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NIO

NIO designs, develops, manufactures and distributes premium smart electric vehicles and drives next-generation innovation in autonomous driving, digital technologies, electric powertrains and batteries.

Lobbying Activity

Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič) and China Chamber of Commerce to the EU and

15 Jul 2025 · Automotive sector and EU trade developments

Meeting with Enikő Győri (Member of the European Parliament)

5 Mar 2025 · exchange of views on EV cars

Meeting with András Gyürk (Member of the European Parliament)

5 Feb 2025 · Electromobility

Response to Standards for wireless recharging, electric road system and vehicle-to grid-communication of recharging infrastructure

17 Dec 2024

NIO manufactures smart premium EVs, is a CPO and charger manufacturer for other CPOs. The draft Annex contains many requirements that contradict the objectives laid out in the delegated acts, as well as the AFIR: publicly accessible (9), recharging competitive market (32), Price transparency (33), non-preferential treatment of MSPs (34), user-friendliness and non-discrimination (37). Our concerns focus on two topics: ISO 15118-2 mandate for public AC and DC chargers and the -20 requirement for private chargers. As regards the short-term ISO 15118-2 requirement 2.1.1 for public AC and DC chargers, the additional hardware and higher software costs associated with this complex communication protocol and the necessary Public Key Infrastructure will increase the total cost of deploying charging stations. This is particularly challenging in an industry struggling to provide charging to the public at attractive prices while being profitable. For public AC chargers, this requirement is even more challenging, as there are barely any AC charger manufacturers, who will be able to implement ISO 155118-2 in such a short timeframe. This will stall the rollout of AC chargers, as manufacturers cannot be sure that newly produced non-ISO compatible chargers can be deployed in time. Every charger that is not compatible and not installed before the due date will become electronic waste on an enormous scale. Technology often prescribes a certain business model and ISO 15118-2 is no exception. The current and future implementation of Plug&Charge according to 15518-2 and -20, does not allow for the direct payment to a CPO. Unlike a credit card, CPO App or Autocharge, Plug&Charge requires an MSP - usually one closely aligned with the OEM - to act as an intermediary. There is also no legal basis for independent MSPs to gain access to a Plug&Charge compatible vehicle. This leads to increased costs and reduced price transparency, as the price displayed at the charger is seldom the price paid by the user, since MSPs typically create their own pricing rules. This reduces the ability of CPOs to charge time-dependent prices to spread out demand and reduce waiting lines. In addition, while EMVCo is asking to be included, currently there is no realistic roadmap to transfer credit card information via Plug&Charge to the CPO for direct payment. Unfortunately, point 2.1.2 indicates Autocharge as a method of offering automatic authentication services will be outlawed from 2027. As stated above, Plug&Charge is not a direct substitute to Autocharge as it does not allow the user to pay the CPO without an intermediary. Point 2.1.3 is equally problematic, as mandating ISO 15118-20 for even simple AC home chargers will greatly increase the cost of owning an EV. AC chargers will need to add a Powerline Communications Module and an active internet connection to regularly renew certificates. This will greatly increase product and installation costs, but also lead to many more potential points of failure and a less reliable system overall. The advantages of implementing ISO 15118-20 are only relevant for the bidirectional charging use case. If the intention is to mandate the use of ISO 15118-20 for bidirectional charging, then a more explicit formulation would serve that objective better. National schemes using unidirectional AC home chargers as variable consumption points to balance the DSO and TSO grids work well without an ISO 15118-20 requirement. We see an increased risk of EV drivers shifting their private charging to Mode 2 solutions - slower, less safe and less smart compared to Mode 3 chargers which runs counter to the overall goals. If the Commission seeks interoperability, it should mandate DIN SPEC 70121 on DC chargers for the foreseeable future. Innovation in the charging space should not be curtailed by new regulations. ISO 15118-20 will not be the last standard used for charging EVs and regulations should reflect this.
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Meeting with István Ujhelyi (Member of the European Parliament)

21 Feb 2024 · Transportation and Tourism