renewables, electrolysers, direct air capture (DAC) and e-fuel production facilities would take time and larger e-fuel quantities would likely not be available before 2040.

Thirdly, considering that in 2022 30% of new buses in Europe were already zero emission, an urged confirmation of the 100% Zero Emission mandate target at 2030 for urban buses, with no postponements, is an optimal option, notably with the move of the two subcategories of urban buses, namely class II low-entry (i.e. 31L2 and 33L2) into the coach segment, as they are often used by local and regional authorities for longer distance public transportation. While reducing the CO2 emissions of those groups of vehicles, this choice would also bring substantial public health benefits by lowering the amount of particulate matters (PM) emitted.

Fourthly, we praise the European Parliament’s extension of the emission debts and crediting system from 2030 to 2040 gives additional flexibility to manufacturers to earn credits (when reducing emissions more than required) and use them to offset debts (if emissions are above what is required). Credits now can be used for 15 years to offset debts. Credit’s lifetime should have a maximum of 5 years as do the debts. This would force manufacturers to continuously invest in reducing their CO2 emissions. This mechanism is pivotal in encouraging industry players to adopt sustainable practices and contribute meaningfully to the reduction of greenhouse gas emissions.

Platform members also recognise the positive impact a fleet mandate mechanism would have on the decarbonation of heavy-duty vehicles. On this point, Platform members equally stress the importance of support mechanisms for the rollout of office-based charging, from subsidies to tax discounts.

With a timely conclusion, unequivocal standards without place for questionable alternative fuels, the strongest ambition on decarbonization of urban buses, an ambitious definition of zero-emission heavy-duty vehicles and fit-for-purpose emission debts and crediting system, the CO2 Standards for trucks and buses would truly be the regulatory framework that promotes sustainability, innovation, and the accelerated adoption of zero-emissions road transport.

[1] Estimates indicate that the electricity requirements for the production, transportation, and distribution of various e-fuel types are significantly higher, ranging from approximately 1.6-1.8 times greater for compressed gaseous hydrogen to between 2.2 and 6.7 times higher for liquid e-fuels, in comparison to the direct use of electricity, depending on the specific fuel type. When we account for not just the fuel production phase but also the efficiency losses within the vehicle powertrain during e-fuel usage, the overall efficiency diminishes even further.

Our reaction to the revision of the End-of-Life Vehicles Regulation proposal

ELVR: Our reaction to the revision of the End-of-Life Vehicles Regulation proposal

We express our support to revise the ELVD and to combine it with that of the Directive. As a pivotal legislative tool to enhance the lifelong sustainability of EVs, this revision is key for the e-mobility transition and can accelerate the growth of a robust recycling value chain within the EU.

While our primary focus is on elements of the ELVR directly relevant to ZEVs, we welcome the overall text and notably the decision to turn the directive into a regulation, setting a comprehensive, harmonised regulatory framework across Europe.

We welcome Chapter 5, introducing provisions on the export of used vehicles. The export ban on non-roadworthy vehicles must remain a key point. We welcome the circular economy provisions addressing the design, production and end-of-life treatment of vehicles, effective dismantling, recycled content rate and the recoverability of raw materials. Measures have been forecasted to support the market for reuse, remanufacturing and refurbishment of parts and components of a vehicle

Binding targets for the reuse, recycling and recovery of ELVs must be preserved and their practical achievability ensured. Certain aspects of the proposal require clarification:

Potential overlaps with other existing legislations, e.g. the Batteries Regulation (BR) and the Ecodesign for Sustainable Products Regulation. To reduce excessive administrative burden it t is imperative to clearly define the interlink between the ELV passport and the Battery passport – i.e. how the information is communicated between these platforms and who has access to what information, with the aim of avoiding any redundancy, and if feasible, merging requested information behind a single QR Code. Such a tool has to take into account confidentiality of information and also differentiate on levels of data accessibility depending on stakeholder type, considering the information sharing requirements in the BR.
The annex on roadworthiness needs refinement to ensure that non-functioning batteries will not be exported, and aligning the provisions with the BR’s article on the export of waste batteries.
A close examination of Article 7, on the design of the removability of ‎certain parts of the vehicle, particularly in the context of EV batteries and ‎drive modes (7.2), is needed. Consistency between the BR and the ELVR needs to be ensured with clear roles and responsibilities between the different actors of the value chain (battery and vehicle manufacturers, second-life manufacturers, end-of-life operators).
When regulating the removability and replaceability of EV batteries, safety and appropriate qualification considerations is a priority. Batteries removed from vehicles need to be directed to the right recycling channels to be treated in line with the BR.

We would also encourage co-legislators to consider:

Legacy substances dilemma: The question of whether legacy substances can be used as recycled content must be addressed in a future-proof manner. The regulation needs to anticipate the potential time gap and regulatory changes between the production of EVs and their end-of-life phase. This will help mitigate contradictions between what automakers are required to do and what must be accomplished when permitted recycling facilities receive ELVs.

Beyond the proposed regulation, we would also welcome incentives for consumers to further drive the market to ever more sustainable EVs.

Incentives for low-carbon materials: Similarly to the BR, 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.

[1] Reusability, Recoverability, and Recyclability