Rolling out, not rolling back - How retroactivity and retrofit requirements will slow down the deployment of charging infrastructure throughout Europe

EV sales are hitting new records each year. In 2021, EV sales in Europe grew by about 60 % over 2020, up to almost 1,7 million new registrations, and will continue to grow rapidly as more and more makes and models enter the market. In order to support these EV drivers, significantly more charging infrastructure – both public and private – need to be installed.

Chargers are currently located very unevenly around Europe – concentrated in certain countries and in urban areas in others - and this needs to change as well.  

Thus, the primary goal of the Alternative Fuels Infrastructure Regulation (AFIR), when it comes to electric vehicle charging, is to  

• To create a pan-European charging network accessible to all drivers enabling them to reliably drive from Bulgaria to Belgium. 

• Support and motivate the deployment of charging infrastructure that can support the coming surge in electric vehicles in cities and regions throughout Europe 

• For the charging networks to be so ubiquitous that every soon-to-be EV driver is aware of charging infrastructure around them and ignorance about “where to charge” is no longer a reason not to go electric.  

To achieve this, many, many (millions) more chargers need to be installed – and quickly. ChargeUp Europe and its members are fully supportive of ambitious targets on member states to require adequate infrastructure to be built to achieve these goals. We believe that further development of the charging network needs to be the first, most important priority, and will have a far greater influence on user behaviour than almost anything else.  

Yet, ongoing proposals for AFIR include making changes to, or even replacing, many operational chargers – chargers which serve EV drivers well, are compliant with existing laws, and, in many cases, were even co-financed with taxpayer funds.  

ChargeUp Europe believes that retrofit or replacement obligations are misguided, will slow down and undermine the rapid deployment of additional infrastructure, and will result in a significant amount of unnecessary pollution and waste.  

Undermines the deployment of new chargers – The most important consequence of the need to retrofit or replace existing locations is that this all takes time, attention, focus, and yet more time that the CPO could spend finding new locations and installing more stations. Retrofitting prevents many people on the team (esp. mid-sized CPOs) from doing the important work of finding new locations, working with new location hosts to educate them, selecting the technology and business model, negotiating new contracts, etc. This energy could better be spent adding more locations, which is the far more urgent need from climate, EV driver, and EV recharging perspectives. 

Ties us production lines and supply chains - From the side of the equipment manufacturer, which already faces overwhelming demand and is experiencing chip shortages and other supply chain issues, the need to manufacture new chargers to replace currently operational ones purely for compliance reasons creates a further backlog, reducing the stock of chargers available for new locations, and slowing down the whole process.  

Creates unnecessary waste and pollution - In the cases where perfectly good chargers (especially AC) would need to be replaced, what would happen with the old ones? They are full of motherboard circuitry which needs to be specially disposed of and are not suitable for re-sale. It would be extremely wasteful and polluting to not use these chargers for the duration of their usable life before switching them out and upgrading them with newer technology.  

Unfair to location host - Because these were not necessarily the terms – or the technology - that the location host agreed to, nor the vision they had for their location, it is not fair to change that via regulatory fiat after the fact and in the midst of their contract. It may turn them against the transition to emobility or cause them to shut down their location.   

For these reasons, ChargeUp Europe believes that AFIR requirements should apply only to infrastructure to be newly installed after the Regulation comes into effect.