COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the technological and market readiness of heavy-duty road transport vehicles
Date: 2025-05-27
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: clean technology, commercial vehicle, electric vehicle, energy resources, hydrogen, large vehicle, motor vehicle pollution, reduction of gas emissions, sustainable mobility, technical specification

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 27.5.2025  COM(2025) 260 final  COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the technological and market readiness of heavy-duty road transport vehicles  
 
 
Introduction 

1 
The amended CO2 emission performance standards for new heavy-duty vehicles1 set ambitious 
emission reduction targets for new lorries, buses and coaches for 2030 and beyond. Meeting 
those targets will require rapid market uptake of zero-emission vehicles (ZEVs). In order to 
provide the conditions to enable those zero-emission vehicles to enter the market, Regulation 
(EU) 2023/18042 on the deployment of alternative fuels infrastructure (AFIR) sets mandatory 
deployment  targets  for  sufficient  minimum  dedicated  publicly  accessible  recharging  and 
hydrogen refuelling infrastructure along the TEN-T road network, in urban nodes and in safe 
and secure parking areas. 

To  reflect  the  rapid  developments  in  demand  for  alternative  fuels,  Article 24(1)  of  that 
Regulation  requires  the  Commission  to  adopt  a  technology  and  market-readiness  report 
dedicated to heavy-duty vehicles (HDVs). The article further specifies that the report should 
take into account the initial indications of the preferences of the market. It should also consider 
technological developments in the short term, in particular regarding recharging and refuelling 
standards and technologies, such as high-power recharging standards and electric road systems 
(ERS), and the use of liquid hydrogen. In relation to hydrogen refuelling stations, the report 
should  analyse  the  extent  to  which  the  technical  requirements  referred  to  in  Article 6  of 
Regulation (EU) 2023/1804 are in line with technological and market developments. 

Accordingly, this report provides an analysis of the technology and market readiness of zero-
emission  heavy-duty  vehicles,  taking  into  account  observed  powertrain  technological 
developments  and  market  trends  as  well  as  corresponding  recharging  and  refuelling 
reached  on  Regulation 
infrastructure  deployment  since  political  agreement  was 
(EU) 2023/1804. The assessment presented in this report draws on information received from 
discussions in the Commission Sustainable Transport Forum expert group as well as an external 
support study3 in which relevant market actors were also consulted. 

1  

2  

3  

Regulation  (EU) 2024/1610  of  the  European  Parliament  and  of  the  Council  of  14 May  2024  amending 
Regulation  (EU) 2019/1242  as  regards  strengthening  the  CO2  emission  performance  standards  for  new 
heavy-duty  vehicles  and  integrating  reporting  obligations,  amending  Regulation  (EU) 2018/858  and 
repealing  Regulation  (EU) 2018/956  (Text  with  EEA  relevance),  OJ  L,  2024/1610,  6.6.2024,  ELI: 
http://data.europa.eu/eli/reg/2024/1610/oj. 
Regulation (EU) 2023/1804 of the European Parliament and of the Council of 13 September 2023 on the 
deployment  of  alternative  fuels  infrastructure,  and  repealing  Directive 2014/94/EU  (Text  with  EEA 
relevance), 
OJ L 234, 22.9.2023, p. 1, ELI: http://data.europa.eu/eli/reg/2023/1804/oj. 
Transport & Mobility Leuven, Ramboll & University of Antwerp,  Market Readiness Analysis: Expected 
uptake  of  alternative  fuel  heavy-duty  vehicles  until  2030  and  their  corresponding  infrastructure  needs, 
European Commission Publications Office, 2025.  

1 

 
 
 
Regulatory background 

2 
In line with the EU’s commitment to become climate-neutral by 2050, the revised CO2 emission 
performance standards for new heavy-duty vehicles4 set emission reductions targets for new 
lorries,  city  buses  and  coaches.  A  summary  of  the  legally  binding  targets  to  be  met  by 
manufacturers for new registrations set in the amended CO2 emission performance standards is 
presented in Table 1. 

Scope  

Target year 

CO2 emission reduction target compared to 
2019 levels 

Fleet wide new motor 
vehicles (lorries > 
5 tonnes; buses and 
coaches > 7.5 tonnes) 

Urban buses > 7.5 t 
(ZEV mandate) 

2030 

2035 

2040 

2030 

2035 

45% 

65% 

90% 

90% (ZEV mandate) 

100% (ZEV mandate) 

Table 1: Overview of the targets set in the revised HDV CO2 standards 

In  order  to  meet  the  2030  reduction  targets5,  manufacturers  will  have  to  address  almost  all 
categories of vehicle, in particular almost all lorries of more than 16 tonnes, which account for 
75% of HDV sales in the EU. 

In  order  to  ensure  that  the  lack  of  publicly  accessible  recharging  and  hydrogen  refuelling 
infrastructure  does  not  create  a  bottleneck  in  the  necessary  market  uptake  of  zero-emission 
heavy-duty  vehicles,  Regulation  (EU) 2023/1804  sets  mandatory  deployment  targets  for 
dedicated infrastructure for heavy-duty vehicles. With initial electric recharging targets set for 
this year, 2025, and 2027, full coverage of the EU’s main transport network (the TEN-T road 
network)6 with dedicated recharging and hydrogen refuelling infrastructure is set to be achieved 
by  2030.  This  should  allow  zero-emission  road  vehicles  to  be  used  throughout  the  EU.  A 
summary  of  the  recharging  and  H2  refuelling  infrastructure  requirements  is  presented  in 
Table 2. 

4  

5  
6  

Regulation (EU) 2019/1242 of the European Parliament and of the Council of 20 June 2019 setting CO2 
emission performance standards for new heavy-duty vehicles and amending Regulations (EC) No 595/2009 
and  (EU) 2018/956  of  the  European  Parliament  and  of  the  Council  and  Council  Directive 96/53/EC,  
OJ L 198/202, 25.7.2019, p. 202, ELI: http://data.europa.eu/eli/reg/2019/1242/oj. 
Vocational and some smaller VECTO groups are not included in the CO2 emission performance standards. 
Regulation  (EU) 2024/1679  of  the  European  Parliament  and  of  the  Council  of  13 June  2024  on  Union 
guidelines  for  the  development  of  the  trans-European  transport  network,  amending  Regulations 
(EU) 2021/1153  and  (EU)  No 913/2010  and  repealing  Regulation  (EU)  No 1315/2013  (Text  with  EEA 
relevance), OJ L 2024/1679, 28.6.2024, ELI: http://data.europa.eu/eli/reg/2024/1679/oj. 

2 

 
 
 
 
 
Target 
year 

Scope 

Minimum capacity requirements  

TEN-T core 

2030 

TEN-T 
comprehensive 

Urban nodes 

Safe and secure 
parking 

One dedicated HDV recharging pool with at 
least 3 600 kW of aggregated power output 
with at least two points of minimum 350 kW 
H2 refuelling stations for cars and lorries 
with a minimum capacity of 1 tonne per day 
and equipped with at least a 700 bar 
dispenser 
One recharging pool with at least 1 500 kW 
of aggregated power with at least one point 
of min. 350 kW 
Recharging points with a minimum of 
150 kW each and with an aggregated power 
output of at least 1 800 kW 
One hydrogen refuelling station for cars and 
lorries 
At least four recharging stations of at least 
100 kW in all safe and secure parking areas 

Distance 
requirements 
Every 60 km in 
each direction of 
travel 

Every 200 km 

Every 100 km in 
each direction of 
travel 

Table 2: AFIR requirements for dedicated recharging infrastructure for HDVs by 31 December 2030 

Assessment of market readiness of zero-emission heavy-duty vehicles 

3 
In 2023 a total of just below 6.7 million heavy-duty vehicles, such as lorries, city buses and 
long-distance coaches, were registered in the EU, around 6 million of which were lorries above 
3.5 t7.  In  the  same  year,  about  380 000  new  HDVs  were  registered.  Those  vehicles  are 
responsible for 28% of greenhouse gas (GHG) emissions from road transport in the EU and 
account for over 6% of total EU-27 GHG emissions8. 

Zero-emission heavy-duty vehicles are defined under the CO2 emission performance standards 
for heavy-duty vehicles as vehicles without a combustion engine, or with a combustion engine 
emitting very little CO2

9. 

There  are  currently  two  groups  of  technologies  that  can  meet  these  requirements:  battery 
electric  vehicles  (BEVs)  and  hydrogen  (H2)-fuelled  vehicles.  Hydrogen-fuelled  vehicles 
include both fuel cells (H2 FCs) and internal combustion engines (H2 ICEs). Figures for low-
emission  plug-in  hybrid  vehicles  (PHEVs)  –  although  they  do  not  qualify  as  zero-emission 
vehicles – are also, where relevant, presented in this section, as they contribute to the demand 
for recharging infrastructure10. 

7 https://www.acea.auto/files/ACEA_Report_-_Vehicles_on_European_roads_2025.pdf  
8 https://www.eea.europa.eu/data-and-maps/data/data-viewers/greenhouse-gases-viewer. 
9 No more than 3 g CO2/(tkm) or 1 g CO2/(pkm) as determined in accordance with Regulation (EU) 2017/2400, or 
no more than 1 g/kWh of CO2 as determined in accordance with Regulation (EC) No 595/2009 or no more than 
1 g/km of CO2 as determined in accordance with Regulation (EC) No 715/2007. 
10  Other  alternative powertrain and fuel  technologies  (LNG, CNG,  biofuels,  e-fuels) have not  been part of  the 
required focus of this report. 

3 

 
 
 
 
 
 
 
 
 
Status quo and latest market developments 

3.1 
Although the share of the overall HDV fleet accounted for by zero-emission vehicles is still 
very small, it has been growing quickly over the last few years, mainly due to growth in battery 
electric vehicles, models of which are now available for all use cases. In other words, vehicles 
with  various  ranges  can  be  deployed  for  different  types  of  services  for  both  freight  and 
passenger transport. 

3.1.1  Lorries 
At the end of 2024, the fleet of zero-emission lorries registered in the EU consisted of more 
than 15 000 battery electric lorries and 170 hydrogen lorries. Additionally, more than 300 low-
emission plug-in hybrid lorries had been registered across the EU11. 

More than 7 500 battery electric lorries were newly registered during 2024, accounting for 2.3% 
of all registrations. Of the lorries registered in that period, only 106 were hydrogen lorries. The 
highest share of battery electric lorries reported was in the category of medium lorries with a 
technically permissible maximum laden mass exceeding 5 t but not exceeding 7.4 t (5.4% of 
total registrations)12. 

Figure 1: Lorry fleet and new registrations. Source: EAFO, end of 2024 

3.1.2  Buses and coaches 

Although  zero-emission  buses  and  coaches  (M2  and  M3  vehicles)13  accounted  for  a 
significantly  larger  share,  they  were  driven  almost  exclusively  by  the  urban  bus  segment, 
whereas there are only a few zero-emission coaches in the market. The total stock of battery 
electric buses and coaches reached 23 000 in 2024 while the number of hydrogen buses and 
coaches was close to 500. Low-emission plug-in hybrid vehicles played a slightly bigger role 

11 Unless specified otherwise, all numbers used in this document are taken from the European Alternative Fuels 
Observatory (EAFO), www.eafo.eu. 
12 Transport & Mobility Leuven, Ramboll & University of Antwerp, Market Readiness Analysis: Expected uptake 
of  alternative  fuel  heavy-duty  vehicles  until  2030  and  their  corresponding  infrastructure  needs,  European 
Commission Publications Office, 2025. 
13  Annex II  to  Directive 2007/46/EC  of  the  European  Parliament  and  of  the  Council  of  5 September  2007 
establishing a framework for the approval of motor vehicles and their trailers, and of systems, components and 
separate technical units intended for such vehicles (Framework Directive) (Text with EEA relevance), OJ L 263, 
9.10.2007, p. 1, ELI: http://data.europa.eu/eli/dir/2007/46/oj. 

4 

 
 
 
 
 
in the bus segment than in the lorry segment, with a vehicle stock reaching 1 000 vehicles at 
the end of 2024. 

Approximately 6 600 new BEVs were sold in 2024, almost all of them urban buses. 18.4% of 
all buses and coaches – and 40% of all urban buses – newly registered in 2024 were BEVs. A 
total of 113 H2 buses and coaches were registered over the same period. 

Figure 2: Fleet and market share of total registrations of buses and coaches. Source: EAFO, end of 
year 2024 

3.2  Market availability of zero-emission vehicles 

According to publicly available data and a survey carried out by the support study to this report, 
vehicle manufacturers, commonly referred to as original equipment manufacturers (OEMs), are 
developing and investing in a wide range of technologies and drivetrains to decarbonise their 
fleet.  In  terms  of  the  number  of  models  available  on  the  market,  however,  battery  electric 
vehicles  are  clearly  the  predominant  investment  choice  of  manufacturers.  More  than 
100 models were available in 2024 compared to around 20 models of fuel cell electric vehicles 
(FCEVs)  while  first  models  of  H2  ICEs  are  entering  the  market  in  2025  in  small  series 
production. In the market segments of lorries above 7.4 tonnes, there are around 40 heavy-duty 
BEV models and 6 FCEV models available. Medium lorries include around 15 BEV models 
and one FCEV model. The bus segment accounts for the largest part of the overall range of 
zero-emission  models,  with  around  60  BEV  bus  models  and  around  15  FCEV  bus  models 
available. The range of zero-emission models in the coach segment remains limited, with three 
BEV models and one FCEV model currently available14. EU funded Research & Innovation 
has supported technological developments towards zero-emission HDV powertrains since FP7 
with topics focused on both truck and buses, and more recently on HDV long-haul operations 
and megawatt charging system.15  

14  

15  

‘ZETI  Data  Explorer.’  2024.  Accessed:  11 Sep.  2024. 

CALSTART, 
https://globaldrivetozero.org/tools/zeti-data-explorer/. 
As examples, see EGVI and 2Zero partnership projects ZeEUS, TRANSFORMERS, LONGRUN, 
AEROFLEX, NextETRUCK, ESCALADE, EMPOWER, ZEFES, EBRT2030, MACBETH, FLEXMCS; 
and FCH JU and Clean Hydrogen partnership projects StaSHH, CoacHyfied, H2Haul, H2Accelerate in 
https://cordis.europa.eu/ 

[Online].  Available: 

5 

 
 
 
 
 
Investment planning published by all major OEMs shows that battery electric solutions are set 
to  remain  strongly  predominant  among  zero-emission  powertrains  for  heavy-duty  road 
transport  for  at  least  the  rest  of  the  current  decade.  New  models  are  announced  for  series 
production in all categories between 2025 and 2030, widening the range of models in the long-
haul and interurban coach segments, in particular. Most vehicle manufacturers have, however, 
also  announced  future  investment  in  hydrogen  models  for  all  segments.  These  include  new 
hydrogen fuel cell vehicles and liquid hydrogen fuel cell solutions, but also vehicles powered 
by hydrogen combustion. 

Availability and performance of current zero-emission technologies 

3.3 
Battery electric 

BEV models are available for all use cases of passenger and freight transport services. Current 
battery electric city buses typically have ranges of around 300-400 km. Battery electric trucks 
for urban delivery typically have a range of around 100 km, while battery electric trucks for 
regional  distribution  have  ranges  of  300-400 km.  Current  battery  electric  long-haul  trucks 
typically have a range of around 500 km, but demonstration tests have already reached ranges 
of up to 800 km and more. Most lorry transport services cover a distance of 600 km or less. 
These ranges already allow the operational needs of the vast majority of operators to be met, 
depending on the availability of recharging infrastructure and taking account of driving time 
rules and mandatory rest breaks. Battery electric long-haul truck models with ranges of 700-
800 km are announced for serial production in 2025 and subsequent years. 

From a total cost of ownership (TCO) perspective, battery electric vehicles are already able to 
compete with conventional vehicles in some use cases. This is the case for urban buses and 
urban delivery trucks, in particular. Their significantly higher purchase costs – which can be 
more than twice as high as those of a comparable combustion engine vehicle – still present a 
significant  barrier  to  their  adoption,  however,  especially  by  SMEs  with  limited  access  to 
finance. 

The  combined  charging  standard  (CCS)  is  the  charging  technology  currently  available  for 
recharging battery electric vehicles. The megawatt charging system (MCS) standard should be 
finalised and adopted by international standardisation organisations in 2025. The CCS is the 
direct-current (DC) charging standard currently applied to all DC charging of battery electric 
vehicles in the EU. The MCS standard enables much higher charging power of up to more than 
1 MW16 and additional safety  features. Several  OEMs  and charging point  operators indicate 
that they expect the MCS standard to fully replace the CCS over time, in both vehicle inlets and 
recharging  infrastructure.  In  the  long  term,  these  stakeholders  expect  all  new  heavy-duty 
vehicles to be equipped with MCS inlets and the HDV charging market to develop fully towards 
the MCS, including for recharging points with a power of below 400 kW. It is not, however, 
clear how long this transition will take. At least in the short and medium terms, both the CCS 

16  

Although the MCS standard will allow charging of up to 3 MW, such a high charging power is currently 
not considered necessary for road vehicles. Power output of up to 1 MW is considered sufficient to meet 
the needs for recharging during the mandatory rest times of drivers of such vehicles. 

6 

 
 
 
and the MCS are widely expected to coexist as standards for the recharging of battery electric 
vehicles. 

Hydrogen 

In general, hydrogen heavy-duty vehicles have longer driving ranges than most battery electric 
heavy-duty vehicles. One H2 FC truck available in series production has a range of up to 800 km 
and one prototype is expected to reach a range of 1 000 km. Current FCEV urban buses have a 
range of around 400 km, which is comparable to similar BEV buses. 

As stated in Section 3.2, there are currently far fewer hydrogen than battery electric HDVs on 
the market. Although there are, in general, more hydrogen vehicles in the bus segment than in 
the lorry segment, prices remain high and production capacity limited in all segments. Most 
existing vehicles are fuel cell vehicles that run on compressed hydrogen at either 350 or 700 bar. 
In order to increase range and reduce refuelling times, however, some manufacturers have said 
that  they  plan  to  develop  HDVs  running  on  liquid  hydrogen.  At  the  same  time,  some 
manufacturers have announced that they will produce hydrogen internal combustion vehicles. 
Although much less efficient than fuel cell vehicles, hydrogen internal combustion vehicles are 
cheaper to produce and the technology is considered easier to manage. The market uncertainty 
about  technology  choices for hydrogen vehicles  has  not  decreased since  political  agreement 
was  reached  on  Regulation  (EU) 2023/1804.  This  continues  to  present  problems  to  the 
deployment  of  corresponding  refuelling  infrastructure  as  the  different  technologies  require 
different infrastructure configurations. 

The  initial  purchase  cost  and  operational  costs  of  hydrogen  fuel  cell  vehicles  are  at  present 
much higher  than  both  conventional  vehicles  and battery electric ones, resulting  in  a higher 
TCO under all use cases. Hydrogen internal combustion engine vehicles are expected to have 
lower purchase costs, but significantly higher operational costs, with the exact level depending 
on hydrogen production costs and market prices. Hydrogen vehicles may, however, be able to 
offer operational advantages that might make them preferable to BEVs in specific use cases, 
such as greater torque power, which is essential in the context of transporting very heavy goods. 

Electric road systems (ERSs) and battery swapping 

Electric road systems are designed to provide vehicles with electricity while in motion. This 
allows vehicles to have smaller batteries and reduces the need for stationary charging. There 
are at least three different ERS technologies: catenary systems, inductive charging and ground 
contact charging (e.g. through a rail). On the basis of pilot projects in various Member States 
(Germany, France, Italy, Sweden), the technology has been demonstrated but a broad use case 
is not expected in the short term. There are at present no concrete plans in Germany to expand 
the pilots, and the planned electric road procurement programme in Sweden was stopped since 
the  technology-,  investment-,  operation-  and  maintenance-related  risks  were  considered  too 
high. 

Furthermore, given the long planning and construction time required to cover even relatively 
short road segments, it would be impossible for this technology to cover more than a very small 
part of the European TEN-T road network – which extends over more than 100 000 km – in the 

7 

 
 
short or medium term. The ERS is therefore not expected to make a significant contribution to 
the decarbonisation of HDV transport in Europe by 2030. 

In China, battery swapping has gained momentum in heavy-duty vehicles, in particular, with 
major battery manufacturers investing in this technology. Battery swapping can have significant 
benefits: it facilitates the integration of battery electric vehicles into the electricity system by 
increasing  flexibility,  as  charging  the  batteries  requires  less  power  from  the  electricity  grid 
overall. Despite the existence of a standardisation mandate, European car manufacturers have 
not,  however,  shown  any  interest  in  the  technology  because  of  operational  problems  in 
swapping  and  vehicle  design,  with  batteries  often  being  fully  integrated  into  the  vehicle 
structure.  Nor  have  European  HDV  manufacturers  so  far  shown  any  interest  in  developing 
battery swapping for HDVs. Under the review of Regulation (EU) 2023/1804, the Commission 
will further examine this technology and the relevance and maturity of setting further common 
technical specifications in the EU. 

Expected zero-emission fleet development 

3.4 
Manufacturers have stated publicly that they will both make use of a growing share of zero-
emission vehicles and improve the energy efficiency of their conventional models in order to 
meet the 2025 and 2030 CO2 emission performance standards for heavy-duty vehicles. In this 
context, manufacturers indicated, in the stakeholder consultation carried out under the support 
study, that approximately one in three new heavy-duty vehicles could be expected to be zero-
emission by 2030. 

Estimates  from  various  sources  indicate  that  by  2030  the  zero-emission  vehicle  fleet  will 
comprise in total between 410 000 and 600 000 vehicles (equivalent to between 5% and 9% of 
the HDV fleet). A clear majority of these will be battery electric vehicles: market development 
estimates vary from 65% to more than 90%, with most studies and recent analyses now seeing 
the market at the upper end of the range. Current market shares and announced zero-emission 
vehicle  models  therefore  suggest  that  manufacturers  will  rely  heavily  on  battery  electric 
vehicles in order to reach their 2030 targets. 

4 
4.1 

Infrastructure requirements 
Current development of recharging and hydrogen refuelling infrastructure 

Existing infrastructure 

By the end of 2024, about 140 000 publicly accessible DC recharging points were deployed in 
the EU, of which more than 65 000 were between 150 kW and 350 kW and more than 16 000 
above 350 kW. While most of that recharging infrastructure is designed to serve cars and vans, 
electric  HDVs  can  also  use  it  when  the  dimensions  of  the  recharging  point  and  the  space 
surrounding it allow them to. This may be possible for smaller lorries, in particular, but not for 
most larger ones. Several manufactures have demonstrated that it is already possible to drive 
heavy battery electric trucks across the EU, although it requires a lot of flexibility in terms of 
charging and trailer parking, which is not conducive to real mass-market operation. 

8 

 
 
 
What  is  required  for  mass-market  operation  is  a  dedicated  publicly  accessible  recharging 
infrastructure  network  for  heavy-duty  vehicles  as  envisaged  by  Regulation  (EU) 2023/1804. 
Although no such network currently exists, the situation is expected to change quickly in the 
coming years. A large number of recharging infrastructure installation projects have already 
started  or  are  about  to  start,  many  of  them  assisted  by  the  Alternative  Fuels  Infrastructure 
Facility (AFIF) under the Connecting Europe Facility (CEF)17 (see next section), while others 
with the help of public funding by the respective Member State and under the applicable State 
aid laws18.   

By the end of 2024, more than 250 hydrogen stations, serving a total of 4 700 cars, 320 vans, 
140  lorries  and  320  buses,  had  been  deployed  in  the  EU.  The  existing  H2  refuelling 
infrastructure is broadly sufficient for the current H2 HDV vehicle fleet. Current market trends 
and the latest time frames announced for the series production of new H2 vehicle models by 
OEMs indicate that before 2030 the number of hydrogen heavy-duty vehicles on the market is 
unlikely to reach a level that would require significantly higher capacity than already provided 
for under Regulation (EU) 2023/1804 to ensure network coverage.  Limited vehicle availability 
and lack of availability and affordability of hydrogen – rather than infrastructure deployment – 
are currently the main obstacles to market uptake of hydrogen fuelled road transport vehicles. 

Figure 3: Existing DC recharging and hydrogen refuelling infrastructure. Source: EAFO, end 
of 2024 

Short-term trends and EU support 

In  response  to  the  CO2  emission  performance  standards  for  heavy-duty  vehicles  and  the 
requirements for dedicated recharging infrastructure under Regulation (EU) 2023/1804, a range 
of different companies are investing in both dedicated truck recharging and hydrogen refuelling 

17  

18  

Regulation (EU) 2021/1153 of the European Parliament and of the Council of 7 July 2021 establishing the 
Connecting Europe Facility and repealing Regulations (EU) No 1316/2013 and (EU) No 283/2014 (Text 
with EEA relevance), OJ L 249, 14.7.2021, p. 38, ELI: http://data.europa.eu/eli/reg/2021/1153/oj. 
The relevant State aid instruments, most commonly used to assess compatibility of investments in charging 
infrastructure,  are  the  Guidelines  on  State  aid  for  climate,  environmental  protection  and  energy  2022, 
C/2022/481, OJ C 80, 18.2.2022, p. 1–89, Section 4.3; as well as the Green Deal General Block Exemption 
Regulation, Regulation (EU) No 651/2014 of 17 June 2014 declaring certain categories of aid compatible 
with the internal market in application of Articles 107 and 108 of the Treaty, Articles 36a and 36b. 

9 

 
 
 
 
 
infrastructure.  Under  the  AFIF,  the  European  Commission  supports  the  deployment  of  this 
infrastructure19. 

Under  the  second  (2024-2025)  phase,  AFIF  support  is  specifically  targeted  at  high-power 
recharging for battery electric trucks. Under the first cut-off date, there was particularly great 
interest in investments in electric recharging infrastructure dedicated to HDVs. It is expected 
that grant agreements will be signed for up to 2 070 recharging points (up to 1 540 points of 
350 kW and up to 530 of at least 1 MW) at around 600 locations in 17 Member States. This 
represents around 20% of locations and around 15% of the aggregated power output required 
under Regulation (EU) 2023/1804 by 2030. There will be two further cut-off dates under the 
second AFIF call. Many Member States have started national programmes to support industry 
in  building  up  the  required  dedicated  HDV  recharging  infrastructure.  This  dedicated 
infrastructure  will  supplement  more  than  2 000  existing  fast  recharging  points  of  at  least 
360 kW  financed  under  the  first  phase  of  the  AFIF.  This  could  support  smaller  lorries,  in 
particular. The AFIF is already supporting the deployment of 178 hydrogen refuelling stations 
across the EU under the first (2022–2024) phase, with around an additional 30 to be financed 
under the first cut-off date of the second phase. 

While industry interest in investing in recharging infrastructure is growing, many projects at 
present face delays because of lengthy permission and grid connection procedures. In fact, both 
the support study and stakeholder consultations indicate that the primary barrier to deploying a 
widespread charging network for heavy-duty vehicles is access to the electricity grid, not the 
cost of deploying the recharging infrastructure. In order to accelerate the deployment of zero-
emission heavy-duty vehicles, it will be crucial to prepare electricity grids for increased demand 
at charging hubs and depots by strengthening the grid and addressing permission processes to 
reduce  lead  times  for  grid  connections.  It  will  also  be  important  to  make  plans  to  enable 
recharging  sites  to  meet  the  requirements  for  recharging  points  and  pools  laid  down  in 
Regulation (EU) 2023/1804, including safe and secure parking areas for trucks. The need for 
accelerating  permitting  procedures  and  provisions  for  specific  grid  priority  areas  will  be 
addressed  as  part  of  the  pilot  European  Transport  Corridor  initiative  developed  under  the 
Competitiveness  Coordination  Tool,  as  announced  in  the  Industrial  Action  Plan  for  the 
European automotive sector20. 

Recharging infrastructure needs up to 2030 

4.2 
According to all market actors and the information gathered through the support study for this 
report, battery electric HDVs will rely on a combination of depot charging, using primarily 100-

19  

20  

(Text  with 

Article 9  of  Regulation  (EU) 2021/1153  of  the  European  Parliament  and  of  the  Council  of  7 July  2021 
establishing  the  Connecting  Europe  Facility  and  repealing  Regulations  (EU)  No 1316/2013  and  (EU) 
No 283/2014 
ELI: 
http://data.europa.eu/eli/reg/2021/1153/oj. 
Communication from the Commission to the European Parliament, the Council, European Economic and 
Social Committee and the Committee of Regions of 5 March 2025. Industrial Action Plan for the 
European automotive sector, COM(2025) 95 final. https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=celex:52025DC0095 

relevance),  OJ 

14.7.2021, 

p. 38, 

EEA 

249, 

L 

10 

 
 
 
 
150 kW  chargers,  and  publicly  accessible  high-power  charging  of  likely  up  to  1 MW  and 
overnight  charging at around  100 kW.  Operators will  maximise the share of depot  charging 
wherever possible, because of lower cost per kWh. 

Depending  on  their  operational  needs,  different  use  cases  will  result  in  different  charging 
strategies and different shares of depot and public charging. Urban delivery trucks will typically 
charge overnight at the depot and may not need to charge during the day. Similarly, urban buses 
will rely almost exclusively on private recharging at the depot or scheduled private opportunity 
charging en route. Regional delivery trucks will typically charge overnight but may need an 
additional  recharge  during  their  journey,  which  can  be  either  during  a  scheduled  stop  at  a 
warehouse or at a publicly accessible recharging point en route. On the other hand, long-haul 
HDVs  (trucks  and  coaches),  which  travel  beyond  the  range  of  depot-based  charging,  will 
regularly make use of recharging en route. They will require a publicly accessible recharging 
network  with  high-power  chargers  allowing  drivers  to  recharge  their  vehicle  during  their 
mandatory rest times, or overnight in the case of multiple-day itineraries. 

Regulation  (EU) 2023/1804  sets  mandatory  targets  for  complete  EU-wide  coverage  of 
recharging infrastructure along the TEN-T road network – for both high-power recharging and 
overnight recharging at safe and secure parking areas – and in urban nodes. Those targets are 
meant  to  provide  only  basic  infrastructure  along  the  EU’s  main  transport  network,  while 
additional infrastructure is expected to develop through market forces where additional demand 
exists. According to the analysis carried out under the support study, dedicated HDV recharging 
stations  mandated  should  be  sufficient  to  meet  at  least  47%  of  the  total  energy  demand  for 
publicly accessible recharging by the electric HDV fleet expected in 2030. The exact share will 
be highly dependent on a number of factors, including the share of long-distance battery electric 
trucks, their driving patterns and the possibility of charging at the depot. 

4.3  Hydrogen refuelling infrastructure needs up to 2030 

Unlike electric vehicles, hydrogen vehicles will rely largely on publicly accessible refuelling 
for all use cases. The costs of installing and operating hydrogen refuelling infrastructure and 
related safety requirements are prohibitively high for private infrastructure operation. 

Regulation (EU) 2023/1804 requires hydrogen refuelling stations to be deployed every 200 km 
along the TEN-T core network to support long-haul transport and in urban nodes for destination 
refuelling.  According  to  the  analysis  carried  out  under  the  support  study,  those  hydrogen 
refuelling stations should, depending on the availability of private refuelling and the technology 
chosen  for  the  vehicles,  by  2030  supply  at  least  48%  of  the  total  demanded  from  publicly 
accessible  infrastructure.  There  are,  however,  further  technological  complications  since  the 
market  is,  as  stated  in  Section 3.3,  not  currently  converging  towards  a  single  approach  to 
refuelling  technology.  Moreover,  the  specification  of  the  capacity  of  refuelling  stations  – 
currently set at 1 t/day for refuelling stations along the TEN-T road network – may need to be 
further  adjusted  in  order  to  take  account  of  the  need  for  fast  back-to-back  refuelling.  The 
Commission  will  continue  to  work  with  stakeholders  on  those  technical  aspects  under  the 
Sustainable Transport Forum. 

11 

 
 
There are still great uncertainties regarding the uptake of hydrogen heavy-duty vehicles and the 
technology  choices  and  technical  requirements  that  it  will  impose  on  the  refuelling 
infrastructure. Given that Article 24(1) of Regulation (EU) 2023/1804 requires an assessment 
of whether it is relevant to extend the scope of targets, it appears premature, at this stage of 
market  development,  to  further  widen  the  scope  of  mandatory  requirements  under  that 
Regulation to infrastructure for liquid hydrogen or other new technologies. It seems  equally 
premature  – given the slow uptake of hydrogen  heavy-duty  vehicles  and the limited overall 
availability of hydrogen vehicle models in series production – to broaden the scope of hydrogen 
refuelling infrastructure targets to the TEN-T comprehensive network. Further observation of 
market development is needed in order to draw any conclusions regarding further policy needs. 
This will be addressed in the review of Regulation (EU) 2023/1804. 

5 

Conclusions 

The vehicle market analysis highlights that the transition to zero-emission heavy-duty vehicles 
is  progressing  rapidly,  though  challenges  remain.  To  reach  the  2030  targets  under  the  CO2 
emission performance standards for heavy-duty vehicles, manufacturers expect by 2030 to put 
one in three new zero-emission lorries on the market across all segments. Even though prices 
of zero-emission heavy-duty vehicles are expected to fall in the coming years and TCO will 
become significantly more favourable, this would be a sharp market increase in a very short 
period of time in a market characterised by small profit margins and many SME operators with 
limited capital to invest and a very small share of zero-emission vehicles in 2025. At the end of 
2024, the share of zero-emission vehicles in new sales in the EU was 2.09%, almost all of them 
battery electric vehicles. Facilitating this market ramp-up will require extended support for the 
deployment of recharging infrastructure and grid modernisation. 

Current developments show marked differences in terms of technological maturity and market 
investment between battery electric technology, on the one hand, and hydrogen fuel cell and 
combustion technologies, on the other. Current market shares and announced vehicle models 
indicate that the contribution of H2 FCs and H2 ICEs to emission reductions by 2030 will be 
limited and that OEMs will rely mostly on BEVs for reaching their 2030 targets. Estimates from 
various sources indicate that by 2030 the zero-emission HDV fleet in the EU will comprise in 
total between 410 000 and 600 000 vehicles. A clear majority of these will be battery electric 
vehicles, which are expected to make up around 90% of the zero-emission HDV fleet. 

The overall targets laid down in Regulation (EU) 2023/1804 will lead to EU-wide coverage of 
dedicated HDV recharging and hydrogen refuelling infrastructure along the TEN-T core – and, 
in the case of electric recharging, the TEN-T comprehensive – road network as well as in urban 
nodes. Significant investments will have to be made in the next five years in order to meet those 
targets.  The  targets  are,  however,  set  to  provide  basic  infrastructure  along  the  EU’s  main 
transport network. Additional demand – especially along heavily used network segments – will 
require  additional  infrastructure,  which  will  be  delivered  by  the  markets.  According  to  the 
the  requirements  under  Regulation 
analysis  carried  out  under 
(EU) 2023/1804  are,  however,  estimated  already  to  supply  almost  50%  of  the  publicly 

the  support  study, 

12 

 
 
accessible  infrastructure  demanded  by  2030.  This  provides  a  solid  basis  for  further  market-
driven investments. 

At the end of 2024, more than 16 000 publicly accessible recharging points above 350 kW are 
already  deployed.  Only  a  small  portion  of  them  is  dedicated  and  fully  accessible  to  HDVs. 
Nevertheless, a wide range of companies have made significant investment plans and, under 
the first  AFIF call, up to 2 070 dedicated recharging  points are being  funded under the first 
AFIF cut-off date. As regards technology choices, it is expected that the CCS and the MCS will 
coexist, at least in the coming years. It remains to be seen if the sector will converge towards 
the MCS for all recharging in the future. The primary barriers to battery electric HDV adoption 
are high TCO and limited coverage of publicly accessible recharging infrastructure in relation 
to the number of vehicles expected on the road by 2030. The roll-out of dedicated recharging 
infrastructure  will  have  to  be  sped  up  considerably,  in  accordance  with  Regulation 
(EU) 2023/1804, between now and 2030. The main obstacles to this necessary deployment of 
additional recharging infrastructure are limited grid hosting capacity and deficiencies in related 
administrative  grid  connection  procedures.  Grid  capacity  constraints  present  the  main 
bottleneck to unlocking recharging infrastructure development, as they limit the potential size 
of charging locations, directly affecting the deployment rate of recharging stations along key 
transport  corridors.  Grid  capacity  constraints  not  only  hinder  the  deployment  of  publicly 
accessible infrastructure. They may also affect the deployment of private recharging at depots.  
Bi-directional charging might be of help in this context, but economic and regulatory hurdles 
still prevail.  

There are already 270 hydrogen refuelling stations operational in the EU: more than enough for 
the approximately 500 hydrogen HDVs and 5 000 hydrogen cars registered in the EU. Vehicle 
availability as well as availability and cost of hydrogen, rather than infrastructure deployment, 
presents the main bottleneck to hydrogen use in road transport, and uncertainty about vehicle 
uptake  and  technology  choices  makes  investments  in  hydrogen  refuelling  risky.  Various 
hydrogen  vehicle  technologies  are  being  developed,  and  there  is  currently  no  clear  market 
convergence across manufacturers. This raises questions about future refuelling requirements 
and the technologies that should be available at publicly accessible refuelling points (700 bar, 
350 bar, liquid hydrogen). The costs of deploying parallel hydrogen refuelling infrastructure 
for these various technologies would be very high, and subject to significant risk of stranded 
assets. In light of the limited availability of models expected by 2030, the very high vehicle 
costs and uncertainty about hydrogen pricing and technologies, the required pace of hydrogen 
infrastructure deployment is not expected to speed up significantly between now and then. 

Although  some  ERS  pilot  projects  have  been  concluded,  the  most  developed  initiatives 
highlighted the high investment, operational and maintenance risks, calling into question the 
overall economic viability of the technology at this stage. Furthermore, the long planning and 
construction time required to cover even relatively short road segments means that it would be 
impossible to cover more than a very small part of the European TEN-T road network in the 
short  or  medium  term.  ERSs  are  therefore  not  expected  to  provide  a  solution  for  the 
decarbonisation of HDV transport in the EU by 2030. Furthermore, in China investments are 
being made in battery swapping, and it appears relevant for industry to determine whether that 

13 

 
 
technology  will play a role  in HDVs  in the EU  in  the future.  Pursuing  such an  approach  to 
technology would, however, require broad alignment between vehicle manufacturers. 

14