1. The ‘Combo 2’ connector as described in EN IEC 62196-3:2022 and Combined Charging System (CCS) are not suitable for most widely used L-category electric vehicles.

• The 'Combo 2' connector is too large to be installed in small-size vehicles such as L1e and L2e vehicles. The specified voltage range of the CCS system (200V to 920V) does not match the 48V battery voltage used in many L1e category vehicles, either.
  • It should be noted that these smaller segments (L1e / L2e) represent more than 95% of the electric two-wheeler market in Europe. These vehicles are viable solutions for crowded cities and are the means of transport with the lowest CO2 footprint of all individual electric vehicles. L3e vehicles are typically electrified versions of heavy motorbikes, and these vehicles can use existing M1 (automotive) category chargers, including Combo 2 connectors. They are developed more for leisure purposes and their market penetration is extremely low.
• Focusing on the wider usage of L1e / L2e and partially (smaller) L3e vehicles, industry stakeholders developed IEC 62196-6, published in 2022, to be used for DC charging system according to IEC 61851-25:2020. More details on these standards are available here.
  • This charging system and its associated connector were recommended by ACEM (European Association of Motorcycle Manufacturers) at the time of the AFID revision (October 2022), as shown in the ACEM's position paper of October 2022.
• A blanket mandate of Combo 2 plugs to all recharging points reserved for L-category electric vehicles risks hindering the development and installation of recharging points for these market segments (L1e, L2e, etc.), stifling innovation, and delaying the electrification of L-category vehicles.
• We propose that the application of the ‘Combo2’ plug be limited to subcategories such as (part of) L3e, L4e, L5e, and that the proposed text be changed to:
  • "Direct current (DC) normal-power recharging points reserved for L-category electric vehicles shall be equipped, for interoperability purposes, at least with vehicle connectors as described in standard EN IEC 62196-6:2022 for Mode 4 recharging,” and
  • ‘at least Combo 2’ to be applied only to high-power recharging points reserved for L-category electric vehicles.

2. We welcome the clause to preserve all existing and working chargers

• Regarding vehicle-to-grid communication (point 2.1), we welcome Recital (21) and (22) of the delegated regulation. These exempt all existing and working chargers, including multi-standard chargers, from Annex II 2.1.1, and preserve all chargers in operation. We appreciate this consideration for the convenience of legacy EV users and to avoid chargers becoming stranded assets.

3. It is regrettable that the application of technical mandates to the entire private domain was proposed without thorough discussion of the consequences

• We were surprised to see the mandate extended to the private domain. As a member of the STF expert sub-group*, we began our work on the premise of considering public domain charging standards covered by AFID/AFIR. It is regrettable that the proposal to apply such technical requirements (which are anticipated to have a significant impact on the industry) to the entire private domain was made without thorough discussion from the outset in the expert group.

 

*CHAdeMO Association is a member of the Sustainable Transport Forum (STF) expert sub-group on governance and standards for communication exchange in the electro-mobility ecosystem, contributing to the discussions around AFIR-related standards since 2021.