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.
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.
Cyber Resilience Act: Ensure the cybersecurity of EV charging!
ChargeUp Europe welcomes the proposal and the intention behind the Cyber Resilience Act (CRA). We share the objective of making our products more resilient and secure, not only physically but also digitally level.
The Commission's proposal could further discuss some points that would be critical to ensuring the correct and effective implementation also in the EV charging sector. As the CRA’s ultimate purpose is to ensure a high level of cybersecurity of all products entering the EU market, it is necessary to consider a broader of scope of actors working on this topic.
In light of the ongoing discussions on the Cyber Resilience Act (CRA), ChargeUp Europe recommends to:
Enable manufacturers to indicate the expected product lifetime and ensure a differential treatment B2B and B2C products.
Make more and better use of standards from compliance purposes, especially critical products.
Ensure coherence with other digital legislation for the reporting obligations.
Download the full paper here.
EV Charging Infrastructure: An agenda for the next European Commission
The European Union has set out the be the first climate-neutral continent by mid-century, with an ambitious decarbonisation pathway by 2030. The transport sector, the second sector responsible for GHG
emissions in the EU, is on course to transform rapidly to contribute to these objectives.
ChargeUp Europe calls for shifting the EU policy focus from EV charging infrastructure targets to enabling conditions, by:
Leveraging the growth-inducing power of the single market, by introducing a type- approval for EV chargers and implementing a regulatory simplification effort (“refit 2.0” for the twin green and digital transitions).
Building an EU grid fit for the electrification agenda, supporting investments in grids and fully leveraging the benefits of smart charging to accelerate the integration of the energy, transport and digital sectors.
Integrating widely accepted open, EU-industry led standards and protocols OCPP and OCPI into EU legal frameworks, emulating the US.
Alleviating pressure on staff shortages by implementing an ambitious standardisation and regulatory simplification agenda to maximise efficiency gains along the value chain.
Supporting system integration (in particular energy, digital and transport) with a reformed institutional set-up, building on the successful US example of the US Joint Office of Transportation and Energy.
Read the full paper here.
Public Key Infrastructure Market Principles
This paper outlines the key market rules that should be implemented to deliver an open, interoperable and competitive public key infrastructure (PKI) for EV charging. Ultimately, this will play an important part in ensuring that in Europe, any EV-Driver can charge in any EV, on any (publicly accessible) charging station using any service provider. It follows up on previous ChargeUp Europe papers on public key infrastructure and also the relationship between PKI and ISO15118.
Read the full paper here.
Life is a Highway: Driving the Electrification of Heavy Duty Vehicles
At a glance
Availability of space to build charging sites (including fast permitting and planning procedures), access to sufficient power supply in a timely manner, the actual charging demand from a growing number of electric trucks and software standards are the critical enablers that can make or break electrification of HDVs.
Tags: HDV, Public Charging, Girds.
Read the paper here.
Statement on the calculation of the GHG savings of renewable electricity in transport under the Renewable Energy Directive (RED II) – Expected outcome of trilogue
The signatories to this letter have consistently advocated for an accurate valuation of the carbon savings from electricity as a transport energy vector in the revision of the Renewable Energy Directive (REDII), properly taking into account the GHG emissions reduction from the EV drivetrain due to superior efficiency (higher energy conversion efficiency of renewable electricity versus other drivetrains, i.e., most power used to propel the vehicle not wasted)2, and for a market framework reflecting that technological fact.
The European Parliament and the Council must ensure that both energy and Greenhouse Gas (GHG) based calculation systems recognise this higher efficiency:
For a GHG-based approach, we urge that the fossil electricity reference value of 183gCO2 eq/MJ (as originally proposed by the European Commission) is a minimum floor under which the revised RED should not fall.3
For an energy-based approach, we urge that an appropriate Energy Efficiency Ratio (“multiplier”) of 4 should be retained to provide parity with the GHG approach.
Read the full letter here.
Renewable Energy Directive Trilogues: EU legislators must ensure market conditions to best enable electrification of transport to meet climate targets
The Renewable Energy Directive trilogues present a unique opportunity to design market conditions to accelerate the uptake of emobility and EV charging in Europe. Electric vehicles already account for over 10% of new passenger cars and market share is growing.
The directive should recognise the superior energy conversion efficiency of renewable electricity vs fuels and properly value it.
Fuel-neutral credit trading should include private EV charging, (workplaces, depots, and private homes), as well, as this accounts for 70% of passenger EVs and 99% of electrified public transport.
This also incentivizes market players to install charging infrastructure and bring electricity into the system, and gives member states more tools to reach their targets with.
Read our joint statement with Eurelectric, AVERE and Transport & Environment here.
Invest Now & Save Later: Advancing building energy efficiency and e-mobility via EPBD
Making sure people can charge at home and at work is why the EPBD is so important to facilitate the transition towards e-mobility. Further, more, smart EV charging can contribute to building energy efficiency by making the building an active, productive participant in the energy system, consuming energy when it’s best to do so, supporting the integration of renewable energy, and even providing clean energy to the building.
Our top asks in one glance:
Ensure pre-cabling requirements to accelerate EV uptake.
A strong right to plug as a standard that guarantees the accessibility of EV charging.
Private charging stations should be digitally connected and smart charging capable.
Read the full paper here.
The Green Deal Industrial Plan: How a thriving, EV manufacturing sector can support the EU's green & digital economy
ChargeUp Europe calls for:
Centering the e-mobility value chain in the Green Deal Industrial Plan: charging stations, software, and other EV enabling tech,should be explicitly recognised as “clean tech”;
Including EV charging infrastructures amongst the sectors that will be benefit from simplified and accelerated permitting processes, integrating the guidance from the Sustainable Transport Forum;
Avoiding distortion of the single market by complementing action on public subsidies with an EU-wide instrument; as EV charging is a rational, market-driven sector, funding should target the "enablers" of the transition e.g. grid capacity & smartness, training and re-skilling;
Bringing a sharper focus on building a single market and the benefits derived from leaner, simpler regulatory frameworks. The Net Zero Act should identify clean tech products that would benefit from the introduction of type approval, such as EV chargers.
Read the full paper here.
Joint statement ahead of the vote of the European Parliament on the Energy Performance of Buildings Directive (EPBD)
Making sure people can charge at home and at work is critical to boost EV uptake. Ahead of the vote in the European Parliament plenary, we have joined forces with other key stakeholders to support the report of the ITRE committee. The level of ambition must be maintained.
Read the full joint statement here.
Hook Us Up! Simplifying and Accelerating the Grid Connection and Permitting Process for EV Chargers
A successful transition to e-mobility requires a quick deployment of large amount of EV charging infrastructure, for which grid connections represent the single largest bottleneck.
What benchmarks would an efficient and fit for purpose grid connection permitting process look like?
✔ Standardization of steps and procedures
✔ Transparency at all stages
✔ Predictability of outcomes
✔ Harmonisation of the process across Europe
✔ Speed in the time between requesting a permit and realising the connection to the grid
To find out how Charge Point Operators, Distribution System Operators and public authorities can better work towards these objectives while making the best of current limited resources and shrinking timelines, read the paper here.
Recently, we also published an open letter on the same issue, bringing together a coalition of over 20 CPOs from the EU who are united in their voice on the way forward in tackling this single largest bottleneck in rolling out charging infrastructure. Have a look at our campaign page, and if you are a concerned CPO, sign the letter!
Joint Letter: Unlock the demand-side flexibility potential through a consumer-centric EU Electricity Market Design
The revision of the Electricity Market Design (EMD) offers a precious opportunity to address in a structural way the current energy resilience and energy affordability crises, while supporting the clean energy transition with consumers in the lead (from households to energy intensive industries, acting individually or collectively).
Thanks to a wide set of Distributed Energy Resources (DER), including demand management, energy storage, electric vehicles and distributed energy efficient and renewable generation, all consumers can become providers of flexibility. As the electricity system transforms, they will become essential actors in an efficient, digitally-enabled, interoperable and renewables-based power system.
ChargeUp Europe and a broad group of ten other business associations, NGOs and civil society organisations welcome that the importance of active consumers and demand-side flexibility (DSF) is central to the considerations of the European Commission for this revision.
To find out the full list of recommendations, read the letter here.
Plug & Charge, ISO 15118, Public Key Infrastructure (PKI), and the Need for Proper Governance
ChargeUp Europe outlines the key aspects of ISO 15118 and how the implementation and governance of this standard will be fundamental to ensure a level playing field for operators and provide choice for EV drivers. If implemented correctly, the services enabled by ISO 15118 can deliver a smoother charging process and bring major benefits to EV drivers and the grid. However, if not governed in a way that enables open and fair competition, EV drivers risk being locked-in to a single provider which then prevents customers from (easily) choosing for access to alternative MSP services and offers. ChargeUp Europe calls for a single legislative instrument which lays out clear market and governance rules which ensure open and fair competition for both Plug & Charge and Smart Charging aspects of the standard. It should address both the vehicle and charger requirements.
Read the paper here.
Joint letter: Demand-side flexibility is a strategic answer to the energy crisis
ChargeUp Europe, together with the European Association for Electromobility (AVERE), Confederation of European Paper Industries (CEPI), the European Association for the Promotion of Cogeneration (COGEN Europe), current, Environmental Coalition on Standards (ECOS), European Federation of Energy Traders (EFET), European Energy Retailers (EER), The European Heat Pump Association (EHPA), European Renewable Energies Federation (EREF), The European association of smart energy solution providers (ESMIG), smartEn, SolarPower Europe and T&D Europe issued a joint letter to Ursula von der Leyen, President of the European Commission; Frans Timmermans, Executive Vice-President for the European Green Deal and Kadri Simson, Energy Commissioner.
In this statement the signatories state that both short and long-term solutions to the current energy crisis is demand side flexibility and to to empower all consumers with decentralised energy resources and allow them to self-consume, adjust and trade their energy consumption, storage and on-site renewable and efficient generation, directly, or through local communities and aggregators.
Read the full statement here.
Statement on EP TRAN Committee adoption of AFIR report
On 3 October, the European Parliament’s TRAN Committee approved MEP Ismail Ertug’s report on the proposal for a Regulation for the Deployment of Alternative Fuels Infrastructure (AFIR), an important step on the journey to a harmonized framework for publicly accessible charging in Europe.
MEPs agreed on ambitious EV charging infrastructure targets, allowing the EU to achieve its decarbonization objectives but are asking for retrofitting of existing AC stations with payment card readers, which would undermine the market for publicly accessible AC charging and would be a significant step backwards.
Read the full statement here.
Statement on the critical role of smart electric transport in addressing the energy crisis
ChargeUp Europe publishes a statement on the critical role of smart electric transport in addressing the energy crisis together with Transport & Environment, AVERE, and SmartEn. The statement contextualises the role of EV charging in the wider context of the worst energy crisis Europe is facing since the 1970s. The statement also calls for a holistic approach that is collective and emphasises the need to explore multiple avenues for engagement.
Read the full statement here.
10-point action plan to make buildings ready for electric mobility
ChargeUp Europe publishes a 10-point action plan together with Transport & Environment, AVERE, and Europe On. The action plan provides a clear guidance for an effective road ahead for calling on the EU institutions to amend the Energy Performance of Building Directive (EPBD) so that EV charging at home or at the workplace becomes easy and accessible for all.
ChargeUp Europe statement on keeping the digital and green transition to e-mobility on track amid an energy crisis
ChargeUp Europe:
Recognises that the European Union is facing the unprecedented, short-term challenge of managing shortages, extreme price volatility and high prices in gas and electricity markets while also confronting the climate crisis and managing the transition to cleaner, more resilient and sustainable energy systems.
Calls for recognition that it is of critical importance that the long-term objective of decarbonization and the digital and green transition to e-mobility are not sacrificed as EU institutions and national governments seek to alleviate short-term pressure.