EV Charging: how to tap in the grid smartly?
EV Charging :
How to tap in the grid smartly?
With a market penetration of 10% in Europe in 2021[1], and with a purchase price and total cost of ownership outperforming that of the internal combustion engine (ICE) before the end of 2027[2], the take-up of electric vehicles (EVs) is expected to accelerate significantly in the coming years. The widespread electrification of transport is the most efficient way to reach Europe’s climate objectives for the sector. Challenges may lie ahead, but smart charging must not be overlooked as the main asset for overcoming these hurdles.
A critical mass of EVs on the market will impact electricity consumption patterns and create an overall increase in electricity demand, particularly during peak-time periods. Smart charging can be a crucial tool for increasing the adoption rate of EVs, by mitigating the stress on the grid and supporting the transition towards sustainable electricity; each connected EV helps reduce CO2 emissions further. Smart charging can reduce CO2 by an estimated annual 600,000 tons by 2030, through the greater integration of renewables in the grid.[1]
With the electrification of usages, a rapid increase in decentralised and local loads could – if not managed correctly – overstretch the current low-voltage distribution grids, particularly in residential or commercial areas[2]; smart-charged EVs provide a solution. Bidirectional charging and other flexible services – where appropriate – can also provide solutions and benefits, both to the grid and to the end-user (of the grid and of the vehicles), and should not be overlooked.
The Platform for electromobility therefore welcomes that the ‘Fit for 55’ package recognises the importance of smart charging for integrating transport in the energy system but we encourage more robust and consistent support for smart charging throughout the package. In order to unlock all the benefits smart charging can deliver to the electricity system, to EV users, to the environment and to society at large, the following considerations should be respected in a coherent manner throughout all relevant legislative files.
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What should be classified as smart charging?
Definitions of smart charging differ between legislations. Indeed, different levels of ‘smartness’ are possible, depending on the business solution deployed and the level of involvement of the consumers. The Platform for electromobility believes that charging installation should be considered smart if:
- it provides real-time adjustment
- it adjusts charging in response to external signals
- the adjustments give additional clear benefits to the EV driving consumers, providing flexibility to the grid.
Bidirectional charging comes to complement smart charging services. While unidirectional charging enables adjustment to the charging process depending on external signals, bidirectional charging – also known as V2X (‘vehicle-to-everything’) goes a step further. It allows the vehicle to exchange energy with the connected asset (grid, home, building) in both directions, as well as charging or discharging for as long as it is plugged in. This means that the vehicle can offer services for a longer timeframe, as unidirectional charging stops once the battery is full.
What are the benefits of smart and bidirectional charging?
Flexibility services are a vital enabler for grid management in the energy system of a carbon neutral Europe, and smart charging can play a crucial role in delivering this flexibility. New and refurbished charging installations (public and private) should therefore be smart.[1] The timeframe for a potential eventual retrofit of existing stations should be defined through a comprehensive impact assessment, coordinated with the stakeholders of all affected sectors and Member States. Such an impact assessment will allow a comprehensive overview of the requirements for retrofitting, and will therefore optimise both the cost and the deployment of smart charging points.
- Smart charging will have a key role for the user in:
- Empowering consumers in the energy transition, by transforming electric vehicles into an energy asset.
- Taking full advantage of low electricity prices in the system for consumers and reduce the consumer’s bill of electricity (savings are estimated between €60 and €170 per year[2]).
- In the heavy-duty vehicle (HDV) segment such as e-buses, smart charger capability offers the possibility to optimise the charging process according to the e-bus’s schedule, managing the allocation of the available power at charging depots (e.g. identifying and setting different priorities and criteria for charging the vehicle based, for example, on the order of arrival, departure-time priority, etc.).
- Smart charging will have a key role for the grid in:
- Increasing system efficiency, by integrating the road transport sector into the energy system. This will optimise the use of the electricity grid and reduce the investments required in the power grid (which could reach €375-€425 billion by 2030[3]) compared to those of unmanaged charging.
- Avoiding grid congestion, by lowering the load pressure and consequently enabling the more efficient integration of EVs into the power system.
- Taking full advantage of the availability of renewable electricity, therefore increasing the penetration of variable renewable energy within our energy system.
- Bidirectional charging could also have a key role for the user in:
- Empowering the consumer in the energy transition to an even greater extent, by transforming the electric vehicle into a ‘battery on wheels’.
- Taking full advantage, and in particular Vehicle-to-Home (V2H), of self-consumption while mitigating their exposure to high prices for customer exposed to dynamic tariffs.
- Selling back electricity to the grid to bring further significant financial benefits for the consumer.
- Generating further revenue streams for public transport operators and/or fleet managers, in particular in the case of depot charging, allowing reductions to the total cost of ownership and thus offsetting the cost of charging infrastructure while generating additional revenues.[4]
In addition, other technological innovations capable of bringing flexibility to the system in the future – as well as a proper determination of the correct balance between charging modes using a case-based approach – should not be ignored but rather be carefully considered.
How to make smart charging work?
An enabling policy framework is needed to unlock these benefits and deliver them to both the electricity system and to society at large. The legal framework should be consumer-focused, consistent, future-oriented, and should allow appropriate reactivity, coordination and data sharing:
- Consumer focused: Any legal framework should create provisions that ensure that those EV drivers who provide flexibility by adopting smart charging solutions receive net positive effect for so doing. Consumer adoption is key to a successful implementation of smart charging technologies, and therefore should be made the central stakeholder.
- Consistent: Any definition and provisions set out in the AFIR, the REDIII and in the revision of the EPBD, should be both mutually consistent and consistent with energy directives in general, in line with the definition of storage. In particular, it will be essential to maintain consistency between the different definitions for smart and bidirectional charging. Furthermore, it will be vital that regulations consistently pursue a level playing field for smart charging and other technologies that provide flexibility to the grid. Consistency between legal definitions should also be ensured by avoiding overlap with the definition of ‘digitally connected stations’. To run the smart charging system in a coherent way, regulatory framework must also support the different actors of the eco-system to cooperate together, including OEMs, to optimize the benefits while ensuring that batteries are preserved.
- Future-oriented: A legal definition of smart charging should be sufficiently broad, and mention benefits without mentioning technicalities, so as to include future technologies.
- Reactivity: Smart charging should allow adjustments that are rapid enough to deal with grid disturbances and emergencies.
- Data: To ensure this necessary level of reactivity, smart charging requires access to information from the battery management system. On the basis of a contractual agreement, relevant and necessary data should be made available to vehicle owners and users, as well as third parties acting on their behalf.
- Cooperation: Smart charging needs the different actors of the eco-system to work together, including OEMs, to optimize the benefits while ensuring that batteries are preserved.
Our specific policy recommendations for smart and bidirectional charging
Incentives and support for the uptake of smart charging should be proposed, as it can offer a full range of additional services compared to regular charging. Bidirectional charging should also be encouraged when demonstrating the positive socioeconomic impact and creating a net benefit for the EV driving consumer who is contributing to the energy efficiency of the entire system.
The Platform calls for ensuring the consistency of the RED III with both the new Regulation on the deployment of alternative fuels infrastructure and with the energy performance of buildings directive (EPBD). The current definition of smart charging and bidirectional recharging should be aligned, and any changes to the related definitions and provisions in one text should also be made in the other.
The Platform welcomes the Commission’s recognition of the role of smart charging in the AFIR for enabling system integration. Improvements should also be made to support smart charging deployment. We therefore call for improvements to the requirements on smart charging (art. 2 and 5.8). You can read more details in our paper dedicated to AFIR here.
Time with the vehicle plugged: as important as using a smart charger: To realise the full potential of smart charging, the recharging points should be deployed at locations where vehicles park for extended periods of time. This allows the flexibility of choosing when to start and stop charging. At or near home is the main one, followed by the workplace. On average in EU, 60% of passenger cars have access to off-street parking at home, where is relatively easy to install a small charger. The other 40% of the car fleet will depend on the urban public infrastructure to recharge their batteries, as most of them won’t have access to a parking space at work.
On average, a battery passenger car in the EU consumes around 50 kWh/week. Three main prototypes of public recharging exist: high-power charge stations (equivalent to a petrol station), chargers in commercial areas (typically 22-90 kW) or chargers in residential areas (3.7-11 kW). High power chargers have limited flexibility. Here drivers usually seek the maximum power in the shortest amount of time possible In a commercial area, the vehicle will need between one to two hours a week, while in a residential area, the car can be plugged in for more than 12 hours a day (even more during weekends) replicating the use case of people with off-street parking at home. In other words, in residential areas, the vehicle can be plugged in for 64-times longer than in a commercial location.
[1] https://insideevs.com/news/564628/europe-plugin-car-sales-2021/#:~:text=Thanks%20to%20the%20strong%20second,in%20ten%20was%20all%2Delectric.
[2] https://www.transportenvironment.org/discover/evs-will-be-cheaper-than-petrol-cars-in-all-segments-by-2027-bnef-analysis-finds/
[3] Elia Group “Accelerating to net-zero: redefining energy and mobility”
[4] Smart charging: integrating a large widespread of electric cars in electricity distribution grids – EDSO, 2018
[5] Exceptions such as underground parking lot, where Wi-Fi to is impossible may exist or through location management system.
[6] https://www.concerte.fr/system/files/concertation/Electromobilite%CC%81%20-%20Synth%C3%A8se%20vFinale.pdf
[7] “Connecting the dots: Distribution grid investment to power the energy transition”, Monitor Deloitte, E.DSO & Eurelectric, January 2021
[8] Currently, and assuming that the availability band made available by the e-buses in depot is 50 KW, it is expected that “Bus 2 Grid” will reduce the costs of the infrastructure to zero and generate additional annual revenues of €1000 per bus. Enel Foundation 2021 “Scenari E Prospettive Dell’elettrificazione Del Trasporto Pubblico Su Strada”.
Ou response to the consultation on the Transeuropean Network of Transport (TEN-T)
TEN-T
Our response to the consultation
The Platform for electromobility welcomes the EC proposal for a revision of the TEN-T guidelines as a necessary instrument to make transport modes more sustainable by setting firm incentives and requirements for transport infrastructure development.
In particular, we welcome:
- The introduction of “The promotion of zero emission mobility in line with the relevant EU CO2 reduction targets” as first point in the Sustainability’s objective of TEN-T.
- The direct link to AFIR provisions on the deployment targets of charging infrastructure for LDV & HDV as well as for the onshore power supply infrastructure.
- The extended core network to be completed by 2040.
However, some adjustments to the proposal are deemed necessary:
Promotion of the transition towards a clean and zero-emission transport system and fostering its charging infrastructure. The “energy efficiency first” principle should be reflected in planning and investment decisions related to the deployment of recharging and refueling infrastructure. The “zero-emission” solutions and deployment of related infrastructure should be explicitly identified within the additional priorities in the promotion of projects of common interest (PCI) for all transport modes. The TEN-T is closely linked to the TEN-E, hence it is paramount to reinforce and support the seamless integration of EV and charging infrastructure with the energy system stimulating solutions such as “energy storage” and “vehicle grid integration”.
Covering regions beyond the Core Network. The deployment targets of charging infrastructure along with the comprehensive TEN-T network as foreseen in the AFIR proposal for LDV should be brought forward as per the Core network. It will fill the gap in terms of social and economic disparity.
Consistency with the AFIR revision. The proposed TEN-T regulation includes clear provisions on indicators for the provision of alternative fuel recharging/refueling infrastructure for the different modes of transport. Its successful implementation will strictly depend on the synergies between the TEN-T and the AFIR, as both are intrinsically dependent on each other. For example, the AFIR proposal regulates the provision of charging/refueling points on the TEN-T network, while the TEN-T Regulation provides the infrastructural basis for their wide deployment from an EU network perspective.
Introduction of the reference to alternative fuels for rail. There is potential for alternative fuels as a complement, particularly where direct electrification is not a viable option. In particular, Art. 14 extends the list of rail infrastructure components including rail services facilities, rail access routes and last mile connections. However, it is sometimes not feasible or economically relevant to mandate direct electrification for some of these segments of the network. In these specific cases, possibility should be opened to offer zero-emission solutions based on alternative propulsion systems (e.g., battery trains). A more flexible derogation process under Art. 15 should also be considered to allow for the deployment of such technologies.
Guarantee of an appropriate level of funding. In this sense, the EC considers that the largest part of investments is estimated to originate from public funding (national public funds, EU funds) and would amount to €244.2 billion over 2021-2050. As possible and suitable additional funding support, the budget for Connecting Europe Facility (CEF) transport could be increased. In addition, given the significant funding allocated to mobility infrastructure including the TEN-T Network within Member States’ National Recovery Plans (NRPs), the tight deadline for the commitment of funds (2023) and its subsequent implementation (2026), the Platform supports the Commission to increase and facilitate further synergies between CEF and funding from the NRP and the Cohesion Policy Programs.
Reaction Paper to the new Article 12 “Infrastructure for sustainable mobility” (EPBD)
Reaction Paper to the new Article 12 “Infrastructure for sustainable mobility” of the Revision of the Energy Performance of Buildings Directive (2010/31/EU, EPBD)
Last year, 2021, set a record for the battery electric vehicle (EV) sales, which achieved 10%[1] of total sales in the European automotive market. This trend is expected to continue to rise, driven by the new ambitious objectives set by the EU along with the national recovery plans implemented by Member States. However, the challenge remains immense. Indeed, the number of EVs is set to increase throughout the EU as a result of the proposed ban of internal combustion engines (ICE) sales by 2035, set out in the revision of the Regulation on the CO2 standards for cars and vans as part of the Fit for 55. Consumer demand for electric bicycles is also increasing strongly, with more than 4.5 million units sold in 2020, representing more than 20% of total sales.
If Europe is to succeed in its transition towards zero-emission mobility, the correct charging infrastructure needs to be put in place to push the EV market into achieving the required growth and ensuring a positive customer experience. Here, the deployment of private charging is of the utmost importance for encouraging the growth of electromobility, as 90% of all charging takes place at home or in the workplace. However, the current electromobility provisions of the Directive on the energy performance of buildings (EPBD) will fall significantly short in establishing the right conditions for the widespread adoption of EVs.
The Platform for electromobility therefore fully supports the revision of the EPBD
The Platform for electromobility therefore fully supports the revision of the EPBD presented in December 2021, as it is the main EU legislation for addressing private charging. The introduction of Art. 12 in the Commission’s proposal, which relates to electromobility in buildings, is therefore central to supporting zero-emission mobility in the EU. In particular, the Platform welcomes the:
However, the Platform believes that further improvements are needed, and has therefore set out five recommendations:
Clarify the scope of application of Art. 12.
The way Art. 12 is currently drafted could be interpreted as meaning that requirements only apply to parking spaces if ‘the car park is physically adjacent to the building’ but not if it is ‘located inside the building’. We believe this is not the Commission's intention and therefore ask for further clarification.
Ensure charging solutions in existing buildings.
Some 80% of the EU’s current building stock will still be in use by 2050, with the average annual major renovation rate just 2.7% for non-residential buildings and 1.5% for residential buildings. As a result, the EC should ensure the installation of charging points in existing buildings.
Completing the charging requirements for new and under major renovation buildings.
The Platform asks to complete the charging requirements for new buildings and buildings undergoing renovation in order to mandate the deployment of smart-charging ready recharging points in all new and existing buildings.
Reinforce the deployment of smart charging functionalities
The development of smart charging and bidirectional charging (V2G) in buildings is an opportunity for EV users. It provides a superior charging experience and reduces the consumers’ electricity bill. Indeed, in France, on average with V2G, the annual cost of recharging an electric vehicle is 240€/year, compared to 420€/year without smart charging functionalities. The Commission has recognised, in its AFIR Impact Assessment, that every smart recharging point could on average create a system benefit of more than 100€/year by 2030. Smart charging also reintegrates electricity surpluses into the grids (V2G) and/or reuse it in the buildings (V2B) and homes (V2H), as well as supporting the uptake of electromobility. It can also create synergies with renewable energies, by integrating them into the electricity grids and providing flexibility services to the system. Furthermore, smart charging complements the right-to-plug by ensuring that charging points optimise the use of the grid capacity of a building and removes the argument that grid connections need to be reinforced.
Reinforce the measures to ensure pre-cabling
Pre-cabling of buildings should refer to both the technical cabling (cable path, technical sheaths, drilling) and the electrical pre-equipment in collective electrical installations (switchboard, horizontal electrical column, bus cable).
The comprehensive pre-cabling of buildings will enable the subsequent connection of individual charging points, at minimum cost, by simply installing a home charger. Furthermore, the pre-cabling of renovated buildings is a low hanging fruit, with little cost involved when done during the construction phase – which is the most efficient way to do it. Cabling after construction is completed is not cost-efficient and would lead to highly cumbersome discussions with project developers. Ducting infrastructure is a future-proof and cost-effective solution, the installation cost of which is minimal when compared to the total cost of constructing or renovating a building. By way of comparison, failure to ensure ducting infrastructure would entail costs that could be up to nine times higher if a building needs to be retrofitted.
EPBD: Our support to the proposal
The Platform for electromobility therefore fully supports the revision of the EPBD presented in December 2021, as it is the main EU legislation for addressing private charging. The introduction of Art. 12 in the Commission’s proposal, which relates to electromobility in buildings, is therefore central to supporting zero-emission mobility in the EU. In particular, the Platform welcomes the:
- Guarantee to the right-to-plug in all buildings and the removal of regulatory barriers (Art. 12. 8)
- Obligatory pre-cabling of all new and under-renovation buildings.
- Requirement for smart charging-readiness for all new and renovated chargers, as well as bidirectional chargers (V2G) when appropriate (Art. 12.6)
- Reinforcement of the charging requirements for new and renovated buildings (Art. 12.1, 12.2 and 12.4)
- Lowering of the existing parking space thresholds for pre-cabling and installation of charge points for all new and renovated non-residential buildings (Art. 12.1, 12. 4)
- Requirements for bicycle parking (Art. 12.1 – 12.4)
- Suppression of the unnecessary exemptions, particularly those applied to SMEs in article 8(4).
EPBD: Reinforce the measures to ensure pre-cabling
Pre-cabling of buildings should refer to both the technical cabling (cable path, technical sheaths, drilling) and the electrical pre-equipment in collective electrical installations (switchboard, horizontal electrical column, bus cable).
The comprehensive pre-cabling of buildings will enable the subsequent connection of individual charging points, at minimum cost, by simply installing a home charger. Furthermore, the pre-cabling of renovated buildings is a low hanging fruit, with little cost involved when done during the construction phase – which is the most efficient way to do it. Cabling after construction is completed is not cost-efficient and would lead to highly cumbersome discussions with project developers. Ducting infrastructure is a future-proof and cost-effective solution, the installation cost of which is minimal when compared to the total cost of constructing or renovating a building. By way of comparison, failure to ensure ducting infrastructure would entail costs that could be up to nine times higher if a building needs to be retrofitted.
Key recommendations:
- Introduce an explicit definition of pre-cabling, in order to encompass the electrical installation; it should not be limited to ducting infrastructure. To secure efficiency, electrical installations should be considered as ‘technical building system’ (Art. 2.6).
- Inform on the readiness of any building to safely install an EV charging point into the Energy Performance Certificates (Annex V).
- Integrate Energy Performance Certificates information about the status (safety and readiness) of electrical installations (Annex V)
- Set up local or regional one-stop-shop accessible websites and portals that combine various services, including the right to request with streamlined permits and installation procedures.
- Ensure that requests for installing charging stations in collective properties do not exceed three months. (reinforce ‘right to plug’).
- Address the administrative hurdles (for example, EV charging as extra-legal benefit for employees) as well as collective action problems (such as split incentives between EV and non-EV drivers, renters vs. owners, employee vs. employer, etc.).
- Encourage Member States to financially support the installation of EV charging in buildings (including depots and logistic hubs for trucks, light-duty vehicles and buses). The Commission and its co-legislators, including the Member States, should also examine the possibilities of using new and current financial instruments to stimulate investment in private charging infrastructure.
EPBD: Reinforce the deployment of smart charging functionalities
The development of smart charging and bidirectional charging (V2G) in buildings is an opportunity for EV users. It provides a superior charging experience and reduces the consumers’ electricity bill. Indeed, in France, on average with V2G, the annual cost of recharging an electric vehicle is 240€/year, compared to 420€/year without smart charging functionalities.[1] The Commission has recognised, in its AFIR Impact Assessment, that every smart recharging point could on average create a system benefit of more than 100€/year by 2030.[2] Smart charging also reintegrates electricity surpluses into the grids (V2G) and/or reuse it in the buildings (V2B) and homes (V2H), as well as supporting the uptake of electromobility. It can also create synergies with renewable energies, by integrating them into the electricity grids and providing flexibility services to the system. Furthermore, smart charging complements the right-to-plug by ensuring that charging points optimise the use of the grid capacity of a building and removes the argument that grid connections need to be reinforced.
Key recommendations:
- Ensure that all newly installed chargers in buildings are capable of smart charging.
- Ensure consistency in the definitions and provisions on smart charging set in the revision of the EPBD with those proposed in the new Regulation on the deployment of alternative fuels infrastructure - which is replacing the current AFI Directive 2014/94/EU (in Art. 2 and 5) - and in the revision of the Renewable Energy Directive.
- Ensure the recognition of mobile storage in the European energy framework.
- Clarify that bidirectional charging (Art. 12. 6) should be encouraged when demonstrating a positive socioeconomic impact and contributing to system efficiency. Co-legislators should also address any remaining barriers for vehicle-to-grid technologies.
[1] [In French] RTE (2019), Report on the development of electromobility.
[2] AFIR Impact Assessment, Annexes, page 86.
EPBD: Completing the charging requirements for new and under major renovation buildings.
Completing the charging requirements for new and under major renovation buildings.
The Platform asks to complete the charging requirements for new buildings and buildings undergoing renovation in order to mandate the deployment of smart-charging ready recharging points in all new and existing buildings.
Key recommendations:
- Include depot charging for heavy- and light-duty vehicles, i.e. extending the scope of the EPBD to cover new or renovated private depots, as well as logistic hubs and distribution centres. This would require them to be ready for future battery electric truck charging (350 kW+ chargers), so that trucks can conveniently charge while loading/unloading. This should include pre-equipment, as well as an appropriate grid connection.
- Charging facilities for e-bikes should match those for e-cars. There are two options:
- recharging points for electric vehicles would be equipped with a household power socket, allowing for the easy charging of both e-bikes and e-scooters as well as certain types of L-category vehicles such as e-mopeds, or
- deploy a separate bicycle charging infrastructure, with dedicated bicycle recharging points.
- The requirements should apply to all buildings that are undergoing a major renovation, regardless of whether the car park is included in the renovation measures.
- Greater ambition for parking spaces for non-residential buildings; there should be a minimum of 50% of parking spaces with charging points.
EPBD: Ensure charging solutions in existing buildings.
Some 80% of the EU’s current building stock will still be in use by 2050, with the average annual major renovation rate just 2.7% for non-residential buildings and 1.5% for residential buildings.[1] As a result, the EC should ensure the installation of charging points in existing buildings.
Key recommendations:
- Extend the scope of Art. 12 to ensure requirements for installing charging points in existing buildings. Incentives or enforcement mechanisms, to make sure that the stakeholders involved comply, should be introduced.
- Avoid putting a disproportionate burden on building owners and tenants, by addressing the necessary elements to reduce the costs of private charging installation.
- Introduce per-cabling requirements for existing buildings:
- 2027: all parking spaces in 15% of all buildings
- 2030: all parking spaces in 30% of buildings (100% for all publicly owned buildings)
- 2035: all parking spaces in all buildings.
- More ambitious charging point requirements for non-residential buildings (15% of parking spaces (2030), 30% (2035) applicable for all buildings with more than ten parking spaces.
[1] EPBD Impact Assessment.
Platform general comments for the trilogue negotiation on Battery Regulation
Battery Regulation
Our recommendations for trilogue
During current trilogue negotiation on the Battery Regulation between institutions, we welcome several changes introduced by the European Parliament (EP) and Council. Notably, we support:
✓ The change of scope for the carbon footprint declaration per battery model and plant, rather than per batch, as initially proposed by the Commission.
✓ In the EP text, ambitious deadlines for recycling and material recovery conditions for batteries on the European market whether they are imported or not.
✓ We welcome the emphasis on the waste hierarchy and the clarification on reuse of batteries when available on the market, notably the explicit transfer of Extended Producer Responsibility from producer to second user.
✓ Both texts base due diligence obligations on the UN Guiding Principles on Business and Human Rights and OECD Guidelines for Multinational Enterprises, and that both EP and Council have strengthened the environmental risk categories in Annex X.
✓ The Grandfathering clause for spare parts proposed in the EP text.
We have however reservations and will remain vigilant on the following points:
Timeline & targets
The innovative approach of this regulation requiring multiple new sustainability criteria declaration and control, accompanied by close to 40 currently unknown secondary acts, is a first in terms of implementation.
➢ Recommendation: ample resources should be dedicated by lawmakers to ensure that the proposed targets and timelines for the implementation of the new sustainability criteria can be met.
Guarantee of origins
Concerns over the explicit possibility in the Council text to use guarantees of origin alone as proof of clean and renewable energy for the purposes of the battery carbon footprint calculations.
Recycling and end of life
Binding recycling content should always go hand in hand with a careful assessment of the environmental costs and benefits, and compatible with the real technological state of the art and availability of recycled materials.
Further, availability of batteries for second life must be considered. We would like to stress that EV batteries should always be handled by professionals with a certain level of qualification, and that the same goes for potential EV battery waste. Minimum conditions for battery recycling outside Europe should be ensured, accompanied by a deadline for when such conditions must be established. This can help to get extra-EU battery recycling industry ready for incoming EOL battery volumes.
➢ Recommendation: Recycling targets in Article 57, Annex XII must be brought forward in the Council text (in line with the timelines proposes by the Commission) to reflect the vital need for a domestic supply of raw materials. At the same time, the possibilities for reuse must be clarified as more EV batteries are available for second life.
The substances needed for EV batteries should always remain in a waste loop. Future potential restrictions of substances must take into consideration the strategic autonomy objective of the EU battery sector, the performance of EV batteries and the closed loop of the substances needed for batteries. In addition, second-life batteries should not be exempted from obligations on performances and durability.
Removability
We want to highlight the significant technical difficulties, safety and performance challenges coming with the EP’s proposed removability and replaceability requirements for EV and industrial batteries at cell level. Such requirements would remove any incentive or space to innovate and contradicts the idea of longer lasting and better performing batteries if battery pack designs are not allowed to change over time.
➢ Recommendation: we do not support the extension of the removability and replaceability requirements to all batteries at cell level, as they would threaten the performance, safety, and technical integrity of the whole battery. We therefore call on maintaining the Commission’s current article 11 setting removability and replaceability requirements for portable batteries only.