COMMISSION STAFF WORKING DOCUMENT EVALUATION of Directive 2014/94/EU of the European Parliament and of the Council on the deployment of alternative fuels infrastructure accompanying the Proposal for a Regulation of the European Parliament and of the Council on the deployment of alternative fuels infrastructure, and repealing Directive 2014/94/EU of the European Parliament and of the Council
Date: 2021-07-14
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: clean technology, electric vehicle, electricity supply, hydrogen, motor vehicle pollution, reduction of gas emissions, renewable energy, substitute fuel, sustainable mobility, transport infrastructure

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 14.7.2021  SWD(2021) 637 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  of Directive 2014/94/EU of the European Parliament and of the Council on the deployment of alternative fuels infrastructure accompanying the Proposal for a Regulation of the European Parliament and of the Council  on the deployment of alternative fuels infrastructure, and repealing Directive 2014/94/EU of the European Parliament and of the Council {COM(2021) 559 final} - {SEC(2021) 560 final} - {SWD(2021) 631 final} - {SWD(2021) 632 final} - {SWD(2021) 638 final}  
 
 
Table of contents 

1. 

2. 

INTRODUCTION ................................................................................................................................ 2 

BACKGROUND TO THE INTERVENTION ..................................................................................... 3 

2.1 
2.2 
2.3 
2.4 

Political context of the original initiative ................................................................................................... 3 
General, specific and operational objectives of the Directive .................................................................... 3 
Intervention logic ....................................................................................................................................... 5 
Baseline and points of comparison ............................................................................................................ 7 

3. 

IMPLEMENTATION / STATE OF PLAY .......................................................................................... 9 

3.1 

3.2 

3.3 

Activities at EU level in support of implementation of the Directive ........................................................ 9 
Delegated Acts .......................................................................................................... 9 
3.1.1 
Implementing Acts on user information ................................................................... 9 
3.1.2 
EU-level reporting and review ................................................................................ 10 
3.1.3 
Financial support to deployment ............................................................................. 10 
3.1.4 
Exchange with Member States and stakeholders at EU level ................................. 11 
3.1.5 
3.1.6 
Other activities ........................................................................................................ 11 
Overview of national activities implementing the Directive .................................................................... 12 
Transposition of the Directive ................................................................................ 12 
3.2.1 
National Policy Frameworks .................................................................................. 12 
3.2.2 
National Implementation Reports ........................................................................... 12 
3.2.3 
Provision of User Information at national level ...................................................... 12 
3.2.4 
Status of markets for alternative fuels vehicles and infrastructure ........................................................... 13 
Electricity................................................................................................................ 13 
3.3.1 
Natural Gas ............................................................................................................. 15 
3.3.2 
15 
CNG 
15 
LNG 
Hydrogen ................................................................................................................ 16 
3.3.3 
Other fuels .............................................................................................................. 17 
3.3.4 

4.  METHODS AND IDENTIFIED LIMITATIONS .............................................................................. 18 

4.1  Methods ................................................................................................................................................... 18 
Desk research .......................................................................................................... 18 
4.1.1 
Modelling................................................................................................................ 18 
4.1.2 
Stakeholder interviews ............................................................................................ 18 
4.1.3 
Survey ..................................................................................................................... 18 
4.1.4 
Open Public Consultation ....................................................................................... 18 
4.1.5 
4.1.6 
Data requests ........................................................................................................... 19 
Identified limitations and action to remedy .............................................................................................. 19 
Stakeholder consultation ......................................................................................... 19 
4.2.1 
Member State reporting .......................................................................................... 19 
4.2.2 
Assessing the role and additionally of the Directive ............................................... 19 
4.2.3 

4.2 

5.  ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS .......................................... 21 

5.1 

Assessment of the effectiveness of the Directive ..................................................................................... 21 
5.1.1 Effectiveness in achieving the general objectives of the Directive ................................ 21 
Effectiveness in achieving the specific objectives of the Directive ........................ 22 
5.1.2 

I 

 
 
 
5.1.3 

Which external factors and developments have contributed or hindered to 
the achievement of the objectives? ......................................................................... 24 
Effectiveness of monitoring of impacts .................................................................. 24 
5.1.4. 
 Effectiveness of the overall focus of the Directive ................................................ 25 
5.1.5 
5.1.6 
Unintended positive and negative effects ............................................................... 25 
Assessment of the efficiency of the Directive .......................................................................................... 26 
5.2 
5.2.1  Proportionality of cost .............................................................................................................................. 26 

5.2.2 

Could  the  same  or  better  results  have  been  achieved  at  lower  costs  for 
public authorities by a different approach? ............................................................. 27 
Is there potential for simplification of the provisions? ........................................... 28 
5.2.3 
5.3 
Assessment of relevance .......................................................................................................................... 28 
5.3.1  Relevance of the general and specific objectives ..................................................................................... 28 
Relevance in view of new challenges ..................................................................... 28 
5.4 Assessment of overall coherence .................................................................................................................... 29 
5.4.1 Assessment of internal coherence .................................................................................. 29 
5.4.2 
Assessment of external coherence .......................................................................... 29 
Assessment of EU Added Value .............................................................................................................. 30 

5.3.2 

5.5. 

6. 

CONCLUSIONS ................................................................................................................................. 31 

ANNEX 1: PROCEDURAL INFORMATION ............................................................................................ 35 

ANNEX 2: STAKEHOLDER CONSULTATION ................................................................................... 37 

Overview of stakeholder input .............................................................................................................................. 37 
Key findings from the OPC................................................................................................................................... 39 

ANNEX 3: METHODS AND ANALYTICAL MODELS ....................................................................... 46 

1.  OVERVIEW ....................................................................................................................................... 46 

2.  DESCRIPTION  OF  THE  PROBLEM,  THE  UNDERLYING  DRIVERS  AND  ITS 

EXPECTED EVOLUTION ................................................................................................................ 46 

3.  DEVELOPMENT OF THE BASELINE AND ALTERNATIVE SCENARIO ................................. 50 

3.1 
Introduction .............................................................................................................................................. 50 
3.2 
PRIMES-TREMOVE model .................................................................................................................... 50 
Overview of the approach adopted for the Baseline and Alternative scenario ......................................... 51 
3.3 
3.4  Main results of the Baseline and the Alternative scenario ....................................................................... 52 
3.5 
Investment  costs  for  alternative  fuel  infrastructure  in  the  Baseline  and  in  the  Alternative 
scenario .................................................................................................................................................... 55 

ANNEX 4: CURRENT STATUS OF THE AFI AND AFV MARKET IN EUROPE .......................... 62 

1. 

ELECTRICITY ................................................................................................................................... 62 

1.1 
1.2 
1.3 

Electricity for road transport .................................................................................................................... 62 
Electricity for water transport .................................................................................................................. 67 
Electricity supply in airports .................................................................................................................... 67 

2.  NATURAL GAS ................................................................................................................................. 67 

3. 

LNG .................................................................................................................................................... 70 

3.1 
3.2 

LNG for road transport ............................................................................................................................ 70 
LNG for water transport ........................................................................................................................... 72 

4.  HYDROGEN ...................................................................................................................................... 72 

4.1 
4.2 

Hydrogen for road transport ..................................................................................................................... 72 
Hydrogen for waterborne transport .......................................................................................................... 74 

5.  OTHER FUELS .................................................................................................................................. 74 

5.1 

LPG .......................................................................................................................................................... 74 

II 

 
5.2 

Biofuels .................................................................................................................................................... 76 

III 

 
 
 
Glossary 

Term or acronym 

Meaning or definition 

AFI 

AFID 

TEN-T 

LNG 

CNG 

NPF 

NIR 

EU 

FCEV 

BEV 

TTW 

WTT 

WTW 

LCV 

CEN 

Cenelec 

CEF 

H2020 

EGVI 

PPP 

FCH JU 

EAFO 

V2G 

alternative fuels infrastructure 

Directive on alternative fuels infrastructure 

Trans-European Transport Network 

Liquid Natural Gas 

Compressed Natural Gas 

National Policy Framework 

National Implementation Report 

European Union 

Fuel cell electric vehicle 

Battery electric vehicle 

Tank-to-Wheel 

Well-to-Tank 

Well-to-Wheel 

Light commercial vehicles 

Committee for Standardisation 

European Committee for Electrotechnical Standardisation 

Connecting Europe Facility 

Horizon 2020 

European Green Vehicles Initiative 

Public Private Partnership 

Fuel Cells and Hydrogen Joint Undertaking 

European Alternative Fuels Observatory 

Vehicle to Grid 

1 

 
 
 
1.  INTRODUCTION 

Directive  2014/94/EU1  (‘hereinafter  the  Directive  or  AFID’)  creates  a  common 
framework of measures for the deployment of alternative fuels infrastructure for vehicles 
and vessels in the EU. It sets out minimum requirements for the build-up of alternative 
fuels  infrastructure  that  are  to  be  implemented  by  means  of  Member  States'  national 
policy  frameworks.  It  further  sets  common  technical  specifications  for  recharging  and 
refuelling  points,  and  user  information  requirements.  It  should  support  a  single  market 
for alternative fuels infrastructure along urban areas and nodes and the core network of 
the Trans-European Transport Network (TEN-T). 

Recently, the Communication on the European Green Deal2 and the 2030 Climate Target 
Plan3 as well as the Communication on the Sustainable and Smart Mobility Strategy have 
underlined the need for a rapid take up of zero- and low-emission vehicles in view of the 
increased  climate  change  ambition  for  2030  and  the  overall  long-term  objective  of 
achieving climate neutrality by 2050. Providing a sufficiently dense, widespread network 
of recharging and refuelling infrastructure is of central relevance in this regard.4  

Against  this  background,  the  Commission  has  carried  out  an  evaluation  of  AFID,  in  a 
back-to-back manner with the Impact Assessment for the review of the Directive. More 
specifically and in line with the Better Regulation Guidelines, this evaluation analyses: 

 

 

 

 

 

its overall effectiveness, i.e. assess the actual changes the Directive has triggered, 
particularly in view of its original objectives; 

its  efficiency,  i.e.  assess  the  actual  costs  relative  to  the  actual  benefits  of  the 
implementation,  and  whether  there  is  potential  for  simplification  and  increasing 
cost-efficiency;  

its  relevance,  i.e.  assess  whether  the  overall  problem  analysis  and  related 
objectives are still adequate and how the policy context has evolved.  

its  added  value  to  the  EU,  i.e.  its  impact  beyond  what  reasonably  could  have 
been achieved by national and regional policies; and 

the coherence of the regulatory framework, regarding both the internal coherence 
and the coherence with other key legislation and policy initiatives at EU level.  

The  evaluation  also  draws  on  the  Commission  assessment  of  the  National  Policy 
Frameworks5 (NPFs) and the recent assessment of the application of the Directive based 
on the National Implementation Reports (NIR)6. 

1 Directive 2014/94/EU of the European Parliament and of the Council of 22 October 2014 on the deployment of alternative fuels, OJ 
L 307/1.  
2 European Commission, ‘The European Green Deal’ COM(2019) 640 final. 
3  European Commission,  ‘Stepping up  Europe’s  2030 climate  ambition  Investing  in a  climate-neutral  future  for  the  benefit  of  our 
people’ COM(2020) 562 final. 
4  European  Parliament,  ‘Report  on  deployment  of  infrastructure  for  alternative  fuels  in  the  European  Union:  time  to  act!’ 
(2018/2023(INI)). 
5 Commission, ‘Report on the Assessment of the Member States National Policy Frameworks for the development of the market as 
regards  alternative  fuels  in the  transport  sector  and  the  deployment  of  the  relevant  infrastructure  pursuant  to  Article  10  (2)  of  Dir. 
2014/94/EU’ SWD(2019) 29 final. 
6 European Commission, ‘Report on the application of Directive 2014/94/EU on the deployment of alternative fuels infrastructure’ 
COM/2021/103 final 

2 

 
                                                 
2.  BACKGROUND TO THE INTERVENTION 

2.1 Political context of the original initiative 

The 2011 Transport White Paper7 stressed the relevance of developing a framework for 
the  adoption  of  alternative  fuels  as  part  of  the  effort  to  reduce  transport  emissions.  In 
2013, the Commission published its  “Clean Power for Transport” strategy8, including a 
legislative  proposal  for  establishing  a  Directive  on  the  promotion  of  alternative  fuels 
infrastructure.9 The “Clean Power for Transport” strategy underlined the need to reduce 
the EU’s dependency on imported oil, the need for low-CO2 fuels and energy sources, as 
well  as  the  need  to  promote  the  use  of  a  range  of  alternative  fuels  to  decarbonise  the 
transport sector. It considered the increased use of renewable electricity and potentially 
hydrogen,  as  well  as  an  increased  use  of  ‘sustainable  biofuels’  and  gas  (including 
biomethane).  

The  Impact  Assessment  accompanying  the  2013  legislative  proposal  for  AFID10  found 
that  on  the  basis  of  projected  market  developments,  the  infrastructure  for  electric, 
hydrogen and natural  gas (LNG and CNG) vehicles is  likely to  remain  insufficient  and 
not  in  line  with  what  a  broad  market  take-up  would  require.  The  reason  was  a 
combination  of  ‘technological  and  commercial  short-comings,  and  a  lack  of  consumer 
acceptance  and  missing  adequate  infrastructure’,  resulting  in  a  “chicken  and  egg” 
problem  (market  failure):  without  a  minimum  network  of  recharging  and  refuelling 
points, the uptake of alternatively fuelled vehicles will be hampered, and vice versa. 

Further, at the time no common technical specifications and related standards existed in 
the EU for alternative fuels infrastructure, creating uncertainty to investment and scale up 
of different technologies at early stage of technological maturity. The impact assessment 
concluded  on  the  need  for  a  framework  of  common  measures  to  ensure  the 
interoperability  of  alternative  fuels  infrastructure  as  a  condition  for  wider  uptake  of 
alternative fuels vehicles and vessels that circulate in urban/suburban agglomerations and 
on  the  TEN-T  network.  In  addition,  it  underpinned  the  need  for  clear,  comparable  and 
understandable information on alternative fuels to consumers, in order to increase public 
awareness, usability and a general appreciation of possible benefits. 

The Commission adopted its legislative proposal on 24 January 2013. Following the co-
decision procedure, the Directive was published on 28 October 2014.   

2.2 General, specific and operational objectives of the Directive 

The  general  objective  is  to  establish  a  common  framework  of  measures  for  the 
deployment of alternative fuels infrastructure in the EU, minimizing the dependency on 
fossil fuel (ensuring the security of supply) and mitigating the environmental impact of 
transport by reducing GHG emissions and air pollutant emissions. 

7 European Commission, ‘White Paper: Roadmap to a Single European Transport Area - Towards a competitive and resource efficient 
transport system’ COM(2011) 144 final. 
8 European Commission, ‘Clean Power for Transport: A European alternative fuels strategy’ COM(2013) 17 final. 
9  European  Commission,  ‘Proposal  for  a  DIRECTIVE  OF  THE  EUROPEAN  PARLIAMENT  AND  OF  THE  COUNCIL  on  the 
deployment of alternative fuels infrastructure’ COM(2013) 18 final. 
10 European Commission, ‘EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT Accompanying the document Proposal for 
a Directive on the deployment of alternative fuels infrastructure’ SWD(2013) 6 final. 

3 

 
                                                 
Specific  objectives  concern:  ensuring  and  supporting 
the  development  of  a 
comprehensive network of alternative fuels infrastructure within the EU for all modes of 
transport  and  to  trigger  investment  therein  (SO1);  supporting  the  interoperability  of 
infrastructure  where  necessary  through  harmonisation  to  enable  economies  of  scale 
(SO2);  increasing  the  availability  of  appropriate  consumer  information  and  awareness 
about  alternative  fuels  (SO3);  and  allowing  the  efficient  integration  of  electro-mobility 
into the electricity system and compliance with electricity market rules (SO4). 

SO1:  Support  the  development  of  a  comprehensive  network  of  alternative  fuels 
infrastructure in the Union for all transport modes (Article 3 to 6 of the Directive) 

In order to ensure that alternatively fuelled vehicles are able to circulate freely in urban 
and  suburban  areas  and  on  the  TEN-T,  Member  States  have  to  implement  the 
requirements  of  the  Directive  by  means  of  their  national  policy  frameworks  (NPFs), 
including  setting  targets,  objectives  and  measures  in  the  NPFs  for  publicly  accessible 
recharging and refuelling points. This would provide certainty for investors, address the 
chicken and egg problem and trigger investment in alternative fuel infrastructure.  

Member  States  had  to  define  and  adopt  a  national  policy  framework  (NPF)  for  the 
development of an alternative fuels market and the deployment of relevant infrastructure 
by  18  November  2016  (Article  3).  NPFs  were  to  include  an  assessment  of  the  current 
state of alternative fuels infrastructure, national targets for the deployment of alternative 
fuels  infrastructure,  measures  to  promote  the  deployment  of  alternative  fuels  in  public 
transport, designation of urban/suburban agglomerations to be equipped with recharging 
points and (separately)  CNG refuelling  points, and an  assessment of the  need to install 
LNG refuelling points in ports outside of the TEN T core network.  

Member States have to provide an appropriate number of recharging points for electricity 
(Article  4)  and  refuelling  points  for  natural  gas  (Article  6)  accessible  to  the  public  in 
urban and suburban agglomerations and other densely populated areas by 2020 as well as 
for CNG and for LNG on the TEN-T core network by 2025. Member States could decide 
whether to include hydrogen refuelling points in their NPFs, but if they decided to do so 
have to provide an  appropriate number by  2025 (Article 5). Similarly to road transport 
vehicles,  Member  States  have  to  ensure  an  appropriate  number  of  refuelling  points  for 
LNG in TEN-T maritime ports by 2025 and in TEN-T inland ports by 2030. They also 
have to ensure that onshore power supply for seagoing and inland waterways vessels is 
installed with priority in TEN-T core ports by 2025, unless there is no demand and the 
cost are disproportionate to the benefits.   

SO2:  Ensure 
harmonisation (Articles 4 to 6 of the Directive) 

interoperability  of 

infrastructure  where  necessary 

through 

Member  States  have  to  ensure  that  refuelling  stations  meet,  as  a  minimum,  European 
standards for recharging/refuelling points for electricity, hydrogen and natural gas (with 
requirements  being  specified  separately  for  LNG  for  maritime  and  inland  waterway 
vessels  and  for  LNG  and  CNG  for  motor  vehicles).  For  developing  technologies,  the 
Directive  contains  several  provisions  to  ensure  that  its  provisions  can  be  adapted  to 
market developments and technological progress by means of delegated acts in respect of 
technical specifications of refuelling and recharging points and relevant standards. 

SO3:  Ensure  availability  of  appropriate  consumer  information  and  awareness 
about alternative fuels (Article 7 of the Directive) 

4 

 
The  Directive  also  contains  provisions  on  the  display  of  information  on  fuel  prices  at 
stations, requiring that comparisons are made available between the different fuels on a 
‘per  unit’  basis,  so  that  consumers  can  identify  which  alternative  fuels  would  provide 
them with the most cost-advantageous option for their needs. 

SO4: Ensure efficient integration of electro-mobility into the electricity system and 
compliance with electricity market rules (Article 4 of the Directive) 

The  Directive  requires  publicly  accessible  recharging  points  to  use  intelligent  metering 
systems wherever technically feasible and economically reasonable to enable the future 
development of functions such as selection of green energy for charging and electricity 
delivery from the vehicle at peak hours. Further, it establishes that operators of electric 
vehicle charging points should be free to purchase electricity from any EU supplier and 
that  electricity  suppliers  must  cooperate  with  any  person  establishing  or  operating 
publicly accessible charge points. Further, it mandates that consumers should be free to 
recharge  their  vehicles  at  any  publicly  accessible  charging  point  on  an  ad-hoc  basis, 
without the need for a contract with the electricity supplier. 

2.3 Intervention logic 

The intervention logic for the evaluation is presented in Figure 1. Implementation of the 
Directive  (actions)  should  lead  to  specific,  short-term  outcomes  (outputs)  as  well  as 
longer-term results and impacts, reflecting the objectives of the Directive. The identified 
outputs  represent  the  expected  direct  outcomes  of  the  activities  and  obligations  of 
Member States  as defined in  the Directive and the NPFs. The results and their impacts 
should  be  in  line  with  the  specific  and  general  objectives  of  the  Directive.  In  addition, 
external  factors  as  well  as  unexpected  or  unintended  impacts  have  to  be  considered  as 
well as their impact on the AFID. 

Direct outputs were expected from the activities at Member States and European level as 
well  as  private  actors.  They  include  the  actual  investment  (public  and  private)  on 
alternative  fuels  infrastructure  with  the  focus  on  covering  the  Directive  requirements, 
while  also  ensuring  that  there  are  no  gaps  in  cross-border  regions.  The  actions  taken 
should  lead  to  improved  information  for  consumers  and  improved  accessibility  to 
recharging/refuelling  points  with  lower  barriers  in  relation  to  technical  and  payment 
aspects  as  well  as  in  relation  to  specific  parts  of  the  population  (e.g.  disabled/older 
people).  It  also  includes  the  improved  operation  of  the  market  to  remove  barriers  to 
access  to  the  market  and,  in  the  case  of  electro-mobility  to  facilitate  the  access  to  the 
electricity  distribution  system.  Those  outputs  should  be  achieved  on  a  consistent  basis 
across the EU while taking into account the specific characteristics of the Member States. 

5 

 
Figure 1: Overview of drivers, problems and implications Intervention Logic 

6 

 
 
 
2.4 Baseline and points of comparison  

A  Baseline  scenario  has  been  developed  for  the  purpose  of  the  current  evaluation, 
showing the projected developments without the  implementation of the AFID. It builds 
on the Baseline scenario of the impact assessment accompanying the AFID but takes into 
account  the  revised  macro-economic  framework,  fuel  price  projections,  changes  in 
technology  costs  and  other  policies  adopted  by  the  end  of  2019.  Annex  3  provides  a 
description of the Baseline scenario. 

Baseline of the Impact Assessment underpinning the 2013 legislative proposal 

At  the  time  of  the  adoption  of  the  Directive,  there  was  a  limited  deployment  of 
alternative fuels  and infrastructure. The  Impact  Assessment  accompanying the proposal 
for  the  Directive  considered  the  infrastructure  network  for  electricity,  hydrogen  and 
natural  gas  (LNG  and  CNG)  as  insufficient  compared  to  a  network  that  would  be 
necessary  to  enable  market  take  up  of  these  fuels.  The  availability  of  recharging  and 
refuelling stations was regarded not only as a technical prerequisite for the functioning of 
alternative  fuel  vehicles,  but  also  one  of  the  most  critical  components  for  consumer 
acceptance. 

The Impact Assessment developed a projection of the expected evolution of the problem 
and its expected impacts under the ‘no-policy change’ scenario  with no additional policy 
interventions  besides  those  already  in  place  or  those  already  announced  by  Member 
States, including funding for R&I and deployment at national and European level.   

Despite  existing  initiatives  and  projected  increase  in  oil  prices,  under  the  ‘no-policy 
change’ scenario the level of infrastructure would be expected to remain below what was 
considered necessary to enable the market take up of alternative fuelled vehicles.  

In  terms  of  the  identified  root  causes  of  the  problem,  common  standards  would 
eventually develop since the persistence of different technical solutions would represent a 
serious  obstacle  to  pan-European  mobility.  However,  delays  would  still  lead  to 
considerable stranded costs and additional expenditure for adaptation. 

Besides,  investment  uncertainty,  problems  of  coordination  and  the  identified  market 
failures  would  continue.  Member  States  would  take  relevant  measures  to  address  these 
problems.  Those  however  could  lead  to  a  fragmented  market,  driving  up  costs  and 
limiting consumer confidence with a negative impact on both demand and supply.  

Therefore,  the  baseline  of  the  Impact  Assessment  underpinning  the  2013  legislative 
proposal  projected  that  the  share  of  alternative  fuels  in  the  energy  consumption  of 
passenger cars and vans would remain less than 10% by 2050 without further action on 
infrastructure.  LNG  and  CNG  would  not  make  significant  inroads  in  road  transport, 
while the same would be the case for LNG use in waterborne transport due to the lack of 
refuelling infrastructure. 

Updated Baseline for this evaluation – no-policy-change (no AFID) scenario 

Even  without  the  Directive  in  place,  there  are  some  important  European  policy 
instruments  that  drive  the  uptake  of  alternative  fuels,  vehicles  and  infrastructure  that 
entered into force after the adoption of the Directive in 2014. Key among them are the 

7 

 
 
CO2  standards  for  light-duty  vehicles11  and  heavy-duty  vehicles12,  the  recast  of  the 
Renewable  Energy  Directive13  and  the  revision  of  the  Clean  Vehicles  Directive14.  As 
explained above, the Baseline scenario (‘no-policy change’ scenario) for this evaluation 
builds  on  the  Baseline  scenario  of  the  impact  assessment  accompanying  the  AFID  but 
takes  into  account  the  revised  macro-economic  framework,  fuel  price  projections, 
changes  in  technology  costs  and  other  policies  adopted  by  the  end  of  2019.  It  does 
however not include measures that are part of the “Fit for 55” package.  

In  the  Baseline  scenario,  the  car  stock  is  projected  to  continue  to  be  mainly  based  on 
thermal  engine  technologies  for  the  years  to  come.  The  share  of  conventional  gasoline 
and diesel vehicles in the total stock would reduce from 97% in 2010 to 65% in 2030 and 
36%  in  2050.  Importantly,  the  implementation  of  the  post-2020  CO2  standards  would 
drive the uptake of hybrid vehicle technologies in the market, in the absence of a larger 
contribution from battery electric vehicles (BEVs) and plug-in hybrids (PHEVs), due to 
the lack of recharging infrastructure. The hybrid technologies would increase their share 
from less than 1% in 2010 to 25% in 2030 and 35% by 2050, at which point the hybrid 
vehicles would hold the second largest share in the total car stock, comparable to that of 
conventional gasoline and diesel vehicles. For electric vehicles, a gradual market uptake 
would  take  place  driven  by  the  CO2  standards  and  the  gradual  reduction  of  the  battery 
costs, with BEVs and PHEVs each reaching a share of around 3% in 2030 and 13% in 
2050 in the total stock of cars. The share of the liquefied petroleum gas (LPG) cars would 
decrease from 3% in 2010 to about 2% in 2050. The share of fuel cell electric vehicles 
(FCEVs) is projected to remain negligible for all the projection period. Similarly to cars, 
for  light  commercial  vehicles  (LCVs)  the  share  of  conventional  gasoline  and  diesel 
vehicles is projected at 66% by 2030 and 37% by 2050, while that of hybrid technologies 
at  32%  by  2030  and  48%  by  2050.  The  uptake  of  battery  electric  and  plug-in  hybrids 
would  be  more  limited  in  lack  of  recharging  infrastructure  (up  to  15%  by  2050).  For 
heavy-duty  vehicles,  fuel  cell,  LNG  and  electric  vehicles  would  not  make  significant 
inroads in the vehicle stock by 2050 in the Baseline scenario. 

The  share  of  alternative  fuels  in  the  energy  consumption  of  passenger  cars  and  vans 
would remain limited, at around 14% by 2030 and 18% by 2050, without further action 
on infrastructure. The share of alternative fuels in the energy use in transport would go 
up from 7% in 2010 to 12% in 2030 and remain limited to around 17% by 2050.   

What concerns infrastructure, in the baseline scenario around 172,000 recharging points 
would be deployed by 2020, increasing to just under a million by 2030 and to 5.4 million 
by 2050. The number of hydrogen stations would increase to 174 by 2030 and 1,236 by 
2050.  For  LNG  bunkering  in  ports,  9  facilities  would  be  deployed  by  2030  and  14  by 
2050.      

11 Regulation (EU) 2019/631 
12 Regulation (EU) 2019/1242 
13 Directive 2018/2001/EU 
14 Directive (EU) 2019/1161 

8 

 
 
 
                                                 
3.  IMPLEMENTATION / STATE OF PLAY 

This section provides an overview of the implementation of the AFID at EU and national 
level up to now, together with an overview of the current status of the AF market. The 
analysis is primarily based on information extracted from the Member States’ NPFs and 
National  Implementation  Reports  (NIRs),  supplemented  by  relevant  literature,  data 
sources  and  inputs  from  stakeholder  engagement  activities.  The  evaluation  cross-
references the recent Commission report on the application of that Directive.  

3.1 Activities at EU level in support of implementation of the Directive 

3.1.1  Delegated Acts 

In 2015, the Commission requested the European Committee for Standardisation (CEN) 
and  the  European  Committee  for  Electrotechnical  Standardisation  (Cenelec)  to  develop 
and  adopt  appropriate  European  standards,  or  to  amend  existing  European  standards 
concerning  alternative  fuels  for  transport  (M/533)15  The  Commission  adopted  the 
Delegated Regulation (EU) 2018/67416 to include technical specifications for L-category 
vehicles, short-side electricity supply for inland waterways vessels, CNG/LNG refuelling 
points  for  motor  vehicles,  inland  waterway  vessels  and  sea-going  ships  and  replace 
specifications for hydrogen refuelling points in the Directive. The act was repealed and 
replaced  by  Commission  Delegated  Regulation  (EU)  2019/174517.  The  standards 
included  in  this  Regulation  will  apply  to  renewed  and  newly  deployed  recharging  and 
refuelling points from 12 November 2021.  

The Commission adopted specification for the majority of infrastructure network aspects 
listed  in  Annex  II  of  the  Directive;  however,  no  technical  specifications  for  points  1.3 
(wireless  recharging  for  motor  vehicles),  1.4  (battery-swapping)  and  1.6  (recharging 
points  for  electric  buses)  were  adopted  yet.  A  delegated  regulation  for  point  1.6  is 
foreseen for 2021; a delegated regulation for point 1.3 might be adopted by end of 2021 
subject to progress of discussion within the European Standardisation Organisations; no 
action is currently planned on point 1.4. 

3.1.2  Implementing Acts on user information 

The  Commission  adopted  Implementing  Regulation  2018/73218  on  a  common 
methodology  for  alternative  fuels  unit  price  comparison,  in  line  with  Article  7(3)  and 
initiated a Common Programme Support Action under the Connecting Europe Facility to 

15 COMMISSION IMPLEMENTING DECISION of 12.3.2015 on a standardisation request addressed to the European standardisation 
organisations, in accordance with Regulation (EU) No 1025/2012 of the European Parliament and of the Council, to draft European 
standards for alternative fuels infrastructure, C(2015) 1330 final. 
16  Commission  Delegated  Regulation  (EU)  2018/674  of  17  November  2017  supplementing  Directive  2014/94/EU  of  the  European 
Parliament  and  of  the  Council  as  regards  recharging  points  for  L-category  motor  vehicles,  shore-side  electricity  supply  for  inland 
waterway  vessels  and  refuelling  points  for  LNG  for  waterborne  transport,  and  amending  that  Directive  as  regards  connectors  for 
motor vehicles for the refuelling of gaseous hydrogen [2018] OJ L 114/1. 
17 Commission Delegated Regulation (EU) 2019/1745 of 13 August 2019 supplementing and amending Directive 2014/94/EU of the 
European Parliament and of the Council as regards recharging points 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 and repealing 
Commission Delegated Regulation (EU) 2018/674 [2019] L 268/1. 
18 Commission Implementing Regulation (EU) 2018/732 of 17 May 2018 on a common methodology for alternative fuels unit price 
comparison in accordance with Directive 2014/94/EU of the European Parliament and of the Council [2018] OJ L 123/85. 

9 

 
 
                                                 
identify  possible  approaches  to  the  implementation  of  the  common  methodology19.  By 
Commission  Implementing  Regulation  2020/85820,  amending  Implementing  Regulation 
2018/732, the entry into force was postponed to December 2020 because of the impact of 
the COVID-19 pandemic. 

3.1.3  EU-level reporting and review 

The Commission adopted the following reports and guidelines: 

 

 

 

 

 

 

In  2016,  a  Commission  Guidance  document21  to  support  Member  States  in 
developing their NPFs. 

In  2017,  a  Commission  Staff  Working  Document  assessing  the  NPFs  of  24 
Member States that were available at the time22;  

In  2017,  a  Commission  Action  Plan  towards  the  broadest  rollout  of  alternative 
fuels  infrastructure,  outlining  different  supporting  actions  including  funding 
available under EU financial instruments23. 
In 2019, a Commission Guidance document accompanied by an Excel® reporting 
template  to  facilitate  compliance  with  the  national  reporting  requirements 
outlined in Article 10(1). 

In 2019, an updated Commission Staff Working  Document to  include the NPFs 
of EL, MT, RO and SI24. 

In 2021, a report on the application of Directive 2014/94/EU on the deployment 
of alternative fuels infrastructure25 

3.1.4  Financial support to deployment  

Connecting  Europe  Facility  (CEF)  Transport  was  the  main  EU  funding  instrument 
used  to  support  investment  in  AFI  in  the  time  period  covered  by  this  evaluation.  It 
supported investments into alternative fuels infrastructure for road transport and ports.  

Since  2014,  alternative  fuel  projects  have  been  funded  under  nine  different  calls  for 
proposals,  in  the  form  of  annual  and  multi-annual  work  programmes  covering  general, 
blending and cohesion calls26. One such call is the CEF Transport Blending Facility27, 
a tool to promote the participation of private sector investors and financial institutions in 
projects  concerning  the  deployment  of  alternative  fuels.  It  was  launched  in  2019  and 

19 German Energy Agency (DENA), Study on the Implementation of Article 7(3) of the Directive on the “Deployment of Alternative 
Fuels Infrastructure” – Fuel Price Comparison: Final Report (2017). 
20  Commission  Implementing  Regulation  (EU)  2020/858  of  18  June  2020  amending  Implementing  Regulation  (EU)  2018/732  as 
regards postponing its date of application [2020] OJ L 195/57. 
21  European  Commission,    Clean  Transport  -  Support  to  the  MS  for  the  Implementation  of  the  Directive  on  the  Deployment  of 
Alternative Fuels Infrastructure: Good Practice Examples (2016). 
22 COM(2017) 652 final, SWD(2017) 365 and SWD(2019) 29. 
23 European Commission, ‘Towards the broadest use of alternative fuels  - an Action Plan on Alternative Fuels  Infrastructure under 
Article 10(6) of Directive 2014/94/EU, including the assessment of national policy frameworks’ COM(2017) 652 final. 
24 European Commission, ‘Report on the Assessment of the Member States National Policy Frameworks for the development of the 
market as regards alternative fuels in the transport sector and the deployment of the relevant infrastructure pursuant to Article 10 (2) 
of Directive 2014/94/EU’ SWD(2019) 29 final. 
25 COM/2021/103 final 
26 Blending calls are open for projects aimed at maximising the private involvement in the delivery of CEF transport and cohesions 
calls are open exclusively for MS eligible for funding from the Cohesion Fund (under the European structural and investment funds).  
27 https://ec.europa.eu/inea/en/connecting-europe-facility/cef-transport/apply-funding/blending-facility 

10 

 
 
                                                 
accepts proposals on a rolling basis with quarterly cut-offs and blends loans with grants 
and  other  financing  form.  The  infrastructure  deployment  supported  by  CEF  has  been 
located  on  all  nine  Core  Network  Corridors,  including  the  urban  nodes  with  a  total 
project value of 3,883.6 million.   

Further, the CEF Debt Instrument addresses projects with expected financial viability 
but  a  risk  profile  that  is  too  high  for  conventional  market  financing.  By  the  time  of 
concluding  this  evaluation  five  projects  related  to  alternative  fuels  infrastructure  had 
received grants under the debt instrument, with a total of € 1.1 billion funding. This, in 
combination with the calls for proposals, brings the total CEF contribution towards AF in 
excess of € 6.8 billion. 

Funding for R&I for alternative  fuels  has been made available through Horizon 2020 
(H2020)  programme,  for  electric  vehicles  and  recharging  infrastructure  in  particular 
through  the  Societal  Challenge  ‘Smart,  Green  and  Integrated  Transport”  and  the 
European  Green  Vehicles  Initiative  (EGVI)  Public  Private  Partnership  (PPP),  but  also 
through  funding  for  H2020  Smart  City  Lighthouse  projects.  In  addition,  the  Fuel  Cells 
and  Hydrogen  Joint  Undertaking  (FCH  JU)  PPP  supported  projects  that  will  improve 
performance and reduce the cost of products as well as demonstrate on a large scale the 
readiness  of  the  technology  to  enter  the  market  in  the  fields  of  transport  and  energy. 
Finally, H2020 also supported projects on natural gas (CNG, LNG, biomethane)  

EU  R&D  funding  allocated  from  2014  in  the  areas  of  transport  electrification  and 
methane-based  fuels  sums  up  to  €  1.57  billion  of  which  the  majority  was  spent  on 
electrification. 

3.1.5  Exchange with Member States and stakeholders at EU level  

The Committee on Alternative Fuels Infrastructure (C49500) was created under Article 9 
of the Directive and started meeting in July 2017. The Committee has addressed actions 
to  support  the  deployment  of  alternative  fuels  infrastructure  including  drafting  of 
implementing  acts,  programme  support  action  for  the  comparison  of  alternative  fuels 
prices and voting to postpone the date of effect for the implementing act on harmonised 
rules on electro-mobility28. 

The  Sustainable  Transport  Forum  (STF)  was  created  in  201529  as  an  expert  group  on 
alternative  transport  fuels,  involving  Member  States  and  32  interest  organisation  and 
companies.  The  STF  aims  to  help  the  Commission  to  advance  the  application  of  the 
Clean  Power  for  Transport  Strategy  and  facilitate  the  implementation  of  the  AFID,  in 
particular  through  exchange  of  technical  expertise  and  information.  Under  the  STF, 
different subgroups have been formed on advanced biofuels (dissolved), on the creation 
of an electro-mobility market of services; on alternative fuels in cities (dissolved), on the 
implementation of the Directive, on the standards for alternative fuels infrastructure and 
on electric buses.   

3.1.6  Other activities 

The  Directive  mandated  CEN  to  develop  standards  that  would  improve  existing  user 
information. CEN adopted on 12 October 2016 standard EN 16942, "Fuels-Identification 
of vehicle compatibility-Graphical expression for consumer information", which entered 
into force 2 years later, on 12 October 2018. Furthermore, the standard EN 17186:2019 

28 Meeting minutes can be accessed here: https://ec.europa.eu/transparency/regcomitology/index.cfm?do=search.search 
29 C(2015) 2583 final 

11 

 
                                                 
laying  down  harmonized  identifiers  for  power  supply  for  electric  road  vehicles  was 
adopted in 2019 and is due to enter into force in February 2021. 

The  European  Alternative  Fuels  Observatory  (EAFO)30  disseminates  information  on 
alternative  fuels  in  Europe,  funded  by  the  Commission.  The  portal  regularly  updates 
figures on AFI and AFV and includes details on each of the national policy frameworks, 
including information on the targets and objectives. 

3.2 Overview of national activities implementing the Directive 

3.2.1  Transposition of the Directive 

Member  States  had  to  transpose  the  Directive  by  18  November  2016.  Some  Member 
States delayed its transposition. 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 were no open 
infringement cases against Member States for non-transposition of the Directive.  

3.2.2  National Policy Frameworks 

By  the  original  deadline  of  18  November  2016,  not  all  Member  States  had  submitted 
their  national  policy  frameworks.  By  summer  2017,  24  NPFs  were  available  that 
informed the first assessment of NPFs by the Commission in 2017. By end of 2018 all 
NPFs had been received.  

In its 2017 assessment of the NPFs and in  its 2019  update, the Commission  concluded 
that  the  NPFs  are  not  fully  coherent  from  an  EU  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 
sufficiently ambitious targets and objectives, supported by comprehensive measures.  

3.2.3  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). Not all reports were delivered 
on time, but by end of 2020 all reports had been received.31  

3.2.4  Provision of User Information at national level  

Ensure relevant, consistent and clear information 

As well as providing information through vehicle manuals, dealerships and on cars, the 
analysis of the NPFs and NIRs shows that the information has also been made available 
on websites, national information points and through educational programmes in schools.  

30 https://eafo.eu/ 
31 Full information on the process can be found in the Commission Report on the Application of the Directive, COM (2021)103 final  

12 

 
 
                                                 
Furthermore,  Member  States  are  required  to  ensure  that  information  to  consumers  on 
nozzles  and  pumps  is  provided  via  graphical  expressions,  in  line  with  the  standards 
developed by relevant ESOs. The standards for graphical expressions came into effect in 
October  2018,  as  such  these  MS  may  have  introduced  similar  schemes  prior  to  this. 
There  is  no  comprehensive  and  coherent  database  to  assess  the  use  of  those  graphical 
expressions in Member States.  

The common methodology for alternative fuels unit price comparison came into effect by 
07  December  2020  under  Commission  Implementing  Regulation  2020/858.  To  support 
implementation of this Regulation, the Commission issued a programme support action 
(PSA) under CEF for Transport32. It aims to pilot different options of price comparison to 
support,  ensure  consistent  implementation  of  Article  7(3)  of  the  AFID  and  develop  an 
online portal to display fuel prices and costs. 33Aside from this, there has been little action 
taken by MS to implement this article.  

Open data for geographical location of AFI 

AFID intends to facilitate exchange of data. There is no comprehensive information for 
all  Member  States  that  information  on  infrastructure  was  provided  via  databases, 
containing  information  on  location,  prices,  accessibility  and  status  of  recharging  and 
refuelling  points.  From  the  analysis  of  the  NPFs  and  NIRs,  AT,  BE,  FR,  HR,  LT,  LU, 
PL, RO, SI and ES all stated that they have introduced specific measures on publishing 
data  on  AFI.  As  part  of  the  survey  underpinning  the  evaluation  support  study,  five 
national authorities34 stated that they share information accordingly.    

The Commission has also supported the implementation of Article 7(7) through another 
Programme Support Action on data collection related to recharging/refuelling points for 
alternative  fuels  and  the  unique  identification  codes  related  to  e-Mobility  actors 
(IDACS)35.  Starting  in  January  2019,  16  Member  States  work  together  to  set  up 
harmonised identification codes for charging point operators, implement  ID registration 
repository  for  exchanging  information  on  these  ID  codes  and  ensure  that  all  data  of 
infrastructure of electricity and hydrogen is readily available.  

3.3 Status of markets for alternative fuels vehicles and infrastructure 

An overview of the current status, broken down by fuel type and transport mode has been 
prepared  through  the  report  on  the  state  of  the  alternative  fuels  transport  system  in 
Europe36.  Moreover,  the  Commission  has  provided  a  full  assessment  of  the  status  of 
markets as part of its recent report on the application of the Directive37. The evaluation 
draws on those assessments and summaries the status of markets below.  

3.3.1  Electricity 

Electricity for Road Transport 

At EU level, the data provided by EAFO points to six-fold increase in the total number of 
electric  charging  infrastructure  between  2014  and  2019,  from  25,268  to  165,106 

32 http://fpc4consumers.eu/ 
33 Greece is coordinating the project and the Netherlands, Finland, Germany, Croatia, Spain, Portugal and France are participating. 
34 Luxembourg, Belgium, Austria, Poland and Romania 
35https://ec.europa.eu/transport/content/programme-support-action-addressed-member-states-data-collection-related_en 
36 https://op.europa.eu/en/publication-detail/-/publication/fd62065c-7a0b-11ea-b75f-01aa75ed71a1 
37 COM/2021/103 final 

13 

 
                                                 
recharging  points.  The  number  of  EVs  (BEVs  and  PHEVs)  during  the  same  period 
increased at an even higher rate (9.4 times) with the share BEVs remaining rather stable 
(ca.  60%).  The  EAFO  data  also  point  to  a  significant  increase  in  the  number  of  fast 
chargers (>22kW) per 100 km of highway (from 2 per 100 km in 2014 to 20 in 2019).  

Fast chargers represented in 2019 around 10% of the total public chargers, up from 5% in 
2014. According to T&E, there were approximately 780 ultra-fast chargers38 in Europe at 
the start of 2020. Germany has the highest number of ultra-fast recharging points (269), 
representing approximately a third of the network. Other MS with a significant number 
of ultra-fast recharging points are the Netherlands (98) and France (88).  

At EU level, the number of charging points per million population increased from 112 in 
2015 to 376 in 2019.  The increase of recharging infrastructure at EU level is not equally 
spread  across  MS.  A  small  number  of  MS  are  far  ahead  in  terms  of  the  density  of  the 
network  while  others  are  still  at  the  very  early  stages.  At  the  same  time,  among  the 
frontrunners there have been different levels of development of fast infrastructure.39  

All Member States have seen an overall increase in the number of electric vehicles from 
2015 to 2019. Vehicle fleets increase has been fragmented across Member States though. 
Except for Sweden, the Member States with the greatest increase in electric vehicles per 
million population from 2015 to 2019 are also those with a corresponding high increase 
in recharging infrastructure.  

Electricity for waterborne transport 

In relation to electricity installations in sea/inland ports, in 2015, there were 20 maritime 
ports in the EU providing shore side electricity (SSE) supply (high or low voltage). By 
2019  this  had  increased  to  44  ports.40.Out  of  the  44  EU  ports,  22  are  ports  on  TEN-T 
Core Network and 11 are ports on the TEN-T Comprehensive Network out of a total of 
186 Core ports (104 maritime and 82 inland) and 394 comprehensive ports (225 maritime 
and  169  inland).  In  total,  there  were  over  189  berths  with  SSE  in  these  EU  ports  with 
voltage ranging from 0.4 to 11 kV and power ranging from 0.015 to 10 MW.  

In  terms  of  vessels  powered  by  electricity,  EAFO  includes  only  data  on  the  global 
seagoing fleet for 2020 with no corresponding data for inland shipping. As of May 2020, 
there  are  101  seagoing  vessels  using  SSE,  of  which  53  (52%)  are  pure  electric  and  48 
(48%) are plug-in hybrid ships. There are a further 125 hybrid vessels that do not require 
electric infrastructure in ports.  

According  to  report  on  the  State  of  Alternative  Fuels  transport  systems,  there  are  166 
battery-powered vessels in operation, of which 56% are passenger ferries41. Furthermore, 
less than 0.5% of inland waterway vessels are hybrid or electric. Interviews with ECSA 
and ESPO stated that OPS is available in only a limited number of ports.  

38 This number includes recharging points above 100kW in Europe (including Norway, Switzerland and UK) and excludes the Tesla 
Supercharger network.  
39 For  example, Netherlands has only  a small share of fast charging infrastructure (2.1%) in comparison to a much higher share in 
Germany (15.1%). Other countries with high levels of EV infrastructure include Belgium, Sweden, Austria and Denmark with around 
500 charging points per million population 
40 European Commission, State of the Art on Alternative Fuels Transport Systems in the European Union – 2020 Update (2020). 
41 https://op.europa.eu/en/publication-detail/-/publication/fd62065c-7a0b-11ea-b75f-01aa75ed71a1  

14 

 
                                                 
Electricity supply in airports 

An ACI EUROPE survey  in 2018 based on the replies  of 51 airports, found that 42 of 
them  (82%)  provide  Fixed  Electrical  Ground  Power  to  aircraft  on-stand.42  In  the  same 
survey, 86% of respondents reported that their vehicle fleet included electric vehicles and 
47% included hybrid models. Furthermore, an interview with ACI noted that there are an 
increasing  number  of  airports  offering  fixed-electrical  ground  power.  However,  it  does 
not work for all types of operation, particularly low-cost airlines with short turn-around 
times.  

3.3.2  Natural Gas 

In comparison to the electric charging infrastructure, the increase in the level of natural 
gas (CNG/LNG) infrastructure has been more moderate, but this also reflects the fact that 
the natural gas infrastructure is much more centralised and with much higher throughput 
per station. It also reflects the moderate increase in CNG vehicle fleet that only increased 
by around 20% between 2014 and 2019 while the number of LNG vehicles remained low 
in  2019  with  only  4,540  registered  vehicles.  In  the  case  of  CNG,  a  network  of  around 
3,000  stations  was  already  in  place  in  2015  (mainly  in  Italy  and  in  Germany).  This 
increased by 20% (ca 3,500 stations), largely in line with the increase in the number of 
vehicles. The increase in the share of LNG stations was much greater (3.8 times) albeit 
from a much lower starting point.  

CNG  

In terms of its distribution, the CNG network is concentrated in a few MS. The greatest 
share of filling stations are located in Italy (1,391 in 2019) both in absolute and relative 
terms,  representing  close  to  40%  of  the  total  filling  stations  in  the  EU.  Other  countries 
with  high  number  of  CNG  infrastructure  are  DE  (854),  SE  (192)  and  CZ  (207). 
Accounting for population, AT and BG also display a high number of refilling stations. 
Since  2015,  most  investment  in  CNG  filling  station  has  taken  place  in  Italy  (217  new 
stations),  followed  by  the  CZ  (99)  and  BE  (87).  Conversely,  some  Member  have  been 
reducing the number of CNG refuelling points, namely, AT, DE, PL, and LU.  

In terms of vehicles, Italy represents almost 80% of all CNG vehicles in Europe, with a 
ratio of 822 vehicles per refilling station. Other MS with a high ratio are Poland (309), 
Sweden  (295)  and  Finland  (213).  Italy  has  also  had  the  greatest  increase  in  number  of 
vehicles  since  2015  (103,106),  followed  by  Belgium  (16,543)  and  Czech  Republic 
(11,747).  

LNG  

LNG for road transport 

At  the  end  of  2019,  LNG  fuelling  infrastructure  was  available  in  15  Member  States 
according to the EAFO. Italy had the greatest number of refuelling stations (59) followed 
by Spain (49). However, in terms of per-capita of population, Finland, Netherlands and 
Sweden have the highest number of infrastructure. Since 2015, the number of refuelling 
points  at  the  Union  level  has  increased  almost  fourfold,  with  a  significant  increase  in 
infrastructure in Italy (47 new stations), Spain (49) and France (32).  

42 https://ec.europa.eu/transport/sites/transport/files/2019-aviation-environmental-report.pdf  

15 

 
                                                 
Heavy-duty  vehicles  make  up  99%  of  LNG  vehicles  in  the  EU.  Italy  had  the  greatest 
number  of  vehicles  (1,907)  followed  by  Spain  (1,462),  although  Netherlands  had  the 
greatest number per million population (33.3).  

LNG for water transport  

In relation  to  water transport, in  2018 there  were 16 maritime ports in  Europe that had 
LNG  refuelling  points  in  operation.43  Most  of  them  were  located  in  Belgium,  Spain, 
France, Lithuania, Netherlands, Portugal and UK. At the beginning of 2019, there were 
85  large-scale  operational  LNG  tanks  installed  in  35  ports  in  EU,  mainly  in  Spain  (29 
tanks in 9 ports) and Italy (8 tanks in 3 ports). Furthermore, according to the EAFO, there 
were  50  LNG  powered  seagoing  vessels  in  Europe  (excluding  Norway)  at  the  end  of 
2019, which will increase to 67 in 2020 according to forecasts. There are still a number 
of  LNG  ships  on  order  and  it  is  estimated  that  the  total  fleet  will  increase  to 
approximately 92 ships . 

Concerning  inland  navigation,  there  is  no  specific  data  available.  However,  in  2018,  it 
was  considered  to  be  sufficient  LNG  bunkering  to  meet  the  demand  for  the  very  low 
number of  LNG vessels in  use.44  There are 14  LNG inland vessels operating in  Europe 
today, of which 9 are tanker vessels, and a further 12 on order (European Commission, 
2020).  

3.3.3  Hydrogen 

Hydrogen for road transport 

At EU level, the number of hydrogen filling stations in operation across the EU in 2019 
was still very small (127), up from 35 in 2016 and 39 in 2018. The number FCEVs has 
also increased during the same period, but the total number of vehicles is still very small 
(around 1,200 at the end of 2019).  

Moreover,  hydrogen  refuelling  infrastructure  is  highly  concentrated.  More  than  half  of 
the  stations  in  2019  (60%)  were  located  in  Germany  (76),  followed  by  France  (14).  In 
relative terms, Denmark has the most refuelling stations (1.7 per million population). In 
total,  only 10 MS had at least  one filling station  in  operation  at  the end of 2019. Most 
common types of hydrogen refuelling stations are the high pressure (700 bar) stations for 
road vehicles (108  according to  EAFO). At EU level,  the number of refuelling stations 
remained fairly constant until 2019 where there was threefold increase, with over 70% of 
new refuelling stations deployed in Germany.   

11 Member States had registered hydrogen vehicles in 2019, compared to 7 MS in 2015. 
At the end of 2019, France had the greatest number of hydrogen vehicles (413) followed 
by  Germany  (266).  Adjusting  for  population,  Denmark  and  Netherlands  have  the  most 
hydrogen vehicles with 18.1 and 13.6 vehicles per million population, respectively.  

Hydrogen for waterborne transport 

In  recent  years,  there  has  been  early  adoption  of  hydrogen  for  waterborne  transport, 
although the number of vessels powered by hydrogen is still extremely low. For maritime 
transport,  there  are  three  hydrogen  vessels  in  operation  and  on  order.  Larger-scale 
demonstration projects are in preparation. In addition, the Commission funded a retrofit 

43 https://op.europa.eu/en/publication-detail/-/publication/fd62065c-7a0b-11ea-b75f-01aa75ed71a1  
44 https://op.europa.eu/en/publication-detail/-/publication/fd62065c-7a0b-11ea-b75f-01aa75ed71a1 

16 

 
                                                 
of  an  inland  freight  vessel,  which  features  a  diesel-electric  powertrain  and  can  be 
powered by hydrogen. In terms of infrastructure, there is no data to report on.  

3.3.4  Other fuels 

LPG 

In terms of infrastructure and vehicles, LPG was established as a fuel for road transport 
before the adoption of the AFID. There was a total of 8 million LPG vehicles in 2019, up 
from  7.3  in  2014  and  the  number  of  filling  stations  also  increased  along  similar  lines. 
However, year on year increase of LPG vehicles has decreased, with the number of new 
registrations  of  LPG  vehicles  representing  only  0.9%  in  2020  of  total  vehicle 
registrations, down from 3.5% in 2014. 

At  national  level,  LPG  refuelling  stations  are  present  in  all  MS  but  Finland.  Poland, 
Germany,  Italy,  Bulgaria  and  France  are  the  countries  with  higher  number  of  LPG 
fuelling  stations  and  Bulgaria  has  the  highest  number  when  adjusting  for  population. 
However,  while  the  overall  number  of  refuelling  points  has  increased  in  the  EU  from 
2015  to  2019,  several  MS  that  have  reduced  the  number  of  refuelling  points  in  this 
period, including Bulgaria, Romania, Czech Republic and the Netherlands.  

In terms of vehicles, at the end of 2019, Poland and Italy had the greatest  LPG vehicle 
stock, accounting  for almost 70% of all  LPG vehicles in  the EU. Since  2015,  Italy  has 
seen  the  greatest  increase  in  the  number  of  vehicles,  while  Poland’s  LPG  fleet  has 
reduced.  Romania,  Spain  and  Greece  have  also  seen  a  large  increase  in  the  vehicle 
number during this period but in almost half of the MS there has been a reduction to the 
LPG vehicle fleet. 

Biofuels 

Data on the use of biofuels in transport are sparse and infrequently reported. Low blend 
bioethanol  (e.g.  E5,  E10)  is  supported  by  traditional  refuelling  infrastructure,  thus  is 
widely  available  across  the  EU.  However,  high  bioethanol  blends  (e.g.  E85,  E100) 
require  adaptations  to  refuelling  infrastructure,  which  has  led  to  a  more  fragmented 
market, with some countries (e.g. Sweden) showing a clear preference for their use.  

Of  the  high  blend  bio-gasolines,  E85  is  the  most  prominent  and  is  available  in  8  MS, 
according  to  EAFO.  Sweden  has  the  greatest  number  of  E85  refilling  stations  (1,700), 
followed by France (1,000) and Hungary (403). There is an emerging market for ED95 in 
Finland,  France  and  Sweden,  although  no  specific  data  on  the  number  of  equipped 
refuelling  points  is  available.  In  terms  of  biodiesel,  there  are  9  refuelling  stations 
available for rapeseed methyl ester.45 

45 https://op.europa.eu/en/publication-detail/-/publication/fd62065c-7a0b-11ea-b75f-01aa75ed71a1 

17 

 
 
 
                                                 
4.  METHODS AND IDENTIFIED LIMITATIONS 

4.1 Methods 

The  evaluation  uses  different  tools,  developed  in  line  with  the  evaluation  methodology 
matrix. The evaluation support matrix was elaborated throughout the evaluation support 
study  in  order  to  answer  the  evaluation  questions.46  It  identifies  relevant  operational 
questions,  indicators,  research  tools  and  data  sources  and  the  approach  to  answer  the 
questions. The evaluation matrix is included in the evaluation support study.  

4.1.1  Desk research 

An extensive literature review was carried out and a full list is provided in the evaluation 
support study. Key sources of data used for the analysis included Member State’s NPFs 
and NIRs and EAFO. Other sources were selected on the basis of keyword searches, as 
well as taking on board suggestions from stakeholders. 

4.1.2  Modelling  

The  PRIMES-TREMOVE  model  was  used  to  help  quantify  the  baseline  no-policy 
change  scenario  as  well  as  the  alternative  scenario.  The  alternative  scenario  includes 
policy  changes  triggered  by  the  Directive.  Comparing  the  baseline  with  the  alternative 
scenario helps in the answering of evaluation questions. Annex 3 provides an overview 
of  the  development  of  the  baseline  scenarios,  the  alternative  scenario  as  well  as  the 
results. The model provides the quantitative analysis for the transport sector in the EU27, 
covering transport activity, equipment, energy and emissions. 

4.1.3  Stakeholder interviews 

Interviews were conducted with a range of relevant stakeholders representing EU bodies, 
national  and  local  authorities,  industry  representatives,  members  of  the  civil  society 
(NGOs, consumer groups) and experts. The targeted interviews focus on cross-checking 
or  complementing  the  information  collected  via  desk  research  and  collecting  evidence 
and  opinions  in  relation  to  the  various  evaluation  questions.  Further  information  is 
included in Annex 2.  

4.1.4  Survey 

Two surveys were distributed aimed at national authorities and regional, local and/or city 
authorities  in  EU  Member  States.  The  surveys  focused  on  cross-checking  or 
complementing the information collected via desk research and collecting evidence and 
opinions  in  relation  to  the  various  evaluation  questions  (see  annex  2  for  further 
information). The list of respondents to the survey is included in the evaluation support 
study. 

4.1.5  Open Public Consultation 

The OPC went  live 6th April 2020 and closed on 29th June 2020 (12 weeks). The OPC 
takes account of both the evaluation and the Impact Assessment for the amendment to the 
Directive. In total, 324 responses were received.  

46 The external evaluation support study can be found at : add link once published 

18 

 
                                                 
4.1.6  Data requests 

Targeted  data  requests  were  sent  to  associations  and  representatives  of  people  with 
disabilities. These requests were in the form of additional questions focusing on how the 
Directive  takes  into  account  the  needs  of  people  with  disabilities  (contributing  to  the 
Relevance questions). Four responses were received. Further data requests were sent  to 
Member  States  responding  to  the  survey  to  gain  additional  information  on  the  specific 
budget  allocated  for  the  implementation  of  the  adopted  measures  in  terms  of  public 
funding / investment and excluding private investment (see annex 2 for information).  

4.2 Identified limitations and action to remedy 

4.2.1  Stakeholder consultation 

There were a few challenges identified in the context of the evaluation support study and 
limitations inherent to the methodology: 

The stakeholder engagement task aimed at involving all affected stakeholders. A variety 
of tools were used to collect the evidence needed for the evaluation, including an Open 
Public Consultation, interviews, survey and targeted data requests. 

There were however a few limitations in the capacity to obtain relevant input. The wide 
scope of the Directive  (in terms  of transport modes and types of technologies  covered) 
meant that it was not possible to organise interviews with multiple stakeholder from the 
various groups. Furthermore, it was not always possible to have input from national and 
regional authorities in multiple Member States. As such, for some questions the analysis 
is based on a small number of respondents that may introduce bias either because of their 
interest  or  because  they  may  have  an  incomplete  picture  of  relevant  issues  and 
developments.  Additional  targeted  desk  research  was  used  to  try  to  mitigate  these 
limitations. Besides, stakeholder engagement activities were tailored in a way that aimed 
to minimise the time requirements for individuals, to avoid consultation fatigue.  

4.2.2  Member State reporting 

NIRs  were  a  key  input  to  this  evaluation.  However,  the  level  of  detail  provided  in  the 
NIRs varies significantly among Member States both in terms of the measures adopted as 
well as to the financial allocations along different types of measures. Furthermore, as the 
focus  was  on  reporting  on  the  progress  in  relation  to  the  targets,  there  was  less 
information  on  the  progress  in  terms  of  other  aspects  (interoperability,  access  to 
information). While the information was sufficient to establish an overall picture on the 
implementation  and  progress  made,  it  was  not  fully  useful  when  it  came  to  assessing 
other aspects of the implementation of the Directive. To fill the data gaps, input from the 
national authorities (survey and data requests) along with desk research were used.  

4.2.3  Assessing the role and additionally of the Directive 

Besides the Directive and the national actions, multiple other factors drive the uptake of 
alternative fuels infrastructure including other policy developments as well as market and 
technological  developments.  The  use  of  the  well-tested  PRIMES-TREMOVE  model  to 
define a baseline and alternative scenario helped to control some of these parameters. It 
allowed developing an assessment of the main impacts associated with the Directive.  

Furthermore, during the course of the evaluation support study, various elements of the 
model  (e.g.  AFI  cost  assumptions)  were  refined  to  better  reflect  available  information 
and  recent  developments.  Nonetheless,  the  model  does  only  allow  assessing  certain 

19 

 
aspects (mainly focusing on the adoption of AFVs, the impact on the transport sector and 
to  ensuring 
the  associated  environment 
interoperability,  access  to  information)  were  not  covered.  In  this  case,  input  from 
multiple stakeholder groups was used to get a balanced information base.  

impacts).  Other  aspects  (e.g.  related 

20 

 
 
5.  ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS 

5.1 Assessment of the effectiveness of the Directive 

5.1.1 Effectiveness in achieving the general objectives of the Directive 

This  section  summarizes  to  what  extend  the  Directive  has  been  successful  in  (a) 
establishing  a  common  framework  of  measures  for  the  deployment  of  alternative  fuels 
infrastructure,  (b)  minimising  the  import  dependency  on  oil,  and  (c)  mitigating  the 
environmental impact of transport.  

The  analysis  of  both  the  NPF  and  the  NIR  suggest  that  the  Directive  has  only  partly 
succeeded in developing a clear and consistent policy framework for the promotion of 
alternative fuels infrastructure across the EU. They are not coherent at EU level.  NPFs 
prioritise  different  alternative  fuels  and  include  different  ambition  levels,  yielding  an 
uneven spread of infrastructure. 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%.  

Few  NPFs  define  corresponding  targets  for  infrastructure  or  stated  their  deployment 
status.  Often,  the  support  measures  seem  not  to  be  fully  adequate  to  ensure  that  the 
national targets and objectives of the NPFs would be reached. In most cases the measures 
were  not  fully  implemented  or  were  not  considered  to  be  comprehensive  (scope  and 
expected effect)  and quite often there was not  enough information on the state of play. 
The majority of Member States identified measures in relation to electro-mobility and in 
terms  of  promoting  alternative  fuels  infrastructure  in  public  transport.  Few  Member 
States have addressed other types of alternative fuels infrastructure.  

Consequently, the measures adopted/proposed and the targets set could lead to a market 
fragmentation at EU level and even among neighbouring Member States. The analysis of 
the  NIRs  shows  that  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.47 

To  summarize,  Member  States  took  action  to  identify  targets  and  measures  due  to 
the  Directive.  However,  those  actions  do  not  sum  up  to  a  comprehensive  common 
framework of measures across the EU. However, the implementation of the measures 
adopted  under  the  AFID  enabled  the  uptake  of  alternative  fuels  vehicles.  The  CO2 
standards are the main driving force for vehicle demand, but deployment of infrastructure 
is supportive to this uptake. This impact of AFID would become more pronounced as the 
penetration  of  AFVs  increases  and  more  users  become  reliant  on  public  accessible 
alternative  fuels  infrastructure  rather  than  what  is  deployed  privately  by  the  early 
adopters. 

47 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. 

21 

 
 
                                                 
The evaluation finds a relative increase in the number of alternative fuels vehicles in the 
period  since  the  adoption  of  the  Directive  (2014)  with  a  net  increase  of  3.6  percentage 
points  in  comparison  to  the  baseline.  Nonetheless,  the  overall  share  of  those  vehicles 
remains limited (less than 7% of the fleet in 2019, more than half of which include LPG 
vehicles). The alternative fuels  vehicles market  is  still in its early stages. Similarly, the 
number of alternative fuels infrastructure has also increased in relative terms since 2014, 
though the number of AFI remains small in absolute numbers.  

The early stages in the development of the market make an assessment of the impact on 
the operation of the market difficult. High barriers to entry are mainly associated with the 
costs of upfront investment with high uncertainty as to the capacity to get a high returns, 
most evident in  larger,  more expensive AFI such as hydrogen.  There is  no evidence of 
dominant  positions  among  the  players  active  in  the  market.  There  are  currently  no 
dominant  EU-wide  players,  with  most  providers  focusing  on  one  or  a  few  national 
markets.   
The assessment on the impact of minimising oil import dependency in transport sector 
is difficult. The transport sector has maintained a high share of the total consumption of 
oil products in Europe (close to 66% of total in 2018)48 and has a high oil dependency49 
(93 % in 2018). At EU level, 87% of these oil products came from imports outside the 
EU (2018 data), although this varied among EU Member States50.  

It can be safely assumed that oil importing countries will reduce their overall oil imports 
under  the  alternative  scenario  compared  to  the  baseline  scenario.  However,  a 
quantification of the impacts has not been possible since it requires an in-depth analysis 
of  the  implications  at  Member  State  level  and  assumptions  on  what  the  approach  they 
may follow in the case of lower petroleum product energy needs (e.g. in terms of shifts to 
alternatives). Nonetheless, a reduction on the level of imports is expected. 

Concerning  the  mitigation  of  environmental  impacts,  there  has  been  very  limited 
change  in  terms  of  the  level  of  Tank-to-Wheel  (TTW)  CO2  emission  up  to  2019,  in 
comparison to the baseline. The analysis also pointed to a very small contribution to the 
reduction  of  CO2  emissions  in  transport  (net  decrease  by  0.2%  by  2019),  the 
consumption of oil products in transport (net decrease of 0.2% by 2019) and the share of 
energy from renewable sources (net increase by 0.1% by 2019). Similarly, there has been 
a small positive impact  on the level  of pollutant emissions by 2019 (0.2% reduction of 
CO,  0.3%  reduction  of NOx  and  0.5%  reduction  of  PM).  Savings  in  the  road  transport 
sector are largely due to other policies, such as the post-2020 CO2 emission standards for 
cars and vans. 

The  analysis  points  to  an  expected  positive  and  more  sizeable  contribution  of  the 
implementation of the Directive in terms of the uptake of vehicle and the development of 
infrastructure post 2020.   

5.1.2  Effectiveness in achieving the specific objectives of the Directive 

This section summarizes to what extend the Directive has been successful in (a) ensuring 
sufficient  rollout  of  alternative  fuels  infrastructure  (b)  ensure  full  interoperability,  (c) 
support  adequate  consumer  information  and  d)  efficient  integration  of  electric  vehicles 

48 According to Eurostat, the transport sector represented 47.5% of total oil consumption in 2018, aviation 9% and shipping 9%.  
49 Figure includes international maritime.  
50 Eurostat 

22 

 
                                                 
and  compliance  with  electricity  market  operations.  The  Directive  has  addressed  its 
specific objectives to some extent.  

A considerable increase in the deployment of alternative fuels infrastructure since 2015 
can  be  detected,  driven  mainly  by  recharging  infrastructure,  but  it  is  not  considered 
sufficient  in  view  of  the  need  of  a  dense,  widely  spread  network  of  alternative  fuels 
infrastructure.  The  number  of  publicly  accessible  charging  points  currently  exceeds  the 
recommendation in the Directive of 10 vehicles per public accessible charging point. For 
hydrogen infrastructure,  the relative level  of development  of the network  has  also  been 
significant, albeit at very low level. For natural gas infrastructure, there is already quite 
some network maturity, which explains a low development trend.  

The increased number of recharging points hides significant differences across Member 
States.  There  are  clear  frontrunners  (mainly  in  Western  Europe),  while  other  markets 
(mainly  in  Central,  Eastern  and  South  Europe)  are  lagging  behind.  14  Member  States 
have either exceeded or have been close to their targets (>75%), eight were below 50% 
of their 2020 targets51.  

The  Directive  had  a  considerable  impact  on  interoperability  of  alternative  fuels 
infrastructure. The Directive has ensured standardisation of recharging plugs early on in 
the development of the market and has avoided the situation of multiple standards being 
used  by  players  in  different  markets  for  a  long  period.  Through  delegated  acts  it  has 
helped  to  address  outstanding  standardisation  needs  in  the  field  of  recharging  and 
refuelling infrastructure  in  road and waterborne transport. Technical  specifications (e.g. 
plugs) provided greater certainty to investors, backed by available public support at EU 
and national levels.  

There are shortcomings to the current list of technical specifications requirements under 
the  Directive.  Standardisation  of  communication  protocols  and  of  payment  systems  are 
not under the scope of the current Directive. Ad-hoc payments are often restricted by the 
need to use specific web apps or RFID cards. However, most stakeholders expects that 
functionality  of  roaming  platforms  and  peer-to-peer  network  access  agreements  will 
vastly  improve  and  reduce  the  need  for  multiple  contracts  and  make  simple  contract 
based  charging  solutions  more  common,  while  improving  ad-hoc  payment  remains 
relevant.  

In terms of consumer information, there are still limitation in terms of the availability 
of  information  on  the  location  of  AFI  infrastructure,  despite  the  increasing  coverage 
provided  by  a  number  of  online  platforms  and  apps.  Information  on  pricing  and  price 
comparison  are  even  less  developed,  albeit  with  differences  among  Member  States. 
However, action by some Member States in the context of the AFID (and on the basis of 
EU  funded  Programme  Support  Actions)  should  further  contribute  towards  better 
availability and quality of information. There was limited input on the role of the already 
adopted  standards  of  fuel  labelling  at  pumps  and  nozzles.  The  gas  industry 
representatives  and  the  users  representative  provided  a  positive  assessment,  considered 
that  the  relevant  standards  have  already  played  a  positive  role  although  also  indicating 
that these have not been applied across all Member States.  

When  it  comes  to  the  integration  of  electro-mobility  to  the  electricity  system,  the 
evaluation  identifies  a  mixed  picture.  Public  authorities  largely  considered  that 

51 COM (2021)103 final 

23 

 
                                                 
consumers  can  choose  a  different  supplier  for  electric  vehicle  charging  than  for  their 
general electricity supply and that DSOs cooperate with any charge point operator on a 
non-discriminatory  basis,  but  other  stakeholders  questioned  this  assessment.  However, 
there  was  large  consensus  that  smart  charging  infrastructure  deployment  is  much  less 
advanced. However, the implementation of the Electricity Market Design Directive (EU) 
2019/944 can lead to a greater impact; the role of AFID in this area is limited, as public 
accessible recharging infrastructure is not really used for smart recharging services.   

5.1.3  Which  external  factors  and  developments  have  contributed  or  hindered  to 
the achievement of the objectives? 

In terms of the role of the alternative fuels vehicle uptake the supply of infrastructure has 
been in most cases higher than the level of demand and was mainly driven by the public 
sector financial support in the initial phase. However, this is changing with increases in 
the sales of vehicles being primarily driven by the new CO2 standards for cars and vans: 
they create demand for further infrastructure investment particularly for charging points; 
but  policy  responses  to  alternative  fuels  infrastructure  long-term  planning  depend 
strongly on the willingness of Member States to take action, as the assessment of the NIR 
shows. In the case of other types of infrastructure, the level of development of the market 
and  the  number  of  vehicles  and  vessels  is  still  either  at  low  initial  levels  (hydrogen, 
electricity  for  ship  propulsion)  where  the  viability  of  the  relevant  infrastructure  on  a 
purely  commercial  basis  is  still  questionable  or  there  is  no  real  policy  impulse.  For 
example, the CO2 emission standards for cars and vans, focusing on tailpipe emissions, 
do not set strong incentives for the uptake of gas vehicles (e.g. CNG). 

The  impact  of  the  implementation  of  the  Clean  Vehicles  Directive  (2009/33/EC)  on 
infrastructure  provisioning  has  been  very  limited.  This  was  due  to  the  important 
limitation  of that  Directive:  it  has  not  made  any  significant  contribution  to  the  demand 
for clean vehicles and, as a consequence, to deployment of related infrastructure, leading 
to  its  revision  in  2019.  The  revised  Directive  (2019/1161)  sets  binding  minimum 
requirements  for  the  procurement  of  clean  vehicles  and  is  expected  to  have  a  positive 
effect  by  ensuring  demand  for  clean  vehicles,  though  mainly  in  the  segment  of  buses. 
The  Directive  will  hence  trigger  particularly  demand  for  the  development  of  the  bus 
recharging and refuelling infrastructure in bus depos/stations.  

The  Energy  Performance  of  Buildings  Directive  (EPBD)  (2018/844)  complements  the 
AFID by promoting the deployment of private charging points, but it was just revised in 
2018.  Private  charging  represents  more  than  90%  of  charging.  It  will  maintain  a  very 
high share in the future. The current provisions of the EPBD focus primarily on certain 
new and renovated buildings (residential and non-residential) that represent a small share 
of the stock and introduce additional exemptions. While it is still too early for a proper 
assessment of its contribution, many stakeholders raised doubts as to how much should 
be expected from the implementation of that Directive. 

5.1.4.  Effectiveness of monitoring of impacts 

Reporting  requirements  have  generally  had  a  positive  role  in  creating  a  common 
framework for the presentation of the relevant information on both the development on 
the  supply  and  demand  of  infrastructure  and  the  relevant  measures  taken  by  Member 
States.  AFID  represents  an  important  improvement  in  comparison  to  a  situation  where 
information  would  only  be  available  through  market  reports  or  individual  initiatives  of 
Member  States  without  a  common  reference  framework.  An  important  part  of  the 
information  on  market  development  is  also  included  in  the  EAFO  portal  that  includes 

24 

 
detailed data on the development of infrastructure per Member State. As such, this is an 
area  where  the  MS  reporting  is  probably  of  less  added  value.  Shortcomings  apply  to 
reporting on measures, national policies and future targets at national level.  

While the most recently submitted NIRs are more consistent with the template provided 
by  the  Commission,  there  are  still  important  gaps  among  MS  in  terms  of  the  level  of 
information provided with only a subset of NIRs submitted being in full compliance with 
the guidance on information requirements. The shortcomings in the overall reporting and 
the  quality  of  underpinning  data  has  aggravated  the  common  assessment  of  national 
implementation reports.  

The frequency of reporting (every three years) and the support provided was considered 
by  most  stakeholders  as  generally  adequate.  Only  a  few  Member  States  reported  some 
problems, none of which appearing to be of particular concern.  

5.1.5 

 Effectiveness of the overall focus of the Directive 

The analysis suggests that the focus of the Directive on the urban agglomerations and the 
core network was in line with the need to cover larger part of the population with greater 
level of (potential) demand. At least in the case of electromobility, many Member States 
adopt  such  prioritisation  in  their  NPFs  and  the  national  policies,  and,  explicitly  or 
implicitly, targeted their efforts in urban areas and the core TEN-T network. This appears 
to be particularly the case for the less advanced MS that are still in the initial stages in the 
development.  

At the same time, most stakeholders suggest that an approach without AFID and building 
solely on market deployment would have led to an even higher level of concentration in 
the  larger  agglomerations  and  part  of  the  core  network.  AFID  –  through  the  respective 
national  support  measures  –  has  played  a  role  in  ensuring  a  more  widespread 
development of the network. As such, it possibly contributed to a broader geographical 
scope that would have been the case in the absence of any intervention.  

At the same time, there are still important gaps across the network with secondary parts 
of the network and rural areas much less covered, particularly in  some Member States. 
An important number of stakeholders link this to the prioritisation of the AFID and the 
focus of the associated financial instruments used (particularly CEF).  

In relation to waterborne transport, the prescribed focus on TEN-T core network for the 
development of LNG infrastructure has a limited impact. Member States appear to have 
adopted different approaches, some focusing exclusively on the TEN-T core ports, other 
including ports in the comprehensive network in their future targets for 2025 and  2030. 
But the very early stage of market development does not allow for a real gap analysis, as 
there is little action anyhow. 

5.1.6  Unintended positive and negative effects 

The  evaluation  support  study  did  not  point  out  important  unintended  or  unexpected 
effects.  It  did  identify  some  second  order  economic,  social  and  environmental  effects, 
most of which are positive.  

More specifically, it pointed to positive economic impacts from the development of new 
services  associated  with  the  provision  of  infrastructure-related  services  across  Member 
States.  Linked to  that is  the associated new job  creation in  both  the manufacturing  and 
services sectors. From the environmental perspective, stakeholders pointed to a potential 

25 

 
contribution  to  noise  reduction  from  the  gradually  increasing  use  of  electric  vehicles 
primarily in urban areas. However, a measurable impact can only be expected only after 
2030  when  the  share  of  BEVs  increases  significantly  and  is  mainly  due  to  the  CO2 
standards  for  cars  and  vans.  Finally,  from  the  spatial  perspective,  public  authorities 
pointed  to  the  challenges  that  arise  from  the  need  to  ensure  an  effective  integration  of 
network development.  Specifically in  relation  to  electro-mobility,  authorities pointed to 
the  practical  implications  from  the  increasing  designation  of  charging  spaces  for  the 
overall  availability  of  parking  space,  with  different  approaches  adopted  across  MS  to 
address them. This area is, however, not under the competence of the Directive.  

5.2 

Assessment of the efficiency of the Directive  

5.2.1  Proportionality of cost  

The  evaluation  support  study  finds  that  cost  have  largely  been  proportionate  to  the 
benefits.  

The analysis of the cost  of implementation of the AFID has shown that the majority of 
cost  incurred  by  Member  States  are  related  to  the  implementation  of  the  support 
measures  within  the  AFID.  These  included  administrative  support  and  policy  support 
measures, as well R&D support measures. According to the information from 23 NIRs a 
total  of €8.3 billion (including €1.6 billion from  the UK) was allocated by  MSs during 
the period 2016-2019).     

Taking  into  account  variations  in  terms  of  country  size,  budget  allocations  among 
Member States still varied greatly reflecting the level of ambition and support provided 
and  ranging  from  only  €3  million  to  close  to  €2.7  billion.  On  a  per  billion  GDP  basis 
there was also significant variation ranging from €0.44 million per billion of GDP to as 
low as 0.04. In terms of the distribution of costs by type of measure, the largest share was 
in relation to the implementation of various policy support measures (on average 62% of 
the  total  budget),  followed  by  support  for  research,  technological  development  and 
demonstration  (23%  of  allocated  budget),  and  deployment  and  manufacturing  support 
(15% of the budget).  

In terms of the allocation by fuel type, support for electromobility represented the largest 
focus area of allocated national budgets (69% of the total budget; €5.7 billion) reflecting 
the  fast  development  of  AFI  in  this  area.  Support  for  hydrogen  for  road  transport 
represented  the  second  largest  share  (19%;  €1.6  billion)  while  support  for  natural  gas 
infrastructure (CNG/LNG) was 9% of the total (€697 million). The amount allocated to 
waterborne  transport  was  much  more  limited  (€169  million  to  LNG  for  maritime;  and 
€106million to LNG for IWT; 3% of the total). 

Other  cost  elements,  such  as  cooperation  with  other  Member  States  on  cross-border 
measures and at an EU-level for knowledge exchange, are not as significant.  

Total costs for the NPFs across all Member States were estimated at around €5.3 million 
with a weighted average cost per MS of €196,000. However, this ranged greatly with one 
MS  reporting  €1.1  million  while  others  pointing  to  no  costs  (presumably  not  including 
the  human  resources  allocated  to  the  development  of  the  NPFs).  The  costs  for  the 
development of the NIRs were estimated at €3.4 million with a weighted average cost of 
€126,000. It ranged from €671,000 to no costs as reported by five authorities. 

The PRIMES-TREMOVE model was used to determine whether the benefits achieved by 
the  implementation  of  the  AFID  are  proportionate  to  the  costs.  In  terms  of  the  cost-

26 

 
effectiveness  of  the  intervention,  the  analysis  of  the  net  infrastructure  investment  costs 
(public and private) versus the costs to the transport system (including the external costs 
of CO2 emissions) suggests that over the whole period 2021-2050 analysed there is net 
decrease  in  the  costs  of  €27  billion.  This  is  mainly  a  result  of  the  important  net  cost 
reduction towards the end of the period (2041-2050) where most of the benefits from the 
significant increase in the share of electric vehicles would arise.  

The total level of investment in alternative fuels infrastructure to-date is shown to differ 
between  fuel  types  and  modes of transport, with  road attracting higher investment  than 
waterborne  and  recharging  infrastructure  attracting  higher  investment  than  refuelling 
infrastructure. A comprehensive quantitative analysis  of the extent of the private sector 
share  of  AFI  investment  was  not  carried  out,  due  to  a  lack  of  available  data  and 
information.  The  data  has  not  been  collected  in  a  centralised  way,  which  prevents  a 
quantitative analysis at EU-level and at Member State level. 

National authorities pointed to a moderate role of the AFID in terms of increasing private 
sector  investment  in  AFI:  responses  indicate  that  the  private  sector  would  also  have 
invested in AFI in the absence of the AFID. There appears to be a higher level of private 
sector  share  of  investment  for  countries  with  a  higher  GDP  or  with  a  more  developed 
infrastructure  network.  According  to  national  authorities,  private  investments  in  other 
fuel types such as hydrogen, electricity for inland waterways transport and electricity for 
stationary  airplanes  at  airports  has  stayed  roughly  the  same,  at  low  level,  over  the  last 
three years.  

Feedback from industry  stakeholders, promotional  banks and responses to surveys note 
that  recharging  infrastructure  is  taking  priority  in  terms  of  private  sector  investments  – 
this is due to the fact that it is the market with the highest vehicle demand. 

5.2.2  Could the same or better results have been achieved at lower costs for public 
authorities by a different approach? 

The limited data did not allow the evaluation to reach specific conclusions as to whether 
the  results  could  have  been  achieved  in  a  more  cost-effective  way.  The  input  from 
stakeholders suggests that there are no areas of significant inefficiencies. Most national 
authorities  and  industry  stakeholders  were  very  supportive  of  the  role  public  financing 
has played to-date. This is both, in terms of AFI rollout and in establishing the network 
on a commercial basis.  

There are clear differences in the cost-effectiveness of the deployment of alternative fuels 
infrastructure when considering the NIR budget allocations in comparison to the numbers 
of  infrastructure  deployed  –  these  differences  are  evident  between  Member  States  and 
between  fuel  types.  Deployment  of  electromobility  infrastructure  represents  the  most 
cost-efficient  across  Member  States,  likely  due  to  the  more  mature  market  for  electro-
mobility and lower costs for the infrastructure. Contrastingly, the rollout of hydrogen was 
regarded to be the least cost-efficient, likely due to the relative immaturity of the market.  

Many stakeholders noted that a more coordinated approach to setting targets (i.e. at EU 
level) could have led to  lower levels of fragmentation amongst Member States, thereby 
leading  to  increased  investment  in  infrastructure  and  potentially  lower  costs  to  public 
authorities by improving the efficiency of the rollout. This evidence is however based on 
individual  assessments.  There  are  cost-effective  measures  used  at  Member  State  to 
support the deployment of the AFI network, which could lead to lower costs for public 

27 

 
authorities  when  used  at  EU  level;  however,  there  is  no  unified  consensus  among 
stakeholders.  

5.2.3  Is there potential for simplification of the provisions? 

The  analysis  indicates  that  there  is  little  simplification  potential,  and  there  is  a  strong 
majority of stakeholders pointing out that the Directive does not lead to unnecessary cost 
for target groups. Focusing on specific aspects, the analysis concludes that there is little 
need for simplification of the provisions and requirements of the Directive in terms of the 
development  of  the  NPFs  and  relevant  measures  (Articles  4-6),  the  national  reporting 
requirements (Article 10), and other articles. 

One  potential  area  for  further  improvement  is  related  to  the  requirements  for  user 
information  under  Article  7,  where  some  (5  out  of  23)  national  authorities  and  some 
industry  stakeholders  noted  that  requirements  related  to  fuel  price  comparisons  can  be 
simplified. This aligns with the findings of EQ2, which highlighted that it is an area that 
could be further improved but not removed. 

5.3 

Assessment of relevance 

5.3.1  Relevance of the general and specific objectives  

The analysis of issues and challenges confirms that the general and specific objectives 
were relevant at the time of adoption of the Directive, and maintain their relevance 
at present. Relevant challenges identified at the time of adoption of the Directive include 
shortcomings 
interoperability  and  commercial 
technological 
profitability  or  lack  of  consumer  acceptance.  However,  consumer  acceptance  is 
becoming less relevant, as increase in vehicle availability and decreases in purchase price 
will contribute to such vehicles becoming more and more accepted by customers.  

infrastructure, 

in 

Intervention  at  EU  level  is  still  relevant  as  required  by  most  stakeholders  to  ensure  a 
coherent  policy  framework  for  a  variety  of  alternative  fuels  to  achieve  cross  border 
continuity, avoid varying national implementation, and to promote common standards.  

The analysis also pointed to questions concerning the ongoing relevance of the scope and 
priorities set in the Directive in view of the new policy objectives. More specifically:  

o  The need to review the provisions for infrastructure distributing gaseous fuels and 
their  compatibility  with  a  full  decarbonisation  pathway  (including  needs  for 
blending with bio-methane) 

o  The  extent  that  current  AFI  deployment  targets  developed  in  the  context  of  the 
NPFs  are  not  sufficient  to  meet  future  developments,  as  anticipated  by  policy 
initiatives developed in the context of the Climate Target Plan and the Smart and 
Sustainable Mobility Strategy.  

o  The extent that the current scope of the Directive is sufficient or whether there is a 
need  for  the  inclusion  of  other  sectors/modes  including  public  transport, 
commercial vehicle operations and aviation.  

5.3.2  Relevance in view of new challenges  

Since  its  implementation  in  2014,  there  have  been  a  number  of  developments  and 
trends  that  are  likely  to  impact  on  the  uptake  of  vehicles,  but  are  not  addressed 
through AFID. Connectivity and digitisation of vehicles, and new mobility patterns and 

28 

 
 
business models make it even more important that information and data provision from 
AFI  is  standardised  and  consistently  made  available  for  integration  with  other  digital 
transport and electric grid services. 

New  alternatively  fuelled 
technologies  (including  for  example  electrified  road 
infrastructure,  or  provisioning  of  new  low-carbon  and  renewable  transport  fuels  in 
waterborne or aviation transport (e.g. hydrogen/ammonia) are not reflected in the current 
AFID.  Developments  in  the  trucks  market  following  the  introduction  of  the  CO2 
standards  for  trucks  also  suggest  that  more  focus  may  need  to  be  placed  at  addressing 
alternative fuels infrastructure for the commercial vehicle sector specifically.  

Challenges,  issues  and  obstacles  relating  to  interoperability  of  AFI  with  consumer 
services include particularly better access to information on the availability of charging 
and  refuelling  points  (need  for  real-time  data  and  information  on  the  availability  and 
maintenance  of  charging  points  –  local  and  international  users).  There  is  a  lack  of 
transparency  in  payments  and  unfair  pricing  models.  There  are  issues  relating  to  the 
methods  of  payment  accepted  for  charging  that  need  to  be  addressed,  ensuring 
accessibility for all users. There is also a need to consider how recharging and refuelling 
points could  become more accessible to  persons  with  disabilities and elderly, but  those 
are also subject to local circumstances.  

5.4 Assessment of overall coherence  

5.4.1 Assessment of internal coherence 

In  general,  the  analysis  suggests  that  the  provisions  of  the  AFID  are  internally 
coherent, with some minor issues around fuels definitions.  

The desk analysis noted that there were some examples where the treatment of different 
fuels might have benefitted from being more consistent. For example, only biofuels are 
explicitly  defined,  with  reference  to  another  Directive.  While  a  definition  for  all  of  the 
fuels  and  energy  sources  covered  might  not  be  needed,  for  the  avoidance  of  ambiguity 
the CN codes of the fossil fuels covered could have been stated (as they are in other fuel-
related Directives), while ‘synthetic and paraffinic fuels’ could have been defined in the 
Directive  or,  ideally,  with  reference  to  a  definition  in  a  piece  of  EU  fuel-related 
legislation, rather than in a recital of the AFID.  

With  respect  to  definitions,  the  evaluation  suggests  that  the  definition  of  ‘high  power 
recharging  point’  is  no  longer  relevant,  while  more  recent  electric  vehicle  recharging 
technologies, such as wireless charging and electric road systems, are not defined at all. 
Furthermore,  the  definition  of  recharging  points,  in  particular,  those  that  are  ‘publicly 
accessible’  would  benefit  from  further  refinement.  It  was  also  noted  that  there  are 
different  interpretations  in  different  Member  States,  as  to  what  can  be  classified  as 
biogas, in terms of its origin. This is however, not legislated under AFID. 

5.4.2  Assessment of external coherence 

The evaluation  found  no real issues with  the coherence of the purpose of the AFID 
compared  to  other  relevant  legislation,  although  it  did  identify  some  issues  with 
respect to the scope of some other legislation compared to the AFID.    

Some stakeholders noted to the need to better differentiate the origins of fuels provided 
to ensure that only fuels with a clear value added for emission reduction are considered. 
However,  the  main  focus  of  AFID  is  on  providing  public  accessible  infrastructure, 

29 

 
whereas  fuel  and  emission  related  aspects  are  dealt  with  under  other  EU  legislation 
(Renewable Energy Directive, Fuel Quality Directive, CO2 standards for cars and vans or 
heavy duty vehicles). Also as regards urban mobility, some stakeholders noted the need 
for better alignment of sustainable urban mobility plans (SUMP) and implementation of 
AFID.   

In  relation  to  the  implementation  of  the  electricity  market  design  Directive,  some 
stakeholders suggested that this Directive was not coherent with the aims of the AFID as 
it  limited  the  number  of  potential  investors  by  not  allowing  distribution  network 
operators  to  install  electric  vehicle  charging  points  unless  there  is  substantive  market 
failure.  

Most of the financing instruments and technical  assistance joint  initiatives reviewed do 
not  explicitly identify or define what  they mean  by alternative fuels  for transport, even 
though  they  all  aim  to  support  these  in  some  way.  The  exceptions  to  this  are  the  CEF 
Regulation and ELENA, which explicitly refer to the AFID’s definition of an alternative 
fuel. Hence, these can be considered to be coherent with the AFID.  

AFID focuses on the implementation of infrastructure for alternative fuels that require an 
infrastructure distinct to the one used for distributing conventional transport fuels. Under 
the  evolving  strategic  context  for  the  sustainable  mobility  transition,  there  is  a  clear 
emphasis  of the fact  that all transport fuels  have to  fully  comply with  the requirements 
for  achieving  climate-neutrality  in  the  EU.  As  such,  the  AFID  is  not  incoherent  with 
provisions  of  the  long-term  climate  strategy  or  more  recently  the  Green  Deal 
Communication  or  the  Climate  Target  Plan  as  the  topic  of  decarbonisation  of  fuels  is 
subject to other legislation than AFID. Hydrogen and natural gas refuelling infrastructure 
in  all  modes  of  transport  is  necessary  to  ensure  that  low-carbon  and  renewable  fuels 
(clean hydrogen, biogas, synthetic gas) can be distributed.  

5.5.  Assessment of EU Added Value  

The  intervention  at  EU  level  is  still  required  and  has  provided,  in  spite  of  all  the 
identified  limitations,  an  EU  value  added.  There  is  general  consensus  among 
stakeholders  that  EU  level  intervention  brought  benefits  (in  terms  of  the  effectiveness 
towards  achieving  key  objectives,  as  well  as  in  terms  of  efficiency  and  possible 
synergies) beyond that which would have been possible with action at national or local 
level alone.  

There  continues  to  be  an  important  role  for  the  EU  in  creating  a  coherent  policy 
framework  for  a  variety  of  AFs,  and  action  needs  to  be  intensified  going  forward  to 
guarantee  cross  border  continuity,  avoid  any  further  varying  national  implementation, 
and  to  promote  common  standards.  Analysis  of  NPFs  and  NIRs  support  this,  with 
continued gaps in targets and objectives highlighting the scale of the challenge and that 
further action is required. The recent increasing EU Green Deal decarbonisation targets 
also raise the pressure for ongoing policy action.  

What  has  limited  the  EU  added  value  is  the  absence  of  clearly  defined  and  quantified 
requirements for alternative fuels infrastructure deployment. Not all Member States have 
decided  to  act  and  invest  in  deploying  an  ‘appropriate  number’  of  infrastructure 
deployment, as it has been open to interpretation. This has resulted in a divergent target-
setting under NPFs  that  on average does not  lead to  the ambition needed to  effectively 
contribute  to  the  increased  climate  ambition  for  2030  and  the  transition  to  climate 
neutrality in 2050.  

30 

 
The  development  of  a  common  framework  in  the  context  of  the  AFID  has,  despite  its 
limitations, contributed towards avoiding the fragmentation of measures in relation to the 
promotion  of  alternative  fuels  infrastructure,  supporting  the  development  of  the  overall 
infrastructure network, creating a level playing field within the industry and facilitating 
the  free  circulation  of  alternative  fuels  vehicles  throughout  the  EU.  All  Member  States 
have seen an increase in the level of refuelling and recharging infrastructure that, despite 
the  gaps,  suggest  a  relatively  more  coherent  network  with  fewer  gaps  that  what  would 
have  been  the  case  in  the  absence  of  EU  intervention.  Electricity  recharging 
infrastructure has seen the greatest momentum over past years, where Member States set 
the  greatest  number  of  targets  and  where  the  market  is  more  developed  and  most 
investment has taken place.   

Furthermore,  through  encouraging  interoperability,  relevant  technical  standards  and 
setting of targets on similar timescales, EU level action has provided some cost  savings 
and  better  value  for  money  by  facilitating  economies  of  scale,  avoiding  duplication  of 
effort  and  resources,  and  providing  funding  investments  for  infrastructure.  The 
implementation  of  the  AFID  (and  its  supporting  activities)  have  facilitated  cooperation 
and  information  exchange  on  alternative  fuels  between  MSs,  industry  experts  and  the 
Commission which would likely not exist without it.  

At  the  regional/local  level,  stakeholders’  input  suggests  that  relevant  actions/measures 
adopted would not have been implemented without the EU intervention. These included 
regional  action  plans  for  infrastructure  planning  and  deployment;  standards/technical 
specifications for charging infrastructure and financial instruments and guidelines.  

In contrast, EU added value appears to have been more limited in those areas where the 
legislation does not clearly require Member States to take action, but where there is also 
no provision at EU level, including particularly the area of infrastructure use services. 

Stakeholders noted that if EU action in the form of the AFID were to stop, in general this 
would  negatively  affect  the  capacity  to  address  the  issues  covered  by  both  the  general 
and  specific  objectives  at  national  level.  Certain  Member  States  would  be  less  able  to 
effectively  develop  a  common  framework  and  would  revert  to  conventional  fuels 
vehicles. The analysis of both the baseline and alternative scenarios using the PRIMES-
TREMOVE  model  has  highlighted  that,  in  the  absence  of  the  EU  intervention,  a  less 
developed, more limited network of AFI could be expected, where AFI is also likely to 
be more concentrated in a smaller number of MS by 2030.  

6.  CONCLUSIONS 

The  Alternative  Fuels  Infrastructure  Directive  was  adopted  in  order  to  establish  a 
common framework of measures to support roll-out of public accessible alternative fuels 
infrastructure  in  the  EU.  It  should  support  a  sufficient  network  of  recharging  and 
refuelling 
infrastructure,  adequate  consumer 
information and effective vehicle integration into electricity grids.  

interoperability  of 

infrastructure, 

This  evaluation  finds  that  the  Directive  has  been  slightly  effective  in  achieving  its 
objectives,  namely  by  triggering  policy  action  at  the  level  of  Member  States.  Back  in 
2014  when  the  Directive  was  adopted  markets  for  alternative  fuels  vehicles  and 
infrastructures  were  in  an  early  stage  of  development  and  in  many  Member  States  no 
specific  policies  for  alternative  infrastructure  policy  existed.  Member  States  have 
transposed the Directive and developed their National Policy Frameworks (NPFs). Those 
policy frameworks have started to help building a long-term forward-looking perspective 

31 

 
 
on infrastructure for electricity, natural  gas and hydrogen until  2030 in  Member States, 
although to different extent and detail.  

Through the Directive and delegated acts under that Directive, technical specifications on 
recharging  and  refuelling  infrastructure  were  adopted  early  on  that  helped  to  provide 
certainty  to  investment  into  alternative  fuels  vehicles  and  infrastructures.  Particularly 
relevant in this context was the adoption of a common standard for a recharging plug for 
electric vehicles that helped long-term market certainty. 

Consequently,  the  Directive  has  had  a  certain  positive  impact  on  the  uptake  of 
alternatively  fuelled  vehicles  and  their  infrastructure.  Cost  of  the  Directive  have  been 
rather  proportional  to  the  benefits  of  the  implementation  of  the  Directive  and  the 
evaluation  did  not  find  any  indication  that  there  would  have  been  a  largely  more  cost-
efficient approach possible for delivering the same outcomes. The evaluation confirms a 
principal  EU  value  added  of  the  intervention  at  EU  level.  Markets  for  alternative  fuels 
vehicles  and  infrastructure  would  have  been  less  developed  in  a  scenario  without  the 
Directive. This is a general point of consensus among stakeholders. Individual action at 
Member State level would not have resulted in common market development and related 
adoption of technical specifications for infrastructure and vehicles.  

The evaluation points that there are no real issues with regard to the internal and external 
policy coherence of this Directive. The evaluation also confirms the continued relevance 
of the general and specific objectives of the Directive.   

However,  substantive  shortcomings  of  the  current  policy  framework  are  also  clearly 
visible, and the evaluation finds a relative strong consensus among stakeholders: 

  With regard to establishing a sufficient network of alternative fuels infrastructure, 
Member States took action to identify targets and measures due to the Directive. 
However, those actions do not sum up to a comprehensive common framework of 
measures across the EU. The absence of a detailed and binding methodology for 
Member  States  to  calculate  targets  and  adopt  measures  has  led  to  the  identified 
divergence  in  the  level  of  ambition  in  target  setting  and  supporting  policies  in 
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%.  A  comprehensive  and  complete  network  of  alternative  fuels  infrastructure 
does  not  exist  across  the  Union,  for  both  road  and  waterborne  transport.  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. The infrastructure targets set by Member States under 
their national policy frameworks reflect the different level of ambition, meaning 
that the planned deployment of infrastructure varies greatly. 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.  

  With  regard  to  establishing  full  interoperability  of  infrastructure,  the  evaluation 
points out that important aspects are not well covered under the current Directive, 
including  interoperability  of  infrastructure  for  recharging  and  refuelling  heavy-
duty use vehicles as well as important aspects of user services.  

  With regard to adequate consumer information and payment services, there is lack 
of  pervasive  high  quality  of  information  to  customers  about  the  location, 

32 

 
 
 
 
 
 
availability and use conditions of infrastructure. Moreover, there is a plethora of 
approaches  to  finding,  accessing,  using  and  paying,  particularly  in  the  case  of 
recharging  points,  which  is  leading  to  continued  customer  concerns.  Particular 
points  of  concerns  are  information  on  availability,  price  transparency  and 
payment services.  

  With regard to effective integration of electric vehicles into electricity grids, the 
implementation practice under the Directive has shown that markets do not expect 
public  accessible  infrastructure  to  play  a  role  in  this  market  segment.  A  smart 
integration of electric vehicles and bi-directional charging will provide flexibility 
for  the  overall  management  of  the  energy  system  and  thus  help  to  integrate 
increased shares of variable renewable energy production. However, it is mainly 
private recharging infrastructure, where vehicles are parked for a long time, that 
will contribute to this use case.  

The  Impact  Assessment  supporting  the  legislative  proposal  of  the  Commission  in  2013 
projected much higher levels of alternative fuels infrastructure deployment for road and 
waterborne transport in 2020, but was also building on binding targets for infrastructure 
roll-out, which were dropped in the co-decision procedure, and estimates from Member 
States on alternative fuels vehicle take up that were much higher than those estimates that 
informed the final development of national policy frameworks. At present, investments in 
infrastructure  are  not  profitable  in  many  instances.  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  road  transport 
network  as  well  as  the  provision  of  onshore  power  supply  and  other  alternative  fuels 
infrastructure in ports is at early stage and is likely to require continued public support.  

The  current  implementation  practice  shows  a  strong  link  between  vehicle  demand  and 
infrastructure provision. However, infrastructure provision takes time and requires policy 
direction.  The  current  fragmentation  of  the  internal  market,  where  alternative  fuels 
infrastructure take up is driven mainly by a handful of key Member States, is not future-
proof in view of the expected rapid acceleration of vehicle take up in the years to come. 
The  evaluation  finds  that  the  current  Directive  is  not  fit  for  purpose  in  view  of  the 
increased policy ambition for cutting transport emissions by 2030 and finally 2050.  

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 low-carbon and renewable fuels, vehicles and infrastructure. In 
order  to  achieve  these  ambitious  targets,  the  uptake  of  zero-emission  vehicles  and  the 
related  public  accessible  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 also aviation.  

Moreover  and  importantly,  the  focus  of  the  policy  debate  has  broadened  from  the 
provision  of  sufficient  alternative  fuels  infrastructure  to  the  provision  of  infrastructure 
that is easy and transparent to use for all customers anywhere in the Union. At present, 
the Directive is not well-equipped to address relevant aspects of this dimension, which is 
essential  to  support  an  effective  acceleration  of  the  market  uptake  of  zero-  and  low-
emission vehicles.  

33 

 
 
 
 
The  evaluation  of  the  Alternative  Fuels  Infrastructure  Directive  confirms  the  need  for 
strengthening of the policy framework at EU level for the deployment of alternative fuels 
infrastructure to meet the increased climate ambition of the EU for 2030 and the needs of 
the transition to climate neutrality by 2050.  

34 

 
 
  
ANNEX 1: PROCEDURAL INFORMATION 

1 Lead DG, DEcide Planning/CWP references 

The  lead  DG  is  Directorate  General  for  Mobility  and  Transport  (MOVE),  Unit  B4: 
Sustainable & Intelligent Transport  

DECIDE reference number: PLAN/2019/5028 

The  development  of  this  initiative  was  announced  under  item  1i)  in  Annex  1  to  the 
Commission Work Programme 202152 as part of the revision of the directive. 

2 Organisation and timing 

The  Inter  Service  Steering  Group  (ISSG)  for  the  evaluation  was  set  up  in  March  2019 
and  includes  the  following  DGs  and  Services:  SG,  LS,  CLIMA,  ENV,  ENER,  RTD, 
GROW, MARE, COMP, TAXUD, ECFIN, EMPL, JUST and JRC53.  

The ISSG approved the evaluation and discussed the main milestones in the process, in 
particular the key deliverables from the support study. It approved the study supporting 
the  evaluation  on  13  January  2021.  In  total,  10  meetings  of  the  ISSG  were  organised 
These meetings took place on 8 March 2019, 11 September 2019, 24. September 2019, 
11 December 2019, 31 January 2020, 2 April 2020, 17 June 2020, 23 September 2020, 
19 October 2020, 13 January 2021. This included virtual meetings, due to the COVID-19 
crisis. Further consultations with the ISSG were carried out by e-mails. When necessary 
bilateral discussions were also organised with the most concerned services.  

 3 Consultation of the RSB 

The  evaluation  was  not  selected  for  assessment  by  the  RSB.  The  Regulatory  Scrutiny 
Board received the draft version of the evaluation report on 7 April 2021 as part of the 
documents supporting the Impact Assessment report. The Board meeting on the Impact 
Assessment report will take place on 5 May 2021. 

4 Evidence, sources and quality 

The evaluation is based on research/analyses done by the Commission. The Commission 
also contracted an external, independent consultant (Ricardo) to support this evaluation. 
The external support study will be published alongside this report.  

Qualitative  and  quantitative  data  supporting  this  evaluation  has  been  collected  from 
Member  States,  operators  of  recharging  and  refuelling  infrastructure,  mobility  service 
providers,  fuel  producers  and  distributors,  electricity  suppliers,  Distribution  System 
Operators, technology producers, academia and non-governmental organisations.  

Modelling  of  the  baseline  and  of  the  alternative  scenarios  has  been  performed  by 
E3Modelling with the PRIMES-TREMOVE transport model. This report also draws on 
the  activities  of  the  Sustainable  Transport  Forum,  a  Commission’s  expert  groups  with 

52 https://ec.europa.eu/info/publications/2021-commission-work-programme-key-documents_en 
53 The ISSG was created for the evaluation and its mandate was subsequently enlarged to also cover the Impact assessment reflecting 
that the evaluation and the Impact Assessment were carried out back to back.   

35 

 
                                                 
industry stakeholders and Member States representation, which was established under the 
Directive. 

36 

 
Annex 2: Stakeholder consultation 

This annex provides a summary of the outcomes of the consultation activities which have 
been  carried  out  for  the  evaluation  of  the  Alternative  Fuels  Infrastructure  Directive, 
including in the context of the external support study. It notes the range of stakeholders 
consulted, describes the main consultation activities and provides a succinct analysis of 
their views and the main issues they raised.   

The  objective  of  the  consultation  activities  were  to  collect  information  and  opinions  of 
stakeholders  on the key  objectives and measures of the Alternative Fuels  Infrastructure 
Directive, its implementation and practical outcomes and shortcomings of that process.   

The main consultation activities included: 

-  An  Open  Public  Consultation  (OPC),  organised  by  the  European  Commission 
that did run from 06 April 2020 to 29 June 2020. The OPC took account of both 
the Impact Assessment and the evaluation of this Directive.   

-  Exploratory  interviews  with  EU  level  representatives  of  key  stakeholders, 
particularly  to  support  and  refine  the  overall  problem  definition  and  possible 
policy options.  

-  Two surveys with national and local authorities were organised by the consultant 

in charge of the external support study to the evaluation 

-  Targeted  data  requests  were  send  to  individual  stakeholders,  including  industry 

associations and special interest organisations.   

The Commission drew also strongly on the outcomes of a broad stakeholder consultation 
exercise  on  problems  and  future  policy  needs  in  the  field  of  alternative  fuels 
infrastructure  that  the  Commission  carried  out  among  the  member  of  the  Sustainable 
Transport Forum, the key expert group of the Commission, in the time period of October 
2018 to  November 2019 and that led to  the adoption of a  comprehensive report by the 
plenary  of  the  Sustainable  Transport  Forum  in  November  201954.    Findings  of  that 
exercise helped design the overall consultation activities carried out in the context of this 
evaluation. 

Overview of stakeholder input 

The Commission launched the 12-week OPC on 6 April and it closed on 29 June 2020. 
The OPC invited all citizens and organisations  to provide input on both  the Evaluation 
and the Impact Assessment of the AFID55. In total, 324 responses were received. 

The breakdown of OPC responses by stakeholder type is shown in the Table below.  

54 https://ec.europa.eu/transport/sites/transport/files/2019-stf-consultation-analysis.pdf 
55 The evaluation input was analysed in the stakeholder consultation report supporting the Evaluation Final 

Report.  

37 

 
 
                                                 
Table 1: Classification of stakeholders responding to the OPC 

Stakeholder group 

Number of responses 

% of responses 

Company/business organisation 

107 

Business association 

Public  authority  (national,  regional  and 
local authorities) 

Non-governmental 
(including 
associations) 

relevant 

Consumer organisation 

organisation 
industry 

Environmental organisation 

Academic/research institute 

EU citizen 

Non-EU citizen 

Other 

80 

28 

22 

7 

1 

1 

70 

1 

7 

33% 

24.7% 

8.6% 

6.8% 

2.2% 

0.3% 

0.3% 

21.6% 

0.3% 

2.2% 

In  terms  of  geographical/Member  State  distribution,  the  majority  of  respondents 
indicated  that  their  country  of  origin  was  one  of  the  EU  Member  States  (315 
respondents).  Nine  respondents  were  based  outside  of  the  EU.  The  number  and 
percentage of respondents by country of origin is shown in the following table:  

Table 2: Geographical distribution of responses received 

Country of 
origin 

Number of 
responses 

% of responses 

Belgium 
France 
Italy 
Germany 
Sweden 
Netherlands 
Spain 
Austria 
Czech Republic 
Poland 
Finland 
Hungary 
Ireland 
Slovenia 

Latvia 

60 
53 
50 
49 
19 
17 
11 
10 
8 
8 
6 
6 
5 
3 

2 

18.5 
16.4 
15.4 
15.1 
5.9 
5.2 
3.4 
3.1 
2.5 
2.5 
1.9 
1.9 
1.5 
0.9 

0.6 

Country of 
origin 

Slovakia 
Denmark 
Estonia 
Greece 
Luxembourg 
Malta 
Romania 
Canada 
Grenada 
Israel 
Japan 
Norway 
Switzerland 
United 
Kingdom 
United States 

Number of 
responses 

% of 
responses 

2 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
2 

1 

0.6 
0.3 
0.3 
0.3 
0.3 
0.3 
0.3 
0.3 
0.3 
0.3 
0.3 
0.3 
0.3 
0.6 

0.3 

As part of the targeted consultations, the consultant  in  charge of the support study also 
carried  out  targeted  surveys  with  public  authorities  in  Member  States  and  targeted 
interviews  with  key  stakeholders.  23  national  public  authorities  and  19  regional 
authorities and public enterprises and their interest associations responded to the surveys.  

Table  4  provides  an  overview  of  key  stakeholders  interviewed  in  the  context  of  the 
evaluation.  

38 

 
 
 
 
Table 3: List of stakeholders interviewed  

Stakeholder type 

Stakeholder name 

 High-level 
stakeholder 
category 

Regional / local authorities 

ETRA I+D (invited to respond by CIVITAS) 

Industry 

European standardisation 
body 

Refuelling station/charge 
point operators, fuel and 
battery producers, electro-
mobility service providors  

Polis 

CEN-CENELEC 

AVERE 

European Biogas Association / ENGIE 

Energy and Hydrogen Alliance EHA 

ePURE 

Eurelectric 

NGVA Europe 

Manufacturers of transport 
equipment and  

Organisations of transport 
service providors 

ACEA 

ECSA 

ESPO 

FIA Region I 

UITP 

Port of Rotterdam      

ACI EUROPE 

Inland Navigation Europe (INE) 

European Road Haulers Association (UETR) 

Central Commission for the Navigation of the Rhine 
(CCNR) 

Civic society  Consumer representatives 

BEUC 

NGOs 

Transport & Environment 

Consumers with disabilities  European Disability Forum 

EU  

European Investment Bank 

DG CLIMA 

DG ENER 

DG REGIO 

Irish Rural Link and European Economic Social 
Committee 

Key findings from the OPC  

The OPC asked respondents whether they own or regularly drive an alternatively fuelled 
vehicle.  86  out  of  324  participants  responded  that  they  own/regularly  drive  an  electric 

39 

 
 
car,  17  stated  that  they  own/regularly  drive  a  vehicle  running  on  natural  gas,  34  stated  
that  they  own/regularly  drive  an  ‘other’  type  of  alternatively  fuelled  vehicle,  50  stated 
that  they  did  not  and  137  did  not  answer  the  question.  This  shows  a  considerable  high 
share of active users of alternative fuels vehicles among the respondents to the OPC.  

In answer to the question ‘do you have difficulty finding alternative fuels infrastructure 
to  recharge/refuel  your  vehicle?’,  60  responded  that  they  have  difficulty  on  a  regular 
basis, 59 responded that they sometimes have difficulties, 20 responded that they seldom 
have difficulties and 9 responded that they never have difficulties (see figure 2). 35 did 
not have an opinion and 141 did not respond to the question.  

Figure  2:  Do  you  have  difficulties  finding  alternative  fuels  infrastructure  to 
recharge/refuel your vehicle?  

Respondents  were  asked  to  further  substantive  responses  to  having  difficulties  finding 
recharging/refuelling infrastructure, namely in view of the main underlying problems. Of 
those that responded (15856) the following underlying problems were identified:  

  “There is not sufficient infrastructure in urban areas” – 86 respondents 

  “There is not sufficient infrastructure in rural areas” – 93 respondents 

  “There is not sufficient infrastructure along highways and other  large interurban 

roads” – 108 respondents 

  “Even if there is infrastructure, I have trouble identifying where they are located“ 

- 30 respondents 

166 participants to the OPC did not respond to the question.  

In answer to the question ‘in case you do not on an alternatively fuelled vehicle, would 
you  buy  one,  if  you  were  certain  that  there  was  sufficient  recharging  or  refuelling 
infrastructure?’, 77 agreed that they would buy one and 31 stated that they would maybe 
buy  one,  showing  a  relatively  high  willingness  to  adopt  such  vehicles  provided  that 
infrastructure is available. Of the 19 participants that responded they would not buy one, 
12  stated  that  the  price  for  alternatively  fuelled  vehicles  is  too  high,  3  stated  that  the 
technology is not yet mature and 4 stated that the vehicles on the market are not attractive 
enough. 207 did not answer.  

56 Respondents could select more than one answer 

40 

 
 
                                                 
In  answer  to  the  question  ‘when  you  recharge  your  electric-vehicle,  do  you  feel  well 
informed  in  advance  on  the  price  you  will  have  to  pay  for  the  charging  service?’,  37 
agreed that they did  feel  well informed on a regular basis, 41 stated that they feel  well 
informed sometimes, 33 responded that they seldom feel well informed and 10 feel that 
they  never  feel  well  informed  (see  figure  3).  31  responded  that  they  did  not  know  and 
172  did  not  answer.  This  confirms  outstanding  issues  with  regard  to  having  sufficient 
information available to active vehicle users.   

Figure  3:  When  you  recharge  your  electric-vehicle,  do  you  feel  well  informed  in 
advance on the price you will have to pay for the charging service?  

In  answer  to  the  question  ‘how  often  do  you  face  difficulties  when  trying  to  pay?’,  38 
stated  that  they  face  difficulties  when  trying  to  pay  on  a  regular  basis,  36  stated  they 
sometimes face difficulties, 30 stated that they seldom face difficulties and 9 stated that 
they never face difficulties (see figure 4). 40 respondents did not know and 171 did not 
answer. The fact that only a very small number of participants to the OPC noted that they 
never  face  problems  with  payment  underlines  the  relevance  of  the  shortcomings  of  the 
Directive in this problem area.  

Figure 4: The Directive already requires that users can pay ad hoc at the recharging 
point.  However,  in  practice  many  different  payment  options  have  developed 
throughout Europe. How often do you face difficulties when trying to pay?  

Responding to  the question if they believed that  a common payment  method should be 

41 

 
 
available  at  all  publicly  accessible  recharging  points  the  majority  of  respondents  (69) 
stated  that  payment  by  debit  card/credit  card  (card  payment  terminal  or  contactless 
payment) should be available (see figure 5). 36 stated payment by Smartphone / banking 
app  without  the  need  to  download  a  specific  app  from  the  operator  of  that  recharging 
point, 7 stated payment by specific app of the operator of that recharging point, 1 stated 
cash payment, and 34 stated ‘other’. 8 stated that there is no need for a common payment 
method and 169 did not answer.  

Figure 5: If you believe that a common payment method should be available at all 
publicly accessible recharging points, please indicate which payment option should 
be available? 

In  answer  to  the  question  ‘Do  you  believe  that  roaming  (payment  through  the  user’s 
electro-mobility  service  provider)  should  be  available  at  every  publicly  accessible 
recharging point? 122 respondents agreed compared with 16 that did not. 28 stated that 
they did  not  know and 158 did  not  answer. Roaming is  already a key feature of public 
accessible recharging points.  

The  OPC  confirmed  the  ongoing  strong  relevance  of  the  Directive.  Respondents  were 
asked  ‘In  your  view,  how  relevant  is  a  policy  on  alternative  fuels  infrastructure  at  EU 
level as established by the Alternative Fuel Infrastructure Directive to support the uptake 
of  alternative  fuels?  The  majority  of  respondents  (237)  stated  that  it  is  very  relevant, 
whereas  59  stated  it  was  relevant,  5  stated  it  was  less  relevant  and  2  stated  it  was  not 
relevant (see figure 6). 6 respondents did  not have an opinion and 15 did not answer.  

42 

 
 
Figure 6: In your view, how relevant is a policy on alternative fuels infrastructure at 
EU level as established by the Alternative Fuel Infrastructure Directive to support 
the uptake of alternative fuels? 

In  terms  of  the  scope  of  the  Directive,  respondents  were  asked  ‘In  your  view,  is  this 
scope  still  appropriate  in  the  context  of the  long-term  objective  of  the  European  Green 
Deal  to  reduce  transport  emissions  by  90%  by  2050?  Slightly  more  respondents  (165) 
stated  that  it  is  fully  appropriate  or  appropriate,  compared  with  133  who  stated  it  was 
rather not appropriate or not appropriate. 13 respondents did not have an opinion and 13 
did not answer. 

Respondents  also  pointed  to  the  need  for  a  better  coverage  of  all  modes  of  transport 
under the Directive. 38 respondents stated that the Directive already covered all relevant 
modes, but 131 respondents stated that the Directive should also cover rail infrastructure, 
167 stated that it should cover airport infrastructure for ground movements, and 65 stated 
‘other’. 62 respondents did not have an opinion, and 18 did not answer.  

There  were  clear  views  also  on  the  adequacy  of  the  NPFs.  When  being  asked  ‘In  your 
view,  are  the  NPFs  the  right  instrument  to  ensure  the  development  of  a  coherent 
infrastructure  network  throughout  the  EU?’  (see  figure  7)  the  majority  of  respondents 
(109)  stated  that  they  are  only  partly  sufficient,  and  additional/complementary 
instruments  would  be  needed  to  avoid  diverging  interpretation  and  application  by 
Member  States.  39  stated  that  they  are  the  right  instrument,  89  stated  that  they  are  the 
right instrument but the provisions in the directive are not prescriptive enough to avoid 
diverging interpretation  by Member States (and the provisions should be strengthened), 
51 stated that they are not the right instrument because they are not sufficiently stringent 
(they should be replaced by alternative, more stringent instruments) and 2 stated they are 
not  the  right  instrument  and  should  be  abandoned  without  being  replaced  by  an 
alternative. 20 respondents did not have an opinion and 14 did not answer.  

43 

 
 
 
 
 
Figure  7:  In  your  view,  are  the  NPFs  the  right  instrument  to  ensure  the 
development of a coherent infrastructure network throughout the EU?  

The  majority  of  respondents  (114)  expressed  that  the  Directive  should  cover  all 
infrastructure,  publicly  accessible  and  not  publicly  accessible.  76  stated  that  it  should 
cover  publicly  accessible  infrastructure  only  (with  distinction  required  between  public 
infrastructure  on  public  grounds  and  publicly  accessible  infrastructure  on  private 
ground), 53 stated that the current scope is fine, and 41 stated ‘other’. 27 did not have an 
opinion and 13 did not answer.  

information 

is  made  available 

that  relevant,  consistent  and  clear 

The Alternative Fuels Infrastructure Directive currently requires from Member States to 
ensure 
to 
consumers/users as regards those motor vehicles which are fuelled with alternative fuels. 
Such  information  has  to  be  made  available  in  motor  vehicle  manuals,  at  refuelling  and 
recharging  points,  on  motor  vehicles  and  in  motor  vehicle  dealerships  in  their  territory 
(Article  7).  Respondents  were  asked  ‘In  your  view,  are  the  current  provisions  in  AFID 
effective  in  ensuring  that  consumers/users  receive  relevant,  consistent  and  clear 
information  on  the  compatibility  of  their  vehicle  engine/model  with  the  alternative 
fuels/recharging options available at each refuelling/recharging point?’ (see figure 8). 80 
respondents stated that these provisions are effective, 102 stated that they are only partly 
or not at all effective and additional complementary provisions are needed, 41 stated that 
the Directive is not the right instrument and corresponding provisions should be replaced 
by more effective instrument(s), and 8 stated that the Directive is not the right instrument 
and  corresponding  provisions  should  be  abandoned  without  being  replaced  by  more 
effective instrument(s), 72 did not have an opinion and 17 did not answer. This underpins 
the assessment of shortcomings of the current Directive in this important area.  

44 

 
 
 
Figure 8: In your view, are the current provisions in AFID effective in ensuring that 
information  on  the 
consumers/users  receive  relevant,  consistent  and  clear 
compatibility  of  their  vehicle  engine/model  with  the  alternative  fuels/recharging 
options available at each refuelling/recharging point? 

Targeted consultations 

Three exploratory interviews  were undertaken  with  selected stakeholders in  the initial 
stage  of  the  evaluation  work.  The  purpose  of  the  exploratory  interviews  was  to 
incorporate  the  feedback  from  these  stakeholders  into  the  development  of  survey 
questions  and  interview  guides  and  to  ensure  that  all  important  issues  are  correctly 
identified and are covered in the intervention logic and evaluation matrix. 

28  targeted  interviews  were  conducted  with  a  range  of  relevant  stakeholders 
representing EU bodies, national and local authorities, industry representatives, members 
of the civil society (NGOs, consumer groups) and experts. The targeted interviews focus 
on  cross-checking  or  complementing  the  information  collected  via  desk  research  and 
collecting  evidence  and  opinions  in  relation  to  the  various  evaluation  questions.  They 
included interviews with 5 public national authorities and 2 regional and local authorities 
representatives. Moreover, one targeted interview was carried out with a representative of 
a  European  standardisation  organisation.  15  targeted  interviews  were  carried  out  with 
industry  representatives,  1  targeted  interview  with  a    representative  of  a  transport 
organisation and 3 interviews with representatives of civil society organisations.  

Two targeted surveys were distributed aimed at national authorities and regional, local 
and/or city authorities in EU Member States. The surveys focused on cross-checking or 
complementing the information collected via desk research and collecting evidence and 
opinions  in  relation  to  the  various  evaluation  questions.  44  responses  were  received, 
including  23  national  authorities  and  19  regional  and  local  authorities.  Responses 
represented 20 Member States and 9 different local organisations.  

45 

 
 
 
 
Annex 3: Methods and analytical models 

1.  OVERVIEW 

In  order  to  assess  the  contribution  of  the  AFID  it  is  important  to  define  the  Baseline 
scenario that will provide the benchmark against which we measure the contribution of 
the intervention. For the needs of the AFID evaluation this includes: 

  A description of how the problem and its underlying causes – as identified at the 
time of the adoption of the Directive – were expected to evolve in the case of no 
policy action. 

  A definition of the expected evolution of the relevant parameters that reflects the 
key objectives of the Directive. This presents in quantitative terms (or when not 
possible,  in  qualitative  terms)  the  Baseline  scenario,  namely  what  would  have 
happened  if  the  policies  and  measures  that  are  deemed  to  be  the  result  of  the 
AFID were not in place.  

For the purposes of this exercise the evaluation support study has used a combination of 
desk research and modelling. More specifically: 

 

It  has  analysed  the  information  provided  in  the  Impact  Assessment  study  that 
supported the adoption of the Directive in 201457. It focused on the description of 
the problem, its underlying root causes and the expected evolution under the ‘no 
policy  change’  scenario.  Additional  input  from  stakeholders  and  further  desk 
research is also incorporated.  

  E3Modelling  then used the PRIMES-TREMOVE model to quantify the Baseline 
and the Alternative scenario. The quantitative analysis involves a number of key 
indicators and reflects the objectives of the AFID.  

The structure of this Annex is as follows:  

  Section 2 provides a description of the problem and its underlying root causes as 
defined  at  the  time  of  the  adoption  of  the  AFID.  It  also  presents  a  qualitative 
description  of  how  the  problem  and  the  root  causes  were  expected  to  develop 
under the Baseline scenario.  

  Section 3 presents the PRIMES-TREMOVE transport model and the main results 
of  the  analysis  of  the  Baseline  and  the  Alternative  scenario.  The  expected 
evolution of key relevant parameters is provided for the EU27, for the period up 
to 2050. In addition, section 3 also provides the investment expenditures that are 
required for AFI under the Baseline and the Alternative scenario. 

2.  DESCRIPTION OF THE PROBLEM, THE UNDERLYING DRIVERS AND ITS EXPECTED 

EVOLUTION 

According  to  the  impact  assessment  at  the  time  of  the  adoption  of  the  Directive,  the 
transport system continued to depend heavily on oil and oil products: for more than 95% 
of  its  needs  worldwide  and  96%  in  the  European  Union.  The  decarbonisation  of  the 
transport system had been identified as a priority policy since the adoption of the Europe 

57 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52013SC0006 

46 

 
                                                 
2020  strategy  in  2010  and  the  2011  White  Paper  on  Transport  where  alternative  fuel 
technologies were expected to have a central role to play. The White Paper set a target 
for halving the use of conventionally fuelled cars in urban transport by 2030 and phasing 
them  out  in  cities  by  2050.  Furthermore,  the  Communication  “A  European  strategy  on 
clean and energy efficient vehicles” recognised that there was a European framework for 
electric mobility and presented actions to be taken in the areas of vehicle type-approval, 
and of standardisation and infrastructure for electric charging. 

In  this  context,  the  impact  assessment  report  supporting  the  adoption  of  the  Directive 
identified  the  issue  of  the  development  of  alternative  fuel  infrastructure  as  part  of  the 
broader  problem  that  limited  the  full-scale  deployment  and  commercialisation  of 
alternative fuels. These included a combination of:  

  The high price of vehicles related to technological and production capabilities; 

  Poor consumer acceptance; and  

  Lack of recharging/refuelling infrastructure.  

Focusing  on  the  last  point,  the  impact  assessment  defined  the  problem  as  the 
“insufficient infrastructure network for electricity, hydrogen and natural gas (LNG 
and CNG)” compared to a network that would be necessary to enable market take up of 
these  fuels.  The  availability  of  recharging/refuelling  stations  was  seen  not  only  as  a 
technical prerequisite for the functioning of alternative fuel vehicles, but also one of the 
most critical components for consumer acceptance.  

The impact assessment report also provided detailed analysis of the projected evolution 
of the infrastructure for each type of fuel and mode. This was then compared against the 
expected level of infrastructure that was considered to be necessary to allow widespread 
commercialisation of the corresponding vehicles (i.e. enable market take up of these fuels 
and  serve  the  fleet  of  alternative  fuelled  vehicles  projected  to  be  in  circulation,  on  the 
basis of Member States and industry announcements).  

The  main  conclusion  of  the  analysis  (which  was  based  on  a  number  of  assumptions 
concerning technological developments and expected evolution of demand) was that, in 
comparison with what would be necessary to allow widespread commercialisation of the 
corresponding  vehicles,  the  infrastructure  for  electric,  hydrogen,  liquefied  natural  gas 
(LNG)  for  trucks  and  vessels  and  compressed  natural  gas  (CNG)  for  road  transport 
vehicles was likely to remain insufficient in quantity and (in particular for electricity) in 
quality. 

47 

 
Table 4: State of development of AFI, projected evolution and comparison with the 
required level for commercialisation 

Fuel 

State of play at the time 
of the IA (2012) 

Projected evolution 

Required level of 
infrastructure for 
commercialisation 

Existing imbalance among 
Member States to 
continue 
Network to increase 
significantly only in 
France (4,400,000 points 
by 2020). In the rest of 
EU, only 600,000 points 
by 2020. 

Around  8  million  points 
(majority  located  at  home 
and  at  the  workplace)  to 
service  the  benchmark  4 
million EV vehicles 
Around  1  charging  point 
per  5  vehicles  at  a 
publicly  accessible  car 
park or on-street number 

Electricity   Dedicated e-mobility 

installations at EU level: 
- 
26,080 private (5,830 
existing and 20,250 
commissioned in 
2012)  
29,800 public (10,400 
existing and 19,390 
commissioned in 
2012)  

- 

Significant imbalance 
among Member States in 
terms of quantity and 
quality 

Hydrogen  90 hydrogen refuelling 

stations in operation in the 
EU (DE, DK, UK and 
Benelux) 

Expected  to  exceed  160 
by 2015 

LNG 

Waterborne: One LNG 
terminal in Nynäshamn 
(SE) for ships  
Road: 23 LNG/L-CNG 
fuelling stations for road 
vehicles (ES, IT)  

CNG 

2,800 filling stations in 
the EU concentrated in 
two Member States (DE, 
IT)  

Waterborne: Small-scale 
facilities at 7 location 
planned or proposed  
Addition ports (e.g. 
Antwerp, Rotterdam) 
intended to provide LNG 
by 2015 or later 
(Marseille, Barcelona by 
2017-2020) 
Road: 13 LNG/L-CNG 
stations planned (LNG 
Blue Corridors project) 

No information 

Additional  72  hydrogen 
fuelling stations needed to 
provide  national  coverage 
and  be  connected  via  the 
proposed  Trans-European 
Transport Network (TEN-
T)  Core  Network77  with 
the  maximum  distance  of 
300 km 

Waterborne:  
LNG  terminals  in  the  83 
maritime  ports  of 
the 
TEN-T  Core  Network  to 
enable  the  use  of  LNG  in 
shipping 
LNG  bunkering  facilities 
at  the  41  inland  ports  of 
the TEN-T Core Network  
Road: 21 LNG/L-CNG 
fuelling stations at the 
maximum distance of 400 
km on road 

The analysis also identified two underlying root causes that meant that the infrastructure 
for  electric,  hydrogen  and  natural  gas  (LNG  and  CNG)  vehicles  is  likely  to  remain 
insufficient for what broad market take-up would require: 

48 

 
 
 
 
 
  Existing  recharging/refuelling  equipment  could  not  be  connected  and  was  not 
interoperable in all related alternative fuel vehicles/vessels: While the technology 
necessary for the construction of a network was considered substantially mature, 
there  were  no  common  EU-wide  standards  and  no  harmonisation,  thereby 
discouraging potential infrastructure investors, car manufacturers and consumers.  

This had also led to the fragmentation of the internal market. The lack of common 
standards for recharging/refuelling prevented the creation of a single market and 
the reduction of costs of alternative fuels infrastructure and equipment since there 
were  no  economies  of  scale  that  could  arise  from  an  EU-wide  market.  A 
consequence  was 
investors, 
infrastructure 
it  created  a  disincentive 
manufacturers of alternative fuel vehicles and vessels and consumers.  

to 

 

the  deployment  of  recharging/refuelling 
Investment  uncertainty  hindered 
infrastructure  for  electricity,  hydrogen  and  natural  gas  (LNG  and  CNG):  The 
business  case  for  providers  of  alternative  fuels  infrastructure  had  not  been 
established.  A  co-ordination  failure  among  vehicle  manufactures,  infrastructure 
providers, national authorities and final users led to a so called “chicken and egg” 
issue. Investors would not invest in alternative fuel infrastructure as there was an 
insufficient number of vehicles and vessels, the manufacturing industry would not 
offer  alternative  fuel  vehicles  and  vessels  at  competitive  prices  as  there  is 
insufficient  consumer  demand,  and  consumers  would  not  purchase  the  vehicles 
and vessels for the lack of dedicated infrastructure. In the absence of coordination 
among  the  relevant  actors  uncertainty  for  investors  would  remain  exceedingly 
high, and the markets would continue to deliver a suboptimal solution.  

Related  to  that  was  the  negative  impact  on  investment  in  open-access 
recharging/refuelling infrastructure due to risk of ‘free riding’. First movers were 
expected to experience high upfront costs and uncertain payback times due to the 
low  diffusion  of  AFVs  while  late  comers  could  benefit  from  a  more  developed 
market.  This  risk  discourages  first  movers’  investments.  Principal-agent-type 
market failures were also identified in terms of the provision of charging points 
for tenants/users in private dwellings and in office buildings since landlords had 
limited incentives to invest. 

Further  to  that,  action  to  address  these  issues  by  national  authorities  through 
various measures was expected but was expected to lead to different perceptions 
of  consumers  in  the  respective  national  markets.  It  would  not  be  sufficient  to 
build  up  a  ‘critical  mass’  of  demand  and  signal  long-term  commitment  to  the 
support of alternative fuels.  

In terms of the identified root causes of the problem, it was expected that: 

  Common  standards  would  eventually  develop  since  the  persistence  of  different 
technical  solutions  would represent  a serious obstacle to  pan-European  mobility 
and  would  not  be  tolerable.  However,  delays  would  still  lead  to  considerable 
stranded costs and additional expenditure for adaptation if a decision is delayed. 

 

Investment  uncertainty  hindering  the  investment  in  AFI  and  problems  of 
coordination  and  the  identified  market  failures  would  continue.  Individual 
Member  States  would  be  expected  to  take  relevant  measures  to  address  these 
problems but these could lead to a fragmented market that would limit consumer 
confidence and have a negative impact on both demand and supply.  

49 

 
As a consequence, the share of alternative fuels in the energy consumption of passenger 
cars and vans was expected to remain less than 10% by 2050 without further action on 
infrastructure. LNG and CNG were also not expected to make significant inroads in road 
transport and the same would also happen with LNG for waterborne transport due to the 
lack of refuelling infrastructure. 

3.  DEVELOPMENT OF THE BASELINE AND ALTERNATIVE SCENARIO 

3.1 Introduction 

The  quantitative  analysis  builds  on  a  counterfactual  scenario  logic  comparing  the 
expected  future  impacts  of  the  already  adopted  policies  in  comparison  to  a  no  policy 
scenario. More specifically, E3Modelling used the PRIMES-TREMOVE transport model 
to quantify two scenarios - the Baseline and the Alternative scenario in order to assess the 
effectiveness and the efficiency of the implementation of AFID. 

The Baseline scenario projects the developments under the assumption that the AFID is 
not  in  place.  In  addition,  an  Alternative  scenario  has  been  developed  to  assess  the 
expected impacts as a result of the AFID intervention.  

3.2 PRIMES-TREMOVE model  

The  PRIMES-TREMOVE  transport  model  projects  the  evolution  of  demand  for 
passengers  and  freight  transport,  by  transport  mode,  and  transport  vehicle/technology, 
following  a  formulation  based  on  microeconomic  foundation  of  decisions  of  multiple 
actors. Operation, investment and emission costs, various policy measures, utility factors 
and  congestion  are  among  the  drivers  that  influence  the  projections  of  the  model.  The 
projections  of  activity,  equipment  (fleet),  usage  of  equipment,  energy  consumption  and 
emissions (and other externalities) constitute the set of model outputs.  

The PRIMES-TREMOVE transport model can therefore provide the quantitative analysis 
for  the  transport  sector  in  the  EU,  candidate  and  neighbouring  countries  covering 
activity,  equipment,  energy  and  emissions.  The  model  accounts  for  each  country 
separately which means that the detailed long-term outlooks are available both for each 
country and in aggregate forms (e.g. EU level). 

In the transport field, PRIMES-TREMOVE is suitable for modelling soft measures (e.g. 
eco-driving,  labelling);  economic  measures  (e.g.  subsidies  and  taxes  on  fuels,  vehicles, 
emissions; ETS for transport when linked with PRIMES; pricing of congestion and other 
externalities  such  as  air  pollution;  accidents  and  noise;  measures  supporting  R&D); 
regulatory  measures  (e.g.  CO2  emission  performance  standards  for  new  passenger  and 
heavy  duty  vehicles;  EURO  standards  on  road  transport  vehicles;  technology  standards 
for  non-road  transport  technologies,  deployment  of  Intelligent  Transport  Systems)  and 
infrastructure  policies  for  alternative  fuels  (e.g.  deployment  of  refuelling/recharging 
infrastructure for electricity, hydrogen, LNG, CNG). Used as a module that contributes to 
the PRIMES model energy system model, PRIMES-TREMOVE can show how policies 
and trends in the field of transport contribute to economy-wide trends in energy use and 
emissions.  Using  data  disaggregated  per  Member  State,  the  model  can  show 
differentiated trends across Member States.  

50 

 
The PRIMES-TREMOVE has been developed and is maintained by E3Modelling, based 
on,  but  extending  features  of,  the  open  source  TREMOVE  model  developed  by  the 
TREMOVE58 modelling community. Part of the model (e.g. the utility nested tree) was 
built  following  the  TREMOVE  model.59  Other  parts,  like  the  component  on  fuel 
consumption and emissions, follow the COPERT model. 

Data inputs 

The main data sources for inputs to the PRIMES-TREMOVE model, such as for activity 
and  energy  consumption,  comes  from  EUROSTAT  database  and  from  the  Statistical 
Pocketbook  "EU  transport  in  figures”.60  Excise  taxes  are  derived  from  DG  TAXUD 
excise  duty  tables.  Other  data  comes  from  different  sources  such  as  research  projects 
(e.g.  TRACCS  project) and  reports.  In  the  context  of  this  exercise,  the  PRIMES-
TREMOVE transport model is calibrated to 2005, 2010 and 2015 historical data. 

3.3 Overview of the approach adopted for the Baseline and Alternative scenario 

The  Baseline  (no  policy  change)  scenario  serves  as  a  counterfactual  scenario  which 
presents  what  would  happen  if  the  policies  and  measures  adopted,  as  a  result  of  the 
AFID,  were  not  in  place.  This  means  updating  the  baseline  of  the  impact  assessment 
accompanying  the  AFID  –  considering  revised  macro-assumptions,  technology  costs 
assumptions  and  policies61.  These  assumptions  are  common  with  those  used  in  the 
context  of  the  2017-2018  Mobility  Packages62  and  also  in  the  in-depth  analysis 
accompanying  the  Clean  Planet  for  all  long  term  strategy63.  The  Baseline  scenario 
assumes,  among  others,  the  implementation  of  the  target  of  14%  renewable  energy  in 
transport by 2030 (according to the Renewable Energy Directive II), the post-2020 CO2 
standards  for  cars,  vans  and  heavy  duty  vehicles,  the  Clean  Vehicle  Directive,  the 
implementation of TEN-T network, etc. 

In addition, it accounts for specific policies and measure that would have been adopted 
by  some  Member  States  in  support  of  alternative  fuel  vehicles  and  infrastructure  even 
without  the  implementation  of  the  Directive  (Table  5Error!  Reference  source  not 
found.). These specific policies and measures have been identified in the context of the 
evaluation  support  study,  based  on  field  research.  In  addition,  it  was  confirmed  by  the 
Member State concerned that those measures would have been carried out irrespective of 
the AFID. 

58 Source: https://www.tmleuven.be/en/navigation/TREMOVE    
59 Several model enhancements were made compared to the standard TREMOVE model, as for example: for the number of vintages 
(allowing  representation  of  the  choice  of  second-hand  cars);  for  the  technology  categories  which  include  vehicle  types  using 
electricity  from  the  grid  and  fuel  cells.  The  model  also  incorporates  additional  fuel  types,  such as  biofuels  (when  they  differ  from 
standard  fossil  fuel  technologies),  LPG,  LNG,  hydrogen  and  e-fuels.  In  addition,  representation  of  infrastructure  for  refuelling  and 
recharging  are  among  the  model  refinements,  influencing  fuel  choices.  A  major  model  enhancement  concerns  the  inclusion  of 
heterogeneity in the distance of stylised trips; the model considers that the trip distances follow a distribution function with different 
distances  and  frequencies.  The  inclusion  of  heterogeneity  was  found  to  be  of  significant  influence  in  the  choice  of  vehicle-fuels 
especially for vehicles-fuels with range limitations. 
60 Source: European Commission (2020) EU Transport in Figures. Statistical Pocketbook 2020. 
61 The scenario analysis does not account for the Covid-19 impact on the economy and the transport sector. 
62 https://ec.europa.eu/transport/modes/road/road-initiatives_en 
63 https://ec.europa.eu/clima/sites/clima/files/docs/pages/com_2018_733_analysis_in_support_en_0.pdf 

51 

 
                                                 
Table  5:  Mapping  of  Member  States  that  would  have  implemented  policies  and 
measures related with AFI and AFV without the roll-out of AFID on the indicated 
transport modes  
Member 
State 
AT 

CNG/LNG 

LDVs, 

Buses, 

HDVs 

EVs 

H2 

Cars, 
HDVs 

BE 
DE 

EE 

FI 

IE 

LU 

LV 

NL 

Buses, HDVs 
Buses, HDVs 

All modes/fuels 

Cars, Buses, LDVs, HDVs 

Cars, LDVs 

Cars, Buses, LDVs, HDVs 

Buses, HDVs 

SE 
Source: Ricardo et al. (2021), Evaluation support study 

All modes/fuels 

Cars, Buses, LDVs, HDVs 

Cars, Buses, LDVs, HDVs 

Cars, Buses, LDVs 

Cars, Buses, LDVs 

HDVs 

The  Alternative  scenario,  unlike  Baseline,  includes  national  policies  and  measures 
(NIRs)  adopted  for  all  MS  (including  those  denoted  in  Table  5),  as  a  result  of  the 
implementation  of  the  Directive  on  the  deployment  of  Alternative  Fuels  Infrastructure. 
More details on the design of the Baseline and Alternative scenarios are available in the 
evaluation support study.  

3.4 Main results of the Baseline and the Alternative scenario 

This  section  presents  the  key  results  of  the  Baseline  and  the  Alternative  scenario  that 
have been quantified with the PRIMES-TREMOVE model. The results are provided at 
EU27 level.  

Energy consumption in the transport sector 

In  the  Baseline  scenario,  the  share  of  alternative  fuels  in  the  energy  use  in  transport 
would  go  up  from  7%  in  2010  to  12%  in  2030  and  remain  limited  to  around  17%  by 
2050.  The  uptake  of  alternative  fuels  in  the  Baseline  is  mostly  driven  by  the 
implementation of the post-2020 CO2 standards for cars, vans and heavy duty vehicles, 
the Renewables Energy Directive and the Clean Vehicles Directive. However, the lack of 
infrastructure acts as a barrier for the vehicle market uptake. In the Alternative scenario, 
the  implementation  of  AFID  enables  higher  uptake  of  electric  vehicles  (battery  electric 
and plug-in hybrids) as well as the uptake of LNG heavy duty vehicles, given the roll-out 
of recharging and refuelling infrastructure. Thus, the Alternative scenario projects a 3.4 
percentage points increase in the share of alternative fuels relative to the Baseline in 2030 
and a 11.1 percentage points increase in 2050.  

The  share  of  alternative  fuels  in  the  energy  consumption  of  passenger  cars  and  vans 
would remain limited in the Baseline scenario, at around 14% by 2030 and 18% by 2050, 
without  further  action  on  infrastructure.  The  deployment  of  recharging  infrastructure 
enables higher uptake of electric vehicles (battery electric and plug-in hybrids) instead of 
hybrids, as explained below, and leads to an increase in the share of alternative fuels (by 
4.9 percentage points in 2030 relative to the Baseline and 19 percentage points in 2050).  

52 

 
 
 
 
 
 
 
 
 
 
 
 
Figure  9:  Energy  consumption  in  the  transport  sector,  by  type  of  fuel,  in  the 
Baseline and the Alternative scenario (EU27) 

Source: PRIMES-TREMOVE, E3Modelling 

Vehicle stock 

In  the  Baseline  scenario,  the  car  fleet  is  projected  to  continue  to  be  mainly  based  on 
thermal  engine  technologies  for  the  years  to  come.  The  share  of  conventional  gasoline 
and diesel vehicles in the total stock would reduce from 97% in 2010 to 65% in 2030 and 
36%  in  2050.  Importantly,  the  implementation  of  the  post-2020  CO2  standards  would 
drive the uptake of hybrid vehicle technologies in the market, in the absence of a larger 
contribution from battery electric vehicles (BEVs) and plug-in hybrids (PHEVs), due to 
the lack of recharging infrastructure. The hybrid technologies would increase their share 
from less than 1% in 2010 to 25% in 2030 and 35% by 2050, at which point the hybrid 
vehicles would hold the second largest share in the total car stock, comparable to that of 
conventional gasoline and diesel vehicles. For electric vehicles, a gradual market uptake 
would  take  place  driven  by  the  CO2  standards  and  the  gradual  reduction  of  the  battery 
costs, with BEVs and PHEVs each reaching a share of around 3% in 2030 and 13% in 
2050 in the total stock of cars. The share of the liquefied petroleum gas (LPG) cars would 
decrease from 3% in 2010 to about 2% in 2050. The share of fuel cell electric vehicles 
(FCEVs) is projected to remain negligible for all the projection period.  

In  the  Alternative  scenario,  the  stock  of  cars  would  shift  from  thermal  engine 
technologies  mainly to electric power trains  (Figure 10).  The share of the conventional 
gasoline and diesel vehicles in the total stock is reduced by 3.2 percentage points relative 
to the Baseline in 2030 and by 13.8 percentage points in 2050. The hybrid technologies 
also  significantly  reduce  their  share  in  the  car  stock  relative  to  the  Baseline  (by  8.1 
percentage  points  in  2030  and  19.1  percentage  points  in  2050).  On  the  other  hand,  the 
share  of  battery  electric  cars  is  increasing  significantly  relative  to  the  Baseline  (by  6.5 
percentage  points  in  2030  and  20.6  percentage  points  in  2050),  enabled  by  the 
availability of infrastructure and the decreasing battery costs. As previously explained, in 
the Baseline scenario the lack of infrastructure acts as a barrier for the uptake of electric 
vehicles,  despite  the  implementation  of  CO2  standards  for  cars.  The  uptake  of  plug-in 
hybrids also increases relative to the Baseline, but at lesser extent relative to the increase 
in  the  uptake  of  the  BEVs.    The  share  of  fuel  cell  vehicles  increase  by  2050  in  the 
Alternative scenario but still remains limited to around 3% of the stock.   

53 

BaselineAlternativeBaselineAlternative201020302050Electricity & hydrogen48121631Gas & bio-methane159817Biofuels1216161714Petroleum products291243238216177050100150200250300350Energy consumption (Mtoe) 
 
Figure 10: Stock and penetration of electric cars in the Baseline and the Alternative 
scenario in the EU27 

Baseline scenario 

Alternative scenario 

)
s
r
a
c
n
o

i
l
l
i

m

(

k
c
o
t
s
V
E

160

120

80

40

0

8% 

6% 

11% 

13% 

0,8%  2,8% 

)
s
r
a
c
n
o

i
l
l
i

m

(

k
c
o
t
s
V
E

160

120

80

40

0

9,3% 

2,5% 

34% 

31% 

26% 

18% 

2025

2030

2035

2040

2045

2050

2025

2030

2035

2040

2045

2050

PHEVs

BEVs

Penetration BEVs

PHEVs

BEVs

Penetration BEVs

Source: PRIMES-TREMOVE, E3Modelling 

Similarly to cars, in the Baseline scenario for light commercial vehicles (LCVs) the share 
of  conventional  gasoline  and  diesel  vehicles  is  projected  at  66%  by  2030  and  37%  by 
2050, while that of hybrid technologies at 32% by 2030 and 48% by 2050. The uptake of 
battery  electric  and  plug-in  hybrids  would  be  more  limited  in  lack  of  recharging 
infrastructure (together representing up to 15% by 2050). In the Alternative scenario the 
uptake of battery electric LCVs would increase significantly and represent up to 25% of 
the LCV stock.  

For  heavy  duty  vehicles  (HDVs),  fuel  cell,  LNG  and  electric  vehicles  would  not  make 
significant inroads in the vehicle stock by 2050 in the Baseline scenario. The Alternative 
scenario projects slightly higher uptake of fuel cells and electric HDVs but the share of 
these  types  of  power  trains  only  increases  by  around  1  percentage  point  relative  to  the 
Baseline. The share of LNG HDVs would go up by 6.8 percentage points in 2050 in the 
Alternative scenario relative to the Baseline.    

CO2 emissions and air pollution emissions 

In the  Baseline scenario, tank to  wheel  CO2 emissions  from  transport64 are projected to 
decrease  by  15%  by  2030  relative  to  2010  and  by  24%  by  2050.  In  the  Alternative 
scenario,  the  implementation  of  AFID  would  have  a  limited  impact  on  the  CO2 
emissions from transport by 2030 (1.2% reduction relative to the Baseline). However, the 
impact  would  be  larger  by  2050  (15.1%  reduction  relative  to  the  Baseline)  due  to  the 
higher uptake of low- and zero-emission vehicles.  

The implementation of the AFID would also have a positive impact on reducing the NOx 
and PM emissions. In the Alternative scenario, NOx emissions would go down by 5.5% 
relative  to  the  Baseline  in  2030  and  8.4%  in  2050.  The  impacts  on  the  PM  emissions 
would  be  higher  (9.4%  reduction  in  2030  relative  to  the  Baseline  and  20.7%  in  2050). 
Similarly to CO2 emissions, the reduction in the air pollution emissions is driven by the 
higher  uptake  of  low-  and  zero-emission  vehicles,  enabled  by  the  deployment  of 
infrastructure.   

64 Excluding international shipping.  

54 

 
 
 
                                                 
 
 
 
 
 
 
 
 
3.5 Investment costs for alternative fuel infrastructure in the Baseline and in the 

Alternative scenario 

In  the  Baseline  scenario,  the  cumulative  capital  expenditures  on  alternative  fuel 
infrastructure (i.e. public and private infrastructure) are estimated at €29 bn for the period 
2021-2030  and  to  €123  bn  for  2031-2050  (Figure  11).  The  capital  investments  on 
infrastructure due to the demand induced by the AFID increase significantly, to  €82 bn 
until  2030  and  to  €310 bn  for  2031-2050.  In  addition  to  these  costs,  O&M  and 
refurbishment costs are projected to be around €24 bn in the Baseline, and €63 bn in the 
Alternative scenario in the period 2021-2050, which make up about 14% of total costs. 
More details on the methodology for determining the alternative fuel infrastructure costs 
are available in the evaluation support study.  

Figure 11: Cumulative investment expenditures of alternative fuel infrastructure in 
the Baseline and the Alternative scenarios per type of cost in the EU27 

)
o
r
u
E
n
b
(

s
t
s
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v
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a
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u
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400

350

300

250

200

150

100

50

0

Baseline

Alternative

Baseline

Alternative

2021-2030

2031-2050

Capital investment costs

O&M

Refurbishment

Source: Ricardo et al. (2021), Evaluation support study 

The  vast  majority  of  the  total  expenditures  (i.e.  capital  investment  costs,  O&M  and 
refurbishment)  is  projected  for  electric  vehicle  charging  infrastructure  (Figure  12).  In 
2021-2030,  electric  vehicle  recharging  infrastructure  makes  up  to  82%  and  88%  of  the 
total expenditures that occur in the Baseline and the Alternative scenario, or €26 bn  and 
€77 bn , respectively. In the period 2031-2050, investments in electric vehicle recharging 
infrastructure increase significantly, by a factor  5 in  the Baseline to  €132 bn , and by a 
factor  4  in  the  Alternative  scenario,  to  €326  bn  Euro.  In  both  scenarios,  they  make  up 
around 90% of total projected expenditures in alternative fuel infrastructure.  

55 

 
 
 
 
 
 
 
Figure  12:  Cumulative 
costs,  O&M, 
Refurbishment) of alternative fuel infrastructure in the Baseline and the Alternative 
scenarios per type of infrastructure in the EU27 

expenditures 

investment 

(capital 

)
o
r
u
E
n
b
(

s
t
s
o
c
e
v
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a
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400

350

300

250

200

150

100

50

0

Baseline

Alternative

Baseline

Alternative

2021-2030

2031-2050

Source: Ricardo et al. (2021), Evaluation support study 

EV

H2

CNG

LNG

Investment expenditures in electricity recharging infrastructure by 2030 and by 2050 

In the Baseline scenario cumulative investments on capital for recharging infrastructure 
(i.e. public and private infrastructure) reach almost €24 bn in the period 2021-2030, the 
majority  of  which  for  slow  charging  points  installed  off-street,  in  private  households 
(Figure 13;  top).  Investments on public chargers of all types  reach almost  €11 bn . The 
AFID  implementation  has  an  a  significant  impact  on  capital  investments  (Figure  13; 
bottom).  It  increases  investments  made  on  public  infrastructure,  and  particularly  on 
higher powered charging points. For example, in the Alternative scenario investments on 
public charging points are higher by a factor of 3.5-4 compared to the Baseline.  

Figure  13:  Cumulative  capital  investment  costs  of  electric  vehicle  recharging 
infrastructure  per  type  of  charging  point  in  the  Baseline  and  in  the  Alternative 
scenario in the EU27 in 2021-2030 

Baseline scenario 2021-2030: 24 bn Euro  

Slow charging points  (off-road HH
7KW AC)

Slow charging points  (on-road HH
7KW AC)

Slow charging points  (public spaces
22KW AC)

Rapid charging points (public spaces
50KW DC)

Rapid charging points (public spaces
150KW DC)

11% 

9% 

10% 

13% 

0,8% 

57% 

56 

 
 
 
 
 
 
 
 
 
Alternative scenario 2021-2030: 64 bn Euro  

15% 

12% 

13% 

45% 

15% 

0,8% 

Slow charging points  (off-road HH
7KW AC)

Slow charging points  (on-road HH
7KW AC)

Slow charging points  (public spaces
22KW AC)

Rapid charging points (public
spaces 50KW DC)

Rapid charging points (public
spaces 150KW DC)

Source: Ricardo et al. (2021), Evaluation support study 

Looking  into  the  2021-2050  horizon  (Figure  14),  it  is  estimated  that  the  cumulative 
capital investments of the Alternative scenario are by a factor 2.5 higher than those of the 
Baseline. In the Baseline, 45% of cumulative investments are on public chargers, while 
in  the  Alternative  public  charging  infrastructure  makes  55%  of  total  investments.  As 
such, the share of public chargers in the total charging infrastructure and the total number 
of  public  charging  points  increases  progressively  upon  the  AFID  implementation, 
compared to the Baseline.  

Figure  14:  Cumulative  capital  investment  costs  of  electric  vehicle  recharging 
infrastructure  per  type  of  charging  point  in  the  Baseline  and  in  the  Alternative 
scenario in the EU27 in 2021-2050 

Baseline scenario 2021-2050: 142 bn Euro  

11% 

8% 

11% 

13% 

0,8% 

55% 

Slow charging points  (off-road HH
7KW AC)

Slow charging points  (on-road HH
7KW AC)

Slow charging points  (public spaces
22KW AC)

Rapid charging points (public spaces
50KW DC)

Rapid charging points (public spaces
150KW DC)

57 

 
 
 
 
Alternative scenario 2021-2050: 360 bn Euro  

15% 

11% 

14% 

45% 

15% 

0,8% 

Slow charging points  (off-road HH
7KW AC)

Slow charging points  (on-road HH
7KW AC)

Slow charging points  (public spaces
22KW AC)

Rapid charging points (public spaces
50KW DC)

Rapid charging points (public spaces
150KW DC)

Source: Ricardo et al. (2021), Evaluation support study 

Investment expenditures in hydrogen refuelling stations by 2030 and by 2050 

The  impact  of  the  AFID  implementation  is  also  significant  on  hydrogen  refuelling 
stations (Figure 15). Capital investments of the Baseline are estimated at €310 million in 
2021-2030.  The  investments  in  the  Alternative  scenario  are  higher  by  a  factor  5 
compared  to  the  Baseline,  reaching  more  than  €1.6  bn  in  2021-2030.  The  impact, 
however, of the AFID is by a factor 10 higher in the period post-2030, when cumulative 
capital  investments  increase  by  €18  bn  in  the  Alternative  scenario  (cumulative  costs  in 
2021-2050 reach €20 bn, Figure 16).  

Figure 15: Cumulative capital investment costs of hydrogen refuelling stations per 
station size in the Baseline and in the Alternative scenario in the EU27 in 2021-2030 

Baseline scenario 2021-2030: 
310 MEuro 

Alternative scenario 2021-2030:  
1 650 MEuro 

9% 

35% 

56% 

8% 

32% 

60% 

Small stations

Medium stations

Small stations

Medium stations

Large stations

Large stations

Source: Ricardo et al. (2021), Evaluation support study 

58 

 
 
 
 
 
Figure 16: Cumulative capital investment costs of hydrogen refuelling stations per 
station size in the Baseline and in the Alternative scenario in the EU27 in 2021-2050 

Baseline scenario 2021-2050:  
2.8 bn Euro 

Alternative scenario 2021-2050:  
20 bn Euro 

9% 

29% 

62% 

9% 

27% 

64% 

Small stations

Medium stations

Large stations

Small stations Medium stations

Large stations

Source: Ricardo et al. (2021), Evaluation support study 

Investment expenditures in CNG and LNG refuelling stations by 2030 and by 2050 

The investments in natural gas-based refuelling infrastructure reach around €3.8 bn in the 
Baseline  and  more  than  €6.3  bn  in  the  Alternative  scenario  in  2021-2030  (Figure  17). 
The difference between the two scenarios is about €2.5 bn and is attributed primarily to 
LNG stations (€1.6 bn more investments in the Alternative scenario) and somewhat less 
to  CNG  stations  (€0.95  bn),  as  the  EU27  CNG  fleet  may  still  largely  benefit  from  the 
infrastructure  already  deployed.  In  the  period  2031-2050,  investments  in  new  CNG 
stations  are  lower  compared  to  the  period  2021-2030  in  both  scenarios.  This  is  partly 
because of the demand reduction due to the decrease of the CNG vehicle stock over time, 
as more EVs penetrate the market due to the decreasing battery costs. In addition, since 
significant capacity of CNG stations has been deployed before 2020 (according to EAFO, 
about 1.3 million stations were in the EU27 in 2019), investments in refurbishing vintage 
capacity take place, in the order of €1.4 bn and €1.6 bn in the Baseline and Alternative, 
or 33% and 25% of the total costs, respectively (Figure 18). 

59 

 
 
 
Figure 17: Cumulative capital investment costs of CNG and LNG refuelling stations 
in the Baseline and in the Alternative scenario in the EU27 in 2021-2030 and 2031-
2050 

7 000

6 000

5 000

4 000

3 000

2 000

1 000

 0

)
o
r
u
E
M

(

s
t
n
e
m

t
s
e
v
n

i

l

a
t
i
p
a
c
e
v
i
t
a
u
m
u
C

l

Baseline

Alternative

Baseline

Alternative

2021-2030

2031-2050

CNG stations

LNG stations

Source: Ricardo et al. (2021), Evaluation support study 

Figure  18: Cumulative capital investment, O&M and refurbishment costs of CNG 
stations in the Baseline and in the Alternative scenario in the EU27 in 2021-2050 

12 000

10 000

8 000

6 000

4 000

2 000

 0

)
o
r
u
E
M

(

s
t
s
o
c
e
v
i
t
a
u
m
u
C

l

Baseline

Alternative

2021-2050

Capital investment costs

O&M

Refurbishment

Source: Ricardo et al. (2021), Evaluation support study 

60 

 
 
 
 
 
 
 
 
 
 
 
Investment expenditures in LNG terminals by 2030 and by 2050 

The  number  of  LNG  bunkering  terminals  deployed  in  the  Baseline  and  the  Alternative 
scenario in the EU27 is presented in Figure 19. Medium/large LNG terminals represent 
about 5% and 8% of total terminals in the EU27 in 2030 and 2050, respectively.    

Figure 19: LNG bunkering terminals in the EU27 in 2030, 2040 and 2050 

Baseline scenario 

Alternative scenario 

15

10

5

0

i

s
l
a
n
m
r
e
t
G
N
L

f
o
r
e
b
m
u
N

2030

2040

2050

Small

Medium/Large

200

150

100

50

0

i

s
l
a
n
m
r
e
t
G
N
L

f
o
r
e
b
m
u
N

2030

2040

2050

Small

Medium/Large

Source: Ricardo et al. (2021), Evaluation support study 

Figure 20: Cumulative investment costs in LNG bunkering terminals in the Baseline 
and the Alternative scenario in the EU27 in 2021-2030 and 2031-2050 

Baseline scenario 

Alternative scenario 

l

a
t
i
p
a
c
e
v
i
t
a
u
m
u
C

l

)
o
r
u
E
M

(

s
t
n
e
m

t
s
e
v
n

i

100

80

60

40

20

0

l

a
t
i
p
a
c
e
v
i
t
a
u
m
u
C

l

2021-2030

2031-2050

)
o
r
u
E
M

(

s
t
n
e
m

t
s
e
v
n

i

1 500
1 250
1 000
 750
 500
 250
 0

2021-2030

2031-2050

Small

Medium/Large

Small

Medium/Large

Source: Ricardo et al. (2021), Evaluation support study 

The cumulative investment costs in 2021-2050 (Figure 20) for LNG bunkering terminals 
reach  €175  million  in  the  Baseline  scenario.  They  are  substantially  higher  in  the 
Alternative  scenario  reaching  €2,215  million.  In  both  scenarios,  the  investments  are 
slightly  higher  in  the  period  2021-2030  than  in  the  period  2031-2050.  Investments  on 
medium/large  LNG  terminals  are  about  15%  of  total  investments  in  LNG  terminals  in 
2021-2030 and 25% in 2031-2050.  

61 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  ANNEX 4: CURRENT STATUS OF THE AFI AND AFV MARKET IN 
EUROPE 

This  section  presents  an  overview  of  the  current  status  of  the  AFI  and  AFV  market  in 
Europe,  broken  down  by  fuel  type  and  transport  mode.  The  principle  source  of 
information/data  is  the  European  Alternative  Fuels  Observatory  (EAFO).  It  has  been 
supplemented by other sources, where relevant,  

1.  ELECTRICITY 

1.1 Electricity for road transport 

At  EU  level,  the  data  provided  by  EAFO  (see  Error!  Reference  source  not  found.) 
points to six -fold increase to the total number of electric charging infrastructure  over the 
period  2014-2019.  The  number  of  EVs  (BEVs  and  PHEVs)  during  the  same  period 
increased at an even higher rate (9.4 times) with the share BEVs remaining rather stable 
(ca.  60%).  The  EAFO  data  also  point  to  a  significant  increase  in  the  number  of  fast 
chargers (>22kW) per 100 km of highway (from 2 per 100 km in 2014 to 20 in 2019). 
Fast chargers represented in 2019 around 10% of the total public chargers, up from 5% in 
2014. According to T&E, there were approximately 780 ultra-fast chargers65 in Europe at 
the start of 2020. Germany has the highest number of ultra-fast recharging points (269), 
representing approximately a third of the network. Other MS with a significant number 
of ultra-fast recharging points are the Netherlands (98) and France (88).  

65 This number includes recharging points above 100kW in Europe (including Norway, Switzerland and UK) and excludes the Tesla 

Supercharger network.  

62 

 
 
 
 
                                                 
Table  6:  Evolution  of  electric  vehicles  and  charging  infrastructure  for  road 
transport in EU27 

Indicator 

Number  of  normal 
public 
chargers 
(≤22kW) 

Number of Fast public 
chargers (>22kW) 

2014 

24,917 

2015 

44,786 

2016 

93,721 

2017 

97,287 

2018 

2019 

107,502 

148,035 

1,331 

3,396 

8,124 

8,784 

11,155 

17,071 

Total chargers  

26,248 

48,182 

101,845 

106,071 

118,657 

165,106 

%  of  fast  chargers  in 
total 

Number  of  MS  with 
stations 

Fast  chargers  per  100 
km highway 

BEVs 

PHEVs 

5.1% 

7.0% 

8.0% 

8.3% 

9.4% 

10.3% 

24 (20 fast) 

2 

26 (24 
fast) 

5 

27 (25 
fast) 

7 

27 (25 
fast) 

12 

27 (25 fast) 

27 (25 fast) 

15 

20 

75,611 

146,700 

214,205 

299,380 

466,831 

726,706 

57,585 

128,651 

196,580 

272,625 

385,895 

517,395 

Total EVs 

133,196 

275,351 

410,785 

572,005 

852,726 

1,244,101 

%  share  of  new  M1 
registrations 

0.6% 

1.0% 

0.9% 

1.4% 

1.8% 

3.3% 

Vehicle  per  charging 
point (average) 
Source: EAFO and Ricardo elaboration 

5.7 

5.1 

4.0 

5.4 

7.2 

7.5 

The  overall  increase  of  EV  infrastructure  at  EU  level  is  not  equally  spread  across 
Member States. As can be seen, a small number of Member States are far ahead in terms 
of the density of the network while others are still at the very early stages. It highlights 
the  high  share  of  infrastructure  –  both  in  absolute  and  in  relative  terms  –  in  the 
Netherlands and less so in Germany and France. Luxembourg has also a high number of 
charging  points  per  population.  At  the  same  time,  among  the  frontrunners  there  have 
been different levels of development of fast infrastructure. Thus, Netherlands has only a 
small share of fast charging infrastructure (2.1%) in comparison to a much higher share 
in Germany (15.1%). Other Member States with high levels of recharging infrastructure 
include  Belgium,  Sweden,  Austria  and  Denmark  with  around  500  charging  points  per 
million population.  

63 

 
Figure  21:  Charging  infrastructure  in  EU27  by  Member  State,  type  and 
million population (2019) 

Source: EAFO 

The  comparison  of  the  evolution  of  recharging  points  between  2015  and  2019  point  to 
the fact that the Member States with the highest level of infrastructure (NL, LU, BE, DE, 
AT, SE. FR) are also those with the highest level of additional investment in the last few 
years,  based  on  budget  data  provided  in  the  NIR  (see  Error!  Reference  source  not 
found.). Nonetheless, even at smaller rates, all Member States saw an overall increase in 
the number of charging points per million population over the same period. At EU level, 
the number of charging points per million population increased from 112 in 2015 to 376 
in 2019 (on the basis of EAFO data).   

64 

 
 
Figure 22: New recharging points between 2015 and 2019 by Member State 
(total and per million population) 

Source: EAFO 

As  with  recharging  infrastructure,  the  increase  has  not  been  equal  amongst  Member 
States.  The  number  of  electric  vehicles  in  each  Member  State  at  the  end  of  2019  is 
presented in  Error! Reference source not found..  It  shows a high volume of vehicles 
for Germany and France in absolute terms. In relative terms (per million population) the 
higher  numbers  are  reported  in  the  Netherlands,  Sweden  and  (to  a  lesser  degree) 
Luxembourg  are  leading.  In  general,  BEVs  are  more  common  than  PHEV  with  the 
highest share of BEVs in Estonia (91%), Malta (87%), Latvia (82%) and Austria (81%). 
Sweden and Finland have the lowest share of BEV, with 32% and 21%, respectively.  

65 

 
 
 
Figure  23:  Electric  vehicles  in  EU27  by  Member  State,  type  and  million 
population (2019) 

Source: EAFO 

Furthermore, all EU MS have seen an overall increase in the number of electric vehicles 
from  2015  to  2019.  Except  for  Sweden  (which  has  seen  the  highest  increase  vehicles 
alongside only a moderate increase in infrastructure), the MS with the greatest increase in 
electric vehicles per million population from 2015 to 2019 are those with a corresponding 
high increase in recharging infrastructure.  

Figure  24:  New  electric  vehicles  between  2015  and  2019  (total  and  per 
million population) 

Source: EAFO 

66 

 
 
 
 
1.2 Electricity for water transport 

In  the  water  transport  sector,  data  from  EAFO  on  the  relevant  AFI  (including  onshore 
power supply and LNG) are less comprehensive. In relation to electricity installations in 
sea/inland  ports,  in  2015,  there  were  20  maritime  ports  in  the  EU  providing  shore  side 
electricity  (SSE)  supply  (high  or  low  voltage).  By  2019  this  had  increased  to  44  ports 
(European  Commission,  2020).  Out  of  the  44  EU  ports,  22  are  ports  on  TEN-T  Core 
Network  and  11  are  ports  on  the  TEN-T  Comprehensive  Network.  In  total,  there  were 
over 189 berths with SSE in these EU ports with voltage ranging from 0.4 to 11 kV and 
power ranging from 0.015 to 10 MW. Among the ports with SSE, 48% offer high voltage 
and 86% offered low-voltage electricity supply (ESPO, 2019). Fixed installation supply 
is  far more  widespread than mobile installations, with  96% and 16% of  equipped ports 
housing these types of infrastructure, respectively.  

In  terms  of  vessels  powered  by  electricity,  EAFO  includes  only  data  on  the  global 
seagoing fleet for 2020 with no corresponding data for inland shipping. As of May 2020, 
there  are  101  seagoing  vessels  using  SSE,  of  which  53  (52%)  are  pure  electric  and  48 
(48%) are plug-in hybrid ships. There are a further 125 hybrid vessels that do not require 
electric  infrastructure  in  ports.  According  to  report  on  the  State  of  Alternative  Fuels 
transport systems, however, there are 166 battery-powered vessels in operation, of which 
56%  are  passenger  ferries.  Furthermore,  less  than  0.5%  of  inland  waterway  vessels  are 
hybrid or electric. Interviews with ECSA and ESPO stated that OPS is available in only a 
limited number of ports.  

1.3 Electricity supply in airports 

An ACI EUROPE survey  in 2018 based on the replies of 51 airports, found that 42 of 
them  (82%)  provide  Fixed  Electrical  Ground  Power  to  aircraft  on-stand66.  In  the  same 
survey, 86% of respondents reported that their vehicle fleet included electric vehicles and 
47% included hybrid models. Furthermore, an interview with ACI noted that there are an 
increasing  number  of  airports  offering  fixed-electrical  ground  power.  However,  it  does 
not work for all types of operation, particularly low-cost airlines with short turn-around 
times.  

2.  NATURAL GAS 

In comparison to the electric charging infrastructure, the increase in the level of Natural 
gas (CNG/LNG) AFI has been more moderate. In the case of CNG, a network of around 
3,000  stations  was  already  in  place  in  2015  (mainly  in  Italy  and  in  Germany).  This 
increased by 20% (ca 3,500 stations), largely in line with the increase in the number of 
vehicles. The increase in the share of LNG stations was much greater (3.8 times) albeit 
from  a much lower starting point.  

66 https://ec.europa.eu/transport/sites/transport/files/2019-aviation-environmental-report.pdf  

67 

 
 
 
                                                 
Table  7:  Evolution  of  natural  gas  vehicles  and  fuelling  infrastructure  for 
road transport in EU27 by type 

Type 

CNG 

Indicator 

Number 
CNG 
stations  

of 
filling 

Number  of  MS 
with stations 

2014 

n.d. 

n.d. 

100 

per 
highway 

km 

n.d. 

2015 

2,957 

2016 

3,091 

2017 

3,111 

2018 

3,216 

2019 

3,519 

24 

3.9 

24 

4.1 

24 

4.1 

23 

4.2 

25 

4.6 

Number 
CNG 
vehicles 

of 
fuelled 

%  share  of  new 
M1 
registrations 

Vehicle 
filling 
(average) 

per 
station 

Number 
LNG 
stations 

of 
filling 

Number  of  MS 
with stations 

LNG 

1,065,157 

1,209,033  1,252,745  1,274,392  1,321,666  1,377,985 

1.0% 

0.7% 

0.5% 

0.4% 

0.5% 

0.6% 

n.d. 

408.9 

405.3 

409.6 

411.0 

391.6 

n.d. 

n.d. 

63 

8 

80 

10 

110 

133 

242 

11 

12 

15 

km 

n.d. 

0.08 

0.11 

0.15 

0.17 

0.32 

423 

6.7 

637 

3,128 

2,897 

4,154 

8.0 

28.4 

21.8 

17.2 

100 

per 
highway 

Number 
vehicles 

of 

257 

Vehicle 
filling 
(average) 

per 
station 

n.d. 

Source: EAFO 

CNG  In  terms  of  its  distribution,  the  CNG  network  is  concentrated  in  a  few  Member 
States. The greatest  share of filling stations  are located in  Italy (1,391 in 2019) both  in 
absolute and relative terms, representing close to 40% of the total filling stations in the 
EU. Other countries with high number of CNG infrastructure are DE (854), SE (192) and 
CZ (207). Accounting for population, AT and BG also display a high number of refilling 
stations. Since 2015, most investment in CNG filling station has taken place in Italy (217 
new stations), followed  by the CZ (99) and  BE  (87). Conversely, some  Member States 
have been reducing the number of CNG refuelling points, namely, AT, DE, PL, and LU.  

68 

 
 
Figure  25:  CNG  infrastructure  in  EU27  by  Member  State  and  million 
population (2019) 

Source: EAFO 

In terms of vehicles, Italy represents almost 80% of all CNG vehicles in Europe, with a 
ratio of 822 vehicles per refilling station. Other MS with a high ratio are Poland (309), 
Sweden  (295)  and  Finland  (213).  Italy  has  also  had  the  greatest  increase  in  number  of 
vehicles  since  2015  (103,106),  followed  by  Belgium  (16,543)  and  Czech  Republic 
(11,747).  

69 

 
 
Figure  26:  CNG  vehicles  in  EU27  by  Member  State  and  million  population 
(2019) 

Source: EAFO 

3.  LNG  

3.1 LNG for road transport 

At  the  end  of  2019,  LNG  fuelling  infrastructure  was  available  in  15  Member  States 
according to the EAFO. Italy had the greatest number of refuelling stations (59) followed 
by  Spain  (49).  However,  in  relative  terms,  Finland,  Netherlands  and  Sweden  have  the 
highest  number  of  infrastructure.  Since  2015,  the  number  of  refuelling  points  at  the 
Union level has increased almost fourfold, with a significant increase in infrastructure in 
Italy (47 new stations), Spain (49) and France (32).  

70 

 
 
   
Figure  27:  LNG  infrastructure  in  EU27  at  the end  of  2019  by  Member  State 
and per million population 

Source: EAFO 

According  to  the  EAFO,  there  were  only  5  Member  States  that  have  registered  LNG 
vehicles  at  the  end  of  2019.  However,  it  should  be  noted  that  on  the  EAFO  website, 
Bulgaria, Czech Republic, Finland, France, Poland, Slovakia and Slovenia have all had 
vehicles  registered  in  previous  years.  Heavy-duty  vehicles  make  up  99%  of  LNG 
vehicles in  the EU and the Netherlands is  the only MS to  have any other  LNG vehicle 
types  registered.  Italy  had  the  greatest  number  of  vehicles  (1.907)  followed  by  Spain 
(1,462), although Netherlands had the greatest per million population (33.3.).  

71 

 
 
 
Figure  28:  LNG  vehicles  in  EU27  at  the  end  of  2019  by  Member  State  and 
per million population 

Source: EAFO 

3.2 LNG for water transport  

In relation  to  water transport, in  2018 there  were 16 maritime ports in  Europe that had 
LNG  refuelling  points  in  operation  (European  Commission,  2020).  Most  of  them  were 
located  in  Belgium,  Spain,  France,  Lithuania,  Netherlands,  Portugal  and  UK.  While 
limited,  the  dedicated  LNG  bunkering  infrastructure  for  ships  has  also  increased 
significantly. At the beginning of 2019, there were 85 large-scale operational LNG tanks 
installed in 35 ports in EU, mainly in Spain (29 tanks in 9 ports) and Italy (8 tanks in 3 
ports) (European Commission,  2020). Furthermore, according to  the EAFO, there were 
50  LNG  powered  seagoing  vessels  in  Europe  (excluding  Norway)  at  the  end  of  2019, 
which will increase to 67 in 2020 according to forecasts. There are still a number of LNG 
ships on order and it estimated that the total fleet will increase to approximately 92 ships 
when fulfilled (European Commission, 2020). 

Concerning  inland  navigation,  there  are  no  specific  data  available.  However,  in  2018, 
there  was  considered  to  be  sufficient  LNG  bunkering  to  meet  the  demand  from  a  very 
low number of LNG vessels in use. There are 14 LNG inland vessels operating in Europe 
today, of which 9 are tanker vessels, and a further 12 on order.  

4.  HYDROGEN 

4.1 Hydrogen for road transport 

At EU level, the number of hydrogen filling stations in operation across the EU in 2019 
was still very small (127), up from 35 in 2016 and 39 in 2018. The number FCEVs has 
also  increased  during  the  same  period  but  an  even  slower  pace  (as  can  be  seen  from 

72 

 
 
 
lower ratio of vehicles to refuelling stations) and the total number of vehicles is still very 
small (1200 at the end of 2019).  

Table 8: Evolution of hydrogen vehicles and fuelling infrastructure for road 
transport in EU27 

Indicator 

Number of filling stations 

Number of MS with stations 

per 100 km highway 

Number of FCEVs 

Vehicle per filling station (average) 

2014 

n.d. 

n.d. 

n.d. 

59 

n.d. 

2015 

n.d. 

9 

n.d. 

229 

n.d. 

2016 

2017 

2018 

35 

10 

0.05 

431 

12.3 

39 

10 

0.05 

630 

16.2 

39 

10 

0.05 

817 

20.9 

2019 

127 

10 

0.15 

1,203 

9.5 

The network of H2 infrastructure is concentration in a small number of MS. More than 
half of the H2 filling stations in 2019 (60%) were located in Germany (76), followed by 
France (14). In relative terms, Denmark has the most refuelling stations (1.7 per million 
population). In total, only 10 MS had at least one filling station in operation at the end of 
2019. Most common types of hydrogen refuelling stations are the high pressure (700 bar) 
stations  for  road  vehicles  (108  according  to  EAFO).  At  EU  level,  the  number  of 
refuelling stations remained fairly constant until 2019 where there was threefold increase, 
with over 70% of new refuelling stations deployed in Germany.   

Figure  29:  Hydrogen  infrastructure  in  MS  that  have  at  least  one  refilling 
station, by Member State and million population (2019) 

Source: EAFO 

The number of hydrogen vehicles has seen a steadier increase at EU level since 2014. In 
total,  11  countries  had  registered  hydrogen  vehicles  in  2019,  compared  to  7  Member 
States in 2015. At the end of 2019, France had the greatest number of hydrogen vehicles 
(413) followed by Germany (266). Adjusting for population, Denmark and Netherlands 

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have  the  most  hydrogen  vehicles  with  18.1  and  13.6  vehicles  per  million  population, 
respectively.  

Figure  30:  Hydrogen  infrastructure  in  MS  with  at  least  one  hydrogen 
vehicle, by Member State and million population (2019) 

Source: EAFO 

4.2 Hydrogen for waterborne transport 

In  recent  years,  there  has  been  early  adoption  of  hydrogen  for  waterborne  transport, 
although the number of vessels powered by hydrogen is still extremely low. For maritime 
transport,  there  are  three  hydrogen  vessels  in  operation  and  on  order.  In  addition,  the 
Commission funded a retrofit of an inland freight vessel, which features a diesel-electric 
powertrain and can be powered by hydrogen. In terms of infrastructure, there is no data 
to report on.  

5.  OTHER FUELS 

5.1 LPG 

In terms of infrastructure and vehicles, LPG was established as a fuel for road transport 
before the adoption of the AFID. There was a total of 8 million LPG vehicles in 2019, up 
from  7.3  in  2014  and  the  number  of  filling  stations  also  increased  along  similar  lines. 
However, year on year increase of LPG vehicles has decreased, with the number of new 
registrations  of  LPG  vehicles  representing  only  0.9%  in  2020  of  total  vehicle 
registrations, down from 3.5% in 2014.       

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Table  9:  Evolution  of  LPG  vehicles  and  fuelling  infrastructure  for  road 
transport in EU27 by type 

of 

filling 

Indicator 
Number 
stations  
Number  of  MS  with 
stations 
per 100 km highway 

2014 

29,343 

25 

n.d. 

2015 

29,733 

25 

n.d. 

2016 

29,969 

25 

n.d. 

Number of vehicles 

7,282,036 

7,607,215 

7,737,726 

2017 

31,174 

25 

n.d. 

7,847,447 

2018 

32,196 

2019 

33,724 

26 

26 

n.d. 
7,936,844 

n.d. 
8,011,479 

%  share  of  new  M1 
registrations 
Vehicle 
station (average) 
Source: EAFO 

filling 

per 

1.9% 

248.2 

1.9% 

255.9 

1.8% 

258.2 

2.0% 

251.7 

1.3% 

246.5 

1.5% 

237.6 

At national level,  LPG refuelling stations are present in all Member States but Finland. 
Poland,  Germany,  Italy,  Bulgaria  and  France  are  the  countries  with  higher  number  of 
LPG  fuelling  stations  and  Bulgaria  has  the  highest  number  when  adjusting  for 
population. However, while the overall number of refuelling points has increased in the 
EU  from  2015  to  2019,  several  Member  States  that  have  reduced  the  number  of 
refuelling  points  in  this  period,  including  Bulgaria,  Romania,  Czech  Republic  and  the 
Netherlands.  

Figure  31:  LPG  infrastructure  in  EU27  by  Member  State,  type  and  million 
population (2019) 

Source: EAFO 

In terms of vehicles, at the end of 2019, Poland and Italy had the greatest  LPG vehicle 
stock, accounting  for almost 70% of  all  LPG vehicles  in  the EU. Since  2015,  Italy  has 
seen  the  greatest  increase  in  the  number  of  vehicles,  while  Poland’s  LPG  fleet  has 
reduced.  Romania,  Spain  and  Greece  have  also  seen  a  large  increase  in  the  vehicle 
number  during  this  period  but  in  almost  half  of  the  Member  States  there  has  been  a 
reduction to the LPG vehicle fleet. 

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Figure  32:  LPG  vehicles  in  EU27  by  Member  State,  type  and  million 
population (2019) 

Source: EAFO 

5.2 Biofuels 

Data on the use of biofuels in transport are sparse and infrequently reported. Low blend 
bioethanol  (e.g.  E5,  E10)  is  supported  by  traditional  refuelling  infrastructure,  thus  is 
widely  available  across  the  EU.  However,  high  bioethanol  blends  (e.g.  E85,  E100) 
require  adaptations  to  refuelling  infrastructure,  which  has  led  to  a  more  fragmented 
market, with some countries (e.g. Sweden) showing a clear preference for their use. Of 
the  high  blend  bio-gasolines,  E85  is  the  most  prominent  and  is  available  in  8  Member 
States,  according  to  EAFO.  Sweden  has  the  greatest  number  of  E85  refilling  stations 
(1700), followed by France (1000) and Hungary (403). There is an emerging market for 
ED95  in  Finland,  France  and  Sweden,  although  no  specific  data  on  the  number  of 
equipped  refuelling  points  is  available.  In  terms  of  biodiesel,  there  are  9  refuelling 
stations available for rapeseed methyl ester (European Commission, 2020).  

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Figure  33:  E85  refuelling  points  in  EU27  by  Member  State  and  per  million 
population 

Source: EAFO 

77