As charging infrastructure deployment accelerates across passenger and heavy-duty transport, the regulatory framework must remain coherent, forward-looking, and aligned with practical market realities.
CharIN has submitted its response to the European Commission, setting out recommendations to strengthen interoperability, reduce unnecessary complexity, and support long-term investment confidence across the EV charging ecosystem.
ISO 15118-20 is a key enabler for next-generation charging functionalities such as Plug & Charge, smart charging, and bidirectional energy flows. While strongly supported by industry, the proposed 1 January 2027 mandate date for software implementation is not technically realistic.
CharIN therefore recommends postponing the mandate to 1 January 2028, allowing sufficient time for conformance testing frameworks and complementary standards to be fully developed.
The Megawatt Charging System (MCS) is the only charging solution capable of supporting zero-emission long-haul operations for heavy-duty vehicles. To enable market rollout at scale, regulatory certainty is now required.
CharIN calls for a Delegated Act in 2026 to formally integrate MCS into the AFIR framework and unlock investment in high-power charging corridors.
To support advanced charging functionalities, backend communication systems must evolve in parallel with vehicle-side standards. CharIN recommends mandating prEN IEC 63584 (OCPP 2.1) as the backend communication layer, providing the basis for smart charging, certificate handling, and ISO 15118-20 implementation.
Definitions of key actors outlined in AFIR should be aligned with the more granular work on definitions, roles and responsibilities being developed under the Sustainable Transport Forum (STF). Clear governance supports consistent implementation across Member States.
AFIR requirements should remain consistent with other EU legislation, including the Low Voltage Directive (LVD) and RED III, to avoid conflicting obligations and unnecessary burden for manufacturers and operators.
Today’s fragmented landscape of National Access Points creates avoidable administrative complexity. CharIN supports a top-down European approach, centered on a single European Access Point, while recognising established industry protocols such as OCPI alongside DATEX II.
CharIN supports a self-declaration model for demonstrating compliance with technical AFIR requirements, similar to the approach under the Low Voltage Directive. This provides a workable pathway while avoiding disproportionate administrative complexity.
To avoid stranded assets and unnecessary e-waste, equipment placed on the market before new rules apply should retain the right to be installed where deployment has been delayed by permitting or grid connection constraints.
Europe currently has around 2,000 heavy-duty charging stations, while an estimated 20,000 will be needed by 2030. Closing this gap requires a robust framework that de-risks capital-intensive infrastructure projects.
Existing AFIR requirements on ad-hoc payments and price transparency should remain stable. Reopening these provisions risks costly retrofits, inconsistent implementation, and avoidable disruption to ongoing deployments.
CharIN remains committed to working with policymakers and industry stakeholders to ensure AFIR continues to support an interoperable, scalable, and future-proof charging ecosystem. A pragmatic and phased implementation approach is essential to deliver Europe’s mobility and climate objectives.
