Joint Letter on the Revision of RED II

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We, the undersigned associations and companies, representing the entire spectrum of the electric mobility ecosystem, call on Parliament and Council to set a true level playing field between zero-emission options in amending the Renewable Energy Directive (RED II), so that they can compete fairly in reaching RES (Renewable Energy Sources) targets for road transport.

Road transport is undergoing a major transformation: the share of electric vehicles in car sales in Europe has increased to more than 10% in 2021, and the industry is transitioning towards a complete phase-out of internal combustion engines in new passenger vehicles, as proposed by the Commission for 2035.

The revision of RED II presents a unique opportunity to accelerate the transport sector’s transition towards zero emissions, and to modernise the legislative framework for renewable energy in Europe’s transport system by going beyond the blending of biofuels. As battery electric vehicles offer the highest conversion efficiency compared to other available solutions, electricity should be able to compete on an even footing and under the same rules and conditions as other energy options.

Providing  the right incentives will enable operators in the e-mobility ecosystem across the EU  to significantly accelerate the transition towards zero-emissions transport, in line with the EU’s decarbonisation aims and the changes to the ecosystem required with electrification, in particular supporting the business case to deploy chargers.


More specifically, we call on Parliament and Council to:

1. Guarantee appropriate Energy Efficiency Ratios (EERs) to account for the superior energy conversion efficiency of renewable electricity versus fuels

2. Extend the scope of fuel-neutral credit trading to include private charging

3. Allow for the accounting of renewable electricity beyond the national grid average


1. Consider the links between current multiplier system and proposed GHG-based mandate


We therefore recommend to:

1. Maintain the fossil fuel comparators proposed by the Commission for the new GHG based system

2. Include appropriate EERs if Member States are allowed to keep accounting on an energy basis


2. Extend the scope of fuel-neutral credit trading mechanisms beyond public charging


We therefore recommend to:

1. Expand the scope of the EU-level mandate for credit systems to any type of charging, including private charging.


3. Allow for accounting of renewable electricity beyond direct connection in the same way as for Renewable Fuels of Non-Biological Origin (RNFBOs)


We therefore recommend to:

1. Introduce an obligation on the European Commission to develop a framework providing a pathway for operators to credit up to 100% renewable electrons supplied to road vehicles, as is the case for RNFBOs.

2. Allow operators to use the best available data for the compliance year in question to determine the renewable share present on the grid, rather than resorting only to the previous two years’ national average.



[1] Under RED II Article 27, paragraph 2

[2] See recent T&E study/briefing:

[3] Art. 27(c)(iii): average share of renewable electricity supplied in the territory of the Member State in the two previous years; fully counted as renewable if electricity is obtained from a direct connection to an installation generating renewable electricity.

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