Circularity and E-Mobility: Supporting a win-win relationship with the CEA
SUPPLY & INDUSTRY
We welcome the announcement of the Circular Economy Act (CEA), a key tool to develop a European Single Recycling market and scale effective recycling across the EU. Transport industries, especially the forward-looking sectors of electric mobility, must be considered as a central part of the CEA and the broader policy discussions surrounding Europe’s transition to a circular economy. Compared to fossil-fueled transport, electromobility practices and industries have the potential to significantly boost resource efficiency, reduce waste, and foster sustainable practices across the continent.
Notably, the CEA represents a timely opportunity to build a truly circular market for electric vehicles (EV) and their batteries in Europe.
With the right regulatory framework, Europe can unlock the full recycling and reuse potential of EVs and batteries, turning them into strategic assets for industrial competitiveness, innovation, and strategic autonomy. Ensuring that end-of-life vehicles and batteries are processed and recycled within Europe will foster high-value circular value chains, create future-oriented jobs, and support the EU’s environmental leadership.
This paper first revisits the essentials of a truly circular economy; then outlines the inherent circular nature of electric mobility; and finally proposes concrete recommendations to enable a circular electric transport system and industry via the CEA
THREE STEPS TO ENABLE A RECYCLING SYSTEM FOR ELECTRIC TRANSPORT.
Scale up Europe’s recycling capacity: The CEA should prioritise the rapid development of industrial-scale pre-processing and high-quality recycling facilities in Europe, particularly for EV batteries, to close the gap between expected waste volumes and current limited capacity.
Increasing the use of recycled materials, with recycled and local content targets: Prioritise incentive-based measures to boost the use of recycled and locally sourced battery materials, going hand in hand with gradually binding local content targets, while allowing exemptions for materials where the recycling market is already functioning well.
Create a true single Recycling Market: Harmonise and simplify intra-EU waste shipment rules, while fostering conditions that favour the processing of strategic waste streams within Europe, to ensure that valuable materials are recovered and reinvested into European clean tech industries.
I. Applying circular thinking to transport and mobility sectors
Firstly, we remind policymakers that a circular economy is one that produces only what is needed, reduces resource consumption, maximises product use through repair, reuse, and refurbishment, and ensures effective recovery notably during the pre-processing stage, which prepares the fractions to be recycled in high-quality recycling processes. This will ensure the successful reintegration of materials into the economy.
This attitude must be embedded in transport industries and mobility practices if Europe is to reach its climate and sustainability goals. To this end, entire systems must be designed with circularity in mind, aiming at building products – such as vehicles and their components – for long lifetimes, and making them repairable, upgradeable, and recyclable, without overburdening manufacturers.
Implementing circular practices like reuse, remanufacturing, and recycling also results in reduced energy consumption and raw material usage in comparison to manufacturing new products, ultimately decreasing the carbon footprint of a product.
Essential parts should be replaceable, and end-of-life processing should be considered from the design stage. The European Union must put in place the enabling conditions and incentives allowing its industry to achieve this objective competitively.
In this context, we welcome the new Circular Economy Act. The CEA will be key to scaling effective recycling across the EU and building up local recycling companies, and must complement and enable implementation of the already adopted Ecodesign for Sustainable Products Regulation (ESPR), which remains a key tool. In parallel, there are opportunities to make up for missed opportunities in the End-of-Life Vehicles Regulation (ELVR), for example by introducing recycled content targets for aluminium and steel from 2030 onwards.
RECYCLING EV BATTERIES: OPPORTUNITIES TO SOURCE MATERIALS LOCALLY AND SUSTAINABLY
Whilst also ensuring Europe’s strategic autonomy in clean tech manufacturing. According to T&E analysis, end-of-Life batteries and scrap from battery gigafactories in Europe have potential to provide 14% of all lithium, 16% of nickel, 17% of manganese, and a quarter of cobalt demand by 2030 already.
These materials will be enough to build between 1.3 and 2.4 million EVs locally in 2030, up to 10 mln in 2035, and up to 15 mln EVs by 2040. Nevertheless, the EU is currently not ready to capitalise on this opportunity. The existing recycling capacity across Europe is 10 times below where it needs to be in 2030, with almost half of Europe’s battery recycling plans at risk. Therefore, Europe will need to significantly scale up its recycling capabilities, and the CEA provides a key lever to create the regulatory space to help scale Europe’s recycling industry.
II. Electromobility is an asset for circularity
Before presenting recommendations for the CEA, it is important to highlight the high circularity potential of electric mobility.
a. Superior energy efficiency of electromobility
Unlike internal combustion engine (ICE) vehicles, which burn fossil fuels and lose energy through heat, battery electric vehicles (BEVs) do not involve irreversible consumption of fossil energy but can rather rely on 100% clean energy. The energy they use can be generated locally from renewable and zero-emission sources. BEVs are also inherently more energy efficient than ICE vehicles[1]. Promoting electric mobility is therefore in itself a resource-saving policy[2].
Beyond individual mobility, trains are by far the most energy-efficient for long distances. Europe is already a global leader in rail transport, and a concerted push to increase modal shift from road to rail could unlock substantial efficiency gains.
b. Second life of EV batteries
EV batteries, after around 15 years of use, retain sufficient capacity for less demanding applications. Their repurposing in stationary storage systems (for example in fast-charging hubs, residential buildings, or industrial facilities) represents a major opportunity to support renewable energy integration. However, while the concept of second-life batteries holds long-term potential, its large-scale deployment remains challenging in the short term, as current priority is – rightfully – given to the recycling and recoverability of critical materials. In the longer run, second-life batteries could become a valuable asset for energy storage, grid management, and flexibility services, complementing renewable energy deployment.
To unlock this potential at scale, batteries should be designed for easy removal, disassembly, repair and repurposing, while reliable data on their state of health must be fully accessible to authorised operators, with implementation best left to industry under existing regulatory frameworks. OEMs and battery manufacturers should ensure that these processes run smoothly, and costs are kept to a minimum, in line with existing regulatory obligations rather than through new legislative measures.
In addition, we call for the swift implementation of the Battery Regulation, especially regarding implementation of the battery passport and availability of standards regarding data on the state of health (SoH) of batteries, key for facilitating reuse and repurposing.
c. High recyclability and material recovery potential
EVs and their batteries are already subject to EU battery regulation requirements on recycling efficiency and recovery targets. Advanced recycling technologies now allow recovery rates of around 90–95% for key battery metals such as cobalt, nickel, and copper[3].
For these reasons, a successful and impactful CEA should support and actively enable the development of electric mobility, by scaling Europe’s recycling capabilities. Doing so will also reinforce Europe’s strategic autonomy in clean transport and green technologies.
III. A circular economy that boosts electric mobility
A well-designed CEA is an act that leverages the potential of electric mobility modes and industries for boosting a competitive and circular European economy. This would be notably possible through the following recommendations:
Boosting circularity in the supply chain
The CEA should boost investment in end-of-life vehicle and battery recycling facilities, support repair and repurposing businesses, and promote cooperation along the value chain, within the limits of EU competition rules. Upskilling support and financial incentives (e.g. tax credits or bonuses) should be offered to companies engaged in repair, refurbishment, and remanufacturing of EV components. While the CRMA has selected strategic projects in recycling, more can be done to ensure recyclers can scale efficiently, faced with significant competition. The EU Innovation Fund, InvestEU, the European Investment Bank (EIB), the future European Competitiveness Fund and national state aid should provide similar Capex and Opex support to recycling and circularity projects as cleantech, focusing on commercialisation and technology gaps (e.g. hydrometallurgical recovery of lithium, graphite and other elements). Ensuring the ramp up of competitive black mass refinement capacities at scale in Europe is especially key. The CEA should also explicitly support second-life applications through clear regulatory pathways and economic incentives.
Furthermore, the development, economic viability, and global competitiveness of European end-of-life and recycling industrial stakeholders relies on the development of a vigorous electromobility industry in Europe, sustained demand for EVs and particularly midstream battery components, and a stable, supporting legislative framework.
Increasing the use of recycled materials
We support the objective of increasing the use of locally recycled materials in batteries. This ambition must be pursued in coherence with the current state of the European recycling value chain, the availability of secondary raw materials, and the need to scale capacity. While we support the introduction of local content requirements, these should be approached with caution, ensuring that targets are aligned with actual supply and processing capabilities. Establishing a solid and competitive European recycling and refining value chain must be prioritised, going hand in hand with incentivising the use of local recycled content supporting the development of the value-chain in the EU.
The CEA could therefore explore mechanisms such as incentive-based approaches to encourage the use of secondary material recycled in Europe. This, in turn, has the potential to incentivise the development of recycling and refining capacity within Europe, rather than increasing reliance on external sourcing..
Where the ELV has so far failed to introduce recycled content targets for steel and aluminium in new cars, the CEA should see these targets being introduced as the Commission is due to finalise its feasibility studies on the aforementioned targets by Q4 2026. This should not, however, be the case for all materials, as for some the market is already very mature.
In conclusion, we call for prioritising or incentive schemes, ensuring they are implemented in line with the development of a resilient European recycling and refining ecosystem.
Harmonising and facilitating intra-EU waste shipment
Classifying battery black mass as hazardous waste has been a welcome step, banning its export to non-OECD countries. However, further steps are needed as one of the main challenges for recyclers remains access to waste. The CEA should ban or significantly limit waste material shipments of black mass, and other materials, outside of the EU. Progress so far has been a one-off; we need a systematic EU waste code structure to avoid exports of aluminium, steel, etc. as well as their final end-of-life products.
Additional measures should be taken to facilitate intra-EU shipments of black mass with harmonised criteria, allowing smooth transportation between pre-processing facilities and material recovery plants. Importantly, this waste criteria harmonisation should not encourage the export of black mass outside the EU. Finally, the forthcoming Green Listing Initiative should explicitly include waste batteries among its priority materials, ensuring that the recycling of strategic resources remains within the EU value chain.
At present, the complex and fragmented rules under the Waste Shipment Regulation act as a barrier to the circular economy. A harmonised set of rules for the transport of end-of-life batteries and related waste across Member States is urgently needed. Companies co-operating across the EU should be able to collaborate more easily: for example, when one company is handling collection, another refining, and another repurposing, they are facing administrative hurdles. Consideration should be given to treating such cross-border collaborations as a single entity for regulatory purposes. While the introduction of pre-consented statuses and fast-track notification for intra-EU waste shipments is a good start, more needs to be done to overcome national fragmentation. To this end, ensuring the automatic recognition of such pre-consented statuses among all EU Member States is key, as is the efficient use of ‘tacit consent’ to enable capable facilities to quickly receive and send battery waste.
The current classification and nomenclature for various waste streams is overly complex and inconsistent across Member States. It comes on top of the current restrictions and administrative burden, including lots of paperwork, associated with their shipment between EU member states under the Waste Shipment Directive. A revision of these provisions would improve coordination, simplify compliance, and encourage more businesses to engage in recycling and repurposing operations. Waste transportation rules should be modernised to reflect the collaborative, cross-border nature of the emerging circular battery economy creating a true European single recycling market.
Creating standardised recycled products
Different industries need varying quality standards for use of recycled products, e.g. lower grades of scrap steel are required in the construction industry often compared to the higher purity grades needed in many automotive applications. No differentiation of recycling grades based on quality standards, or “nomenclature” (e.g. in terms of contamination thresholds, etc) exist currently as it is assumed that all grades should be free of significant contamination. In practice, contamination levels vary, including copper contamination, which creates uncertainty as to the quality of the scrap. Creating such a nomenclature with clear thresholds on copper content for instance could allow recyclers to specialise and create better partnerships with the downstream industry, e.g. carmakers, to design recycled products based on specifications while achieving the necessary scale.
Therefore, the CEA should put in place quality standards for secondary materials to ease scaling and investment. Simpler recycling quality standards, as well as a more harmonised end of waste criteria, is needed to drive scale and cost-effectiveness for a few materials, such as steel and aluminium. By creating 2-3 categories (largely based on the levels of copper contamination), with the most pure being for automotive, recyclers can specialise and create standardised products, simplifying the process.
A FOCUS ON COPPER
On recycled content target, copper’s intrinsic value drives market demand for secondary copper, and there is no need for additional regulatory measures to increase demand.
For copper, purity standards are not needed, as high-quality recycling facilities, such as smelters and refiners, can recycle copper scrap to a purity of 99.9935% (copper grade A cathode), regardless of the purity of the scrap they receive, ensuring material quality equivalent to that of primary production.
"To support Europe’s strategic autonomy and climate goals, we must keep strategic raw materials like copper in the loop. The Circular Economy Act is an opportunity to remove barriers to high-quality recycling, simplify material flows, and fully align circularity with the EU’s green transition."
— Rikarnto Bountis, Senior Policy Manager
International Copper Association Europe
Conclusion:
A win-win relationship between circularity and e-mobility
Just as renewable energy development and electrification go hand in hand, electric mobility and circular economy objectives are mutually reinforcing. The high recyclability and reusability of EV components can support the growth of circular value chains in Europe, while circular policies can strengthen Europe’s industrial leadership in clean transport.
However, we are faced with a key moment to ensure the scaling of effective recycling across the EU, building up local recycling companies and getting volumes and actual recycling production going, in the face of significant competition.
A strong Circular Economy Act must therefore focus on creating a single European recycling market, whilst acknowledging and supporting the electrification of transport as both a driver and a beneficiary of circularity.
[1] Negri, M., & Bieker, G. (2025). Life-cycle greenhouse gas emissions from passenger cars in the European Union: A 2025 update and key factors to consider (ICCT Report). International Council on Clean Transportation. [2] Platform for Electromobility. (2024, November 27). Prioritising energy efficiency in EU’s transport ecosystem. [3] Agoro, H. (2025, March). Comparative Study of EV and Internal Combustion Engine (ICE) Vehicles. University of Ibadan
Boosting Europe's competitiveness with an ambitious MFF for clean transport
Ad-hoc group
The transition to electric mobility is one of Europe’s most strategic industrial and societal projects. It delivers on climate neutrality, strengthens energy independence, and secures competitiveness in a rapidly changing global market. As the European Commission presents its proposal for the next Multiannual Financial Framework (MFF), the Platform for Electromobility calls for a budget that is fully aligned with Europe’s long-term policy objectives and capable of unlocking the massive investments required for deployment.
1. Guaranteeing stability and predictability
The upcoming MFF must send a strong signal of regulatory and investment stability. Investors and industry require clarity, not only on the rules of the game but also on the tools available to deliver on them. A stable framework with appropriate tools and budgets adapted to the new geopolitical realities and priorities will maintain Europe’s attractiveness as a destination for clean tech investment in the face of global competition.
Any deviation from the agreed implementation path would generate uncertainty, reduce the credibility of the EU’s climate framework, and jeopardise our ability to meet emissions reduction targets.
2. From strategy to delivery: aligning policies and funding
The EU has already put in place a clear regulatory framework for the decarbonisation of transport, with milestones such as the CO₂ standards for vehicles, the TEN-T Regulation, AFIR and the Batteries Regulation. To make sure instruments are deployed timely to successfully reach the 2035 CO2 reduction ambitions, the new MFF must now match this ambition with financial instruments that accelerate the deployment of clean infrastructure and technologies across the value chain. Strategic policy without corresponding financial planning risks creating uncertainty and slowing down investment. Therefore, the transition to electric mobility should be a priority area under the main headings of the MFF.
3. Unlocking investment needs through smart financial tools
Europe’s e-mobility ecosystem requires unprecedented levels of investment in sustainable infrastructure, railway electrification, clean transport assets technologies, charging infrastructure, battery production, and research & innovation. Key programmes such as Horizon Europe, the European Competitiveness Fund (including the InvestEU fund), and the Connecting Europe Facility should provide targeted support in these areas and key enabling and interoperable digital technologies across all transport modes. In this regard, we welcome the focus of the proposed CEF on railway infrastructure and call for additional dedicated, easily accessible instruments to prolong AFIF, ensuring continuity and predictability for investors. Beyond grant funding, the next MFF should place emphasis on instruments that crowd in private capital (e.g. loans, guarantees, risk-sharing mechanisms, etc).
4. A partnership approach through national and regional plans
National and regional partnership plans (NRPPs) must become genuine drivers of deployment. They should prioritise projects that deliver the highest value for decarbonisation, energy security, and industrial competitiveness. Coordination with local authorities will be crucial to ensure that funding is channelled towards projects with real impact while ensuring synergies with investments under CEF and ECF.
5. Funding conditionality as a driver of implementation
Access to EU funds should be firmly linked to the correct and timely implementation of existing EU legislation. Conditionality will help ensure a level playing field across Member States, reward frontrunners, and avoid undermining Europe’s collective progress toward climate and industrial goals. Co-legislators should align the respective indicators within the performance framework and other horizontal rules for the Union programmes and activities the respective indicators with the sector’s concerns These indicators will determine the effectiveness of the National and Regional Partnerships. The indicators must be aligned with legal requirements, should be future-proof (with a 2035 horizon), and use definitions that are commonly used in the sector.
6. Defining clean tech industries
To ensure that EU funding instruments effectively strengthen Europe’s strategic autonomy, the next MFF should establish a clear definition and criteria for what constitutes clean technology industries. This will provide clarity, avoid dispersing resources, and prevent clean technologies from being placed in direct competition with unrelated sectors within instruments such as the Competitiveness Fund. Establishing such a framework will ensure that financial support is directed towards industries that demonstrably contribute to Europe’s energy independence, decarbonisation, and long-term competitiveness.
Conclusion:Level of ambition must be maintained or strengthened during the negotiations
The next MFF represents a unique opportunity to transform Europe’s climate and industrial ambitions into reality. By aligning financial planning with strategic objectives, ensuring dedicated and predictable support for deployment, and maintaining conditionality and regulatory stability, the EU can secure its trajectory towards 2050 and its leadership in the global race for e-mobility, all modes considered. The Platform for Electromobility stands ready to work with institutions and Member States to make this vision a reality.
"Europe has already set ambitious climate and mobility targets. The next EU budget must provide the tools to deliver them. With stable, predictable and well-targeted financial instruments, Europe can turn its strategic vision for clean mobility into a global competitive advantage."
— Xavier Sol, Director Sustainable Finance, T&E
ETS 2: Staying the course for an effective and fair transition to e-mobility
Vehicles & Markets
The Platform for Electromobility, representing a broad coalition of industries committed to the decarbonisation of transport, reiterates its firm support for the timely implementation of the ETS 2 (Emissions Trading System for road transport and buildings) as scheduled in the previous mandate, in line with the vote of the European Parliament on April 18, 2023.
1. Uphold ETS 2 to unlock investments
Rolling back or delaying the ETS 2 would undermine investor confidence and reduce the available financial tools to accelerate the uptake of electric vehicles, the development of alternative and collective mobility modes, and related infrastructures. The new system is not only a pillar of the Fit for 55 package, it is also a key driver for directing public and private capital towards the clean transition ecosystem and industries.
Any deviation from the agreed implementation path would generate uncertainty, reduce the credibility of the EU’s climate framework, and jeopardise our ability to meet emissions reduction targets.
2. Timely transposition: a key step for fair and effective implementation
As of today, only 10 Member States have transposed the ETS 2 directive into national law. Accelerating transposition is essential to ensure a coherent and effective rollout of the system across the EU. It will provide legal certainty, enable better coordination among stakeholders, and help deliver the expected climate and social benefits in a timely manner. Encouraging swift action from all Member States will also strengthen the credibility and impact of ETS 2 as a key pillar of the EU’s climate policy.
Moreover, citizens and businesses need a clear price signal. A stable and well-communicated carbon price will encourage behavioural change, spur investment in energy efficiency and zero-emission solutions, and support long-term planning across the value chain.
3. Ensuring ETS 2 is effective and socially fair
To guarantee that ETS 2 delivers both environmental and social outcomes, we recommend the following measures:
- Reinvest 100% of ETS 2 revenues into decarbonisation and targeted social support. We call to ensure transparency and additionality of Member State spending, so EU funds do not replace existing national support schemes.
- Strengthen complementary policy tools: ETS 2 must work alongside a robust regulatory framework. This includes preserving the CO₂ reduction ambitions for cars and heavy-duty vehicles, supporting the Clean Corporate Vehicles initiative, and ensuring the rollout of charging and multimodal infrastructure.
- Frontload ETS 2 revenues. We must accelerate investment to protect vulnerable groups from the impact of rising carbon prices and to deliver visible benefits early in the transition.
- Reinforce the Social Climate Plans (SCPs): push Member States to increase the co-financing rate above 25% to ensure meaningful national action.
- End fossil fuel subsidies: Use ETS 2 as an opportunity to rebalance taxation in favour of electrification, including reducing the tax burden on electricity and removing outdated exemptions for fossil fuels.
- Early auctions should be launched in 2026. Early auctions would help market participants form their view on expected prices. It would be a market friendly move to enhance transparency and ensure a smoother transition into full system operation.
Conclusion
"ETS 2 is not only about cars – it is also key to decarbonising heavy-duty transport. By sending a predictable price signal, the system will support investment in zero-emission trucks, strengthen the CO₂ standards for heavy-duty vehicles, and accelerate the rollout of charging and refuelling infrastructure needed for long-haul freight."
— Koen Noyens, Head of Public Affairs, MILENCE
ETS 2 is a cornerstone of Europe’s decarbonisation strategy. It must be implemented as planned to send a clear signal to markets, enable effective carbon pricing, and channel investments into clean mobility. Our coalition of industries stands ready to support this effort and ensure that ETS 2 is both socially just and economically effective.
Words of Members - Video series
Video series
In our video series "Words of Members", Platform members provide their perspectives on the coalition and vision for the electric mobility ecosystem
Platform members include EU-based industries and environmental NGOs across the whole value chain of electric mobility, across all land transport modes.
1/ Ivo Cré (POLIS) on the role of local authorities in the electric mobility transition.
Polis is an association of cities and regions working on urban mobility innovation. We’ve been with the platform from the start, also one of the founding members. We are, as a network, involved in the full cycle of electromobility innovation on the research side through our involvement in the 2zero platform, but also in the deployment side.
Cities and regions are essential stakeholders in the electromobility deployment. We buy a lot of vehicles. We set regulations for vehicles in our cities. We also are parking managers and parking means charging.
The Platform offers a unique environment to discuss policies on electromobility to make sure that electromobility does not lose its momentum in European policy. We are also convinced that the Platform is the right ecosystem to really keep electromobility in focus as a transformational technology.
We believe electromobility is a transformational technology because we don’t want a one-on-one replacement of one car by an electric car. We are interested to see the whole mobility system change. We look at shared mobility, at new forms of logistics in cities, at new forms of car use and car ownership.
Electromobility can be an essential part of that system overhaul and system change.
We will fight with the Platform to keep the 2035 deadline in European legislation. And a lot will have to happen to make that policy objective a reality. And we think that we as cities and regions, as procurers, as regulators,as asset owners also, we can really make a contribution to that mission.
2/ Nicolas Erb (Alstom) on Regulatory Stability Matters for European railway industry
Alstom is the European leader for railway equipment, trains from tramways to high speed, signalling, infrastructure and we deliver projects all around the globe thanks to our 85,000 colleagues.
Rail is the best in class in terms of environmental performance of all collective transport modes. And there is no way Europe will achieve its decarbonization targets without increasing the modal share of railway, be it for freight transport or passenger transport.
We call for regulatory stability because in our sector, projects have a very long life cycle. They take years to be prepared and several years to execute.
So any change in the regulatory framework that impacts ongoing projects creates a risk of additional cost, additional delays, which are ultimately detrimental for everyone.
This is why we have to make sure that our regulatory framework changes less frequently, and especially, and this is most important, that new regulatory requirements apply to new projects only.
Statement on the CO2 Standards ahead of the Strategic Dialogue with automotive industry
Statement
European clean transport industries urge EU to
stay the course on 2035 zero-emission car target
The members of the Platform for Electromobility reaffirm their strong support for the 2035 zero-emission targets for cars and vans, as adopted in 2023, ahead of the Strategic Dialogue with the automotive industry of the 12 September 2025 which might cover this legislation. We call for their persistent, robust and timely implementation for both Europe’s competitiveness in global competition and Europeans’ access to clean transport solutions.
Electrification is a global race. Europe cannot afford to fall behind. A clear and consistent regulatory path is vital to maintaining the competitiveness of Europe’s automotive industry and whole electromobility value chain, ensuring its ability to export high-value, future-proof technologies in a rapidly evolving global market.
A stable and effective regulatory framework is essential.
Europe’s clean tech industrial development needs long-term legal certainty. The current CO₂ Standards for cars and vans are not only instrumental in driving down emissions in line with climate targets, they also represent a cornerstone of the EU’s industrial policy. Stability in legislation is key to attract investment in the scale-up of clean technologies, the creation and expansion of manufacturing capacity, and the reskilling and upskilling of Europe’s workforce. Let’s not send a counterproductive signal to markets and investors at a critical time for Europe’s competitiveness.
Building a zero-emission transport system will require smart and diversified use of multiple transport modes. An unstable regulatory framework hampers long-term investment in multimodal solutions and infrastructure. Clear and ambitious targets provide certainty for investors and industry, helping the automotive and e-mobility value chain to plan ahead, scale production, and remain globally competitive while the transition to clean transport is accelerating worldwide.
BEVs are the driver of efficient and competitive decarbonisation.
Electric vehicles are the most energy-efficient individual transport mode. Energy efficiency in transport should be a central pillar of the EU’s energy transition, as it strengthens energy security, cuts costs for businesses and citizens, and reduces pressure on renewable energy deployment compared to alternative fuels solutions.
We strongly urge European lawmakers to reject the introduction of alternative fuels for cars and vans due to their inefficiency, high costs, and negative impact on industrial competitiveness, consumer protection, and air quality.
Let’s stay focused on the enablers of electrification.
Today, European policy should focus on the key drivers of electrification, rather than weakening existing legislation. These include: an ambitious Clean Corporate Fleet Regulation to be proposed later this year, which can further stimulate demand and set clear signals to the market; the implementation of AFIR as a key enablers for EV uptake for European consumers the mobilisation of EU funds to finance demand-side support mechanisms in Member States; coordination between automotive and energy sectors; and a broader policy framework to ensure affordable and clean energy for industries and consumers alike. On the production side, fostering innovation through smart regulation streamlining and setting the conditions to produce in Europe efficient and affordable EVs (such as by incentivising battery cells/modules made in Europe by rewarding each kWh produced) is key to powering the continent’s EV shift.
We trust that the Strategic Dialogue will serve to reinforce confidence in the EU’s regulatory direction and to support the full deployment of zero-emission mobility across the Union. The Dialogue is an opportunity to solve the genuine challenges our members face on the road to the 2035 target and to explore how to best seize the opportunities it offers.
“The Platform for Electromobility’s call is clear: stop disrupting investments by creating uncertainty and focus on the enabling conditions for industrial leadership along the e-mobility ecosystem to allow European clean tech industries to prosper – such as batteries. A stable regulatory framework is essential, as are concrete effective actions to support Europe’s electromobility value chain."
— Kinga Timaru-Kast, Chair of the Platform for Electromobility
[Video] "Let’s not change the course" - Industry calls for clarity
Supply & Industry
In a strong show of unity, ten industrial leaders of the Platform for Electromobility have come together at the start of this political year to deliver a single, clear message to European lawmakers: “let’s not change the course.”
The uncertainty surrounding recently agreed climate and industrial legislation – most notably the CO₂ Standards for cars and vans – poses a direct threat to investment in Europe. Without regulatory stability, the essential investments, innovations, and workforce upskilling in key sectors such as batteries are being delayed or put on hold. Meanwhile, global car sales figures confirm that the rest of the world is moving forward at speed. Europe cannot afford to be left behind or trapped in technological limbo.
This uncertainty also affects the wider ecosystem necessary for the transition: from charging networks and power grid upgrades to the development of a robust recycling value chain. Beyond road transport, urban and collective transport industries and stakeholders are also needs stability to development long-term projects and infrastructures.
Disruptions to these sectors would only further delay Europe’s transition to clean mobility.
Regulatory stability is the rallying call of clean industries of this 2025 “rentrée”. Now is the moment for Europe to stay the course, safeguard its industrial competitiveness, and secure the long-term benefits of the transition for its workers, industries, and citizens.
Swift and Smooth | Cross-sectoral recommendations for a swift transport electrification, smooth for the grid
ENERGY & INFRASTRUCTURES
The transport sector is electrifying across the EU. Optimised integration of electric vehicle (EV) charging infrastructure to distribution grids is one of the main enablers to EV uptake. Currently, System Operators[i] face a high number of connection requests from sectors electrifying in parallel while often being bound to managing these requests on a first-come-first-served basis. At the same time, electrified transport offers significant flexibility potential from battery storage, which can be leveraged to optimise use of existing grid capacity, notably when using smart charging solutions.
In this context, the members of the Platform for Electromobility recognise the need for a policy framework that supports beneficial and grid-friendly transport electrification. We welcome the opportunity to contribute to the development of such a framework following the announcement of the Automotive Action Plan. With this paper, we align our views on three key topics addressed by the upcoming Action Plan:
- Acceleration of grid connection requests
- Standardisation for interoperability and data exchange
- Future needs to guide anticipatory investments
As announced in the Automotive Action Plan, the Commission is working on the Guidance and recommendation on shortening grid connection procedures and grid connection prioritisation. The Platform welcomes the initiative, considering the unprecedented demand for grid connections from various sectors and recognising that Member States need flexibility in their approaches to grid connection queue management beyond ‘first-come, first-served’ as the default method. We see the upcoming Guidance as going in the needed direction of greater harmonisation of grid connection processes across the EU where currently, practices differ greatly among system operators.
This paper outlines shared recommendations from our sectors on how European legislators can support us in addressing these challenges in a coordinated and forward-looking manner[ii].
[i] System Operators in this document refers to both DSOs and TSOs [ii] The Platform would like to thank the Regulatory Assistance Project (RAP) for its technical advice supporting this paper.
I. More efficient grid connection requests
Recommendation 1/ Prioritising grid connection requests
Many system operators have identified inefficiencies with the ‘first-come, first-served’ approach, such as “ghost applications” to secure potential charging sites. System operators should have the possibility to actively manage these queues, with proper guidance from their national governments and regulators, where ‘first-come, first-served’ is no longer useful for their customers or themselves. Some Member States[i]are already moving beyond this principle by introducing criteria for projects to be connected, e.g. mature and fully developed projects, projects that provide system value. The Platform recommends that the Commission consider the options mentioned in this paper in view of accelerating grid connections while using tools to use existing grid capacity most efficiently.
The prioritisation of grid connection requests to manage limited grid capacity more efficiently and reduce connection queues is essential to enable a timelier connection of critical infrastructure for the electrification of transport – particularly charging stations for electric heavy-duty vehicles (e-HDVs). Clear criteria for prioritisation should be established at European and national level by governments and national regulatory authorities (NRAs). These guidelines should allow system operators to prioritise projects that provide the greatest benefit to the grid and society and, at the same time, give system operators legal certainty in their allocations of grid connections.
[i] European Commission. (2023, December 14). Communication on future-proof network charges for a decarbonised and increasingly digitalised electricity system. https://energy.ec.europa.eu/publications/communication-future-proof-network-charges-reduced-energy-system-costs_en
Recommendation 2/ Balance technological neutrality with emerging markets needs
Guidelines for prioritising requests must be integrated into the regulatory framework to avoid delays and ensure that urgent, high-priority projects are fast-tracked. It is important to note that, under existing regulations, DSOs and TSOs must remain technology-neutral in their planning and investment decisions. While no specific technology type should be prioritised by default, the application of clear and objective criteria can help identify projects that offer the greatest system-wide value. In this context, EV charging projects that enhance overall network efficiency, resilience, and flexibility may merit prioritisation, provided they are assessed based on their contribution to broader system benefits.
In emerging and still-fragile market segments, such as infrastructure for eHDVs, some degree of prioritisation may be justified, particularly where projects demonstrate clear potential to contribute to grid flexibility or resilience. Similarly to how renewable energy projects were prioritised in the early stages of the energy transition, certain eHDV charging projects may warrant faster access through the connection queue, provided they meet predefined, transparent criteria. The Clean Transport Corridors initiative under the EU Automotive Industry Action Plan offers a relevant example of how public authorities can support the roll-out of strategic infrastructure without undermining technology neutrality for system operators, by focusing on systemic benefits rather than specific technologies.
Recommendation 3 / Regularly updating grid hosting capacity maps
To accelerate grid connection processes and support efficient deployment of recharging infrastructure, accessible and regularly updated information on available grid capacity should be accessible. Examples from Flanders show that maps with regularly refreshed data and clear visualisation significantly improve stakeholder engagement and planning. Conversely, tools such as the Dutch colour-coded heatmaps, while a step forward, have limited usability. In the UK, the open data portal also is a promising model[i][ii] . Overall, increasing the digitalisation, transparency, frequency, and functionality of capacity maps would empower project developers, reduce delays, and support more effective grid usage. In order to ensure harmonisation across the Union, we call upon the European Commission to create open and updated pan-European grid capacity maps to coordinate with project promoters on locations already available for grid connection. Regulators should ensure that such improvements are incentivised or at least cost-neutral for DSOs and TSOs.
[i] UK Power Networks. (n.d.). Open Data Portal. Retrieved June 30, 2025, from https://www.ukpowernetworks.co.uk/our-company/open-data-portal
Recommendation 4/ Digitalisation of requests via confidentiality agreements
Digitalisation and standardisation are increasingly recognised as essential enablers for managing the growing volume and complexity of grid connection requests. As electricity demand rises, manual approaches are no longer sufficient. Digital tools should not only streamline internal workflows and technical assessments for system operators, but also ensure that those requesting a grid connection, such as CPOs and other stakeholders, have easy and transparent access to key information. This includes the procedures to submit a connection request, timelines for each step, the current status of their application, and any additional relevant updates. Making this information accessible through digital means is crucial for improving transparency, predictability, and efficiency in the connection process and any additional relevant updates and upfront information on costs and fees.
To fully leverage these advancements, there is a clear need for transparent and accessible information for current and future connection request and plans to be provided by CPOs to DSOs. For a competitive and well-functioning market, it is essential to ensure information on CPOs’ future connection request and charging network planning is shared bilaterally with involved DSOs in a manner that ensures confidentiality and protect commercial sensitivities when this information is needed for DSOs to prepare network development plans and efficiently plan infrastructure upgrade and modernisation
Recommendation 5/ Flexible grid connection agreements
Electrification of transport increases the load on electricity distribution grids, leading sometimes to network congestion during specific periods of time of certain days. By introducing flexible, timed connection options while new distribution infrastructures are built, peak-time demand can be managed more effectively, ensuring that more EVs can be connected to the grid without causing congestion or reducing grid expansion cost. When deemed necessary by the system operators, flexible connection agreements can accelerate the efficient and timely connection of new projects to the grid. In some Member States, such as Sweden, certain grid operators already offer flexible grid connections; however, they face uncertainty in managing the technical aspects due to the lack of complete standardisation.
These agreements, often useful as a temporary solution before physical grid reinforcement should include provisions for vehicle-to-grid readiness, smart charging capabilities, and power requirements for different charging use cases (e.g., ultrafast vs. overnight). Such agreements can in some cases, such as charge points with limited hours of operation, be a more permanent solution when there is a specific agreement in place for that situation. It should also be acknowledged that the concept of flexible connection is defined differently across Member States, and national interpretations and frameworks may vary accordingly. This can facilitate the early adoption of zero-emission vehicles of all sorts however, the regulatory framework must support timely investment in the grid, with a clear timetable for the provision of firm capacity. Without replacing market-based alternatives, permanent flexible connection agreements could also be offered as a viable solution only if agreed by both parties
Recommendation 6/ Smart pricing to ensure best use of existing power networks
Enabling smart and, where possible, bidirectional EV charging, based on the growing offer of smart charging tariffs and services, would help consumers use the grid most efficiently. National energy regulators implementing time-varying network tariffs , based on recent EU guidance recognising the pressing nature of network pricing reform[i] are a basic key ingredient to drive efficient grid utilisation from grid customers such as EV fleets and CPOs.
[i] European Commission. (2024). [Title of the publication] (Publication No. 96b7e60d‑9efe‑11ee‑b164‑01aa75ed71a1). Retrieved July 9, 2025, from https://op.europa.eu/en/publication-detail/-/publication/96b7e60d‑9efe‑11ee‑b164‑01aa75ed71a1
II. Standardisation for interoperability and data
Recommendation 7/ Establishing common standards
The importance of interoperability between EVs and the grid is critical for ensuring seamless connectivity across borders and vendor-independent. This includes establishing common standards for charging infrastructure and vehicle-to-grid (V2G) communications to ensure that EVs and charging stations can interact with the grid across the EU. Adopting common standards for data exchange across the EU is essential to seamlessly exchange information on charging infrastructure, capacity needs, and vehicle data. Therefore, clear guidelines for data sharing formats need to be developed to ensure that all parties involved can easily access and use the relevant data. Standardisation ensures interoperability, safety, and efficiency in the integration of electric vehicles with the power grid.
The promotion of common standards is paramount for ensuring interoperability and reliability across V2X systems. These should allow the Electric Vehicle Charging System (EVSE) to provide smart and bidirectional charging. and communicate with the grid. The necessary standards should be implemented as soon as the standardisation processes are finalised, in the charging stations, the cars and the grid. , while taking into consideration industry capabilities. This is key to deploy future-proof infrastructure and to deliver the smart-charging services we will need for the energy transition to succeed. Standardisation bodies should prioritise development 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.
Recommendation 8/ EU-wide interoperability grid data and asset certification
The data sets and formats based on common definitions concerning available grid capacity across EU distribution system operators would significantly facilitate project development for grid users operating in multiple EU countries, by improving transparency and comparability of grid information. In parallel, certification for assets connecting to the grid plays a crucial role in ensuring that charging infrastructure complies with quality standards and safety requirements.
This certification process typically involves a formal assessment to verify that electrical assets, such as charging stations and associated equipment, meet defined technical, safety, and quality benchmarks prior to grid connection.
Technical compliance ensures that the infrastructure is compatible with the operational requirements of the grid and does not introduce disturbances or compromise stability. Safety standards are assessed to protect both users and grid operators, covering aspects such as protection against electrical faults, fire risks, and correct installation procedures. Quality assurance confirms the infrastructure’s reliability, durability, and performance over time, supporting long-term functionality and user confidence.
Establishing common EU-wide certification requirements and procedures would support cross-border deployment of charging infrastructure and reduce administrative complexity for manufacturers and operators alike.
III. Future needs to guide anticipatory investments
Recommendation 9/ Detailed forecasting and transparency in demand
Accurate forecasting of future transport demand and the capacity needs for EVs is critical to guide infrastructure investments and grid planning. Early data on power requirements per station enables system operators to have better-informed decisions and to prioritise grid connection requests more effectively. A clear guidance on how this data needs to be collected and shared in full respect of protection of commercial interests among the stakeholders involved is needed to reduce connection queues and help manage grid capacity congestion efficiently.
Recommendation 10/ Anticipatory Investments in grid capacity and Infrastructure
A stable and predictable legal framework that also allows anticipatory investments enables the network to meet capacity requirements when needed. Such a framework needs to be built on holistic European and national energy plans formed with policies that fully deliver on decarbonisation ambitions, keeping in view sufficiently long-time horizons, and implemented and monitored by independent energy regulators. Anticipatory investments[i] are not a new form of grid investment, and as such do not require a brand-new regulatory framework, though regulatory frameworks can often be further improved in this respect. Optimal investment still entails investing so that the additional cost of build matches the expected societal benefit of this extra capacity.
The need for anticipatory investments[ii] and a concomitant regulatory framework that facilitates their implementation are key for ensuring that grid infrastructure is developed ahead of demand. This includes addressing the growing demand from transport while simultaneously investing in grid upgrades to prevent future congestion. To target these investments optimally, demand forecast processes should be structurally embedded in a wider and regular scenario building exercise and joint grid planning process.
Based on the aforementioned outlined checks and risk evaluation with regards to future utilisation, DSOs should be empowered to make anticipatory investments that can handle future needs, particularly in areas where high-capacity charging stations are required (e-HDVs). These investments should support the implementation of the AFIR provisions and the rollout of grid-optimised e-HDV charging infrastructure TEN-T networks, e.g. via the Clean Corridor initiative, with a specific focus on enabling cross-border traffic, thereby avoiding price distortion in the emerging market for truck charging services.
[i] Regulatory Assistance Project (RAP): Revitalising regulation to guide anticipatory investment. https://blueprint.raponline.org/deep-dive/revitalising-regulation-to-guide-anticipatory-investment/
[ii] European Commission. (2025, June 2). EU guidance ensuring electricity grids are fit for the future. Retrieved June 13, 2025, from https://energy.ec.europa.eu/news/eu-guidance-ensuring-electricity-grids-are-fit-future-2025-06-02_en
Recommendation 11/ Implementing a blueprint for recharging infrastructure
The costs and complexity of grid connections can be rationalised by optimising the deployment of recharging infrastructures, in accordance with charging infrastructure needs (number of points to be installed per EVs on the road, location, power, type of socket, etc.). If the infrastructure is installed at the right place, taking into account EV user demands and patterns of charging behaviour, namely where the grid is already available or sufficiently robust, with consistent sizing, the cost and length of grid connection processes can be mitigated. To this end, it is necessary to promote the cooperation between local/regional authorities and stakeholders of the electromobility ecosystem in the deployment of recharging infrastructures, for instance by implementing a “blueprint for recharging infrastructure”. This document, defined by local authorities in consultation with relevant stakeholders, would comprise the local planning rules for the implementation of recharging infrastructure in main highways and national roads and would assess charging infrastructure needs, considering the existing publicly accessible infrastructure and also the existing and expected private charging infrastructure. It could further enhance existing work completed by the Sustainable Transport Forum (STF).[i].
[i] Autoriteit Consument & Markt. (2024, May 22). Codebesluit prioriteringsruimte bij transportverzoeken. https://www.acm.nl/nl/publicaties/codebesluit-prioriteringsruimte-bij-transportverzoeken
The final word by our member
“This paper is clear evidence of the power of cross-sectoral cooperation in addressing the challenges of transport electrification. Breaking down siloes between the electricity and mobility sectors is essential to ensuring a swift and smooth energy transition. In the context of the Automotive Action Plan, it is encouraging to see E.DSO members actively driving this collaboration forward”
—Charles Esser, Secretary General at E.DSO