CHAdeMO Association
CHAdeMO
With a vision of 'powering global zero emission mobility for the happiness of future generations,' and a mission of 'bringing safe, affordable and interoperable charging to EV drivers,' CHAdeMO Association develops CHAdeMO DC charging protocols (IEC/EN standards).
ID: 747880212094-25
Lobbying Activity
28 Dec 2024
CHAdeMO Association wishes to comment on Annex II 1.3.3 (DC charging for L-category) as well as on 2.1 (vehicle-to-grid communication). Regarding Annex II 1.3.3, requiring at least Combo 2 for Mode 4 normal- and high-power charging for L-category electric vehicles does not meet the needs of the industry or users. 1. The Combo 2 connector as described in EN IEC 62196-3:2022 and Combined Charging System (CCS) are not suitable for most widely used L-category electric vehicles. This connector is too large to be installed in small-size vehicles such as L1e and L2e vehicles. The specified voltage range of the CCS system (200V to 920V) does not match the 48V battery voltage used in many L1e category vehicles, either. It should be noted that these smaller segments (L1e / L2e) represent more than 95% of the electric two-wheeler market in Europe. These vehicles are viable solutions for crowded cities and are the means of transport with the lowest CO2 footprint of all individual electric vehicles. L3e vehicles are typically electrified versions of heavy motorbikes, and these vehicles can use existing M1 (automotive) category chargers, including Combo 2 connectors. However, they are developed more for leisure purposes and their market penetration is extremely low. 2. Focusing on the wider usage of L1e / L2e and partially (smaller) L3e vehicles, industry stakeholders developed IEC 62196-6, published in 2022, to be used for DC charging system according to IEC 61851-25:2020 (see attached document for more details on these standards). This charging system and its associated connector were recommended by ACEM (European Association of Motorcycle Manufacturers) at the time of the AFID revision (October 2022), as shown in the Associations position paper of October 2022 (https://acem.eu/wp-content/uploads/2022/10/ACEM_Position_Paper_-_Emobility.pdf, attached). 3. A blanket mandate of Combo 2 plugs to all recharging points reserved for L-category electric vehicles risks hindering the development and installation of recharging points for these market segments (L1e, L2e, etc.), stifling innovation, and delaying the electrification of L-category vehicles. 4. We propose that the application of the Combo2 plug be limited to subcategories such as (part of) L3e, L4e, L5e, and that the proposed text be changed to: "Direct current (DC) normal-power recharging points reserved for L-category electric vehicles shall be equipped, for interoperability purposes, at least with vehicle connectors as described in standard EN IEC 62196-6:2022 for Mode 4 recharging and at least Combo 2 to be applied only to high-power recharging points reserved for L-category electric vehicles. Regarding vehicle-to-grid communication (point 2.1), we welcome Recital (21) and (22) of the delegated regulation. These exempt all existing and working chargers, including multi-standard chargers, from Annex II 2.1.1, and preserve all chargers in operation. We appreciate this consideration for the convenience of legacy EV users and to avoid chargers becoming stranded assets. However, we were surprised to see the mandate extended to the private domain. As a member of the STF expert sub-group, we began our work on the premise of considering public domain charging standards covered by AFID/AFIR. It is regrettable that the proposal to apply such technical requirements (which are anticipated to have a significant impact on the industry) to the entire private domain was made without thorough discussion from the outset in the expert group. CHAdeMO Association is a not-for-profit organisation developing DC charging standards for electric vehicles of all types and is a member of the Sustainable Transport Forum (STF) expert sub-group on standards. The Associations 500+ worldwide members (including 140 European companies) provide EV-charging related products and services, and are active contributors in the domain of electro-mobility international standardization.
Read full responseResponse to Revision of Alternative Fuels Infrastructure Directive
17 Nov 2021
CHAdeMO Association calls for a truly transparent, open and inclusive process for the development of technical specifications and advise against prematurely mandating standards that would stifle innovation.
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CHAdeMO Association embraces the Commission’s enthusiasm and ambition for accelerating zero-emission transport. The association also welcomes the importance given to the bidirectional charging, also known as V2G (Vehicle to Grid). Today, CHAdeMO is the only enabling standard of V2G and the Association is keen to continue accompanying Europe in its journey to carbon neutrality.
While the Association considers the proposed revision of AFID a step in the right direction, the proposal also raises concerns about the necessity of mandating some technical requirements for interoperability of recharging and refuelling points.
The Commission identified and included more than 40 new technical requirements ‘to be standardised’ in its proposal for the revision of AFID (Annex II). Of these, we find the below items to be particularly premature and unnecessary to standardise and urge the Commission not to set the European de jure standards in a hasty manner. On the contrary, market players should be given options on a level playing field so that innovations are fostered for Europe to get ahead and for its consumers to select the products and services of their choice.
• Technical specifications regarding the connector for recharging heavy-duty vehicles (DC charging) (Annex II, 1.17)
• Technical specifications for communication exchange in the electric vehicle recharging ecosystem (Annex II, 2)
o 2.1 communication between EV and CP (charge point)
o 2.2 CP and CP management system (back-end)
o 2.3 CP operator, electromobility service providers and e-roaming platforms (roaming)
o 2.4 CP operator and distributed system operators (grid)
For the domains listed above, international standardisation and harmonisation efforts are on-going by the global experts, and mandating ‘European’ standards for these categories ahead of international standardisation shall risk locking in the European consumers with a technology that is not fully validated in the market. In particular, communication exchange (Annex II.2) is an extremely rapidly evolving domain, where technologies are known to become quickly outdated. CHAdeMO Association would therefore alert that mandating a specific protocol at this early stage would stifle innovation rather than encouraging it, which in turn would harm consumers in Europe.
For example, when we start seeing more and more advanced identification and authentication methods such as facial and biometric recognitions, why should Europe choose to mandate a costly wired EV-CP communication with limited bandwidths to all charging infrastructure?
There are numerous solutions already existing in the market in Europe in communication exchange, some of which are considered to be the de facto industry standards. The market players pick and choose the options that best suit their needs, and innovations are born through such competitions for each layer of communication. We advise the Commission to set high-level rules and architecture, instead of mandating specific protocols.
For example, without additional communication protocols, existing solutions (e.g. CHAdeMO + OCPP) can manage almost all smart charging and even bi-directional charging use cases already. We inform that with the increasingly connected and automated vehicles, wireless communication (Wi-Fi) may prove to be more future-proof.
Should Europe decide to mandate specific technical specifications despite the premature state of international standardisation, the Association invites the Commission to consult and coordinate with all stakeholders so as not to compromise the transparency, openness and consensus of the standardisation procedure.
Read full responseResponse to Standards for recharging points for e-buses
20 Apr 2021
We support Europe in its efforts of advancing zero-emission mobility and the European EV market’s rapid expansion as demonstrated in 2020 despite the COVID-19 outbreak. It is no doubt that the ambition of the Commission and the policy tools helped the industry achieve the big jump in EV sales. We would be willing to assist the Commission in accelerating this trend in an inclusive manner, leaving no one behind, by contributing to this public consultation initiative.
With this background, CHAdeMO Association wishes to express our support for the proposed Commission Delegated Act regarding electric bus recharging points, especially its article 1 b) in which the combined charging system ‘Combo 2’ is defined as the minimum requirement of DC high power recharging technology. At the same time, we would like to recall that this should apply only to ‘publicly accessible’ charging infrastructure as defined in Recital 26 of 2014/94/EU:
The specificities of bus recharging system should be taken into account for an open and fair competition for e-bus charging
o Bus recharging system can greatly differ from one another and have typically been bespoke. This is due to the fact that bus recharging systems are needed primarily to fulfil performance requirements to ensure service reliability, which differ greatly depending on various factors such as the vehicle specifications, service route and frequency, and also because they are typically in the grounds of the bus depot inaccessible to the public.
o Bus depots that are inaccessible to the public can also be quite suited to smart charging, especially overnight charging at the depots. Operators of bus fleets should be able to select their standard of choice: for example, CHAdeMO charging protocol, the only standardised solution of V2G bi-directional charging, is already available to be integrated in the grid, in accordance with the grid codes of various European markets.
o With regards to the contact interface automated device for electric buses recharging concerning the various automated connection devices (ACD), it is even rarer that these devices are made open to the public or shared with other vehicles.
Publicly accessible e-bus charging systems should cater to as many EV users as possible and to this effect multi-system charging is the natural choice
o Considering the aforementioned heterogenous character of bus recharging needs, we wonder to what extent mandating a single recharging standard can be an effective policy measure to accelerate the e-bus uptake. However, in some use cases such as where the e-bus recharging infrastructure on the publicly accessible ground can be shared for public use during specific periods of time, it makes sense to make the charger available to the public.
o In order to serve as many EV users as possible, multi-standard charging should be the natural choice. By extending the European multistandard de facto charging system offering various DC charging options (CHAdeMO/Combo2 and potentially AC high power charging), Europe can optimise the use of its publicly accessible public e-bus recharging infrastructure.
Keep in mind that this clause should apply to publicly accessible chargers only
o We wish to recall that this charging system mandate applies exclusively to publicly accessible chargers. As per Recital 26 of the Directive 2014/94/EU, the bus fleet operator should not be bound by this new decision outside of publicly accessible charging.
o Open market and fair competition are key for better services for end customers. Keeping requirement minimum (publicly accessible recharging facilities only, ‘at least CCS’) can leave choices to customers and leave room for innovations, leading to greater service delivery for the customers in the long run. We therefore invite European Commission to inform the stakeholders that this clause should apply to the above specific cases only.
Read full responseResponse to Evaluation of the Alternative Fuels Infrastructure Directive
20 Mar 2019
The Directive on the deployment of Alternative Fuels Infrastructure (DAFI) went into effect when electro-mobility was still at its nascent stage in Europe. With the expected acceleration of the market, it is indeed important to revise its content to keep it aligned with the dynamic changes that are taking place in and around electro-mobility today and to help decarbonise the European Economy in a longer term.
In terms of the effectiveness of the DAFI, we have observed how the EU funds and initiatives such as TEN-T and CEF projects have provided an excellent kick-start to the multi-standard (equipped with both CHAdeMO and the CCS Type 2 connectors) high-power charging infrastructure to enable long distance driving for all EVs. This can further accelerate to fully cover at least all key corridors on the TEN-T Core Network, in urban/suburban agglomerations and other densely populated areas as described in the DAFI.
In terms of efficiency, as ultra high-power vehicles (“up to 350kW) could only be expected to become the mainstream around 2030, we suggest prioritising 150kW-level chargers as a good compromise to enable long-haul drives and for the deployment along the key corridors.
As to the technical requirements, we ask the absolute minimum be prescribed, in order to encourage healthy (and fair) competition amongst various technologies and to allow for the easy integration of future innovative breakthroughs and not just those available today. As the international technical experts meet on a regular basis to strive for harmonised technical standards the political intervention on the technology front should be avoided to the maximum.
Additionally, CHAdeMO is the only enabler of V2X (vehicle-to-everything), sometimes referred to as vehicle to grid (V2G) or vehicle-grid integration (VGI), with series-production EVs and V2X-capable certified chargers (or power conditioners, PCS) readily available in the market, and our members have been actively engaged in innovative V2X projects in Europe and on a global scale. As the benefits of V2X for grid services are clear drivers for EV adoption as well as RES (renewable energy source) integration, it is our hope to see the V2X-related technical requirements be harmonised on a pan-European level, so that the integration of plug-in vehicles as DES (distributed energy sources) via aggregators can be facilitated, although it is to be clearly defined as to what items of this domain should fall under the realm of the AFI Directive revision.
It is indeed extremely important that the DAFI remain technologically neutral and prescribe only the minimum requirements for faster and more innovative way forward. CHAdeMO Association wishes to make further contribution in the revision of the DAFI and share our experience in high-power charging and standard harmonisation, as well as our expertise in V2X.
About CHAdeMO:
CHAdeMO Association is a unique alliance of e-mobility stakeholders around the CHAdeMO DC high power charging protocol (IEC/EN/IEEE), supporting electro-mobility from the charging infrastructure side. With 430 members from over 40 countries (of which 130 EU companies from 26 countries), CHAdeMO is the leading high-power charging protocol serving 50% of fast-chargeable BEVs in Europe and 44% of global fast-chargeable EVs (2009-2018) on the roads.
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