Recommendations for the deployment of sustainable infrastructure of BE HDVs

Logistics & Infrastructures

Driving the adoption of Battery Electric Heavy-Duty Vehicles

General policy recommendations for the deployment of sustainable infrastructure

Download PDF here

The members of the Platform for electromobility recognise the importance of driving uptake of the required infrastructures for Battery Electric Trucks and buses (BEHDVs). They also recognise the need for policy recommendations that complement the Alternative Fuels Infrastructure Regulation (AFIR) and Energy Performance of Buildings Directive (EPBD).

The challenges in this area span multiple sectors, from energy, through land management and on to data security. We therefore emphasise the importance of cooperation between all sectors of the electric road transport system, resulting in this paper, which outlines the key elements that legislators should keep in mind when addressing this topic.

In this position paper, we identify three areas that require attention and provide policy recommendations to ensure the successful roll out of infrastructures for BEHDVs: the grid, the data framework and the land.

Beyond infrastructure (which this paper is dedicated to), we stress the importance of ambitious, clear and timely revision of both the CO2 Standards for trucks and buses Regulation and the Weights and Dimensions Directive. We have discussed both of these in previous publications (respectively here and here).

The grid

A. Assessments: per country and per usage

While strong CO2 Standards would prove useful for anticipating actual and future demand, a situation where a grid connection may not be available can potentially undermine the trajectory defined by those new CO2 Standards. It therefore becomes urgent to immediately and proactively assess whether there is sufficient potential grid-capacity to allow for sufficient connection for the charging infrastructure needed for BEHDVs. Assessment becomes all the more pressing when considering the lengthy lead times, the need for grid reinforcement, the likely demand for BEHDVs and the number of actors involved.

Grid infrastructure varies between countries. Some may need important investments in order to prepare for the integration of BEHDVs, with the development of megafast chargers where required. In the Netherlands – a European Member State at the forefront of road transport electrification (along with other such as Germany and, to a lesser extent, Belgium) – it appears to be extremely difficult for transport operators to obtain the needed capacity for BEHDVs, both at their depots and on the road, due to a lack of effective planning. Even where capacity increases are possible, long delays for connection and procedural constraints present barriers to the swift adoption of BEHDVs.

Grid infrastructure varies between usages. While large charging hubs for BEHDVs along motorways will be the exception and the depot/destination charging overnight the rule, the need for very high-level connection capacity along the motorway should be tackled. Medium- and high-voltage connections to the power grid will be necessary to support the fast charging times in the event of opportunity charging. To deliver the necessary power capacity, grid strengthening may be required at both public locations and – for different reasons – at private charging depots/distribution centres.

BEHDVs-suitable charging locations can be mapped and the power needs for those locations assessed. Recent existing mapping[1] – based on the GPS records of large numbers of trucks routes during one year throughout Europe – can provide a good starting point. Truck stakeholders can subsequently confirm or propose new locations for the recharging infrastructure and the power required. Distribution System Operators (DSOs) and Transmission System Operators (TSOs) should confirm whether there is sufficient capacity and, where necessary, propose alternatives.

We would welcome support for undertaking a similar mapping exercise for coaches and interurban buses. Such analysis would also support the task forces (see below) in deciding the pre-equipment needed for depots and distribution centres, as well for existing service stations. This would ensure that delays in installing charging stations for BEHDVs do not exceed reasonable timescales.

Mapping analysis shows some 10% of locations will account for half the opportunity charging stops.[2] Pre-identifying these would help accelerate the coordinated development of charging infrastructure for BEHDVs and facilitate discussion within the dedicated task forces.

B. Task Forces

The task forces – constituted as follows – should be established and moderated by transport ministries or designated government agencies. National task forces: DSOs or their representations; TSOs; manufacturers of BEHDVs, BEHDVs operators and national associations[3]; representations of energy aggregators operators; fleet managers; road and urban planners; national Charging Point Operator (CPOs) associations.

Such task forces would be well suited for indicating the investments required to extend and reinforce charging infrastructure and to determine suitable charging locations and power requirements. This will enable DSOs and TSOs to plan the necessary grid extensions and reinforcements. This is extremely important for those areas that are not being developed by project developers due to high investment costs and long lead times for grid connections. The bottom line for achieving a comprehensive approach to planning involves early engagement with fleet managers, road operators, local municipalities, CPOs and grid utilities. Such an approach helps in proactively addressing public acceptance, potential land use challenges and in establishing a workable and timely power delivery schedule.

C. National deployment plans

In order to forge a stronger link between the AFIR implementation and the deployment of charging infrastructure for BEHDVs, we propose that Member States base their own national deployment plans on the AFIR targets, reflecting the anticipated demand at each location.

These plans should align with the anticipated demand for BEHDV charging, while also considering such factors as traffic density and projected growth in BEHDV usage and stops. By adopting such an approach, Member States can provide network operators and other stakeholders with longer lead times for planning future infrastructure uptake and anticipated connection requests, particularly post-2030.

D. Public & private investments

A high-capacity grid does not come without costs. Ultrafast charging stations are expected to require large MVA network connections, which usually occur directly at high voltage level but can also occur at MV level, depending on Member State specificities.

Well-designed European financing programmes can attract private investments for BEHDV infrastructure development. To facilitate implementation, and considering the high CapEx involved, public funding should be made available: The Connecting European Facility (CEF) is a vast programme, one that is primarily focused on passenger cars rather than on BEHDVs. This limits its alignment with the needs of the heavy-duty vehicle sector. Typically, the Alternative Fuels Infrastructure Facility (AFIF) Call of the CEF Programme supports BEHDVs infrastructure between 150kW and 350kW while for 800kW and higher, power the financial solutions provided by European Commission are too limited. The annex should be adapted to better take account of the needs of BEHDVs.

2. The Data Framework

A. Align grid codes, regulations to ultrahigh-power charging standards under development

The introduction of ultrahigh power charging standards necessitates global and European recognition. When being designed, standards should take into account factors such as space and interoperability as well as the futureproofing of those ultrahigh power charging standards currently under development. Any existing regulations that did not anticipate BEHDVs and their charging infrastructure must be updated to in order to accommodate this new paradigm. Definitions of technical aspects and use cases must be integrated into existing technical codes and regulations. Temporary exceptions will likely be required in areas such as standardised and certified energy metering concepts, which are currently lacking for megawatt charging. Member States should implement standards for BEHDV infrastructures for both public and private applications. Last, it is not possible to apply to EU funding for deployment of standards that have yet to be adopted.

B. Harness the flexibility potential of BEHDVs

Smart and bidirectional charging can be key in increasing the uptake of renewable energy and in offering flexibility potential to the grid. While initially this may seem challenging to implement, given the fast-charging requirements dictated by the road transport business model based on opportunity charging. Yet, the potential to harness the flexibility of the BEHDVs is actually significant, particularly considering their battery sizes, the high predictability of their routes and time schedules and the predominance of depot/overnight charging.

Smart energy management systems can therefore be deployed, specifically through the implementation of balancing mechanisms between connectors. This will synchronise with renewable energy production and provide a fast-frequency response to keep the grid stable. This would further require signals to use the flexibility from batteries, such as incentives for aggregators and dynamic tariffs, etc. Beyond advanced planning, tariffication incentives and financial incentives in the grid services markets are other crucial elements for minimising grid impact and allowing potential grid balancing.

Bidirectional and smart charging can be particularly suitable for certain business models, notably buses and trucks that are not operated on a 24/7 basis (short-haul and regional transport). Their large batteries can offer key services to the grid. Smart meters should be considered as one of the solutions for smart charging in depots and distribution centres. However, regulatory frameworks will need to be adapted in order to enable bidirectional charging and provide economic incentives.

Finally, the sector is currently exploring the potential of flexible storage positions within local energy systems, such as incorporating stationary batteries into charging stations or exploring battery swapping solutions. Such approaches can help reduce the strain on the grid, offering advantages to both charging operators and system operators by enhancing flexibility. In addition, configurations integrating renewable energy sources on site should be examined for smart charging, as they have the potential to mitigate expected peak loads.

C. Data sharing for smooth logistic operations

A proper regulatory framework would also enable data and information exchange along with digitalisation for cross-sector integration:

Smooth reservation and non-discriminatory access to, and reliable operation of, public recharging infrastructure can accelerate the transition to BEHDVs. Standardised data sharing and interoperability between value chain players are a prerequisite for third-party operators of smart charging services and for the proper functioning of smart charging technologies.

Currently, however, data sharing and interoperability are often limited, which can lead to inefficiencies and reliability challenges. For example, charging point operators may not have access to real-time data on the location and battery state of charge of heavy-duty trucks. This in turn can make it challenging to plan optimal power needs and manage the charging process. Likewise, logistics operators may not have access to real-time data on the availability of charging infrastructure, which can lead to delays in delivering goods. There are multiple data types for multiple use cases that require a minimum of data sharing across the industry to enable efficient logistics and reliable charging.

Agreeing minimum specific list of data points for BEHDVs, interoperability standards and developing a robust, open and non-discriminatory data sharing framework will allow logistics operators, truck manufacturers, grid and charging point operators to put solutions in place for improving the reliability and efficiency of logistics operations and recharging infrastructure.[1] The European Commission should support the parties involved, with the aim of establishing an open data-sharing framework built around a set of industry-agreed data types, made accessible to the market and public authorities. Ultimately, it should strive to establish a reliable European legal framework for smooth data exchange for electric HDV recharging operations throughout the EU.

D. Understand the charging patterns

Last, further research is required to understand the charging patterns and to demonstrate the cost opportunities for transport operators and Mobility Service Providers (MSPs) of participating in the flexibility services market. TSOs – in collaboration with fleet operators – can play a crucial role, for example by introducing pilot projects and regulatory sandboxes to gather experience on grid impacts and reactions to time-varying tariffs, and to eventually assess the real flexibility potential.

The Land

A. Quantity: Sufficient space for trucks and buses public and private charging

According to the European Commission[1], there is a shortage of around 100,000 suitable parking spaces for HDVs, of which only around 54,000 offer a reasonable standard of safety. We can therefore no longer ignore the shortage of parking space for truck drivers. This current lack of parking leads to improperly parked trucks, leading to both environmental and safety issues for truck drivers and other road users and places a considerable burden on truck drivers. Even existing parking areas frequently lack adequate facilities or are in a state of disrepair.

The need for additional charging infrastructure created by the advent of electrification makes these issues even more acute. Consequently, the availability of ample parking space – now in parallel with charging facilities – represents more than a mere convenience; rather, it is an indispensable prerequisite for driving the transition to a decarbonised transport system.

B. Quality: Safe and Secure Truck Parking Areas (SSTPAs) suited to charging

Private investment in constructing increasingly costly infrastructure such as large-scale parking facilities, warrants reinforcement through European and national public funding initiatives. Such incentives include grants, tax benefits and subsidies geared to attracting private investment in the construction of parking areas with integrated charging stations for BEHDVs. Such moves can help offset initial infrastructure costs and incentivise the expansion of such facilities. While establishing more ambitious – yet attainable – targets for each Member State at an EU level emerges as a sensible strategy, the reality of achieving these minimum standards is frequently faced with lack of available land, particularly in densely populated areas. To overcome this challenge, the EU should support Member States in pursuing following options:

  • Earmarking publicly owned land for investors to develop new parking and charging spaces. Alternatively, streamlining the permitting process and alleviating bureaucratic complexities to incentivise private investments in additional parking capacity.
  • Enhancing the synergy between private landowners and operators of parking and charging spaces through improved matchmaking mechanisms and by leveraging digital platforms.
  • Tendering (greenfield) locations where investors are hesitant via a ‘concession model‘, eventually combined with incentivised deployment on certain locations. In a concession model, governments can accelerate permitting and realisation of grid connections.
  • Cooperating with system operators to secure grid capacity on shared (or tendered) locations.

C. Must-have for market models

Other market models (land sale, rental, long lease) are viable alternatives, but lead to more commitment in implementation (profitable business case, cooperation, multiple operators on one site). All market models should consider monopoly on ‘premium’ sites, market forces in designated locations, differences between HDV and LDV infrastructure markets and maximising market forces.

D. The role of concession holder

In essence, the role of concession holder can play an ever-more prominent role in accelerating the market by:

  • Taking the lead in all restrictive conditions (such as grid connection, land ownership)
  • Securing grid capacity before locations are offered for tender. Participate with system operators to secure grid capacity on multisite (multiple operators using a single grid connection). Facilitate consortia to own and initiate a shared site with multiple operators of zero emission infrastructure.
  • Acting as a bridge function in sharing construction and basic infrastructure costs when multiple operators settle on a site (such as direction on site layout, site paving).
  • Promoting a location for charging infrastructure operators by attracting other services (retail, hospitality, etc).

Don't miss future publications

The Grid



[3] Shippers and carriers such as TLN in the Netherlands or RHA in the United Kingdom.

The Data Framework

[1] Smart charging, BET eRoaming, Plug and Charge, Value Added Services (i.e., Preconditioning), flexibility provision services in relation to battery degradation patterns etc.

The Land


Recommendations to trilogue negotiators on EPBD

EPBD Trilogue
Our recommendations to negotiators

Download PDF here

In 2023, battery electric vehicle (EV) sales reached a milestone, accounting for 15% of total sales in the European automotive market. At the same time, about 25% of bicycles sold are e-bikes. These positive trends are expected to continue, driven by ambitious EU objectives and legislations and national recovery plans.

To ensure the success of Europe’s transition to zero-emission mobility, the deployment of private charging infrastructure is of utmost importance, given that 75% of all charging takes place at home or in the workplace. While the EPBD consider the upcoming needs of electromobility, we believe that safeguarding the strongest agreements are needed to establish the right conditions for widespread EV adoption.

The Platform for electromobility fully supports the revision of the EPBD, particularly the introduction of Article 12, which focuses on electromobility infrastructure in buildings. We commend to preserve provisions that guarantee a strong and coherent right to plug in all buildings, remove regulatory barriers, and require smart charging-readiness for new and renovated chargers, among other measures.

As the EU institutions start trilogue talks, it’s clear the European Parliament wants more than the Council. But the many exceptions for installing infrastructure could make things confusing and inconsistent across Europe, we would like to present five additional recommendations:

  1. Clarify the scope of application of Art 12

The current wording could be interpreted restrictively. We seek clarification to ensure that requirements apply to parking spaces both adjacent to and inside buildings.

  1. Ensure charging solutions in existing buildings

Given that a significant portion of existing buildings will remain in use by 2050, we propose extending the scope of Article 12 to require clear and transparent rules for EV charging points in existing buildings. Incentives and compliance mechanisms should be introduced.

  1. Complete charging requirements for new and renovated buildings

Extend requirements to cover depots, logistic hubs, and distribution centres, ensuring they are ready for future EV charging.

  1. Reinforce smart charging functionalities

Mandate that all newly installed chargers in buildings are capable of smart charging. Ensure consistency in definitions and provisions with related regulations and recognize the value of mobile storage.

  1. Reinforce measures to ensure pre-cabling

Provide an explicit definition of pre-cabling, inform about readiness in Energy Performance Certificates, and simplify permit and installation procedures. Address administrative hurdles and encourage Member States to financially support EV charging installations.

  1. Ensure adequate bicycle parking:

Opt for bicycle parking to represent 15 % of total user capacity in non-residential buildings, and with space required also for bicycles with larger dimensions than standard bicycles.

  1. Reject opt outs for SMEs

98% of all commercial enterprises are SMEs, therefore the Directive would no longer apply to 98% of commercial non-residential buildings. This is a tool that is too moderate.

  1. Re-ensure provision on Right-to-plug

The Right-to-plug lowered since in point 8 both co-legislators mentioned a “request by tenants or co-owners to install CPs can only be refused if there are serious reasons for doing so”. This could weaken provision on Right-to-plug, giving the possibility to landlords and condominium assemblies to refuse the Right-to-plug and install a charging infrastructure in not so clarified cases. We call to remove or clarify the point 8.

  1. Preserving precabling

In contrast to prevailing targets, where the European Commission’s proposal advocates for 100% precabling, the Council suggests a balanced approach of 50% precabling and 50% ducting. Additionally, in the case of new and renovated residential buildings, the Parliament recommends a complete shift towards 100% ducting if 100% precabling is deemed unfeasible. However, we propose retaining the precabling targets in alignment with the European Commission’s proposal. This approach ensures the preservation of cost-efficiency in future installations and reinforces the fundamental right to access plug-in infrastructure.


Now, it’s crucial for policymakers to act and make sure that every European can charge their electric vehicles at home and work, be it an EV or an e-bike. This is where most EV charging happens already. By doing this, we can make EV charging available to everyone and fully harness the environmental benefits it offers, contributing to the development of an energy system powered by renewables.


Don't miss future publications

EU Election Manifesto: Investment Plan to Implement the Green Deal

Manifesto Second Pillar

An Investment Plan
to Implement the Green Deal

The 2023 Net Zero Industrial Act and the Critical Raw Materials Act needs an accompanying European Net-Zero Infrastructure Investment Plan. A long-term, easy-to-access investment facility – aimed at sectors key to Net Zero – should be a core issue during the European elections.

Freight and logistics infrastructure are a vital component in the movement of goods within Europe. There should be comprehensive investment in developing and deploying sustainable logistics infrastructure. The key elements for decarbonising freight in Europe while remaining competitive are the roll-out of high-power charging infrastructure required for deploying electric trucks of all ranges, the completion of a high quality, interoperable rail network with very high-speed connections, while ensuring a level playing field with other non-emitting modes of transport of goods.

Europe must also improve support for urban transport. Cities are working to accelerate the modal shift and to increase the electrification of their vehicle fleets. To avoid cities becoming the weakest links Europe should be providing parallel support to investments in zero-emission public transport networks and to the deployment of smart and efficient charging infrastructure within urban areas. To support the required local infrastructure investments, the next Connecting Europe Facility (CEF) transport programme should include a dedicated budget for urban nodes, building upon the experience of the Alternative Fuel Infrastructure Facility. Further support from EU research and innovation programmes as well as guidance, will also be needed to overcome challenges such as the constraint of public space, uneven distribution of private investments in EV charging infrastructure in cities or their integration in multimodal hubs, as well as lack of grid capacity.

Net Zero Sectors include the sustainable mining, processing and recycling of critical minerals and metals, modernising power grids and facilities for industrial material recovery as well as renewable energy production. Although existing European funds could contribute significantly, prioritising access to the current EU funding mechanisms and tailoring them to the specific needs of the sustainable transports value chain participants is essential.

EPBD: 3 Pillars to ensure the private charging of EVs

3 Pillars to ensure the private charging of EVs

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

Importance of private charging
for multifamily dwellings


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

for users and grid

Smart functionalities

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

For existing buildings


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

The added-value of electricity for mobility

The added-value of electric mobility
Platform for electromobility Statement on the Plenary vote on AFIR

View PDF Flyer

As the AFIR prepares a solid legislative basis for the decarbonisation of transport in the next years, it is important to support only clean solutions and to refuse the usage of fossil fuels. An increasing penetration of e-mobility also implies a demand-reduction for fossil-fuel, that are mostly imported from instable regions, and thus higher security of supply. The European Union should be very cautious with the list of alternative fuels. Fossil fuels cannot be alternative fuels and must remain transitional with a concrete specification of their end date.

Thus, electric mobility is the most satisfactory option and should be supported in the AFIR by a strong set of targets for charging infrastructure. Here are the 4 main reasons:

Ensure energy efficiency

BEVs are the cleanest and most efficient types of powertrains for individual vehicles (T&E, 2022). Electric cars for road transport are far more energy efficient (85-90% efficient) than ICE cars (17-21%). Regarding natural gas for vehicles (NGV), 30m3 of natural gas, converted to electricity, yields 735km in an EV but 580 km in an NGV vehicle (MIT, 2010). In terms of the rail sector, it accounts for just 2% of total EU energy consumption in transport (Commission, 2021), being the most energy efficient transport mode (T&E, 2022).

T&E, 2022
car energy efficiency
car pollution

Improve air quality

Road transport is a major source of air pollution in European cities. In 2019, 307,000 premature deaths were attributed to chronic exposure to fine particulate matter (PM). 40,400 premature deaths were attributed to NO2 exposure (European Energy Agency, 2021). In comparison to other technologies, electric vehicles produce no exhaust emissions. EVs are estimated to emit 20% less PM10 from non-exhaust sources per kilometre than internal combustion engine vehicles (ICEVs) (OECD, 2020) . Modal shift and the use of urban electric rail can improve air quality. In Europe, the rail sector’s share of total Nitrogen Oxide (NOx) and PM emissions of transport is respectively 3% and 4,5% (UCI, 2018).

European Energy Agency, 2021

Integrate renewable energy into the grid

Battery-on-wheel solutions, like bidirectional charging, can facilitate the integration of renewable energy to the electricity system. The combination of EVs, their batteries and smart charging functionalities as sources of ancillary services for the electricity grid will clearly bring benefits in terms of RES (Renewable Energy Sources) integration.

Platform for electromobility, 2022
wind and solar square
train in NL

Reach climate neutrality

Electric cars and trains are the only available technology to reach climate neutrality. Full life cycle emissions of electric cars in Europe emit, on average, more than three times less CO2 than equivalent fossil fuel cars (Transport & Environment, 2022). Rail accounts for less than 0,4% of transport related greenhouse gas emissions in the EU (Commission, 2021).

T&E, 2021

EV Charging: how to tap in the grid smartly?

EV Charging :
How to tap in the grid smartly?

Download PDF here

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.

  1. 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:

  1. it provides real-time adjustment
  2. it adjusts charging in response to external signals
  3. 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.

  1. 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.).

  1. 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.

  1. 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:

  1. 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.
  2. 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.
  3. Future-oriented: A legal definition of smart charging should be sufficiently broad, and mention benefits without mentioning technicalities, so as to include future technologies.
  4. Reactivity: Smart charging should allow adjustments that are rapid enough to deal with grid disturbances and emergencies.
  5. 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.
  6. 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.



[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.


[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)

Transeuropean Networks - Transport
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

Download PDF here

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:

Provisions we support

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.

Our key recommendations

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.

Our key recommendations

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.

Our key recommendations

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.

Our key recommendations

The 10 points for success of the new Alternative Fuels Infrastructure Regulation (AFIR)

Download PDF here

The Platform for electromobility supports the AFIR proposal, which is vital for boosting the electrification of transport and providing the right tools to drive the growth of electromobility.

In particular, the Platform welcomes:

  • The switch from a Directive to a Regulation

As supported by our members in a previous communication, a Regulation will ensure the strong, rapid and more uniform implementation in all Member States.

  • The setting of minimum mandatory targets for light-duty vehicles (art. 3)

The AFIR sends the right signals to meet the EV demand on the roads. The sales of electric vehicles (EVs) in the EU1 continue to grow. Combined with the coming ban on sales of internal combustion engines by 2035 - as proposed in the revision of the Regulation on the CO2 emission standards for cars and vans - it is key to speed-up the roll-out of charging infrastructure across Member States. This will require the deployment of operational and accessible charging points where they are needed, and capable of delivering the right power output. Combining fleet-based targets with distance-based targets on the TEN-T ensures that the roll-out of charging stations matches the uptake of EVs.

  • New mandatory targets for heavy-duty vehicles (HDVs), maritime and inland waterway ports and stationary aircraft (art. 4, 9, 10 and 12)

The Platform fully supports the proposal for setting mandatory targets for HDVs, as this addresses the specific charging needs of electric trucks on the TEN-T networks as early as 2025. We also welcome the introduction of targets for maritime and inland waterway ports and stationary aircraft, as it helps boost the electrification of the transport sector.

Keeping those provisions is the first priority to make AFIR a success. However, the Platform believes that further improvements are needed, and has therefore set out a series of recommendations:

Clarify the definition of “alternative fossil fuels for a transitional phase”

The definition of “alternative fossil fuels for a transitional phase” (CNG, LNG, LPG, synthetic and paraffinic fuels produced using non-carbon-free energy) should specify until when this transitional phase will last.

Strengthen the level of ambition of the mandatory targets for light-duty vehicles (LDVs) (art. 3)

Currently, the power ratio of 1kW per 100% battery EV (BEV) and 0.66kW per plug-in hybrid EV (PHEV) would be already met by all but one of the Member States. In addition, the Commission’s analysis follows a methodology in terms of kW used (consumption evenly distributed during the year), which does not allow a response to peak demand. It is essential to consider the actual power delivered by a charging station, not the maximum power output (art. 2.37).

- Accordingly, the targets for BEVs and PHEVs should significantly increased until a point where a market can function organically. The targets should then be progressively lowered as the EV fleet size grows, and then ultimately phased out entirely when it reaches 7.5% of the entire fleet, as by then there will be sufficient demand to support a competitive private sector for EV recharging.

- The distance-based target of 60km between charging stations along the TEN-T network should be maintained during the upcoming negotiations. The customer-friendliness of charging stations should also be taken into consideration.

- The targets for the TEN-T comprehensive network should be brought forward by five years, so that all citizens can reach any destination within the EU using an EV.

- The deployment of alternative fuels infrastructure at the local level should be based on systematic consultation with local authorities as well as on the content of Sustainable Urban Mobility Plans (‘SUMP’).

- A density parameter can be included, to ensure that urban areas are properly covered and that there is a balanced territorial coverage.

Increase the power output for HDV-charging targets and consider the development of electric road systems for HDVs (art. 4 and 13)

Member States should have the possibility of promoting the deployment of Electric Road Systems (ERS) on sections where this is appropriate, in order to complement the targets for electric recharging stations. The Commission’s estimation of zero-emission trucks is significantly lower than the sales envisaged by truck makers.

- An increase total power output of HDV-charging pools along the TEN-T network should be considered, along with higher targets for urban nodes and for safe and secure parking areas.

- Targets for (semi-)public chargers at logistics centres and depots should also be introduced.

- The current timeline (targets starting from 2025 along the TEN-T core network) should be maintained, in order to not hinder the ramp up in the market for zero-emission trucks.

Complement rail electrification with additional guidance on deploying alternative fuels for the rail sector

We welcome the fact that the deployment of alternative fuels for railways has been included within the scope of the Regulation proposal, in the context of the National Policy Framework (art. 13). Setting decarbonisation targets for the rail sector would be consistent with the objectives set out in the European Green Deal and the Sustainable and Smart Mobility Strategy.

- Given the specific circumstances for investing in railway infrastructure, the deployment of hydrogen refuelling points or electric recharging points for battery trains are best dealt with on a national level. This should be done via the National Policy Framework of article 13, respecting the general EU principle of subsidiarity.

- Investment in alternative fuels infrastructure should take into consideration the national context as well as those rail network segments that are not going to be electrified.

- Investment in alternative fuel infrastructure for railways would be consistent with the provision -under the CEF2 Work Programme - of funding eligibility for hydrogen refuelling infrastructures for rail. Therefore, provisions of the Commission proposal for deploying rail alternative fuels infrastructure should be maintained (as set in art. 13.1 point (p)).

Improve the requirements on smart charging (art. 2 and 5.8)

The Platform welcomes the Commission’s recognition of the role of smart charging in the AFIR for enabling system integration. However, Platform has concerns over the retroactive effect of the measure. The following improvements should also be made to support smart-charging deployment.

- Amend the definition of smart charging (art. 2.59) as follows: “a recharging operation in which the power of charging can be adjusted within a specified time, based on external commands in order to enable a better integration of EVs into the whole power system to allow the possibility of a grid- and user-friendly way services”.

- Clarify the scope of ‘digitally-connected charging’ (art. 2.14), which should be limited to communication capacity needed for availability status and payment methods. The definition as currently written is confusing, as it may interfere with the smart modulation of power, thus overlapping with the definition of smart and bidirectional charging. The definition should leave a degree of flexibility, in order to take into account the differing levels of technological maturity in Member States.

- Cater for the future introduction of bidirectional charging capabilities in art. 5.8, allowing this technology to advance in the coming years. In addition, the development of bidirectional charging should not be left to an assessment by System Operators alone (art. 14); it should involve all relevant stakeholders, in order not to limit its uptake.

- The obligation in art. 5.8 should apply to all newly installed and refurbished or replaced recharging facilities as well as those financed by public funds.

- Given the environmental issues and to avoid the high compliance costs for CPOs, Member States should evaluate regularly (e.g., every three years) the need to retrofit existing charging stations.

- The reference to ‘normal power’ should be removed. Smart charging should be done in coherence with the proposal of revision of the Renewable Energy Directive. Therefore, para. 8 of art. 5 should be amended as follows: “From the date referred to in Article 24, operators or recharging points shall ensure that publicly accessible newly built and refurbished as well as publicly funded recharging stations operated by them are capable of smart charging.”

Harmonise the status of charging at EU level

The AFIR should harmonise the status of charging (as a good or as a service) without modifying the statuses that are already in place at national level in the majority of the Member States. The alignment between the different elements of legislation on the interpretation of what constitutes a recharging session would avoid business uncertainties.

In art. 2.46, the ‘recharging service’ definition should be amended as follow: “‘recharging service’ means a service consisting of multiple elements, including the  provision of electricity and services, through a  recharging point;”

Remain flexible and forward-looking, in order to be ready for future innovation while avoiding prematurely mandating standards (art. 19 and Annex II)

We welcome the proactive identification of standardisation needs. This will bring benefit from an interoperability point of view. We support the fact that the proposal is not prematurely mandating unfinished standards (such as IEC 63110 and IEC63119) as to retain the possibility to identify additional needs at a later stage and avoid possible technology lock-ins.

- In line with this approach, we would like to point out the need for additional technical specifications for communication between the EV, its owner and the EV services infrastructure. This is necessary to ensure control for the user and a fair and open ecosystem. For example, EV drivers should be able to connect their EV to any home energy or fleet management system, as well as to grant access to their charging data to the e-mobility service providers of their choice.

- This should be done in agreement with the expert group of the Sustainable Transport Forum mandated by the European Commission.

Bring forward the date of submission of the National Policy Frameworks (art. 13 and 16)

The Platform believes that the calendar for the NPFs (National Policy Frameworks) should be brought forward by one year, for both the submission of the first draft to the European Commission (to 2024) and the final NPFs (to 2025).

Maintain consistency with other ‘Fit for 55’ legislation

The Platform would also like to underline that any definition and provisions set out in the AFIR, and the revision of the Renewable Energy Directive (REDIII), should be consistent2 with the revision of the Energy Performance of Buildings Directive (EPBD), given that its art. 12 will address private charging. In particular, it will be vital to keep consistency between the different definitions on smart and bidirectional charging.

Our response to the consultation on the revision of the TEN-T regulation