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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Source: https://web-assets.bcg.com/82/0a/17e745504e46b5981b74fadba825/is-e-mobility-a-green-boost.pdf 

The members of the Platform for electromobility, which brings together more than 40 members from  across all transport modes, are fully committed to promote sustainable mobility solutions and contribute to the on-going European green transition.

The Platform welcomes the EU’s initiative to establish a European Taxonomy to classify economic activities and direct public and private funding towards sustainable investments. This will be essential to achieve the ambitious climate targets of 2030 and 2050 set by the European Green Deal and the Sustainable and Smart Mobility Strategy . As transport is responsible for 27% of emissions at EU level, the European Taxonomy will play a key role in informing investors on sustainable transport activities and guiding decisions towards green investments.

Following the first reporting exercise of 2022 and the Commission’s intention to focus on the “usability” of the published Taxonomy delegated acts, the Platform would like to relay a number of observations commonly shared by its members representing the whole electromobility value chain.

• Some of the key players in the e-mobility value chain, such as the main suppliers, do not necessarily have all their economic activities covered by the taxonomy categories included in the climate delegated act, despite their significant contribution to the manufacturing of more sustainable products (BEVs, trains, etc.). This is mainly due to the fact that the taxonomy categories mainly focus on the activities of the OEMs and not necessarily on the activities of upstream suppliers[1].
• The Platform’s proposal would be to allow suppliers and subcontractors to disclose their activities in the same category as the corresponding OEM activity, particularly where these upstream activities supply single purpose technologies to be used exclusively in taxonomy-aligned assets. This would better reflect their real contribution to sustainable products, while encouraging sustainable financing of the entire electromobility value chain segments

Most of the transport activities are largely covered by the first Climate Delegated Act. Therefore, a number of companies are already preparing to report on the Taxonomy-alignment from 2023. In order to carry out this exercise, the Platform would welcome clarification on the interpretation of the Do No Significant Harm principle (DNSH) criteria on pollution and in particular on the use of substances (listed in Appendix C). These raise usability concerns, because of the difference in scope of the pieces of legislation referred to in Appendix C (notably REACH and RoHS) and the requirements of that appendix. In particular, the concept of essential use not defined in EU legislation may lead to differences in appreciations by economic operators. As a result, the information available to taxonomy users may be lacking.

• In order to avoid difficulties in proving alignment with the DNSH criteria and differences in the implementation thereof, the Platform calls for the Commission to ensure that the information gap is bridged.

• A number of delegated acts and derived documents (e.g. FAQs,) were published well after the adoption of the taxonomy regulation, even though the first eligibility reporting exercise for activities covered by the climate delegated act was required in 2022.
• The Electromobility Platform requests the stakeholders to be given appropriate time to prepare for the reporting and to have all the necessary clarifications and interpretations to fully implement all three sets of alignment criteria (substantial contribution, DNSH and minimum safeguards).

• The EC considers that the largest part of investments to complete the Trans-European Transport Network (TEN-T) is estimated to originate from public funding (national public funds, EU funds) and would amount to €244.2 billion over 2021-2050. However, to complete the core infrastructure of the TEN-T for all modes of transport, €750 billion between 2016 and 2030[2] is required. Considering the public funding contribution will cover only a limited part, a massive private investment injection will still be needed to complete the TEN-T infrastructure and achieve decarbonization objectives in the coming years.
  • The Platform’s calls the European Commission to ensure a full taxonomy eligibility of electromobility members’ economic activities in order to preserve the future required investments for the e-mobility sector.

All these elements should be taken into account when amending the existing delegated acts and adopting future delegated acts & FAQs. In particular, these considerations should enhance the positive signal of the Taxonomy for electromobility technologies, which will contribute to decarbonising transport, at a time when the Green Deal objectives need more than ever to be accompanied by a coherent Taxonomy framework to finance the transition.

[1] Sometimes the NACE codes included in the Climate Delegated Act  appear to be not entirely exhaustive and sometimes even misleading.

[2] According to the latest Core Network Corridor Work Plans,

The Platform for Electromobility supports the overall greenhouse gas emissions reduction target of 55% by 2030 and the climate neutrality objective by 2050. Reducing – and ultimately eliminating – emissions from cars, vans and trucks will be key to achieving these objectives.

The Platform for Electromobility would like to emphasise that the EU CO2 standards regulation delivers genuine benefits for transport, setting clear signals to both car makers and consumers on the required pace for the transition to zero-emission mobility. This regulation is the most effective way to do so, when compared to the extension of the ETS system to road transport.

The future cars and vans CO2 legislation will increase the offer and promote the market uptake of zero-emission vehicles. With an increased market, zero-emissions vehicles will also become more affordable with a continuously reduced total cost of ownership and more choice for consumers and will also help tackle air quality and noise issues, bringing an overall benefit to society.