Joint Letter on AFIR - Comments from the e-mobility ecosystem

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The recently adopted TRAN Committee’s position on the Alternative Fuel Infrastructure Regulation has brought clarity on the cross-political group approach the European Parliament is taking. We, the co-signed below - as representatives of industry and consumers, and as such representing the whole e-mobility eco-system - would like to take this opportunity to welcome the progress made in light of the Compromise Amendments. At the same time, we would like to clarify certain points that do not account for operational realities and depict an opposition between the interests of the consumers and that of industry. The electric vehicle market is gradually moving to the tipping point of becoming the main automotive market. In this context, it is even more significant that availability and access for the consumer lie at the core of the business case for charging infrastructure.

  1. Remain ambitious on targets

We commend the revised Articles 3 and 4, which set out an ambitious rollout trajectory for charging infrastructure all across the Union. These targets will guarantee that the growth of the European network will remain in line with EV deployment and that users will not have to worry about range when travelling on the TEN-T network. We particularly welcome the provisions for early market stages and the increased ambition on charging infrastructure for heavy-duty vehicles, which are already coming to market and for which charging infrastructure cannot be a bottleneck if Europe is to reach its climate aims. Moreover, we suggest that once AFIR is under review and only when a mature EV market is reached, an end to mandatory build-up targets should be considered.

  1. Maintain useful clarification on retrofits

To achieve the quick and comprehensive rollout Europe needs over the coming years, it is imperative to exploit the useful lifespan of existing recharging stations to the fullest. Hence, we welcome the vigilance some of the adopted Compromise Amendments have taken on the burden that new farreaching retrofitting requirements for existing charging infrastructure would imply. This includes the proposed provisions on smart recharging:

  1. Balance payment obligations

We remain concerned about the obligation to install card payment systems as well as its link to the obligation for retrofit. We strongly support the facilitation of a seamless, accessible, user-friendly and interoperable European charging network. However, requiring the installation of full card readers

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