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Platform for Electromobility

PfEM

The Platform for Electromobility is an alliance of organisations promoting sustainable transport and electric vehicle technology in Europe.

Lobbying Activity

Meeting with Beatriz Yordi (Director Climate Action)

6 Nov 2025 · Discussion on an industry statement in support of ETS2

Response to Circular Economy Act

5 Nov 2025

We welcome the announcement of the Circular Economy Act (CEA), a key tool to develop a European Single Recycling market and scale effective recycling across the EU. Transport industries, especially the forward-looking sectors of electric mobility, must be considered as a central part of the CEA and the broader policy discussions surrounding Europes transition to a circular economy. Compared to fossil-fueled transport, electromobility practices and industries have the potential to significantly boost resource efficiency, reduce waste, and foster sustainable practices across the continent. Notably, the CEA represents a timely opportunity to build a truly circular market for electric vehicles (EV) and their batteries in Europe. With the right regulatory framework, Europe can unlock the full recycling and reuse potential of EVs and batteries, turning them into strategic assets for industrial competitiveness, innovation, and strategic autonomy. Ensuring that end-of-life vehicles and batteries are processed and recycled within Europe will foster high-value circular value chains, create future-oriented jobs, and support the EUs environmental leadership. This paper first revisits the essentials of a truly circular economy; then outlines the inherent circular nature of electric mobility; and finally proposes concrete recommendations to enable a circular electric transport system and industry via the CEA To enable a recycling system for electric transport, we recommend to: 1. Scale up Europes recycling capacity: The CEA should prioritise the rapid development of industrial-scale pre-processing and high-quality recycling facilities in Europe, particularly for EV batteries, to close the gap between expected waste volumes and current limited capacity. 2. Increasing the use of recycled materials, with recycled and local content targets: Prioritise incentive-based measures to boost the use of recycled and locally sourced battery materials, going hand in hand with gradually binding local content targets, while allowing exemptions for materials where the recycling market is already functioning well. 3. Create a true Single Recycling Market: Harmonise and simplify intra-EU waste shipment rules, while fostering conditions that favour the processing of strategic waste streams within Europe, to ensure that valuable materials are recovered and reinvested into European clean tech industries. Please find all details and recommendations in the attached document.
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Platform for Electromobility seeks budget for clean transport deployment

14 Oct 2025
Topic — Consultation on the EU's post-2027 long-term budget focusing on European competitiveness.
Message — The Platform calls for a budget aligned with long-term goals to unlock massive investments in electric mobility. They advocate for financial instruments that accelerate the deployment of clean infrastructure and technologies across the value chain. Access to funding should be linked to the correct and timely implementation of EU legislation.123
Why — Dedicated funding would provide the necessary predictability to attract private clean tech investment.4
Impact — Unrelated industries lose out as funding is restricted to strictly defined clean technologies.5
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Meeting with Matthias Ecke (Member of the European Parliament)

14 Oct 2025 · Automobilsektor / Elektromobilität

Meeting with Elena Sancho Murillo (Member of the European Parliament) and Apple Inc.

14 Oct 2025 · Relevant issues to the ITRE Committee

Platform for Electromobility urges EU regulation for corporate fleets

5 Sept 2025
Topic — Proposal setting minimum requirements for zero-emission vehicle registrations in EU corporate fleets.
Message — The group calls for a regulation to ensure legal certainty and faster implementation. They recommend the scope cover all transport segments including light electric vehicles and trucks.12
Why — Mandates would increase demand for electric vehicles, supporting European manufacturers' climate targets.3
Impact — Non-compliant companies would face financial penalties that fund their electric-focused competitors.4
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Meeting with Moumen Hamdouch (Head of Unit Mobility and Transport)

15 Apr 2025 · Exchange of views on the European Clean Transport Corridor Initiative

Meeting with Lukasz Kolinski (Director Energy)

11 Apr 2025 · Recharging infrastructure and grid connections

Meeting with Grégory Allione (Member of the European Parliament)

10 Apr 2025 · Visio Platform for Electromobility

Meeting with Beatriz Yordi (Director Climate Action) and

24 Feb 2025 · Fuels in CO2 standards for cars and vans

Meeting with Pär Holmgren (Member of the European Parliament)

7 Feb 2025 · Recycling for Electromobility

Meeting with Michał Kobosko (Member of the European Parliament)

6 Feb 2025 · Discussion on clean industrial deal

Meeting with Benedetta Scuderi (Member of the European Parliament)

24 Jan 2025 · Efficiency for Electric Vehicles

Meeting with Elisa Roller (Director Secretariat-General)

15 Jan 2025 · Legislative instrument on electric vehicles in corporate fleets

Meeting with Sander Smit (Member of the European Parliament)

29 Nov 2024 · ENVI

Meeting with Eero Heinäluoma (Member of the European Parliament) and Bloomberg L.P.

26 Sept 2024 · Current Affairs

Meeting with Bruno Gonçalves (Member of the European Parliament) and Knauf Insulation

3 Sept 2024 · ITRE policies

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

25 Jun 2024 · Presentation of their investment plan for zero emission mobility

Meeting with Aleksandra Baranska (Cabinet of Vice-President Maroš Šefčovič)

26 Apr 2024 · Electromobility

Meeting with Daniel Mes (Cabinet of Commissioner Wopke Hoekstra)

19 Feb 2024 · automotive industrial agenda

Platform for Electromobility urges harmonized EU vehicle recycling rules

4 Dec 2023
Topic — This initiative aims to improve vehicle collection, recycling, and circular car design.
Message — They support a harmonized regulatory framework and an export ban on non-roadworthy vehicles. The group seeks alignment with battery laws to avoid administrative redundancy via merged digital passports. They also seek incentives for low-carbon materials and consumer demand for sustainable EVs.123
Why — This would reduce their compliance costs by preventing duplicative reporting requirements for batteries.4
Impact — Exporters of old cars lose revenue because of the ban on non-roadworthy vehicles.5
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Meeting with Ciarán Cuffe (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

24 Oct 2023 · Weights and dimensions directive

Meeting with Pablo Fabregas Martinez (Cabinet of Commissioner Adina Vălean)

7 Jun 2023 · Electromobility

Platform for Electromobility urges inclusion of electric vehicles in NZIA

11 May 2023
Topic — This consultation addresses the Net Zero Industry Act to accelerate the transition to climate neutrality.
Message — The organization requests that zero-emission vehicles and enabling technologies be classified as Strategic Net Zero Technologies. They advocate for faster permitting, simplified state aid rules, and the creation of a European Sovereignty Fund. These measures aim to support the entire value chain from cell manufacturing to downstream industries.123
Why — The industry would benefit from increased competitiveness and dedicated financial incentives to match global rivals.4
Impact — International manufacturers from Asia and the US would face stronger, subsidized European competition.5
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Response to European Critical Raw Materials Act

27 Apr 2023

The European Commissions proposed Critical Raw Materials Act is a much-needed initiative in today's world. Demand for critical raw materials (CRMs) will continue to increase, in order to underpin a sustainable transport system in the near future. Indeed, the proposed Act aims to ensure the sustainable supply of those CRMs essential for electric mobility-enabling sectors, electric cars themselves and renewable energy technologies. We particularly welcome the Acts efforts to balance resilience, security of supply and environmental protection with the new focus on refining and remining, which are crucial steps in producing and securing CRMs. Refining refers to the process of purifying raw materials, which can reduce the waste and environmental impact of their extraction. Remining, meanwhile, involves the extraction of raw materials from the waste or by-products generated during the production process or from legacy mining sites. Furthermore, the Act also stresses the importance of the responsible extraction and processing of CRMs. This includes promoting the use of new and innovative technologies for reducing the environmental impact of extraction and processing activities. By adopting these measures, the European Union (EU) can lead the way in sustainable mining practices, while also ensuring the ongoing availability of critical raw materials for the production of high-tech products. These measures will also help reduce the dependency of the EU on raw materials sourced from outside its borders, thereby ensuring a stable, sustainable and secure supply of these much-needed CRMs. For these reasons, the CRMs Act proposed by the European Commission is a generally welcome initiative, one which can help ensure the sustainable supply of critical raw materials. However, the following addition improvements, proposed by all members of the Platform for electromobility, from NGOs to industries, should be considered by co-legislators: 1. Ensuring funding, particularly for national mapping and prospective activities (Art. 18) 2. Removing measures on stockpiling (Art. 21) 3. Ensuring recyclability capacities in Europe (Art. 25) 4. Easing shipment of end of life batteries/black mass intra EU background 5. Facilitating transboundary waste streams (Art. 26) 6. Making national exploration plans publicly accessible (Art. 18). 7. Ensuring coherence and adherence to corporate sustainability due diligence for strategic projects (Art. 5; Art. 7) 8. Clarifying the rules on the environmental footprint of CRMs (Art. 30) 9. Ensuring coherence with other legislations 10. Ensuring that industry and civil society are given a voice in the governance board (Art. 34) You may find more information on each point in the attached document.
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Response to European Year of Skills 2023

5 Dec 2022

A 2021 study undertaken by the BCG (shorturl.at/dgkO5) looked into the opportunities and challenges created by the transition of the automotive industry towards electrification. The study shows that shift to EVs will have only a minor net impact on jobs through to 2030. The relatively small net impact should not, however, obscure the massive structural changes resulting from electrification. Changes in production will modify both the skills requirements and distribution of labour. Over the next decade, direct employment in carmakers and ICE-focused suppliers will decrease by 5%, while the workforce in adjacent industries will increase by 34%. On top of this large transfer from core automotive industries to adjacent industries, a further 40k jobs will be created each year in construction and civil works for adapting energy production and distribution infrastructures needed for electrification. By 2030, the job profile of 2.4mn positions will change, with different degrees of training needs to prepare them for future job demands, which means 42% of all employees in the core automotive and adjacent industries will have dedicated training needs. Specifically, 1.6mnwill require retraining, while remaining in their current position; another 610k will need requalification while remaining in the same industry cluster; and 225k people will need support to requalify for work in other industries outside the automotive ecosystem. Some regions those more dependent on the traditional automotive sector will feel this impact more acutely, so it is vital that governments provide policies and support to help those regions adapt to the coming change. The right political and regulatory choices will help workers fully grab the upskilling opportunity created by the transition to electromobility. To support workers during this transition: the EU, governments and companies should prioritise programmes that invest in the education, training, upskilling and reskilling of the labour force to capitalise on new opportunities, raising the bar on employment conditions, to ensure no one is left behind. The social changes triggered by the Fit for 55 should be tackled with similar levels of ambition by empowering companies, governments and regional authorities to equip the workforce with new skillsets. Workers in the automotive sector should benefit from a policy framework similar to the Just Transition Fund, Just Transition Platform and Just Transition Mechanism for the energy-intensive industries and assist industrial stakeholders, local, regional and national authorities to: For industrial stakeholders, support will be needed to design requalification and upskilling programmes and hiring as well as restructuring programmes. Rapid growth of adjacent industries (like battery manufacturing and charging stations operations and production) should be underpinned by ambitious requalification and upskilling and targets. Support should be provided, particularly for SMEs and fast-growing enterprises, as they will lack the analytics and training resources of bigger companies. Relocations should be avoided where possible by adapting existing production plants, and training for new skills where they are needed. Via their industrial, attractiveness and educations competences, local and regional authorities will play a key role in addressing the knowledge gaps in the workforce. The new ESF+ should be an instrument for supporting local and regional authorities. Governments need to perform whole-of-economy workforce planning in close cooperation with regional and local authorities and industrial stakeholders to: - Help employers and employees manage their transitions. - Tailor educational curricula towards new automotive technologies. - Build new career and employment platforms to help workers navigate to jobs and training opportunities. - Increase student seats at universities in new automotive technologies and production/process engineering.
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Response to European Critical Raw Materials Act

25 Nov 2022

The vital transition away from fossil fuels towards cleaner technologies for transport will drive, depending on the technology, the demand for raw materials like lithium, nickel. Whilst some CRMs are available in the EU, Europe is largely dependent on third countries for mining, processing, refining and recycling, even more so in the case of batteries needed for EVs and considering the current geostrategic tensions. We would therefore strongly welcome a CRM package beginning of 2023 to tackle our three concerns: 1. With the e-mobility transition, the EU is lacking an EV value chain beyond battery manufacturing - i.e. extraction, refining, processing, and recycling, which today is located in third countries - and a coherent approach of using existing EU sources of battery materials. 2. Hurdles to permitting is due to a) the plurality of mining codes in Europe bringing different levels of ambition and lack of coherence across Member States. This leads to, in some cases, not having any safeguards in relation to social or environmental protection; b) lengthy permitting processes when multiple permits are required for both renewable energy production and sustainable mineral extraction projects; c) lack of expert capacity to ensure the efficient, robust and timely evaluation of Environmental Impact Assessments and Area Assessments. 3. Limited amounts of sustainably sourced materials, notably due to limited geological mapping of available resources. Barriers also exist to the reuse and repurposing of EV parts that could extend the lifecycle of CRMs before recycling. The Raw Material Act should thus: o Include a single strategy on raw materials that defines expected needs, challenges, priorities and key lines of action with specific objectives of reducing the need of primary CRMs, with efficient reuse and recycle. o Assess the need of stockpiling mechanisms. o Provide financial, political support (e.g. tax reductions) to economic actors meeting the highest existing environmental and social standards. For EU-sourced material, the initiative would then work in relation with the package of environmental policies that control impacts from its domestic mining and refining operations and the high EU social standards. o Incentivise keeping valuable battery material in Europe, available for domestic recyclers, justifying their investments in EU today and incentivise the recycling of production scrap and blackmass/BAMM in EU. o Ensure the sustainability of CRMs by addressing adverse environmental and social impacts of their production or recycling. For imports, supply should come from responsible sources with robust certification, due diligence rules setting legal requirements for suppliers to control risk across their supply chains. o Support geological surveys to determine accessibility of domestic resources, including waste. o Mandate specific marking for any product containing CRMs to facilitate their recovery and recycling. o Streamline robust permitting processes without undermining existing environmental laws and in compliance of ESG criteria. o Support permitting authorities with additional expert capacities. o Digitalize permitting processes to ensure transparency and full engagement from project developers to local communities. o Support financially the development of recycling capacities as all recycling activities are not financially viable today due to the low cost of some primary resources. Support for the development of recycling capacities is indeed crucial to the circularity and sustainability aspect of CRM sourcing. o Ensure consistency across different pieces of legislation notably the proposed lithium salts classification - and make sense of the needs of the CRM demand sector. o Give the ERMAlliance the overall view of EU levers and make it a driving force behind the implementation.
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Meeting with Ismail Ertug (Member of the European Parliament)

1 Jun 2022 · Preparation of the event: "Electric vehicles - how to tap in the grid smartly?"

Platform for Electromobility urges faster rollout of charging infrastructure

13 May 2022
Topic — Revision of EU guidelines for the development of trans-European transport networks.
Message — The Platform requests faster deployment of charging infrastructure in comprehensive networks and better integration with energy systems. They also support battery trains for rail segments where direct electrification is not feasible while seeking increased funding.123
Why — These changes would create more business opportunities for electric vehicle and charging infrastructure providers.4
Impact — National governments and taxpayers would face significantly higher investment requirements to meet these accelerated goals.5
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Response to Review of the CO2 emission standards for heavy-duty vehicles

14 Mar 2022

The Platform for electromobility very much welcomes the opportunity to respond to the public consultation for the revision of the HDV CO2 standards. The standards are a fundamental tool to advance the zero emission transition, as outlined in the European Green Deal and advance the transport sector. More ambitious standards set the right pace and a clear trajectory for manufacturers and logistics operators. Hence, the revision of the Directive (EC) 2019/1242 is a needed and welcome step of the Commission to lower emissions from trucks and other heavy-duty vehicles. The revision should align the CO2 targets for the transport sector with the EU’s overall -55% GHG reduction target in 2030 and the climate neutrality target of 2050. Importantly the HDV CO2 standards are the single most effective tool to achieve scaling effects in production and technology development, which contributes to making electric HDVs more competitive and widespread. In particular, the Platform calls the European Commission to prioritise the following: • Almost all newly registered heavy duty vehicles (including long haul) should be zero emission at the latest by 2035, whilst an exemption can be considered for some niche vocational vehicles (such as construction trucks) with a 100% ZEV target by 2040. • The introduction of an intermediary target in 2027 is necessary to accelerate the transition to electric trucks already in the 2020s • Strengthening the ambition in 2030 is crucial to spur the momentum and further scale up production and sales of ZETs. • Crucially, no mechanism for renewable and low-carbon fuels should be included under this regulation The Platform wants to stress that with regards to urban buses the revision of the CO2 standards should also take into account the demand-side targets from the Clean Vehicle Directive (Directive 2019/1161), especially when taking into account the purchasing of heavy-duty ZEVs for public authorities. The standards are an important tool to drive down the prices of buses of publicly procured vehicles, making them affordable for public institutions. Lastly, the Platform highlights that the transition to electric trucks and buses is a considerable opportunity for the European electromobility value chain and the competitiveness of the economy. Ambitious targets would make Europe a leader in zero emission HDVs and thus further unlock the potential of the electromobility value chain. Electrifying heavy trucks is particularly crucial in the wider context of reducing Europe’s GHG emissions as it makes up the largest part of the HDV emissions and allows to drastically improve noise and air pollution. Investments need to be made for higher grid capacity to serve truck charging demand.
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Response to Revision of Combined Transport Directive

16 Sept 2021

The Platform for Electromobility welcomes the opportunity to give its feedback on the Inception Impact Assessment for the revision of the ‘’Combined Transport Directive’’. Directive 92/106/EEC is the only EU legal instrument directly targeting combined transport (CT), incentivising a more sustainable operational model for freight transport. Nearly thirty years later, the effectiveness of the Directive needs to be improved as the freight market and transport have gone through considerable changes. Furthermore, the political context has shifted as well, with an increased ambition on emissions-reduction objectives deriving from the European Green Deal and the Sustainable and Smart Mobility Strategy. The Platform for Electromobility agrees with the European Commission that, without an intervention to promote the use of multimodal transport, the uptake of more sustainable transport options will not take place to the desired degree and in the desired time-frame to reach 2030 and 2050 EU objectives. Strengthening combined transport fits perfectly into the vision of an integrated and sustainable comprehensive mobility system. The role of intermodal terminals, in this context, stands out through the optimisation of the connectivity of the different modes, and incorporating rail, roads and waterway systems into the freight logistics chain. Among the options envisaged by the Inception Impact Assessment, Option 3 appears as setting the most effective way to crucially improve the framework for combined transport in Europe. The extension of the support from today’s narrowly defined combined transport operations to all intermodal or multimodal operations, and the categorisation of terminals based on infrastructure and operational efficiency – both proposed also under Option 2 – would broaden the Directive’s scope and streamline investments for combined transport’s infrastructures. Moreover, Option 3 foresees an assessment of the efficiency of the measures to support the attainment of the objectives of the revised Combined Transport Directive. This measure would improve the reporting and monitoring conditions of the Directive. Following this further, the Platform remains cautious about the viability of Option 4, which envisages mandatory harmonised support measures – such as a support to transhipment costs. Such proposal may open the door to state aid-related questions and be challenged across Member States. The Platform for Electromobility looks forward to work with the European Commission to ensure that freight transport do not miss the decarbonization revolution and contributes efficiently to a sustainable, integrated and multimodal mobility system for Europe and set best practices for the world.
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Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean) and Transport and Environment (European Federation for Transport and Environment) and

13 Apr 2021 · Meeting to discuss the state of play of the Eurovignette

Response to Modernising the EU’s batteries legislation

1 Mar 2021

The Platform welcomes the proposal for a Battery Regulation and strongly supports the need for modernisation of the existing batteries legislation. It must ensure harmonisation in the internal market and facilitate an accelerated shift to electrified mobility by engaging all parts of the battery supply chain. The regulation must establish proportional and well-designed provisions to enable sustainable battery production, use, and end-of-life management. Generally, the timeline for the provisions should be well thought through to ensure robust and harmonised application and enforcement. We need to strike a balance between the need for a quick implementation of the Regulation while ensuring a robust methodologies. Overall, the proposed measures shall promote clean, competitive and efficient battery manufacturing. To avoid duplication or overlaps with existing legislation and requirements and limit excessive administrative burden on the nascent battery industry, the Platform sees a need to streamline and align provisions. While the Platform believes that the proposed requirement for carbon footprint declarations goes in a positive direction, we are concerned about the measure's enforceability at the Member State level. Provisions should apply per battery model and manufacturing plant instead of "for each battery model and batch per manufacturing plant." Rules on enforcement, methodology, and electricity accountability should also be clarified, to ensure: 1.Harmonised enforcement at Member State level and for imported batteries; 2.The use of representative data and supply-chain configurations to ensure comparability of declarations. E.g certification of energy use should reflect real world use of renewable energy and must not rely on purchase of green certificates (Guarantees of Origin). 3.The confidentiality of the declared primary data is respected. As an additional means to accelerate the transition to climate-neutrality, we support positive measures such as preferential taxation for frontrunners. The Platform strongly supports the introduction of rules for the responsible sourcing of raw materials for batteries.Similar due diligence requirements must also be applied as soon as possible to the fossil fuel sector as part of the upcoming horizontal due diligence legislation. The Platform highlights that economic operators must have sufficient time to adapt to new data sharing requirements.The chosen method, be it battery passport or QR Code, should be streamlined with a focus on a single, innovative, and digital approach.The Commission must identify which data sets are essential to boost the data-sharing economy while ensuring confidentiality. The Platform welcomes the Regulation’s intention to provide a regulatory framework for the transfer of liability and safety requirements for second-life EV batteries. The current provisions, however, require clarifications as regards access to BMS, conditions for the safe treatment of batteries, property rights protection, as well as ownership of data created by EVs.Moreover, the waste status of batteries is vital: the collection of waste batteries potentially suitable for repurposing should be designed in such a way that a second life business model can develop without creating a free pass for illegal waste transport. In particular, a clear-cut transfer of extended producer responsibility is pivotal to avoiding the risk of illegal export. On end-of-life management, we welcome the recognition of batteries within a circular economy. Also, the Batteries Regulation now better differentiates between battery chemistries.However, the future regulatory framework should be aligned and consistent with EC 1907/2006 (REACH). To work towards a level playing field, we propose including a deadline for the adoption of equivalent conditions criteria for export of waste batteries to third countries.Minimum recycling conditions outside Europe must be set, including environmental and social criteria.
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