REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the application of Directive 2014/94/EU on the deployment of alternative fuels infrastructure
Date: 2021-03-08
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: EU Member State, clean technology, electric vehicle, environmental impact, motor vehicle pollution, national implementing measure, non-polluting vehicle, reduction of gas emissions, substitute fuel, transport infrastructure

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 8.3.2021  COM(2021) 103 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the application of Directive 2014/94/EU on the deployment of alternative fuels infrastructure  {SWD(2021) 49 final}  
 
 
1 Introduction  

The  European  Union  is  committed  to  achieving  the  highest  levels  of  climate  and 
environmental  protection.    As  a  result,  ramping  up  the  production,  deployment  and  use  of 
sustainable  alternative  fuels  is  a  key  priority  of  European  transport,  energy  and  climate 
policies.  Building-up  a  dense,  widespread,  reliable  and  easy-to-use  alternative  fuels 
infrastructure network across all modes is a key element to reach the climate neutrality target 
by  2050  and  to  contribute  to  the  zero-pollution  ambition  as  set  out  in  the  European  Green 
Deal.1  This  network  will  be  an  important  enabler  for  the  market  uptake  of  zero-  and  low-
emissions vehicles, vessels and aircraft.2 For road transport, the European Green Deal sets the 
objective of having at least 1 million publicly accessible recharging and refuelling stations in 
place by  2025 that  establishes a springboard for  the necessary much larger roll-out  of such 
infrastructure until 2030, as projected in the Sustainable and Smart Mobility Strategy.  3 The 
strategy sets important and ambitious milestones for the ramp up of production, deployment 
and use of sustainable alternative fuels in all modes of transport by 2030 and 2050, including, 
where necessary, for the roll-out of needed infrastructure.  

This  report  presents  the  results  of  the  assessment  of  action  taken  by  Member  States  in  the 
implementation  of  Directive  (EU)  2014/94  on  the  deployment  of  alternative  fuels 
infrastructure  (AFID)  and  the  development  of  markets  for  alternative  fuels  and  alternative 
fuels infrastructure in the Union. It follows the provisions of Article 10(3) of that Directive, 
which requires the Commission to submit a report on the application of the Directive every 
three years with effect from 18 November 2020. 

The  reporting  draws  on  an  extensive  information  base.  The  Commission  has  made  an  in-
depth assessment of the national implementation reports as received from the Member States 
under  this  Directive4  ,  building  on  interactions  with  Member  States  in  the  design  of  that 
assessment. The Commission has also carried out an external support study in the context of 
the ongoing evaluation of that Directive.5 Moreover, the Commission has updated its report 
on  the  state  of  art  on  alternative  fuels  transport  systems  in  the  EU6.  These  assessments  are 
published alongside this report. 

These  assessments  show  that  full  implementation  of  planned  targets  and  measures  by 
Member  States  would  lead  to  an  infrastructure  roll-out  by  2030  that  –  looking  at  the 
aggregated numbers - could potentially support a fleet of alternative fuels vehicles that is in 
line  with  projections  under  a  pathway  meeting  a  40%7  overall  greenhouse  gas  emission 
reduction in the EU. However, the current deployment is not leading to a comprehensive and 
complete  network  coverage  of  easy-to-use  infrastructure  throughout  the  Union  as  large 
differences between Member States’ plans continue to persist, and modes other than road are 
either  excluded  or  underrepresented.  Moreover,  the  2030  Climate  Target  Plan8  raises  the 

1

2

 COM(2019) 640 final 
  In  the  remainder  of  this  communication,  where  no  otherwise  specified,  the  tern  vehicles  refers,  as  relevant  in  the  give  context,  to  all  types  of  vehicles, 
including, inter alia, cars, lorries, buses, coaches, trains, aircrafts, ships, ferries, etc.   
3
 COM(2020) 789 final 

4

5

6

7

8

 SWD NIRs  
 Evaluation support study 
 https://op.europa.eu/en/publication-detail/-/publication/fd62065c-7a0b-11ea-b75f-01aa75ed71a1 
 Defined under the 2030 Climate and Energy Framework 
 COM(2020) 562 

1 

 
 
                                                           
ambition  by  increasing  the  2030  EU  greenhouse  gas  emissions  reductions  target  to  55%, 
hence  requiring  a  considerably  higher  increase  in  the  number  of  zero-  and  low-emissions 
vehicles and the appropriate roll-out of infrastructure.  

This report points to the benefits of stepping up action in the further implementation of the 
national  policy  frameworks  of  Member  States  and  the  further  development  of  the  policy 
framework  at  European  level.  This  finding  corresponds  to  earlier  conclusions  raised  by  the 
Commission  in  the  Communication  “Action  Plan:  towards  the  broadest  use  of  alternative 
fuels  infrastructure  in  the  EU”9  and  conclusions  raised  by  the  European  Parliament  in  its 
report  on  deployment  of  alternative  fuels  infrastructure10.  The  publication  of  the  in-depth 
assessments  of  the  individual  national  implementation  reports  provides  a  basis  for  further 
discussion on how Member States can support the quick build-up of a sufficient alternative 
fuels infrastructure. In this context, the synergies between the national recovery and resilience 
plans under the Next Generation EU recovery instrument and the opportunities linked to an 
investment agenda for sustainable mobility are apparent. 

2. State of play: Technological progress and the development of the markets  

Since the adoption of the Directive in 2014, the markets for the various alternative fuels have 
developed differently with respect to vehicle uptake and infrastructure deployment within and 
between modes.  

Table 1: Number of alternatively fuelled passenger cars registered 2014 - 2020 in the EU  

2014 

2015 

2016 

2017 

2018 

2019 

2020 

Increase 
2014 - 
2020 

Battery Electric 

Plug in Hybrid 

Hydrogen 

Compressed 
Natural Gas 
Liquefied 
Petroleum Gas 
Total Alternative 
Fuels Cars 
Alternative Fuels 
Cars in % 

75,067 

119,222 

164,681 

244,231 

376,534 

616,644 

904,262 

1105% 

56,758 

126,032 

191,561 

254,249 

349,181 

474,724 

755,282 

1231% 

53 

192 

362 

531 

714 

1,187 

1,492 

2715% 

999,044 

1,058,992 

1,089,701 

1,113,714 

1.161,118 

1.193,806 

1,207,069 

6,906,769 

7,089,523 

7,232,050 

7,264,118 

7.628,053 

7.714,409 

7,707,823 

8,037,691 

8,393,961 

8,678,355 

8,876,843 

9,515,600 

10,000,770 

10,575,928 

21% 

12% 

32% 

2.99% 

3.12% 

3.23% 

3.30% 

3.59% 

3.72% 

3.93% 

Source: European Alternative Fuels Observatory, January 2021 (www.eafo.eu) 

Compared to the market situation at the time of the adoption of the Directive, the market of 
electric vehicles has strongly matured, particularly for light-duty electric vehicles and buses 
(both battery-electric and plug-in hybrid). Especially electric cars have seen a rapid increase 
in  terms  of  total  vehicle  registrations  and  growth  in  available  models  in  the  period  2010-
2020. In the 3rd quarter of 2020, shares increased to 9.9% of all car sales, compared to 3% in 
the  year  before11.  While  the  car  stock  shares  are  still  low,  further  acceleration  of  vehicle 
uptake is expected, driven also by the need to comply with legal requirements under the CO2 

9

 COM/2017/0652 final, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM:2017:0652:FIN 
10
 (2018/2023(INI)) https://www.europarl.europa.eu/doceo/document/A-8-2018-0297_EN.html 
 www.acea.be 

11

2 

 
 
 
 
 
  
 
 
                                                           
emission performance standards for light-duty vehicles12, the Clean Vehicles Directive13 and 
the pressure to comply with air quality legislation. Model availability for cars and vans, but 
also for buses, has strongly improved over the last years. Following technical developments 
and  increases  in  battery  capacity,  ranges  of  electric  vehicles  are  significantly  above  the 
average daily driven distance in the EU and enable long distance travel, which is contributing 
to increased user acceptance. For trucks, maturity of markets has developed at much slower 
pace since 2014. The stock of vehicles (including retrofitted ones) is still at a very low level. 
Trucks are now starting to enter the market for distribution trucking, and manufacturers have 
announced  new  models  (including  with  longer  ranges)  to  come  into  the  market  over  the 
coming years. A further market uptake in this segment is expected until 2025, also in view of 
the need to comply with the legal requirements of the CO2 emission performance standards 
for heavy-duty vehicles14. Electric buses, and here especially public transport buses in urban 
areas,  have  seen  a  significant  uptake  and  the  number  of  registered  buses  has  more  than 
doubled in 2019. Moreover, many cities have set very ambitious targets for electrifying their 
bus fleets, pointing at a likely acceleration of this trend.     

Compared to the market situation at the time of the adoption of the Directive, the market of 
hydrogen fuel cell vehicles has developed with a significant growth rate albeit from a very 
low  starting  point.  While  fuel  cell  cars,  vans  and  buses  are  technologically  mature,  their 
registration  rates  remain  very  low.  Model  availability  of  light-duty  fuel  cell  vehicles  has 
made incremental progress only: for example, in 2020, four fuel cell car models were on offer 
in  the  EU,  but  not  in  all  Member  States.  European  OEMs  have  not  announced  significant 
investment  into  hydrogen  fuel  cell  cars  and  vans.  The  situation  is  slightly  better  for  buses: 
different European manufacturers have started production and a number of cities and regions 
have started to  deploy hydrogen fuel  cell bus fleets.  While the market  did  not  record much 
momentum  for  trucks,  the  situation  is  currently  changing.  With  the  new  CO2  emissions 
standards in place, different OEMs are now starting to invest strongly into hydrogen fuel cell 
truck solutions, in view of their series production for long-distance road haul post 2025. With 
the  European  Clean  Hydrogen  Alliance15,  the  EU  is  setting  up  a  strong  impulse  for  better 
coordinating  action  of  market  actors  through  a  full  value-chain  approach  that  should  also 
elevate  the  development  of  the  fuel  cell  trucks  market,  and  furthermore  the  market  for 
coaches.  

Compared  to  the  market  situation  at  the  time  of  the  adoption  of  the  Directive,  the  overall 
market development of natural gas vehicles differs per segment. The technology for natural 
gas  vehicles  and  components  is  fully  mature  for  both  compressed  natural  gas  (CNG)  and 
liquefied natural gas (LNG) of both fossil and biological origin. The fleet of passenger cars in 
2020  was  approx.  1.2  million  cars.  Vehicle  models  are  for  sale  in  the  EU  market  in  all 
segments. However, the number of brands providing CNG vehicles has contracted in recent 
years.16  Natural  gas  trucks  have  shown  a  more  steady  growth,  in  particular  in  the  LNG 
segment.  

12

13

 2019/631/EU https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019R0631 
 2019/1161/EU https://eur-lex.europa.eu/eli/dir/2019/1161/oj 
14 2019/1242/EU https://eur-lex.europa.eu/eli/reg/2019/1242/oj 
15

 https://ec.europa.eu/growth/industry/policy/european-clean-hydrogen-alliance_en 

16 The decreasing demand for new natural gas vehicles is confirmed in the volume of natural gas used in road transport: this has more than doubled between 
2008 and 2015, but has remained broadly stable since then. 

3 

 
 
                                                           
Already  before  the  adoption  of  the  Directive,  a  fleet  of  around  7  million  LPG  vehicles 
existed in  the market.  Since the adoption of the  Directive, vehicle uptake increased slowly. 
Three quarters of those vehicles were registered in just two Member States; hence, a strong 
geographic  concentration of those vehicles persists in  the EU. Fleets  of  LPG buses  exist in 
several  cities.  However,  the  number  of  new  acquisitions  or  replacements  of  LPG  buses  are 
decreasing. 

In  addition,  renewable  liquid  fuels  and  synthetic  fuels  –  including  e-fuels  –  can  be 
produced  to  meet  the  current  fuel  standards  for  diesel  and  petrol;  they  can  therefore  be 
distributed  through  existing  infrastructure  and  used  in  standard  vehicles.  Dedicated 
infrastructure for biofuels (e85) to be used in dual fuel vehicles exists only in a few Member 
States and registration of such vehicles remains stable at a very low level. A main question 
regards  the  potential  for  future  production  capacity  of  sustainable  alternative  biofuels.  In 
view of feedstock availability, overall efficiency of the production process and overall costs – 
for  both  biofuels  and  synthetic  fuels  –  use  of  biofuels  needs  to  particularly  serve  transport 
modes that are more difficult to decarbonise (aviation, waterborne).   

Concerning waterborne transport, data availability on the uptake of biofuels, alternatively 
fuelled  vessels  and  Onshore  Power  Supply  (OPS)  for  ships  at  berth  is  limited.  The  total 
number of commissioned  LNG ships worldwide was about 300 in 2019. Only half of those 
ships  were  in  operation.  The  other  half  remains  on  order.  The  amount  of  electric  vessels 
(including hybrids) in operation worldwide is similarly low, but has been growing recently: in 
2019, 160 ships were in service and a further 104 were under construction17. At the end of 
2019, around 50 inland and maritime ports in the EU had at least one OPS connection point18. 

Concerning the use of alternative fuels in rail, around 60 percent of the network serving 80 
percent  of all traffic volume is  electrified19. First  market  orders of hydrogen fuel  cell trains 
have started recently. Concerning the use of alternative fuels in aviation, biofuels and e-fuels 
can  already  today  be  blended  with  kerosene.  However,  the  use  of  liquid  biofuels  is  still 
marginal with 0.05% of air transport energy use. Aircraft manufacturers have also started to 
invest in the development of electric, hybrid and hydrogen aircraft.   

3 Implementation of the Directive  

Transposition 

Member States had to transpose the Directive by 18 November 2016. There have been delays 
in the transposition in many Member States. The Commission opened 24 infringement cases 
for non-transposition in 2017 and 2018. The Commission closed most cases in the course of 
2018 and closed the remaining cases in 2019 and 2020. At the end of 2020, there are no open 
infringement cases against Member States for non-transposition of the Directive.  

Status of National Policy Frameworks  

17 https://safety4sea.com/352-confirmed-ships-are-using-battery-installations/ 
18 https://eafo.eu/shipping-transport/port-infrastructure/ops/data 
19 Electrification of the Transport System: https://ec.europa.eu/programmes/horizon2020/en/news/electrification-transport-system-expert-group-report 

4 

 
 
 
 
                                                           
The  Directive  requires  each  Member  State  to  adopt  a  national  policy  framework  (NPF)  for 
the development of the alternative fuels market in the transport sector and the deployment of 
its  relevant  infrastructure.  In  particular,  the  NPFs  had  to  comprise  national  targets  and 
objectives for the deployment of alternatives fuels infrastructure, taking into account national, 
regional  and  union-wide  demand.  In  addition,  Member  States  had  to  provide  the  necessary 
measures to reach national targets and the objectives set out in the NPFs. Member States had 
to notify their NPFs to the Commission by 18 November 2016.  

In its 2017 assessment of the NPFs and in its 2019 update20, the Commission concluded that 
the NPFs are not fully coherent from an EU-wide perspective in terms of the priorities they 
set.  Member  States’  ambition  with  regard  to  the  uptake  of  alternative  fuels  and  their 
infrastructure varied significantly. It also concluded that not all NPFs set clear and sufficient 
targets and objectives, supported by comprehensive measures. 

Action Plan on Alternative Fuels Infrastructure  

To  support  the  implementation  of  NPFs  and  in  accordance  with  Article  10(6)  of  the 
Directive, the Commission adopted an EU Action Plan for Alternative Fuels Infrastructure on 
8  November  201721.  It  supports  the  establishment  of  an  alternative  fuels  infrastructure 
backbone with full coverage of the TEN-T network by 2025, and ramp up of investment into 
infrastructure.  The  plan  announced  an  additional  support  of  EUR  800  million  from  the 
Connecting  Europe  Facility  (CEF)22  and  NER  300  programme23  to  spur  investment.  The 
Action  Plan  also  noted  the  need  to  increase  the  level  of  policy  ambition  in  Member  States 
plans, particularly regarding infrastructure roll-out in urban and cross-border areas and action 
on improving use services.    

Submission of National Implementation Reports 

The Directive requires that Member States submit to the Commission by 18 November 2019 
a  national  implementation  report  (NIR)  on  the  execution  of  its  national  policy  framework 
(NPF)  in  the  period  from  submission  of  the  NPF  until  at  least  31  December  2018.  These 
reports  shall  cover  the  information  listed  in  Annex  I  of  the  Directive,  including,  where 
appropriate,  relevant  argumentation  on  the  level  of  attainment  of  the  national  targets  and 
objectives referred to in Article 3(1). By 1 May 2020, the Commission had received 25 NIRs. 
By 1 October 2020, the Commission had received the reports from all but one Member State. 
The  findings  of  the  Commission  assessment  are  presented  in  this  report  and  the  Staff 
Working Document that accompanies this report.  

Aspects of the Directive that required direct action by the Commission 

Fuel labelling 

20 SWD(2019) 29 final:  https://ec.europa.eu/transport/sites/transport/files/legislation/swd20190029.pdf 
21 COM/2017/0652 final, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM:2017:0652:FIN 
22

 https://ec.europa.eu/inea/en/connecting-europe-facility/cef-transport 

23

 https://ec.europa.eu/clima/policies/innovation-fund/ner300_en 

5 

 
 
 
 
 
                                                           
The  Directive  requires  that  Member  States  shall  ensure  that  relevant,  consistent  and  clear 
information  is  provided  to  consumers  on  the  compatibility  of  their  vehicles  with  the  fuels 
placed  on  the  market.  The  supply  of  information  shall  be  based  on  the labelling  provisions 
regarding  fuel  compliance  under  standards  of  the  European  Standardisation  Organisations 
setting  the  technical  specifications  of  fuels.  In  that  respect  the  European  Commission 
requested the European Committee for Standardisation (CEN) and the European Committee 
for  Electrotechnical  Standardisation  (Cenelec)  to  adopt  the  corresponding  standards  to  this 
end. Subsequently, CEN and Cenelec adopted the standard EN 16942 ‘Fuels - Identification 
of  vehicle  compatibility  -  Graphical  expression  for  consumer  information’  wich  came  into 
force  on  12  October  2018  and  the  standard  EN  17186  ‘Identification  of  vehicles  and 
infrastructures compatibility - Graphical expression for consumer information on EV power 
supply’  that  will  come  into  force  on  20  March  2021.  Consistent  data  on  the  application  of 
those standards in the markets of Member States is limited. The Commission is verifying the 
situation  with  Member  States.  Information  up  to  date  suggests  that  fuel  labels  are  quite 
commonly applied at fuel stations in Member States.     

Fuel price comparison 

The Directive establishes that, when fuel prices are displayed at a fuel station, a comparison 
between the relevant  unit prices should be displayed for information  purposes, in  particular 
for natural gas and hydrogen. The Commission Implementing Regulation (EU) 2018/732 of 
17 May 2018 enacts a common methodology for alternative fuels unit price comparison. In 
response to the COVID-19 crisis, Member States agreed to the Commission proposal to delay 
the date of application of the Regulation  until 7 December 2020.24 Under the methodology 
adopted, fuel prices are expressed as amounts of applicable currency per 100 km. The display 
of  the  comparison  of  the  fuel  prices  at  the  fuel  stations  should  be  based  on  transparent 
samples  of  passenger  cars  that  are  comparable,  at  least  in  view  of  their  weight  and  their 
power.  A  Programme  Support  Action  (PSA)  under  the  CEF  issued  recommendations  for  a 
harmonised implementation of the provision by Member States, including when making use 
of digital tools.   

Data accessibility  

The  Directive  sets  out  that  data  indicating  the  geographic  location  of  the  refuelling  and 
recharging  points  accessible  to  the  public  are  available  on  an  open  and  non-discriminatory 
basis  to  all  users.  To  assist  Member  States,  a  PSA  under  the  CEF  was  established  with  15 
participating  Member  States.  It  focuses  on  a  format  for  e-mobility  identification  codes  for 
charging point operators (CPOs) and e-mobility service providers (EMSPs), laying down the 
foundations for a structure cross-referencing exchange of information among Member States. 
It provides suggestions on how Member States can develop and implement their national IT 
infrastructure from which the data will be gathered and made available through the National 
Access Points (NAPs) under Directive (EU) 2010/40 on Intelligent Transport Systems. 

Standardisation of alternative fuels infrastructure 

The  Directive  was  supplemented  and  amended  by  Commission  Delegated  Regulation  (EU) 
2019/1745. The Regulation sets out the technical specifications applying to recharging points 

24 Commission Implementing Regulation (EU) 2020/858 of 18 June 2020 

6 

 
 
                                                           
for  L-category  motor  vehicles,  shore-side  electricity  supply  for  inland  waterway  vessels, 
hydrogen supply for road transport and natural gas supply for road and waterborne transport. 
It amends Annex II of the Directive by specifying standards that were recommended by CEN 
and Cenelec in response to a standardisation request by the Commission. 

Action  to  respond  to  Annex  II  requirements  regarding  technical  specifications  for  wireless 
recharging  points  for  motor  vehicles,  battery  swapping  for  motor  vehicles  and  recharging 
points  for  electric  buses  is  still  outstanding.  However,  technical  specifications  for  wireless 
recharging  points  and  recharging  points  for  electric  buses  will  be  subject  to  planned 
Delegated Regulations in 2021. 

4 Analysis of Actions taken by Member States 

The  Directive  requires  Member  States  to  set  targets  for  alternative  fuels  infrastructure  and 
develop  corresponding  measures  for  reaching  those  targets  under  their  national  policy 
frameworks.  While  the  Directive  clearly  specifies  the  overall  needs  for  road  infrastructure 
and ports, it does not provide a common methodology to inform target setting and measure 
development. 

The  assessment  shows  that  there  has  been  progress  in  the  quantity  and  quality  of  data 
provided  in  most  NIRs  compared  to  the  NPFs.  However,  many  reports  do  not  fully  and 
satisfactorily  address  the  reporting  requirements  of  the  Directive.  There  is  still  significant 
divergence  among  Member  States  concerning  target  setting  and  measure  description.  This 
divergence  aggravates  a  coherent  assessment  of  Member  States’  ambition  towards  the 
development of a network of alternative fuels infrastructure in the EU.25   

Member State estimates on vehicle uptake and targets for infrastructure deployment  

An aggregation of Member State vehicle estimates and infrastructure targets under the NIRs 
at  the  EU  level  shows  that  these  are  slightly  more  ambitious  compared  to  those  under  the 
NPFs in 2016. Significant differences between Member States continue to exist.  

Member States estimate a rapid uptake of electric vehicles, albeit with very strong regional 
differences. Member State projections suggest that there could be around 2.5 million electric 
vehicles in 2020, more than 7 million in 2025 and more than 30 million in 203026. While at 
the  end  of  2020  around  1.8  million  electric  vehicles  were  registered,  many  Member  States 
have revised the ambition on targets and corresponding measures. They are likely to support 
an  accelerated  vehicle  uptake  and  infrastructure  deployment  in  those  Member  States  post 
2020. For 2030, the estimates would represent an overall share of electric cars of around 15% 
of the total current car stock. However, at single Member State level, planning and ambition 
for 2030 ranges from less than 1% to more than 40% of electric cars in the total car stock.  

25

 Most Member States have provided estimates for the uptake of electric vehicles and provided targets for the deployment of electric rechargers for the year 
2020.  However,  only  around  two  thirds  provided  data  on  targets  for  2025  or  2030.  Target  setting  for  other  alternative  fuels  infrastructure  is  more  limited. 
Around  half  of the Member States provide targets  for CNG and  for  LNG. Only around one third of Member  States  have set targets  for  LNG bunkering and 
Onshore Power Supply (OPS) for both maritime and inland waterways. Finally, around half of the Member States opted for setting targets for road hydrogen 
infrastructure. 
26

 These figures are based on data from 25 Member States. 

7 

 
 
 
 
                                                           
At the end of 2020 around 213,000 publicly accessible rechargers were deployed in the EU27, 
of which approx. 10% were fast chargers (>22 kW and up to 350 kW). This is higher than the 
aggregated target of Member States of more than 180,000 recharging points by 2020. Most 
Member States with reported targets plan a recharging point to vehicle ratio of around 1 to 12 
for  2030.  Using  this  ratio  also  for  Member  States  that  have  not  reported  a  target  would 
suggest that Member States currently target a total number of recharging points of 2.7 million 
in 2030. However, the distribution of those recharging points is expected to be very uneven 
across Europe with gaps in the network expected especially in Southern and Eastern Europe 
where large parts of the TEN-T core network do not have recharging points installed every 60 
km28. 

With respect to electric vehicles and their infrastructure, 2019 and 2020 saw a much stronger 
increase in electric vehicle registrations than in publicly accessible recharging infrastructure 
deployment.  This  trend  continued  in  2020.  In  fact,  in  2019  electric  vehicle  registrations 
increased by 50% and in 2020 by 52% in comparison to the previous year, while the increase 
in recharging infrastructure was only 38% and 30% respectively29. While the deployment of 
faster  recharging  technology  can  help  to  address  part  of  the  increased  vehicle  uptake, 
continuation of this trend would still imply a serious risk that infrastructure deployment will 
not  go  hand  in  hand  with  electric  vehicle  uptake  in  the  years  to  come.  This  could  lead  to 
important shortcomings that can undermine the overall uptake of those vehicles.      

The  16  Member  States  that  provide  estimates  on  CNG  vehicles  suggest  a  doubling  of 
vehicles by 2025 and a further increase by 2030 in those Member States. However, even with 
that increase and taking into account the existing vehicle stock of Member States that did not 
report growth estimates, CNG vehicles are expected to represent only a share of around 1% 
of  the  total  vehicle  stock  in  the  EU  by  2030.  The  existing  infrastructure  of  approx.  3,600 
refuelling  points  in  2020  seems  largely  sufficient  to  cover  the  future  demand.  The  same  is 
true for current LPG infrastructure as Member States do not estimate a relevant increase of 
the current fleet by 2030.     

Estimates by the 11 Member States that reported on LNG suggest that the LNG heavy-duty 
vehicle  fleet  could  increase  significantly  by  2030.  However,  even  with  that  increase,  those 
vehicles will still represent only approximately 1% of EU’s truck fleet.  In 2020, there were 
around 310 LNG refuelling points in the EU that served the main TEN-T transport corridors. 
While some gaps  persist, the  existing refuelling  points already  largely  provides a sufficient 
network connectivity.   

Hydrogen  fuel  cell  mobility  is  still  a  niche  market.  Some  Member  States  report  great 
ambition with respect to uptake of hydrogen fuel cell vehicles. Those ambitions could lead 
to around 300,000 vehicles in the EU by 2030. However, around half of the Member States 
have not provided any estimates and many Member States do not seem to have a hydrogen 
strategy in place yet. In 2020, 125 hydrogen stations were in operation while Member States’ 
targets point to around 600 stations by 2030. Since around half of the Member States do not 

27

28

29

 www.eafo.eu 
  SWD(2017) 365 final 
 Eafo.eu, January 2021 

8 

 
 
                                                           
plan  any  infrastructure,  current  implementation  of  the  Directive  would  result  in  limited 
connectivity for hydrogen vehicles in the EU.      

Data provided by Member States on  maritime and inland waterway vessels estimates and 
infrastructure deployment was very scarce. It does not allow drawing a coherent assessment 
of the current and planned development of LNG bunkering and Onshore Power Supply across 
the EU. Directive 2014/94/EU does not contain specific provisions covering rail and aviation.  

Policy and legal measures on national level 

Member  States  have  reported  a  variety  of  measures  to  support  the  uptake  of  alternatively 
fuelled vehicles and achieve their infrastructure targets. All Member States have implemented 
one or more legal and policy measures to promote electric vehicles. Around three quarters of 
Member  States  also  established  measures  to  promote  electric  vehicles  and  related 
infrastructure in public transport. More than half of the Member States also reported legal and 
policy measures to support the uptake of vehicles and infrastructure deployment in the areas 
of  natural  gas  and  hydrogen.  However,  only  a  few  Member  States  reported  on  specific 
measures in relation to waterborne transport.     

According  to  the  limited  information  from  22  NIRs,  Member  States  allocated  a  total  of 
around €6.7 billion during the period 2016-2019. Budget allocations among Member States 
varied  greatly  from  only  €3  million  to  close  to  €2.7  billion.  Member  States  directed  the 
largest share to the implementation of various policy support measures (for example support 
of  vehicle  purchase  and  infrastructure  deployment),  followed  by  support  for  research, 
technological development and demonstration, and manufacturing support. The largest share 
of Member States’ budgetary support went to electric vehicles and recharging infrastructure, 
followed by hydrogen for road transport and support for natural gas for road transport. The 
amount allocated to waterborne transport was much more limited and below 5% of the total 
financing.  

On average, the measures reported by Member States seem to be suited to accelerate vehicle 
uptake  and  infrastructure  deployment  in  line  with  the  overall  vehicle  and  infrastructure 
estimates and targets set by Member States. This is particularly true for electric vehicles and 
their infrastructure.  

5 Assessment of the effects of the Directive 

Article  10  (3)  of  the  Directive  requires  reporting  on  its  effect  on  the  uptake  of  alternative 
fuels  vehicles  and  the  deployment  of  the  related  infrastructure.  This  chapter  summarises 
findings  of  the  work  carried  out  under  the  ongoing  evaluation  of  the  Directive.  Findings 
reported  here  do  not  pre-empt  any  conclusion  of  the  evaluation  of  the  Directive,  which  is 
planned  for  publication  by  summer  2021  and  will  present  in  more  detail  the  results  of  the 
evaluation  in  terms  deployment  and  infrastructure  quality,  including  with  regards  to  user 
information.  

Uptake of alternatively fuelled vehicles and deployment of infrastructure  

9 

 
 
 
The  analysis  has  shown  that  the  directive  had  a  considerable  impact  in  combination  with 
other legislative initiatives such as the Regulations on CO2 emission performance standards 
for light-duty and heavy-duty vehicles and the Energy Performance of Buildings Directive  30 
on  both,  the  uptake  of  alternatively  fuelled  vehicles  and  their  infrastructure.  The  share  of 
alternatively  fuelled  vehicles  in  total  vehicle  sales  in  2020  is  slighter  higher  with  the 
Directive in place than in a hypothetical situation without the Directive. This positive impact 
of  the  Directive  increases  significantly  towards  2030  when  the  sales  of  zero-  and  low-
emission vehicles will further increase.   

The  Directive  also  directly  impacted  the  number  of  electric  recharging  points  which  is 
projected to be around twice as high in 2030 compared to a situation without the Directive. A 
similar impact is expected for hydrogen and LNG refuelling points. For CNG infrastructure, a 
lower  impact  of  the  Directive  is  expected,  as  a  network  of  infrastructure  was  already 
available before the Directive was adopted.   

The impact of the Directive on the uptake of alternative fuels and onshore power supply for 
shipping and inland waterways is difficult to assess. From available data it can be concluded 
that  investments  in  alternative  fuels  infrastructure  for  LNG  bunkering  and  onshore  power 
supply (OPS) in ports have been limited in most Member States. However, especially in those 
areas  the  Directive  is  likely  to  have  an  important  impact  closer  to  the  target  dates  for  their 
deployment in 2025 or 2030.    

Effects of the Directive in terms of infrastructure quality31  

The  Directive  also  had  a  considerable  impact  on  the  interoperability  of  alternative  fuels 
infrastructure. However, a number of shortcomings still prevail, that make it cumbersome for 
users to travel in a seamless manner across borders, specifically with electric vehicles.    

In  order  to  ensure  interoperability,  the  Directive  and  subsequent  Commission  Delegated 
Regulation (EU) 2019/1745 set technical specifications for the physical connection between 
the recharging/refuelling point and the vehicle. The ability to adopt delegated acts under the 
Directive  has  helped  to  transpose  technical  specifications  into  European  law  in  a  targeted 
manner, building on the expertise of European Standardisation Organisations. However, the 
Directive  is  not  well  suited  to  address  the  need  for  further  technical  standards  regarding 
communication  interfaces,  for  recharging  heavy-duty  vehicles  and  vessels,  as  well  as  for 
methanol  and  ammonia  bunkering,  refuelling 
liquid  hydrogen  and  ensuring  full 
interoperability in the hydrogen refuelling ecosystem.  

The  Directive  aims  at  establishing  an  easy-to-use  infrastructure.  This  objective  has  only 
been partially achieved. Weaknesses in the user experience, specifically in the area of cross 
border electro-mobility, can be summarised as follows. 

Easy access to information on the location and availability of all recharging and refuelling 
points  is  essential.  However,  this  is  currently  not  always  the  case.  Such  data  are  not 

30 Directive 2010/31/EU,  
31 Information based on Evaluation Support Study and the Report by the Sustainable Transport Forum on the analysis of stakeholder views on key policy needs 
and  options  for  action  in  Alternative  Fuels  Infrastructure  deployment  and  consumer  services:,  https://ec.europa.eu/transport/sites/transport/files/2019-stf-
consultation-analysis.pdf 

10 

 
 
 
                                                           
systematically  available  in  many  Member  States.  Data  quality  varies,  which  is  not  always 
supportive to the development of comprehensive new user services.  

While  the  Directive  requires  transparent  prices,  many  users  still  have  limited  information 
on  the  final  price  of  a  recharging  session.  Prices  are  often  not  clearly  displayed  at  a 
recharging point and are often also not accessible through apps. In addition, many different 
price components exist which makes it difficult to compare end user prices.   

The Directive sets provisions on ad hoc payment to ensure that no user gets stranded due to 
difficulties of payment. However, different digital solutions have emerged in the markets. A 
simple  unified  ad  hoc  payment  method  (such  as  credit/debit  bank  card  payment)  across 
Europe is not available. Contract based recharging does not work uniformly across the Union, 
as not all electro-mobility service providers or roaming platforms offer their services at each 
recharging point. There is an increasing number of consumer complaints about lack of price 
transparency and user-friendliness of the recharging infrastructure, particularly for payments, 
which is considered to be a barrier specifically to smooth longer-distance trips. 

With respect to the integration of electric vehicles into the electricity system, the current 
provisions of the Directive ensure alignment of the rules between the electro-mobility and the 
electricity markets. However, future mass vehicle uptake will require smart and bidirectional 
charging to ensure an efficient integration of electric vehicles into the electricity system. The 
recent recast of the Electricity Directive (2019/944/EU) already provides a framework for the 
development of competitive electricity services that – if transposed swiftly32 and correctly in 
Member States – would lay down the foundations to allow smart charging and vehicle-to-grid 
services to  develop  in  the market,  especially if smart  charging  infrastructure was deployed. 
Smart charging infrastructure includes the recharging point, the communication between the 
recharging point and the vehicle and the vehicle itself. However, the Directive at current does 
little to support smart charging infrastructure and for facilitating that smart and bidirectional 
recharging  services  can  be  developed.  NPFs  and  NIRs  of  Member  States  contain  little 
information on this topic.  

6 Coherence of Member States planning with the implications of the overall increase of 
ambition for the 2030 EU climate target 

The assessment of the national implementation reports of Member States indicates that their 
current overall ambition with respect to the uptake of zero- and low-emission vehicles in the 
road sector is  largely in  line with  projections of needed road transport contribution  to  meet 
the  previously  set  EU’s  40%  greenhouse  gas  emission  reduction  target  by  2030.  However, 
strong regional differences exist. These will not guarantee a coherent network of alternative 
fuels  infrastructure  throughout  the  EU,  and  could  create  a  risk  of  continued  market 
fragmentation.    

The recently adopted Climate Target Plan sets a considerably higher ambition of at least 55% 
greenhouse  gas  emission  reduction  by  2030.  It  will  therefore  require  a  significantly 
accelerated  uptake  of  sustainable  alternative  fuels  and  zero-  and  low-emission  vehicles. 

32 Transposition deadline of related articles in 2019/944/EU:  31.12.2020 

11 

 
 
 
                                                           
Depending  on  the  scenario  presented  in  the  Impact  Assessment  accompanying  the  Climate 
Target plan33, the share of zero- and low-emission cars (including battery electric, fuel cells 
and plug-in hybrids) in the total car fleet would need to increase significantly compared to a 
current policy scenario.   

Under  the  higher  ambition,  the  corresponding  recharging  infrastructure  deployment  would 
also  need  to  increase  more  than  currently  planned  by  Member  States.  The  need  to  ensure 
good  network  coverage  throughout  the  Union  would  require  intensification  of  effort  in  all 
Member  States,  while  it  would  necessitate  significant  effort  in  those  Member  States  with 
currently  relatively  low  ambition.  Next  to  electric  recharging  infrastructure,  sufficient 
hydrogen infrastructure needs to be built up in the period post 2025, particularly to support 
accelerated uptake of hydrogen fuel cell trucks post 2030.  

The impact of the higher 2030 climate target ambition on the need for additional refuelling 
infrastructure for CNG and LNG compared to the current planning of Member States is less 
evident. While an accelerated uptake of CNG and LNG vehicles can be expected until 2030 
especially in the heavy-duty segment, the planned infrastructure appears to be already largely 
sufficient.  This  is  especially  true  for  CNG  infrastructure,  also  considering  that  the  share  of 
CNG  vehicles  is  expected  to  decrease  significantly  after  2035.  LNG  infrastructure  already 
today covers the core TEN-T transport network corridors and can mostly serve the expected 
growth in the fleet.  

The European Green Deal also highlights the great need for decarbonisation in the shipping 
sector.  The  scenarios  underpinning  the  2030  Climate  Target  Plan  reaching  at  least  55% 
economy-wide greenhouse gas emissions reductions project a high share of alternative fuels 
such as renewable and low carbon liquid fuels. Other alternative fuels to be used particularly 
post  2030  will  be  hydrogen  or  hydrogen  carriers,  such  as  ammonia,  as  well  as  bio-LNG, 
electricity,  methanol  and  e-fuels  that  with  the  exception  of  e-fuels  require  distinct 
infrastructure.  

The FuelEU Maritime initiative34 to be adopted in 2021 will further analyse decarbonisation 
and  pollution  reduction  pathways  for  the  maritime  sector.  It  is  clear  that  considerable  and 
long-term  effort  is  needed  to  ensure  adequate  infrastructure  provision  for  such  fuel  supply. 
Current planning of Member States in this area is well behind what will be required to meet 
the short and medium-term GHG and pollutant emission reduction requirements related to the 
implementation of the European Green Deal. Furthermore, substantial additional investments 
are needed for providing the required recharging  and refuelling infrastructure especially for 
zero emission vessels and infrastructure in ports. Those resources are not currently earmarked 
in  the  Member  States’  planning  as  reported  in  the  National  Implementation  Reports  and 
additional financing may be needed to deliver on the climate objective.   

While  not  explicitly  covered  under  the  provisions  of  the  Directive,  the  aviation  and  rail 
transport  sectors  will  equally  need  to  increase  their  efforts  to  meet  the  ambition  of  the 
Climate Target Plan. With regards to aviation, the RefuelEU initiative is aiming to boost the 
supply  and  demand  for  sustainable  aviation  fuels  in  the  EU35.  This  in  turn  will  reduce 

33

 SWD/2020/176 final https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52020SC0176 

34 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12312-FuelEU-Maritime- 
35 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12303-ReFuelEU-Aviation-Sustainable-Aviation-Fuels 

12 

 
 
                                                           
 
aviation’s environmental footprint and enable it to help achieve the EU’s climate targets. In 
addition,  further  efforts  are  required  to  also  accelerate  the  electricity  supply  at  airports  for 
stationary  aircraft  and  to  decarbonise  ground  movements.  Regarding  rail,  further  effort  is 
needed to further electrify railway lines and to establish hydrogen as an alternative for those 
parts of the rail network that are difficult to electrify.  

7. Conclusion  

The  Alternative  Fuels  Infrastructure  Directive  has  been  instrumental  in  triggering  the 
development  of  policies  and  measures  for  roll-out  of  alternative  fuels  infrastructure  in 
Member States.  Member States have transposed  the Directive and developed their National 
Policy Frameworks (NPFs). With differences across Member States, those policy frameworks 
have  started  to  help  building  a  long-term  forward-looking  perspective  on  infrastructure  for 
electricity, natural gas and hydrogen until 2030. Member States have equally reported on the 
implementation of those policy frameworks in their first National Implementation Reports in 
2019.  

The  Directive  has  had  a  positive  impact  on  the uptake  of  alternatively  fuelled  vehicles  and 
their infrastructure. The Commission’s services analysis shows that the markets would have 
been  less  developed  in  a  scenario  without  the  Directive.  However,  the  shortcomings  of  the 
current  policy  framework  are  also  clearly  visible:  as  there  is  no  detailed  and  binding 
methodology  for  Member  States  to  calculate  targets  and  adopt  measures,  the  level  of 
ambition  in  target  setting  and  supporting  policies  in  place  varies  greatly  between  Member 
States.  For  example,  the  share  projected  by  Member  States  for  electric  cars  in  the  total  car 
fleet  for  2030  varies  between  less  than  1%  and  more  than  40%.  The  corresponding 
infrastructure  targets  reflect  the  different  level  of  ambition,  meaning  that  the  planned 
deployment  of  infrastructure  varies  greatly  between  Member  States.  Moreover,  the  policy 
frameworks  often  do  not  display  sufficient  detail  on  the  state  of  play  and  on  the 
implementation  of  existing  and  planned  policy  measures.  This  corresponds  to  findings  of 
earlier  assessments  of  the  Commission  as  well  as  to  the  conclusions  of  the  European 
Parliament Own Initiative Report on alternative fuels infrastructure from 2018.36   

The  current  infrastructure  deployment  level  is  sufficient  to  serve  the  rather  low  number  of 
alternatively  fuelled  vehicles  currently  on  the  road,  the  two  being  correlated.  However,  a 
comprehensive and complete network of alternative fuels infrastructure does not exist across 
the  Union.  For  example  in  the  area  of  electric  recharging,  large  parts  of  the  TEN-T  core 
network do not have recharging points installed every 60 km as recommended. It is therefore 
unlikely  that  under  the  current  legislative  framework  the  needed  network  would  develop 
across  Europe  in  the  coming  years  even  if  all  Member  States  attained  their  targets.  This  is 
equally true for other alternative fuels infrastructure, especially for waterborne transport. 

The  Commission  has  proposed  to  reduce  the  EU’s  greenhouse  gas  emission  by  2030  by  at 
least 55% compared to the previous 40% reduction target. This has a relevant impact on the 
required  uptake  of  sustainable  alternative  fuels,  vehicles  and  infrastructure.  In  order  to 

36

 (2018/2023(INI)) https://www.europarl.europa.eu/doceo/document/A-8-2018-0297_EN.html 

13 

 
 
 
                                                                                                                                                                                     
 
achieve  these  ambitious  targets,  the  uptake  of  zero-emission  vehicles  and  the  related 
infrastructure  needs  to  accelerate  significantly  in  all  market  segments  of  light-duty  and 
heavy-duty vehicles. Efforts will need to be considerably higher than the efforts reported by 
Member  States  under  the  Directive.  This  does  not  only  relate  to  road  transport  but  equally 
and particularly to other transport modes such as waterborne transport and aviation. Uptake 
of sustainable alternative fuels and electricity supply for ships at berth and stationary aircraft 
has to be accelerated.   

While  technical  specifications  developed  under  the  Directive  have  proven  to  be  highly 
relevant,  new  needs  for  technical  specifications  under  the  Directive  have  emerged.  These 
concern particularly the interoperability and transparent exchange of information among the 
different  players  within  the  electric  vehicle  charging  ecosystem.  Standards  for  recharging 
heavy-duty  vehicles  and  refuelling  liquid  hydrogen  are  required.  In  addition,  maritime 
transport  and 
technical 
specifications  to  facilitate  and  consolidate  the  entry  on  the  market  of  alternative  fuels, 
especially in relation to fuel supply for electricity and hydrogen.  

inland  navigation  will  also  benefit  from  further  common 

From a  consumer perspective, using alternative  fuels  infrastructure needs to  be as easy  as 
the  use  of  conventional  refuelling  infrastructure.  This  requires  that  information  on  the 
location as well as prices to be charged are available and that the payment is seamless. The 
current  policy  framework  has  shortcomings  and  consumers  can  face  problems  particularly 
when travelling across borders.  

Finally  and  in  line  with  the  Commission’s  Communication  COM/2020/29937,  the  cost-
efficient  integration  of  an  increased  number  of  electric  vehicles  in  the  electricity  system 
must  be  ensured.  To  avoid  grid  congestion  and  to  limit  costly  investments  into  grid 
infrastructure  smart  charging  of  electric  vehicles  is  key.  A  smart  integration  of  electric 
vehicles and bi-directional charging will also provide flexibility for the overall management 
of the energy system and thus help to integrate increased shares of variable renewable energy 
production. While the Electricity Directive38 and the Electricity Regulation39 adopted in 2019 
provide  the  legislative  framework  on  the  electricity  market  side,  additional  requirements 
concerning the recharging point and the communication between the recharging point and the 
vehicle might be required to fully enable smart and bi-directional charging.  

In  addition,  during  the  transition  towards  alternative  fuels  and  rather  limited  uptake  of 
alternative vehicles, investments in infrastructure may not be profitable. This is particularly 
the  case  for  locations  with  low  demand  and  a  more  difficult  business  case,  for  example  in 
rural areas or areas with little vehicle uptake. In addition, the roll-out of ultra-fast recharging 
points and of hydrogen stations alongside the TEN-T core and comprehensive network might 
require further support. Here, public financing for publicly accessible recharging or refuelling 
points  needs  to  be  continued  and  be  focused  on  those  parts  of  the  network  where  private 
investments will not be profitable to achieve the Commission’s objectives of having at least 1 
million publicly accessible recharging and refuelling points deployed by 2025. 

37 Commission’s Communication COM/2020/299 Powering a climate-neutral economy: An EU Strategy for Energy System Integration 
38 2019/944/EU 
39 2019/943/EU 

14 

 
 
                                                           
Against  this  background,  the  Commission  announced  revisions  of  related  legislation  for 
example the CO2  emission standards for light-duty vehicles in  2021 and the review of CO2 
emission  standards  for  heavy-duty  vehicles  in  2022,  the  upcoming  FuelEU  and  ReFuelEU 
initiatives  for  maritime  and  aviation,  and  the  revision  of  the  Renewable  Energy  Directive40 
that will strengthen the measures for the uptake of renewable fuels, hydrogen and electricity 
in  the  transport  sector.  Further  action  at  EU  level  is  also  required  to  ensure  that  the 
deployment  of 
friendly  recharging  and  refuelling 
infrastructure41 goes hand in hand with the need for an accelerated uptake of vehicles and 
fuels in all transport modes.  

interoperable  and  user 

This  requires  a  strengthening  of  the  current  policy  framework  at  EU  level  to  achieve  the 
increased  climate  ambition  of  the  European  Green  Deal  and  to  avoid  further  barriers  to 
market growth. The Commission is in the process of carrying out an Impact Assessment for 
the  revision  of  the  Alternative  Fuels  Infrastructure  Directive  and  will  duly  consider  the 
findings  of  this  report  as  well  as  those  of  the  ongoing  evaluation  of  the  Directive  in  this 
context.  

40 2018/2001/EU 
41  While  publicly  accessible  infrastructure  will  be  addressed  in  the  revision  of  the  Directive  on  the  deployment  of  alternative  fuels  infrastructure,  private 
recharging infrastructure in residential and non residential buildings will be addressed in the revision of the Energy Performance of Buildings Directive.   

15