For Consumers and Climate ChargeUp Europe’s position on the Alternative Fuels Infrastructure Regulation (AFIR) proposal

ChargeUp Europe, the voice of the European electric vehicle infrastructure sector, has published its response to the European Commission proposal for an Alternative Fuels Infrastructure Regulation (AFIR).

ChargeUp Europe welcomes the overall ambition of the proposals as an important step in the right direction, while also highlighting important issues that require further attention. AFIR comes at a critical time. It will set the framework for how we roll out EV charging infrastructure in Europe and how we harness the full potential of electromobility for decarbonization and energy system integration between now and 2030.

Targets have an important role to play during the early phase of market adoption and especially in lesser developed markets and where ambition is lower. With the support of our knowledge partner Arthur D Little, ChargeUp Europe analysed the European Commission’s proposed targets in light of market realities. We propose that targets are connected to the level of electrification of the total fleet in a given market, and that higher targets are needed when Member States are at an earlier stage, to help kickstart their development. These targets should continue on a decreasing scale until a Member State hits a share of 7.5% of battery-electric vehicles (BEVs) on their market and which point they can be phased out entirely.

According to Christopher Burghardt, President of ChargeUp Europe, “It is important to avoid a two speed Europe situation. New rules should give the right boost to underserved regions, while allowing the market to take over when targets are no longer needed. Higher targets that phase out as the EV fleet increases should provide an incentive for national governments to support infrastructure deployment and reassure citizens they can go electric regardless of where they live.”

ChargeUp Europe wholeheartedly supports the goals of the AFIR proposal to make EV driving and charging more accessible and user-friendly for all. There are two main business models which enable publicly accessible charging today - ad hoc and subscription based - with the subscription-based model accounting for the vast majority of public charging sessions.

ChargeUp Europe feels strongly that AFIR needs to better recognize and promote the key role of the subscription-based model. Well-designed E-mobility subscriptions provide many benefits to EV drivers such as lower prices, tailored offers, the ability to plug & charge, and more. Crucially, they also enable smart charging and thereby drive emissions reduction and energy system integration.

EV drivers need to be able to benefit from these advantages at as many charging stations as possible across Europe. AFIR should therefore ensure that all publicly accessible EV charging stations are capable of e-roaming.

At the same time, we believe it is necessary to maintain a technology neutral approach regarding how payments for ad-hoc and subscription model type charging are made. Mandating specific payment technologies as the current proposal foresees does not reflect the reality in the market today and how most payments on EV charging infrastructure are carried out. The current proposal does not leave sufficient room for market operators to react to market and fintech developments and thus runs counter to consumer interest and preferences.

“The ad hoc model and the subscription model are complementary to each other and should be treated on an equal footing under AFIR” said Christopher Burghardt, President of ChargeUp Europe. “Laws we adopt today have to stand the test of time. We need forward looking rules that harness the potential of new fuelling models to empower citizens and accelerate the decarbonisation of mobility and energy systems in Europe over the next ten years and beyond.”

Please see here our full position paper.

Please see here the detailed methodology developed by ChargeUp Europe and Arthur D Little for light duty vehicle charging infrastructure targets within Alternative Fuels Infrastructure Regulation proposal (AFIR).