FACT SHEET EUROPE

MARCH 2022

A review of the Alternative

Fuels Infrastructure Regulation
(AFIR) proposal
BACKGROUND AND REGULATORY CONTEXT
Decarbonizing road transport is a key lever to meet the European Union’s (EU) Climate
Law objective of carbon neutrality by 2050. Transitioning to zero-emission vehicles,
namely battery-electric and fuel cell vehicles, is necessary to achieve these objectives.
The technological feasibility and economic viability of these vehicles have already been
established in previous ICCT assessments. However, building an extensive charging and
hydrogen refueling network is a prerequisite to enable high adoption of these vehicles.
The EU’s Alternative Fuels Infrastructure Regulation (AFIR) was proposed in July 2021
to address this issue, as part of the “Fit for 55” package of the European Commission.
The proposed regulation would set mandatory targets for deployment of infrastructure
for charging and hydrogen refueling for both passenger cars and vans as well as trucks.

PASSENGER CARS AND VANS

Regarding passenger cars and vans, the AFIR proposal suggests 1 kilowatt (kW) of
publicly accessible charging capacity for each battery electric vehicle (BEV) and 0.66
kW for each plug-in hybrid vehicle (PHV). As shown in Figure 1 below, all EU Member
States had already met the proposed targets as of the end of 2021. This suggests
that the regulation as proposed would not compel additional construction of charging
infrastructure in most of the EU in the near future.
 Total publicly accessible charging power output in

6.1
6
kilowatts per electric car or van on the roads

5.7 5.7

4.6 4.5
4.3
4.0
4

3.0 2.9 2.8 2.8

2.6
2.3 2.1 WEIGHTED MARKET AVERAGE 2.3
2 2.0 2.0 1.8 1.8 1.8 1.7
1.5 1.5 1.4 1.4
1.2
0.8
WEIGHTED ALTERNATIVE FUELS INFRASTRUCTURE REGULATION PROPOSAL (AFIR) 0.8

0
Croatia

Bulgaria

Latvia

Austria

Slovakia

Czech Republic

Netherlands

Hungary

Italy

Estonia

Malta

Belgium

Finland

Luxembourg

Romania

Germany

Portugal

Spain

Cyprus

France

Sweden

Denmark

Ireland

Lithuania

Poland

Greece
Figure 1. Total publicly accessible charging power output (in kW, data from Eco-Movement) per
electric car and van on the roads at the end of 2021 for every European Union Member State
(data not available for Slovenia).

Many countries in the eastern part of the EU (e.g., Bulgaria, Latvia, and Slovakia) are
performing particularly well relative to the AFIR target, and have more public charging
capacity per vehicle than countries in the western and northern parts of Europe (e.g.,
Sweden, Denmark, and France). However, these eastern countries have had lower
electric vehicle uptake and have fewer charge points in absolute terms.

A detailed bottom-up analysis of charging infrastructure needs for passenger cars

and vans in Europe was conducted by the ICCT. Its results suggest that, while the
AFIR- proposed targets are sufficient in the long term, higher targets that vary
with the electric share of car and van stock are necessary in the short term. Indeed,
due to lower expected charge point utilization, higher charging targets are necessary
for markets with less than 15% electric share of passenger car and van stock. This
adjustment can be done using a stepwise approach, as illustrated in Figure 2 below.

2.1
Publicly accessible power output in
kilowatts (kW) per electric vehicle

2.0

1.6
1.5
1.3
Alternative Fuels Infrastructure
Regulation (AFIR) proposed 1.1
target for battery−electric vehicles 1.0 kW per battery electric vehicle
1.0
0.95
0.75
0.65 kW per plug−in hybrid vehicle
0.55
AFIR proposed target for 0.60
0.5 plug−in hybrid vehicles

2% 5% 10% 15% 20%

Share of electric cars and vans on the roads (stock)

Figure 2. Recommended total public power output per BEV (blue) and per PHV (red) depending
on Member States’ electric share of car and van stock.

2 ICCT FACT SHEET | A REVIEW OF THE ALTERNATIVE FUELS INFRASTRUCTURE REGULATION (AFIR) PROPOSAL
Markets with an electric car and van stock share below 5% will require public charging
power output of at least 1.6 kW per BEV and 0.75 kW per PHV. This is currently the
case for all EU Member States but Sweden. In the longer run—once 15% of a Member
States’ car and van stock is electric—the required public charging capacity will be 1
kW per BEV and 0.55 kW per PHV, similar to the AFIR proposal. This level of electric
vehicle uptake is expected for 2028 in the EU as a whole.

HEAVY-DUTY VEHICLES
The AFIR provisions regarding heavy-duty vehicles propose minimum requirements
for the rollout of the charging and hydrogen refueling infrastructure across the core
and comprehensive Trans-European Network for Transport (TEN-T). To assess the
suitability of the targets proposed by the European Commission, the ICCT conducted a
detailed bottom-up assessment of infrastructure needs for zero-emission trucks.

The proposed charging infrastructure rollout targets under the AFIR exceed the needs
of the battery-electric truck fleet in 2025. Nonetheless, it is essential to maintain these
targets because a rapid rollout of the infrastructure for zero-emission trucks is critical
to provide confidence in electric trucks among manufacturers and fleet operators
during the early market uptake phase. On the other hand, the AFIR proposal largely
underestimates the charging infrastructure needs for 2030 by more than 80%
(Figure 3).

The rollout of hydrogen refueling infrastructure resulting from the proposed targets
overestimates the needs of the fleet and would not be needed until 2035. This is
driven by the low expected market uptake for fuel cell trucks relative to battery-electric
trucks. Based on a techno-economic analysis developed by the ICCT, fuel cell trucks
would account for only 9% of the long-haul truck sales by 2050.

The infrastructure rollout must not be homogeneous across Member States but
rather targeted based on traffic volumes along the different segments of the TEN-T
network. This recommendation stems from our analysis of traffic flow data.

Total installed power of public charging infrastructure (Gigawatts)

Commission proposal, 2025 2.2

Parliament rapporteur, 2025 3.1

ICCT, 2025 1.7

Commission proposal, 2030 7.1

Parliament rapporteur, 2030 10.2

ICCT, 2030 13.0

overnight public fast public ultrafast public

(100 kW), 18% (350 kW), 24% (1 MW), 58%

Figure 3. Total required installed power as calculated by the ICCT and compared to targets
proposed by the European Commission and by the European Parliament’s rapporteur.

The AFIR targets for heavy-duty vehicles could be amended to align with the ICCT
results regarding the total required charging power and hydrogen refueling stations’
capacity, while giving flexibility to adopt lower targets based on traffic volume across
the different segments of the TEN-T network. By default, Member States should
comply with the highest proposed targets. However, Member States can pursue lower
targets on some roads of their domestic TEN-T network by applying to the European

3 ICCT FACT SHEET | A REVIEW OF THE ALTERNATIVE FUELS INFRASTRUCTURE REGULATION (AFIR) PROPOSAL
 Commission for a derogation complete with documentation of the low traffic volumes
along these roads.

Several recommendations can be drawn from the analysis. These are summarized
below and presented in Figure 4:

» For the 2025 targets, increase the charging pool nominal power requirements
across the core TEN-T network to 2,000 kW every 60 km, while allowing the
flexibility to adopt lower targets based on traffic volumes.
» For the 2030 targets, align the charging pool nominal power requirements for the core
and comprehensive networks and increase the nominal power to 9,000 kW every 60
km while allowing the flexibility to adopt lower targets based on traffic volumes.
» For hydrogen refueling stations, eliminate the simultaneous requirement for liquid
and compressed hydrogen and increase the hydrogen refueling station nominal
capacity requirement to 3 tonnes per day every 150 km while allowing the flexibility
to adopt lower targets based on traffic volumes. We also recommend postponing
the implementation of these targets until 2035.

Charging: Core network 2025 (every 60 km) Charging: Core network 2030 (every 60 km)
2.5 12
< 3,000 3,000 6,000 > 9,000 < 3,000 3,000 6,000 > 9,000
Charging pool capacity (MW)

Charging pool capacity (MW)

to to to to
6,000 9,000 10 6,000 9,000
2
2 MW 9 MW
8
1.5 COMMISSION’S PROPOSAL

1.4 MW 6
6 MW
1
4 COMMISSION’S PROPOSAL

0.5 0.7 MW 3 MW
2
0.35 MW 1.4 MW
0 0
0 2,000 4,000 6,000 8,000 10,000 12,000 0 2,000 4,000 6,000 8,000 10,000 12,000
Traffic flow (HDVs/day) Traffic flow (HDVs/day)

Charging: Comprehensive network 2030 (every 60 km) Hydrogen: Trans-European network 2035 (every 150 km)
12 4
Hydrogen station capacity (t/day)

< 3,000 3,000 6,000 > 9,000 < 3,000 3,000 6,000 > 9,000
Charging pool capacity (MW)

to to 3.5 to to
10 6,000 9,000 6,000 9,000 3t/day
3
9 MW COMMISSION’S PROPOSAL for 2030
8
2.5 (liquid + compressed H2)

6 2
6 MW
2t/day
1.5
4
1
3 MW 1t/day
2 COMMISSION’S PROPOSAL
0.5
(every 100 km) 0.5t/day
1.4 MW
0 0
0 2,000 4,000 6,000 8,000 10,000 12,000 0 2,000 4,000 6,000 8,000 10,000 12,000
Traffic flow (HDVs/day) Traffic flow (HDVs/day)

Figure 4. ICCT’s proposal for traffic-based targets for the rollout of charging and hydrogen
refueling infrastructure along the Trans-European Network for Transport – core and
comprehensive.

4 ICCT FACT SHEET | A REVIEW OF THE ALTERNATIVE FUELS INFRASTRUCTURE REGULATION (AFIR) PROPOSAL
PUBLICATION DETAILS
Title: A review of the AFIR proposal: How much power output is needed for public charging
infrastructure in the European Union?

Authors: Marie Rajon Bernard, Michael Nicholas, Sandra Wappelhorst, and Dale Hall

Download: https://theicct.org/publication/europe-ldv-review-of-afir-proposal-how-much-power-
output-needed-for-public-charging-infrastructure-in-the-eu-mar22
www.theicct.org
Contact: mrajonbernard@theicct.org
communications@theicct.org

Title: A review of the AFIR proposal: Public infrastructure needs to support the transition to a twitter @theicct
zero-emission truck fleet in the European Union.

Authors: Pierre-Louis Ragon, Eamonn Mulholland, Hussein Basma, and Felipe Rodríguez

Download: https://theicct.org/publication/europe-hdv-review-of-afir-proposal-public-
infrastructure-needs-to-support-transition-to-zero-emission-truck-fleet-in-eu-mar22

Contact: p.ragon@theicct.org

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