Hubject GmbH
N/A
Since 2012, our mission has been leading in enabling the ecosystem to offer customer-friendly charging solutions.
ID: 429679893105-39
Lobbying Activity
Meeting with Anna Panagopoulou (Cabinet of Commissioner Apostolos Tzitzikostas), Helena Hinto (Cabinet of Commissioner Apostolos Tzitzikostas), Simone Ritzek-Seidl (Cabinet of Commissioner Apostolos Tzitzikostas) and
1 Oct 2025 · 1. Clean transport corridors 2. Corporate fleet initiative 3. HDV related elements 4. updates on what happens by then with the working groups set up at the HDV dialogue
30 Dec 2024
At Hubject, we welcome the Delegated Acts amending Regulation (EU) 2023/1804, recognizing their potential to substantially advance interoperability within the e-mobility sector. However, prior to the adoption and enforcement of these draft Delegated Acts, it is essential that several key aspects are addressed and clarified. These include ensuring consistency with existing regulatory framework, resolving ambiguities in key provisions, and providing more detailed guidance on their practical implementation. Data on alternative fuels infrastructure technical specifications (format, frequency and quality): The current data requirements mentioned in the Annex to the Delegated Act on technical specifications do not fully address the specific needs of Heavy-duty vehicles. In this regard, we recommend including additional static data types, such as: Information on the charging point/connector position, in relation to the associated parking space (left/right/central). Availability of reservation and booking service (including a yes/no data field) to enhance user planning and convenience. Specification of cable length (in meters). Information on drive-through capability (including a yes/no data field), ensuring better accessibility for larger vehicles and improving user experience.
Read full responseResponse to Data types for alternative fuels infrastructure
30 Dec 2024
At Hubject, we welcome the Delegated Acts amending Regulation (EU) 2023/1804, recognizing their potential to substantially advance interoperability within the e-mobility sector. However, prior to the adoption and enforcement of these draft Delegated Acts, it is essential that several key aspects are addressed and clarified. These include ensuring consistency with existing regulatory framework, resolving ambiguities in key provisions, and providing more detailed guidance on their practical implementation. Data on alternative fuels infrastructure additional data types: We welcome the fact that additional data types specifically address new technological developments and services, such as Plug&Charge. However, we recommend that additional data types should explicitly indicate which versions of ISO 15118 (e.g ISO 15118-2 and ISO 15118-20) are supported for the Plug& Charge functionality. This will enhance transparency and interoperability with the e-mobility ecosystem. We recommend that additional guidance be provided to ensure the quality and reliability of data provided by operators regarding: Facilities offering associated services: In most cases, these facilities (e.g. amenities) are not owned or operated by the recharging or refueling infrastructure operators, which can lead to discrepancies or inaccuracies in the data. Recharging point maximum power: It occurs frequently that although a charging point would have the capacity to deliver a maximum power rating, this maximum would depend on the available power subscribed with the DNO/DSO and the current power consumption at charging hub at a given time t - hence this data point varies dynamically based on the available power (i.e. real available power at charging point can be less or equal to the maximum rated power). A Dynamic Type of Data for a Data Type that reflects, as an example, the Last Recharging point maximum... available ...power" would correspond more accurately to the real-life use case. Plug&Charge: In certain cases, charging points may use this indicator to inaccurately reflect the Plug&Charge capability based on ISO15118 of the charging point where in such a case, the service may or may not be available as it is not activated by the charging point provider or operator although the charging point is technically capable of delivering it. In such cases, we strongly recommend including an indicator to whether the Plug&Charge based on ISO15118 service is activated/not activated in the same Data Type as well as adding the information, which version of the ISO15118 norm is available ISO15118-2 and/ or ISO15118-20. In addition, to avoid any confusions with other existing authentication methods. Plug&Charge should be referred to as the service described in ISO15118. We recommend the addition of (1) OCPP version and (2) Charging Station manufacturer brand and model names as well as (3) the actually used Firmware version to the list of data of static data points to support maintenance and service operations in controlling efficiently overall service quality. It occurs that several interoperability challenges for vehicle OEMs, CPOs and EVSE manufacturers result from changes in software versions due to required updates/fixes which eventually have negative repercussions on the delivery of services (i.e. Plug&Charge as one example) and by transitivity on the charging sessions success.
Read full response30 Dec 2024
At Hubject, we welcome the Delegated Acts amending Regulation (EU) 2023/1804, recognizing their potential to substantially advance interoperability within the e-mobility sector. However, prior to the adoption and enforcement of these draft Delegated Acts, it is essential that several key aspects are addressed and clarified. These include ensuring consistency with existing regulatory framework, resolving ambiguities in key provisions, and providing more detailed guidance on their practical implementation. Alternative fuels infrastructure standards wireless recharging, electric roads, vehicle/grid communication, hydrogen: This draft of an upcoming delegated act recognizes the importance of a harmonized and standardized framework for enabling smart and bidirectional charging in the future. Today, there is no leading approach visible, market participants are following different approaches, versions and implementations, therefore the value of having a clear perspective on how to enable these very important use cases cant be diminished. Nevertheless, it is important to highlight that such requirements only reflect on the communication between the EV and the charging station and additional actors would need to be addressed in the future. Regarding the actual draft, we recommend that the specific provisions and exact timelines for mandating the ISO15118 norm be more clearly defined to ensure a smooth and effective implementation process. It should be clearly defined if the Delegated Acts include a mandate for the base ISO 15118 norm and which additional features are considered optional or mandatory for different use cases as the ISO15118 norm defines different use cases which are different between ISO15118-2 and ISO15118-20: We welcome the fact that the Delegated Acts in relation to Regulation (EU) 2023/1804 mandate the implementation of ISO15118-2 and ISO 15118-20, thus enabling the implementation of Plug&Charge. However, the Delegated Acts should provide clearer guidance on the Plug&Charge provisions, in terms of implementation timeline and specific requirements for stakeholders: 1) between 2025-2027 and 2) from January 1, 2027, onwards. As the language of the delegated acts is open for interpretation, it should be clearly stated that both ISO118-2 and ISO15118-20 are mandatory starting with January 1, 2027, instead of the formulation ISO15118-2 and ISO15118-20. In addition, it is of utmost importance to clearly define the terminology relating to publicly accessible recharging points built or renovated from 1 January 2027, as this is not mentioned in the text of the Regulation (EU) 2023/1804, to ensure consistently and avoid ambiguity. According to the draft Delegated Acts, private recharging points built or renovated from 1 January 2027 will need to comply with ISO15118-20 for Mode 3 or Mode 4 recharging. However, Regulation (EU) 2023/1804 lays down mandatory minimum targets for the deployment of publicly accessible recharging and refueling infrastructures for road vehicles. Therefore, we deem it necessary to clearly stipulate if the terminology private recharging points refers strictly to private recharging points, which are publicly accessible -and thus within the scope of AFIR -or the intention of the European Commission is to include provisions regarding privately accessible recharging points, which fall within the scope of EPBD. Additionally keeping in mind that the scope of the AFIR is charging infrastructure we recommend a clear requirement on the side of the EVs as well to support the implementation of the ISO15118 norm on the infrastructure side only by having enough EVs in place using both versions in the future will help the charging point operators to direct the right funding into fulfilling this requirement.
Read full response