Our Positions
EV charging issues cross many policy areas - Consumer affairs, energy, IT & cyber, automotive, manufacturing, and many more.
Search below or use our filters to find our position papers on the topics of interest to you.
Joint Letter to Commissioner Designates
Ahead of the hearings of incoming European Commissioners that begin today, ChargeUp Europe, AVERE, Eurelectric and EuropeOn reiterate the importance of sticking to 2035 zero-emission targets for cars and vans and the intermediate goals starting next year.
The 2035 framework is crucial for investment certainty across Europe’s EV ecosystem. A slowdown would jeopardise Europe’s competitiveness in an increasingly electrified market. Now is the time to double down and accelerate, not slow down or prevaricate.
We call on the incoming Commissioners, particularly Executive Vice President-designates Teresa Ribera and Stéphane Séjourné and Commissioner-designates Wopke Hoekstra and Apostolos Tzitzikostas, to seize the opportunities in e-mobility!
You can read the joint letter here.
Harder, Better, Faster, Stronger: Reducing Administrative Roadblocks for the EV Charging Industry - Input for the European Commission
The European Union has recognized the need to reduce administrative burdens, particularly for businesses in the EV charging infrastructure sector, which is crucial to the green and digital transition. ChargeUp Europe's latest paper delves into the significant challenges posed by complex administrative processes, including non-standardized permitting, VAT registration hurdles, and fragmented national regulations.
This paper:
- Maps out the key roadblocks that companies face when navigating the intricate and often divergent administrative processes across the EU, with particular focus on the EV charging infrastructure industry.
- Presents insights gathered from ChargeUp Europe’s consultation with members, identifying both the horizontal challenges, such as lack of process harmonization, and specific burdens like permitting and grid connection delays, which significantly hinder the industry's growth.
- Engages EU policymakers and stakeholders to propose actionable recommendations, such as standardizing permitting processes, improving VAT compliance mechanisms, and ensuring easier access to EU funding, all aimed at fostering a more business-friendly environment for the sector.
A simplified and harmonized approach to administrative processes will not only enhance operational efficiency for companies but also accelerate the deployment of EV infrastructure across Europe.
Read the full paper here.
Joint Statement on the key role of distribution grids for a competitive, green and resilient Europe
Together with a coalition of 16 other European cross-sectoral associations, we support the call to maintain the distribution grid at the centre of the EU agenda!
In the joint statement by DSO Entity, the coalition explains that Distribution System Operators (DSOs) are central players that contribute to driving the energy and digital transition on the ground for the benefit of all European citizens, enterprises, and industries. The distribution grids are incorporating an increasing amount of renewables and are becoming more customer driven. DSOs are the key technical enablers of the 42.5% EU’s renewable energy target, as more than 70% of renewables will be connected to the distribution grid by 2030. This will see more than 30 million electric vehicles (EVs) on the roads by 2030.
In particular, we support the calls to:
Align EU financing instruments with net-zero targets and DSOs’ needs
Introduce a grid mainstreaming approach to ensure that grid expansion doesn't lag behind.
As the #1 bottleneck to the rapid and widespread rollout of charging infrastructure across Europe, strengthening grid infrastructure is a core priority of ChargeUp Europe.
Policymakers must treat it as such.
You can read the joint statement here, or find it on DSO Entity’s website.
ChargeUp Europe Board: The EV outlook today
The Board of ChargeUp Europe, the voice of the EV charging infrastructure industry, met on October 1, and discussed the EV outlook.
The Board is of the view that:
The current slowdown in EV sales in Europe is a bump in the road and does not change the direction of travel. This bump is temporary in nature, driven by slowdown in select markets. Exempting the German market, EV sales grew by 9% in H12024.
The EV charging industry continues to invest heavily in expanding both public and private charging infrastructure. We anticipate that EV charging infrastructure deployment will outpace EV uptake in 2024.
Electric drivetrains are the superior technology and highly energy efficient. There is no better technology to provide an excellent automotive experience and reduce emissions in the light duty vehicle parc.
Policy stability and predictability drives investments decisions. Legal certainty, including the 2035 phaseout of tailpipe emissions, is critical and must be preserved.
The answer to the current sales slump is not to shield Europe from competition, but to increase volumes. Measures that support improved EV volumes – together with the development of a broader offer of makes and models of EVs at different price points to serve more, varied customers - will allow EU carmakers to scale, strengthening them against their foreign competitors.
E-mobility is an economic opportunity for Europe. In 2023, already 50 000 people were working in the EV charging sector alone, up from 13 000 in 2019 – and more jobs will be created in the future. ChargeUp Europe will unveil additional macroeconomic data on 15/10 showing the value and job creation in the sector for the next decade.
Transport electrification remains a dynamic and innovative sector. Our companies are full of people bringing innovative and seamless solutions and improving customer experience. The electrified transportation system is taking shape in front of our eyes, and we’re excited to keep working on it.
Download and read the full statement from the Board here.
Understanding uptime in the EV charging industry: towards a common methodology
In the European Union, even though uptime is currently only mentioned in recital 12 of Alternative Fuel Infrastructure Regulation (AFIR), at the national and local levels public tenders are increasingly featuring uptime requirements of 97% – 99%. The US and the UK have for their part established regulatory requirements, sometimes including fines (for the UK) when these are not met.
The current landscape for measuring uptime in the EU presents several limitations. Our latest paper outlines the proactive steps the industry is taking to address these limitations, and what policymakers need to know.
This paper:
Supports a better understanding of “uptime”, a key concept that is increasingly under scrutiny, from an industry’s perspective. In layman’s terms, “uptime” refers to the total amount (or percentage) of time a connector is working properly for all EV drivers to use.
Presents the findings of extensive technical work started in September 2023 and 2 expert workshops held by ChargeUp Europe members on a (non-regulatory) common methodology to measuring and reporting uptime, the merits of an approach grounded in operational reality, ensuring a level playing field across the sector and fostering a race to the top on operational performance.
Opens the conversation with EU policymakers, tendering authorities, and the broader EV charging infrastructure community, about the significant limitations of the current tendering and regulatory approaches of uptime.
A common methodology not only ensures a level playing field but also pushes CPOs to deliver optimal uptime, enhancing the charging experience for all EV drivers.
Read the full paper here.
ChargeUp Europe Statement: Policy Predictability is Key
Recent reports indicate that some car manufacturers are pressing the European Union to delay its 2025 emissions targets for automakers by two years.
Policy predictability is key, as we’ve been saying clearly for years. It sets the direction and provides confidence for investments, promotes competition, and rewards best performers, not laggards.
Delay is the opposite of that. This about-face also risks undermining many of the agreements made over the last mandate.
Read ChargeUp Europe's statement on policy predictability here.
Sources:
Dude, Where’s My Charging Station? Ensuring Transparency and Competition in Route Planner Development for EV Drivers
Route planners are crucial in connecting electric vehicle (EV) drivers with Charge Point Operators (CPOs), guiding them through available recharging options.
They come in three main types: navigation or third-party apps (e.g., Google Maps), those developed by CPOs or Mobility Service Providers (MSPs), and those by Original Equipment Manufacturers (OEMs) as default tools in EVs.
Ensuring transparent, unbiased access to all recharging options is vital for consumer trust and choice.
ChargeUp Europe advocates for clear, transparent criteria for route planner integration, promoting fair competition and placing EV drivers' needs at the forefront of decision-making.
You can read the full paper on route planners here.
Joint industry recommendations on implementing Right to Plug
The Right to Plug grants anyone the ability to easily install an EV charger at home or at work without unnecessary administrative burdens.
85% of EV charging happens at private locations. Right to Plug is crucial for the continued rollout of EV charging infrastructure. The Energy Performance of Buildings Directive (EPBD) finally acknowledges this right, but swift national implementation is essential.
Our joint recommendations, developed together with AVERE, Eurelectric, EuropeOn and Transport & Environment, provide the roadmap to effectively implementing the Right to Plug on a national level, inspired by successful practices in key Member States.
You can read the full list of recommendations here.
Joint letter- Support for EU CO2 Standards for cars and vans and 2035 zero-emission target
ChargeUp Europe, along with leading European associations, fully supports the EU CO2 standards for cars and vans and the 2035 zero-emission target.
This framework is essential for long-term investments, driving Europe’s industrial future, and achieving decarbonization goals under the Green Deal. If we seize this opportunity, Europe’s e-mobility transition will provide over 580,000 new jobs and significant public health benefits by reducing pollution.
Regulatory stability and legal certainty are the foundation for Europe’s e-mobility ecosystem to accelerate investments and drive a new EU industrial success story. We urge the European Parliament to maintain these standards, invest in comprehensive EU-wide charging infrastructure, and promote zero-emission vehicles.
This will create jobs, improve public health, and ensure Europe remains a leader in e-mobility. Let's collaborate for a zero-emission future.
You can read the full text here.
Charge Smarter, Not Harder: Unlocking the Potential of Smart EV Charging for European Grids and Consumers
With more and more Electric Vehicles (EVs) on the streets, higher use of electricity in buildings and industry, and increasing electricity production from Variable Renewable Energy Sources (VRES) such as wind and solar, network system operators will need to invest massively to upgrade and modernize the grid to maintain supply and demand in balance and to ensure the grid’s resilience and security.
Smart charging has a key role to play in optimizing the use of the existing grid capacity. It can adapt EV charging to the needs of grids and consumers and distribute electricity to as many cars as possible.
Currently, the full potential of smart charging is untapped due to inadequate regulatory frameworks and the nascent state of bidirectional charging technology. To unlock its full potential, existing barriers must be removed. Recent EU legislation is a step in the right direction, but effective implementation is crucial.
In this paper, ChargeUp Europe highlights the benefits of smart charging in the EV sector and the steps that must be taken to overcome legislative barriers and ensure its effective rollout on both a European and national level.
You can read the full paper on smart charging here.
RED III Implementation Guide
REDIII credit mechanism for EV charging infrastructure: an implementation guide for national public authorities.
The Renewable Energy Directive (RED III) mandates that EU Member States establish a market for credits generated from delivering electricity to Electric Vehicles (EVs) via charging infrastructure, with a deadline of May 21, 2025.
ChargeUp Europe has created a guide to assist public authorities in developing this credit mechanism.
The first part of the guide details the RED III credit scheme and examines current credit systems in France, Germany, Austria, Belgium, and the Netherlands. These existing systems offer valuable insights and experiences for creating future credit mechanisms in other Member States.
The second part provides recommendations for implementing the RED III credit mechanism at the national level, drawing from the experiences of ChargeUp Europe's members with existing national schemes.
The guide aims to facilitate the timely and effective establishment of a credit mechanism that promotes private investment and expands EV charging infrastructure across the EU.
You can read the guide to implementation in English here.
Charging Up Europe’s Corporate Fleets
The future is electric, and the EV charging infrastructure industry is at the forefront of developing the solutions to not only support, but also drive the shift to electric road transports.
Maturity levels within the market for corporate fleets vary: policy initiatives must take this into account, while ensuring that electrification stays on track and accelerates where it is possible and desirable.
Love Me (Public) Tender: Input on Sustainable Transport Forum TF7 Work
Several years ago the EU developed a practical tool (“handbook”) for public authorities on how to design tenders for e-charging infrastructure. This practical tool is currently being revised by the “Sustainable Transport Forum” (STF), a body gathering industry and public authorities under the aegis of the European Commission.
A “short” version of the handbook will be released in April 2024, accompanying the application of the Alternative Fuel Infrastructure Regulation (AFIR). As a member of the STF, ChargeUp Europe has gathered information from its members on their experience with tender processes to influence this process and shape the next wave of public tenders across the EU.
Read our latest paper, where we discuss a set of obstacles and provide recommendations for public authorities to prepare fair, effective and balanced public tenders to deploy EV charging infrastructure across the EU.
Find the full version here
Access to In-vehicle Data for EV Charging: Consumer and Grid Benefits
ChargeUp Europe strongly supports the upcoming Commission’s proposal on access to in-vehicle data. Significant benefits to both drivers and energy system will be unlocked as a result of fairer and better sharing of vehicle data with third parties. Effective legislation could ensure an improved experience for consumers, and at the same time enable value-added services to help balance the electricity grid and manage energy consumption.
ChargeUp Europe calls the European Commission to:
Establish EU Regulation that creates a level playing field for access to in-vehicle data, improving consumer choice and experience by enabling CPOs and other third parties to offer high-quality charging services.
Consider the devastating disadvantage of a lack of such level playing field to the EU consumers and the electricity grid, resulting in slower uptake of EVs and inefficient grid upgrades.
Read the paper, here.
One Step Closer to an Open and Interoperable EU PKI Ecosystem that Ensures Fairness and a Level Playing Field
The ChargeUp Europe vision:
An open and interoperable EU PKI EcoSystem that ensures fairness and a level playing field.
As Plug&Charge becomes more widely available for EV drivers, it is critical that the Public Key Infrastructure (PKI) security framework underlying these services is developed in a way which ensures the highest level of security, interoperability, and fair competition. The same applies to the EU PKI EcoSystem, and the market rules that should govern it. ChargeUp Europe advocates for EU regulation and governance that ensure that driver choice is prioritised, delivering a level playing field between MSP offers and ensuring that every MSP (third-party, or EV-OEM or CPO-owned) can provide an equal, seamless (in-vehicle) user experience and functionalities for Plug&Charge and no "self-preferencing" occurs whereby the driver is bundled or locked-in to a specific service. Such bundling undermines the ability of EV drivers to choose and can lead to the market being dominated by a small number of large players, reducing competition on innovation, services, and pricing and reducing choice for the driver.
Read the paper here.
“Action Plan to Facilitate Grids Rollout”: The EV Charging Perspective
ChargeUp Europe calls for:
Fixing permitting: EU legislation should establish a dedicated, permanently simplified permitting procedure for EV charging projects, including: a/ a mandatory permitting framework; b/ simplified permitting processes; c/ binding deadlines to public authorities delivering permits; d/ a one-stop shop concept. In addition, a regulatory framework allowing DSO to prioritise grid connection requests coming from some actors (meeting defined climate and social criteria) must be established, reforming the “queue” system by creating a parallel, “fast lane” for them.
Updating governance: Energy governance needs to evolve, with a/ more direct role on steering implementation from the EU level; b/ a High Representative for Electrification and Grid Modernisation in the new Commission; c/ a Joint Office of Transportation and Energy (as in the US); d/ a regulatory framework requiring National Regulatory Authorities (NRAs) to step in to design national solutions.
Designing pragmatic workarounds to alleviate labour shortages: NRAs should provide for the expansion of certified parties (e.g. technicians and electricians) allowed to work independently on grid connected infrastructure, as a stop-gap measure until more staff are available at DSOs to perform technical tasks such as connections.
Why EV charging?
EV charging, even among Distributed Energy Resources (DER), is perhaps the most distributed. Normal and high power charging locations are deployed all over – public parking lots, highway rest areas, hotels and restaurants, homes and apartment buildings, gyms and malls, logistic or sports centres, etc. Unlike even rooftop solar and heat pumps which are connected to a house or construction site which may take a year or two to build, EV charging stations can be installed and connected in far less time (not counting the associated grid connection work). Due to this extremely distributed nature and relatively short project timeline (from the CPO side) the permitting and process needs of EV charging are different from those of energy generation projects and even other DERs. Properly enabling this sector to scale widely and rapidly is essential to the EU meeting its climate targets. This paper outlines recommendations for the “Grid Action Plan” to do just that.
EV Charging Business Fundamentals Factsheet
The expansive EV charging value chain includes a wide range of actors, ranging from component manufacturing to after-market maintenance.
Here is the factsheet that introduces all actors of the value chain:
EV Charging Business Fundamentals
Here are the actor-specific factsheets:
EV Charging Business Fundamentals & Hardware Manufacturers
EV Charging Business Fundamentals & Charge Point Operators
EV Charging Business Fundamentals & Mobility Service Providers
EV Charging Business Fundamentals & Roaming Platforms
EV Charging Business Fundamentals & The After-Market: Maintenance and Circularity
Call from the Economy to the Grid: The New Highways of Europe
The EU economy is moving towards electrification across systems and sectors, from energy to industry, transport, heating and cooling or the built environment. Markets for electric vehicles (cars, vans, trucks and buses), as well as heat pumps (residential and industrial) and the renewables that will power them are growing at an unprecedented pace. Clean tech is becoming the bedrock of Europe’s economy.
As a cross-industry alliance of associations, we call for a High Representative for Smart Electrification and Grid Modernisation in the European Commission.
Read the joint letter from ACEA, AVERE, EHPA, SolarPower Europe, smarten, EUBAC & ChargeUp Europe here.
Revision of PSDII: Enable easy EV charging!
In light of the the Commission’s proposal on the revision of PSD II, ChargeUp Europe recommends to:
Exempt EV charging sessions from the SCA requirement, aligning it with payments for public parking & public transport.
Ensure coherence between payment requirement in AFIR and the revised PSD.
Expand the definition of payment services according to Annex 1 of PSD II, to include the new forms of payments that have become widely available across the EU in the last years.
To read the full paper, find it here.
European Commission clarifies the application of Measurement Instruments Directive (MID) to EV charging stations
In 2004, when MID was passed, there were almost no charging stations erected in Europe. The market started with mainly AC charging stations that partly contained MID meters known from household appliances, meaning that those AC chargers were manufactured and certified under MID. A decade later, in 2014, the Alternative Fuels Infrastructure Directive (AFID) was passed and Member States started applying metrology law to the meters inside the EV chargers and the chargers themselves, e.g. Germany in 2015. Fast charging was evolving but commercial DC meters designed for fast chargers were not available back then.
In order to ensure a harmonized application of MID across the EU and prevent the introduction of non-harmonized requirements for active electrical meters across the Member States, ChargeUp Europe sent a letter to the European Commission, in support of the work done by DG GROW’s Working Group Measuring Instruments (E01349). The letter sought a confirmation that active electrical energy meters are within the scope of MID, regardless of whether AC or DC is used. The European Commission has replied confirming that ‘the Directive neither excludes DC meters nor restricts the scope to AC meters’.
Read the full letter sent by ChargeUp Europe here and the European Commission’s reply here.