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Hubject GmbH

Hubject

Die eRoaming-Plattform für kundenfreundliches Laden von Elektrofahrzeugen Mit über 750 Partnern ist die Hubject eRoaming-Plattform der international größte digitale B2B-Marktplatz für Dienstleistungen rund um das Laden von Elektrofahrzeugen. Über 250.000 Ladepunkte auf vier Kontinenten sind an der offenen Plattform von Hubject angeschlossen. Seit 2012 vernetzen wir unterschiedliche Marktakteure, um gemeinsam mit unseren Partnern ein digitales und flächendeckendes Ladenetzwerk für Elektroautos zu erschaffen – das intercharge-Netzwerk. Unser Angebot richtet sich z.B. an Ladestationsbetreiber, Fahrstromanbieter, Energieversorger, Flottenbetreiber, Carsharing-Unternehmen, Servicekartenanbieter oder Automobilhersteller.

Lobbying Activity

Response to Revision of Alternative Fuels Infrastructure Directive

18 Nov 2021

Hubject welcomes the Commission’s proposal for the AFIR and sees it as an opportunity for the EU to establish the right legal framework to create the best market conditions for a technologically interoperable EV charging infrastructure (EVCI) ecosystem to equip end consumers across the EU with a seamless EV charging experience. Hubject believes that technological EVCI interoperability is the main pre-condition for strategic EV charging market expansion in the coming years and for the EU reaching climate neutrality by 2050. Hubject foresees that the EVCI expansion will be paired with additional layers of complexity, not only due to the increase of EVs but also due to the integration of new market players. This complexity in an ever-expanding market needs to be properly managed and technological EVCI interoperability is key in this regard. Hubject, therefore, believes that the following considerations should be taken into account: 1. Upholding technology neutrality to foster market competition. For the benefit of a well-developed and forward-looking EV charging market and the consumers’ confidence in technology, AFIR should put all existing EV charging technologies and solutions on an equal footing and treat them in a technology-neutral manner: this includes authentication methods and payment solutions. In this respect, Hubject recommends that CPOs should not be obliged to have payment card readers or contactless payment terminals installed on charging stations. CPOs should also not be obliged to offer alternative authentication methods in case they have installed automatic authentication on the charging stations, and the consumer has previously opted for automatic authentication. 2.Providing right regulatory incentives and tools for fostering innovation. Hubject welcomes the proposal to oblige all publicly accessible recharging points to be capable of smart recharging. For the end-consumers to reap concrete cost-saving benefits from the data trade-off that smart recharging requires, the recharging station at which the recharging session takes places, needs to have a connection with multiple energy providers which compete for the best price and the opportunity to provide energy for the recharging session. Hubject recommends that AFIR ensures a level playing field for all the actors involved in the smart recharging value chain, including MSPs and energy providers, as their involvement improves grid functioning and reliability, and optimises the charging cost for the end-consumer. 3. Increasing transparency for end consumers. In enforcing pricing transparency, Hubject draws the Commission’s attention to the practices of comparable industries, such as telecommunications, where the focus is on the end consumer pricing, rather than business calculations insights, as this impacts the attractiveness of investment, and believes that AFIR should reflect this as well. 4. Creating a truly interoperable EV charging market for the benefit of end consumers. Hubject believes that in an ever-growing EV charging market with multiple -types of- market players, interoperability of charging infrastructure is key to ensure consumer confidence. Over-investments, overlaps of charging infrastructure and lock-ins by certain market players must be avoided. The AFIR proposal needs to put the end consumer first: this means that all EV charging market players, such as CPOs, MSPs, energy providers, parking facilities providers, and others, must be inter-connected in order to avoid lock-in effects and to provide the most reliable and easy-to-access service possible for the end consumer.
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