1. Target setting for recharging and refuelling infrastructure for light-duty vehicles (LDV) as well as for heavy-duty vehicles (HDV)

1.1. LDV charging infrastructure in Estonia is at this stage already actively developed throughout the TEN-T network by the market in conjunction with EU funding (except in exceptional cases on the TEN-T network where traffic density on certain sections is extremely low of under 1000 LDV-s per day). Therefore, further market interference is not necessary at this point.

Additional flexibility in current targets could also help better reflect different market developments. In Estonia, developers competing in the same area has created multiple situations where the charging pools within a close-by area (within a 1-2 km radius) give in total more than the required power output as set out in the AFIR targets, but do not achieve the required power output target set for a charging pool by themselves (e.g. multiple 200-300 kW charging pools close-by near a TEN-T core network road that don’t individually reach the required 400 kW pool requirement). Forced concentration of these charging pools developed by private investors is not an available option and is not prudent considering that they are able to service the market in their current capacity anyway. Further derogations should also be considered for very low traffic density sections (e.g. sections with under 1000 LDV-s per day) of the TEN-T network as development of infrastructure according to AFIR requirements in these sections will not be prudent.

1.2. HDV charging targets are too high for more peripheral areas of the EU, like Estonia. 

Estonia’s distribution network is partially outdated – a significant part of the infrastructure exceeds the design lifetime and has limited capacity. At the same time, distributed production and the associated amount of storage equipment are growing rapidly. In addition, electrification is taking place across the field and the demand for high-power charging solutions is increasing. It is important to ensure sufficient flexibility so that the implementation of the objectives is in line with the development capacity of the network and local circumstances. This implies the need to keep in mind that network development is a long and technically complex process; forward-looking investments require a clear risk-sharing and financing logic; and solutions that increase system costs or undermine security of supply must be avoided.

The installation of recharging infrastructure for heavy-duty vehicles requires significantly higher than usual connection capacities compared to charging infrastructure for electric cars. Network connections are already one of the main bottlenecks in the development of charging infrastructure. The development of the network is very capital intensive, requires long-term planning, involves complex and sometimes time-consuming permit-granting procedures and construction processes. It is also necessary to take into account the delivery times of materials, which can be very long. For example, the delivery times of power transformers today are almost two and a half years.

On the other hand, the transport sector of Estonia has been deeply impacted by the COVID-19 pandemic and the russian invasion of Ukraine which led to decreased volumes of cargo. International cargo on Estonian roads has decreased from around 5-6 million tons per year in 2010s to 3,6 in 2025. This has undermined competitiveness of the sector and contributed to a decline in business which has furthermore impaired the ability to invest, including in greening their fleets. At the same time, Estonia’s budgetary priorities have been refocused towards defence with at least 5% of GDP in 2026 going to defence which means supporting the uptake of HDVs from the national budget is therefore not a viable option in the current geopolitical conditions.

With this in mind, HDV charging infrastructure targets should be postponed by 5 years across the field or reduced. Targets need to take into consideration the actual potential needs vis-a-vis HDV traffic tensity, and the fact that most of the charging of HDVs is done depot-based, especially in Estonia, where the local logistical routes are rather short (ca 200 km per direction). Too early investments into creating charging infrastructure that might remain significantly underutilised for considerable time would be mismanagement of already sparce network resources.
 
1.3. Hydrogen refuelling – the current targets are suitable and should be changed only if there is an actual deficit of refuelling indicated in some areas and in that case for those areas only. 

2. Target setting for alternative fuels infrastructure for vessels and aircraft

2.1. Imposing stricter requirements on Member States' ports would not in itself lead to a faster transition of ships to alternative fuels. The development of infrastructure should primarily be based on actual market needs. The forced development of one of the components (supply of fuels) through administrative interventions will not make alternative fuels an attractive and cost-effective option for companies in the market.

Any consideration on alternative fuels deployment in the Baltic Sea has to consider the cold climate, ice conditions and higher energy consumption of ice-class ships which make the deployment of alternative fuels and infrastructure more costly than in Western European regions. Pipes, tanks and pumping systems require insulation and heating, which increases the cost of investments and operation costs. Regional flexibility, differentiated requirements for smaller ports and transitional periods that take into account the technical and climatic conditions of the Baltic Sea are therefore important in any consideration.

For the successful implementation of OPS, a common EU technical standard for the connection of vessels to the power grid is necessary. Standardisation is particularly important for ships operating on non-scheduled routes, where ships change and ports need to be ready to serve ships with different technical solutions. A common standard will ensure interoperability, reduce investment risks and provide shipowners with certainty that their investments in ship-side systems are usable everywhere in the European Union.

2.2. The absence of deployment targets for electric charging and hydrogen refuelling infrastructure at airports could create a risk of delayed uptake due to both an infrastructure gap and a “chicken-and-egg” problem: airports are unlikely to invest without clear demand, while aircraft manufacturers and operators hesitate to scale without available infrastructure. Moreover, the lack of regulatory direction may result in fragmented and non-standardised approaches, weakening market signals and slowing coordinated investment across the value chain.

However, given technological uncertainty, evolving standards and the absence of a clearly dominant technological pathway, imposing binding infrastructure requirements at this stage would not be proportionate and could lead to inefficient or misdirected investments, including the risk of locking in costly infrastructure that may later prove unsuitable and placing unnecessary financial burdens on airports and other stakeholders.

A more proportionate approach would therefore focus on readiness measures, including ensuring sufficient grid capacity, integrating future energy needs into spatial planning, developing hydrogen-ready airport layouts and addressing relevant safety considerations. These measures could be complemented by targeted pilot projects at a limited number of major airports to test hydrogen refuelling and high-power electricity supply under real operating conditions. Such actions would support standardisation, reduce uncertainty and enable the gradual scale-up of infrastructure in line with technological progress and market developments.

Introduction
Regulation (EU) 2023/1804 (https://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX:32023R1804) on the deployment of alternative fuels infrastructure (AFIR) creates a common framework for the deployment of alternative fuels infrastructure in the EU. AFIR is an important component of the European Green Deal and the Clean Industrial Deal as it provides for sufficient and user-friendly alternative fuels infrastructure.
AFIR sets mandatory deployment targets for publicly accessible recharging and hydrogen refuelling infrastructure for road vehicles, for on shore power supply in inland waterway and maritime ports, for liquid methane infrastructure in maritime ports and for electricity supply to stationary aircraft. It equally sets requirements for the operation of such infrastructure as well as technical standards to ensure interoperability. The regulation also requires Member States to set up long-term National Policy Frameworks (NPFs) for the development of the market as concerns alternative fuels and the planning of the deployment of relevant alternative fuels infrastructure and report on its implementation.
The objective of this public consultation is to allow the general public and stakeholders to express their views on the current state of play and on the need for additional policy action at European level. Under this initiative, the Commission is considering policy measures covering the following aspects:
Ensure sufficient recharging and hydrogen refuelling infrastructure for light-duty and heavy-duty vehicles across all regions; Ensure sufficient recharging and refuelling infrastructure for vessels and aircraft; Improve user aspects, in particular with regards to reasonable and transparent pricing of recharging and refuelling infrastructure for alternative fuels Ensure compliance of recharging and refuelling infrastructure for alternative fuels with technical requirements and standards Reduce the administrative burden related to the national planning and reporting.
This Public Consultation covers different transport sectors. Respondents are encouraged to reply to those sections of the public consultation that are of direct concern to them.

2 Views on the problems
The present initiative aims at addressing five distinct sets of potential problems, which are described below. The Commission intends to assess the appropriateness of various measures that address the potential problems identified.
Problem 1: AFIR sets different targets for the deployment of recharging and refuelling infrastructure for light-duty as well as for heavy-duty vehicles. However, as the targets are set at a national level there is a risk that infrastructure is not developing sufficiently and coherently in all regions across the EU.
Problem 2: AFIR sets deployment targets for electricity supply to stationary aircraft and for on shore power supply to vessels. However, AFIR does not set deployment targets for alternative fuels infrastructure for propulsion fuels such as electricity, hydrogen, ammonia or methanol and on shore power supply targets for inland navigation may fall short of market needs. There is a risk that market uptake of alternative fuel vessels and aircraft are delayed.
Problem 3: AFIR contains provisions that card payment must be accepted at recharging and hydrogen refuelling points and also contains various provisions aiming to ensure that prices are fair and transparent. However, despite such provisions, there is still a lack of full price transparency for the user and the risk to be exposed to unfair prices.
Problem 4: AFIR mandates common technical specifications for the areas referred to in Annex II of the regulation in order to ensure full technical interoperability of the recharging and refuelling infrastructure. However, the legislation does not include any monitoring mechanism which risks that not all standards are properly implemented. Furthermore, the regulation also sets out data sharing requirements on the infrastructure operators but access to data may still be difficult for data users through the National Access Points.
Problem 5: The regulation also contains planning and reporting obligations on Member States and the Commission to ensure that mandatory targets are being achieved. However, the current provisions are perceived by some stakeholders as overly detailed, thus leading to unnecessary administrative burden in the form of multiple reporting requirements. At the same time, no data is available on private charging, in particular for depot charging for heavy-duty vehicles, where most recharging sessions currently take place.


3.1. Target setting for recharging and refuelling infrastructure for light-duty vehicles (LDV) as well as for heavy-duty vehicles (HDV)

3.1.1 The mandatory targets for electric recharging infrastructure of light-duty vehicles (LDV) laid down in AFIR are not sufficient to achieve the objectives of the regulation to ensure a sufficient and coherent recharging infrastructure for LDV across the EU.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree Neutral
Somewhat disagree
Fully disagree
No opinion

3.1.2 The mandatory targets for electric recharging infrastructure of heavy-duty vehicles (HDV) laid down in AFIR are not sufficient to achieve the objectives of the regulation to ensure a sufficient and coherent recharging infrastructure for HDV across the EU.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree
No opinion

3.1.3 The mandatory targets for hydrogen refuelling infrastructure of road vehicles laid down in AFIR are not sufficient to achieve the objectives of the regulation to ensure a sufficient and coherent recharging infrastructure for hydrogen vehicles across the EU.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree No opinion



3.1.4 Would you like to provide additional comments/explanations in case specific targets for road transport are not sufficient?
1000 characters maximum:

Comments in supporting document.



3.2. Target setting for alternative fuels infrastructure for vessels and aircraft

3.2.1 The lack of mandatory targets for alternative fuels infrastructure for propulsion fuels for maritime vessels risks that the market uptake of alternative fuel maritime vessels is delayed.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree
No opinion


3.2.3 The lack of mandatory targets for alternative fuels infrastructure for propulsion fuels for aircraft risks that the market uptake of alternative fuel aircraft is delayed.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree No opinion
3.2.4 Would you like to provide additional comments/explanations in case specific targets for shipping or aviation are not sufficient?
Would you have suggestions about other solutions to reach the same results?
1000 characters maximum:

Comments in supporting document.


3.3. Price transparency and reasonable prices at publicly accessible recharging infrastructure

3.3.1 There is a lack of price transparency for recharging prices charged by operators of recharging points for recharging services paid for by payment card (debit/credit card).
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree
No opinion

3.3.2 Prices charged by operators of recharging points for recharging services paid for by payment card are not reasonable.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree
No opinion

3.3.3 There is a lack of price transparency for recharging prices charged by mobility service providers (MSP) for recharging services paid through apps or MSP cards.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree
No opinion

3.3.4 Prices charged by mobility service providers (MSP) for recharging services paid through apps or MSP cards are not reasonable.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree
No opinion
3.4. Compliance with standards and access to data

3.4.1 Compliance with technical specifications and standards mandated under AFIR is not ensured because of a lack of an appropriate compliance framework (e.g., certification scheme, common testing protocols).
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree
No opinion

3.4.2 Access to data provided by operators of recharging and refuelling points, for example on location of infrastructure, available power output and pricing, is not ensured for end users.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree
No opinion
3.5. Planning and reporting requirements

3.5.1 The current planning and reporting requirements by Member States and the Commission are excessive and lead to unnecessary administrative burden.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree
No opinion
3.5.2 There is currently a lack of information on private recharging infrastructure, in particular for depot recharging for heavy-duty vehicles.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree
No opinion
4. Views on possible policy measures
Below there are statements on a number of possible policy measures to address the problem areas.
The policy measures described below are without prejudice to the instrument used, and may entail a mix of legislative and soft law measures (including guidelines). Given the complexity and multifaceted nature of the problems, these approaches are not necessarily mutually exclusive.
Please rate the policy measures from 1 (not relevant) to 5 (most relevant). Not all of them need to be rated, not indicating a rating for one of the measures means that you do not have an opinion about the relevance of this specific policy measure.

4.1. Measures related to target setting for infrastructure for road vehicles
4.1.1 Adjusted target levels for recharging infrastructure for light-duty vehicles (LDV) to ensure a sufficient and coherent coverage of infrastructure across the EU while maintaining the dynamics of the recharging market.


1
2
3
4
5
Setting of higher deployment targets for recharging infrastructure by increasing the power output that needs to be provided by publicly accessible recharging stations for each registered electric vehicle.
x




Setting of sub-targets at a regional level, to ensure regional coherence and a minimum infrastructure across all regions of the EU territory, including in cities.
x




Setting higher power output targets for recharging pools for LDV along the main EU transport corridors (TEN-T network).
x




Adding flexibility in the target setting for LDV recharging pools along the TEN-T network to better reflect actual demand in different segments of the TEN-T network.




x






4.1.2 Adjusted target levels for recharging infrastructure for heavy-duty vehicles (HDV) to ensure a sufficient and coherent coverage of infrastructure across the EU.


1
2
3
4
5
Setting higher power output targets for recharging pools for HDV along the TEN-T network.
x




Setting higher power output targets of individual recharging points within recharging pools (e.g. mandating a minimum number of Megawatt recharging stations within recharging pools dedicated for HDV).
x




Adding flexibility in the target setting for HDV recharging pools along the TEN-T network to better reflect actual demand in different segments of the TEN-T network.




x
Setting higher targets for recharging infrastructure for HDVs in urban nodes.
x




Setting higher targets for recharging infrastructure for overnight recharging of HDVs along the TEN-T network.
x




Introducing minimum criteria for a recharging point or recharging pool so it can be classified as a recharging point or pool dedicated to HDV. Those criteria can include for example provisions on layout dimensions and other criteria to ensure that dedicated recharging points/pools are fully usable by all trucks.


x



4.1.3 Adjusted target levels for hydrogen refuelling infrastructure for road vehicles to ensure a sufficient and coherent coverage of infrastructure across the EU.


1
2
3
4
5
Setting higher targets for hydrogen refuelling infrastructure along the TEN-T network.
x




Setting higher targets for hydrogen infrastructure in urban nodes.
x




Providing more flexibility in the target setting for hydrogen refuelling infrastructure to better reflect actual demand based on hydrogen vehicle uptake.




x
Setting capacity targets for individual refuelling stations not only in relation to the daily capacity but also in relation to how much hydrogen can be dispensed in e.g. one hour to allow refuelling of multiple trucks in a short timeframe.

x



Mandating that hydrogen refuelling points must provide gaseous and liquid hydrogen to ensure compatibility with all hydrogen vehicle technologies.


x




4.2 Measures related to deployment targets for shipping and aviation
This section is specific to inland waterway and maritime shipping as well as to aviation.
4.2.2 Measures to accelerate the deployment of alternative fuel infrastructure for maritime vessels in line with market needs.


1
2
3
4
5
Expanding the scope of the regulation to setting targets for the deployment of shore side electricity supply for passenger or container ships of a minimum of 400 gross tonnes.
x




Expanding the scope of the regulation to setting targets for the deployment of shore side electricity supply for other ship categories than passenger and container vessels, such as tankers.
x




Setting of deployment targets for recharging and refuelling infrastructure for alternative propulsion fuels for maritime vessels.
x




Strengthening of Member States planning or the decarbonisation of the maritime sector with regards to the required alternative fuels infrastructure in ports. This can for example be achieved by adding further planning requirements for Member States under the National Policy Frameworks.


x



4.2.3 Measures to accelerate the deployment of alternative fuel infrastructure for aircraft in line with market needs.


1
2
3
4
5
Setting of deployment targets for electric recharging infrastructure in airports for battery electric aircraft.


x


Setting of deployment targets for hydrogen refuelling infrastructure in airports for hydrogen-powered aircraft.

x



Strengthening of Member States planning or the decarbonisation of the aviation sector with regards to the required alternative fuels infrastructure in airports. This can for example be achieved by adding further planning requirements for Member States under the National Policy Frameworks.


X











4.3 Measures to improve user experience at publicly accessible recharging and hydrogen refuelling points
Users of alternatively fuelled vehicles should be able to refuel/recharge their vehicles easily and in an interoperable manner, having access to all relevant information. The regulation requires prices charged by recharging point operators to be reasonable, easily and clearly comparable, transparent and non-discriminatory. The questions below seek feedback on the user experience on these aspects.
4.3.1 Measures to improve price transparency at publicly accessible recharging and refuelling points.


1
2
3
4
5
Mandate that ad hoc recharging prices must be displayed at every recharging station. Currently, this is only required for recharging points above 50 kW while for other recharging points the ad hoc price must be made clearly and easily available (e.g., in an app only).


x


Mandate that charge point operators may only charge an ad hoc price based on kWh, plus an occupancy fee at all recharging points. Currently this is only mandated for recharging points with a power output above 50 kW.


x


Mandate that mobility service providers may only charge a price based on kWh, plus an occupancy fee for recharging services at all recharging points.


x



4.3.2 Measures to ensure reasonable prices at publicly accessible recharging and refuelling points.


1
2
3
4
5
Mandate that national competent authorities regularly monitor and report on competition in the recharging market and on price developments.

x



Measures to ensure fair tender and concession practices at Member State level that promote more competition in the recharging market.
x




Regulatory measures intervening in the price setting of charge point operators.
x




Regulatory measures intervening in the price setting of mobility service providers.
x




Further specification in the recitals of the regulation what constitutes fair and reasonable prices as well as non-discriminatory price setting.



x


4.3.3 Other possible measures to improve user experience at publicly accessible recharging and refuelling points.


1
2
3
4
5
Mandate that payment card (credit/debit) must be possible at every recharging point through a payment terminal or NFC reader. Currently such terminals or readers are only required for recharging points above 50 kW, whereas for recharging points below 50 kW, payment card (credit/debit) can also be ensured through other devices using an internet connection such as a specific QR code.



x

Mandate that all new recharging points accessible to the public are capable of bidirectional recharging.
x




Measures to ensure that prices at publicly accessible recharging points reflect price developments at the electricity markets, which could lead to lower prices at times of overall low electricity demand and high renewable generation and to higher prices at times of overall high electricity demand.

x



Measures to ensure that recharging and refuelling points are accessible to persons with disabilities.



x


4.3.4 Are there any other measures to improve the user experience at publicly accessible recharging and refuelling points that should be considered?
500 characters maximum:

4.4 Measures on technical interoperability aspects
4.4.1 Measures to ensure full compliance with technical standards.


1
2
3
4
5
Mandate a self-certification scheme for the manufacturers and/or operators of recharging and refuelling points on the basis of the conformance tests specified in the corresponding mandated standards.
X




Mandate manufacturers and/or operators of recharging and refuelling points to obtain a certification from a relevant national or European certification scheme.
X




Mandate national competent authorities to monitor the implementation of the technical specifications in the regulation and to sanction cases of non-compliance.
X





4.4.2 Measures to ensure data accessibility for end users.


1
2
3
4
5
Development of further technical specifications to ensure that the National Access Points are better harmonised and fully functional for alternative fuels data.


X


Strengthening the role and technical functions of the Common European Access Point to facilitate EU-wide data accessibility.
X




Strengthening the coordination between National Access Points and the Common European Access Point to ensure all data are made accessible in a coherent manner.
X






4.5 Measures on administrative aspects
4.5.1 Measures to ensure fit for purpose planning and reporting.


1
2
3
4
5
Reducing reporting requirements by Member States under Art 15.




x
Reducing the data sharing requirements under Art 18 as the data is in any case publicly available under eafo.eu.




x
Strengthening the planning requirements for Member States on recharging and refuelling infrastructure for HDV to include monitoring and reporting requirements on such infrastructure in private depots and warehouses.



x


4.6 Other Measures
4.6.1 Are there any other measures that should be considered for revising Regulation (EU) 2023/1804?
2000 characters maximum:
The requirement for the Identification Registration Organisation (IDRO) to issue and manage unique identification (“ID”) codes to identify at least operators of recharging points and mobility service providers should be reviewed. Under Regulation (EU) 2023/1804, the purpose of the ID code requirement appears to be to support the identification of relevant market actors within the broader data provision framework, including interoperable and harmonised data exchange related to publicly accessible recharging infrastructure. This requirement does not appear to fulfil a clear regulatory or practical purpose. The obligation to require and use such an identification code does not provide a benefit for the service providers nor does it create clear added value for end users. Identification code doesn’t simplify the use of recharging services, improve transparency or facilitate cooperation between market participants.

The requirement therefore is a formal administrative obligation rather than an effective tool for interoperability or data exchange. It imposes administrative burden on both public authorities and private entities without a public benefit. We therefore recommend that the Commission review the necessity and added value of the ID code requirement. In particular, the review should assess whether the requirement should be removed.

The use of alternative fuels like biogas ought to be given further importance in the greening of HDV-s. Targets set for liquefied methane expired in the end of 2024 but could be extended to 2030 or further with the caveat of ensuring biogas fuelling capability. This would enable to take steps to green the sector as currently available gas-powered vehicles can be made to run on biogas while the technology for electric and hydrogen HDV-s develops and becomes more widely/cheaply available.


4.6.2 You may also attach any document(s) to provide evidence to support your responses.

 1. Target setting for recharging and refuelling infrastructure for light-duty vehicles (LDV) as well as for heavy-duty vehicles (HDV)

1.1. LDV charging infrastructure in Estonia is at this stage already actively developed throughout the TEN-T network by the market in conjunction with EU funding (except in exceptional cases on the TEN-T network where traffic density on certain sections is extremely low of under 1000 LDV-s per day). Therefore, further market interference is not necessary at this point.

Additional flexibility in current targets could also help better reflect different market developments. In Estonia, developers competing in the same area has created multiple situations where the charging pools within a close-by area (within a 1-2 km radius) give in total more than the required power output as set out in the AFIR targets, but do not achieve the required power output target set for a charging pool by themselves (e.g. multiple 200-300 kW charging pools close-by near a TEN-T core network road that don’t individually reach the required 400 kW pool requirement). Forced concentration of these charging pools developed by private investors is not an available option and is not prudent considering that they are able to service the market in their current capacity anyway. Further derogations should also be considered for very low traffic density sections (e.g. sections with under 1000 LDV-s per day) of the TEN-T network as development of infrastructure according to AFIR requirements in these sections will not be prudent.

1.2. HDV charging targets are too high for more peripheral areas of the EU, like Estonia. 

Estonia’s distribution network is partially outdated – a significant part of the infrastructure exceeds the design lifetime and has limited capacity. At the same time, distributed production and the associated amount of storage equipment are growing rapidly. In addition, electrification is taking place across the field and the demand for high-power charging solutions is increasing. It is important to ensure sufficient flexibility so that the implementation of the objectives is in line with the development capacity of the network and local circumstances. This implies the need to keep in mind that network development is a long and technically complex process; forward-looking investments require a clear risk-sharing and financing logic; and solutions that increase system costs or undermine security of supply must be avoided.

The installation of recharging infrastructure for heavy-duty vehicles requires significantly higher than usual connection capacities compared to charging infrastructure for electric cars. Network connections are already one of the main bottlenecks in the development of charging infrastructure. The development of the network is very capital intensive, requires long-term planning, involves complex and sometimes time-consuming permit-granting procedures and construction processes. It is also necessary to take into account the delivery times of materials, which can be very long. For example, the delivery times of power transformers today are almost two and a half years.

On the other hand, the transport sector of Estonia has been deeply impacted by the COVID-19 pandemic and the russian invasion of Ukraine which led to decreased volumes of cargo. International cargo on Estonian roads has decreased from around 5-6 million tons per year in 2010s to 3,6 in 2025. This has undermined competitiveness of the sector and contributed to a decline in business which has furthermore impaired the ability to invest, including in greening their fleets. At the same time, Estonia’s budgetary priorities have been refocused towards defence with at least 5% of GDP in 2026 going to defence which means supporting the uptake of HDVs from the national budget is therefore not a viable option in the current geopolitical conditions.

With this in mind, HDV charging infrastructure targets should be postponed by 5 years across the field or reduced. Targets need to take into consideration the actual potential needs vis-a-vis HDV traffic tensity, and the fact that most of the charging of HDVs is done depot-based, especially in Estonia, where the local logistical routes are rather short (ca 200 km per direction). Too early investments into creating charging infrastructure that might remain significantly underutilised for considerable time would be mismanagement of already sparce network resources.
 
1.3. Hydrogen refuelling – the current targets are suitable and should be changed only if there is an actual deficit of refuelling indicated in some areas and in that case for those areas only. 

2. Target setting for alternative fuels infrastructure for vessels and aircraft

2.1. Imposing stricter requirements on Member States' ports would not in itself lead to a faster transition of ships to alternative fuels. The development of infrastructure should primarily be based on actual market needs. The forced development of one of the components (supply of fuels) through administrative interventions will not make alternative fuels an attractive and cost-effective option for companies in the market.

Any consideration on alternative fuels deployment in the Baltic Sea has to consider the cold climate, ice conditions and higher energy consumption of ice-class ships which make the deployment of alternative fuels and infrastructure more costly than in Western European regions. Pipes, tanks and pumping systems require insulation and heating, which increases the cost of investments and operation costs. Regional flexibility, differentiated requirements for smaller ports and transitional periods that take into account the technical and climatic conditions of the Baltic Sea are therefore important in any consideration.

For the successful implementation of OPS, a common EU technical standard for the connection of vessels to the power grid is necessary. Standardisation is particularly important for ships operating on non-scheduled routes, where ships change and ports need to be ready to serve ships with different technical solutions. A common standard will ensure interoperability, reduce investment risks and provide shipowners with certainty that their investments in ship-side systems are usable everywhere in the European Union.

2.2. The absence of deployment targets for electric charging and hydrogen refuelling infrastructure at airports could create a risk of delayed uptake due to both an infrastructure gap and a “chicken-and-egg” problem: airports are unlikely to invest without clear demand, while aircraft manufacturers and operators hesitate to scale without available infrastructure. Moreover, the lack of regulatory direction may result in fragmented and non-standardised approaches, weakening market signals and slowing coordinated investment across the value chain.

However, given technological uncertainty, evolving standards and the absence of a clearly dominant technological pathway, imposing binding infrastructure requirements at this stage would not be proportionate and could lead to inefficient or misdirected investments, including the risk of locking in costly infrastructure that may later prove unsuitable and placing unnecessary financial burdens on airports and other stakeholders.

A more proportionate approach would therefore focus on readiness measures, including ensuring sufficient grid capacity, integrating future energy needs into spatial planning, developing hydrogen-ready airport layouts and addressing relevant safety considerations. These measures could be complemented by targeted pilot projects at a limited number of major airports to test hydrogen refuelling and high-power electricity supply under real operating conditions. Such actions would support standardisation, reduce uncertainty and enable the gradual scale-up of infrastructure in line with technological progress and market developments.

Introduction
Regulation (EU) 2023/1804 (https://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX:32023R1804) on the deployment of alternative fuels infrastructure (AFIR) creates a common framework for the deployment of alternative fuels infrastructure in the EU. AFIR is an important component of the European Green Deal and the Clean Industrial Deal as it provides for sufficient and user-friendly alternative fuels infrastructure.
AFIR sets mandatory deployment targets for publicly accessible recharging and hydrogen refuelling infrastructure for road vehicles, for on shore power supply in inland waterway and maritime ports, for liquid methane infrastructure in maritime ports and for electricity supply to stationary aircraft. It equally sets requirements for the operation of such infrastructure as well as technical standards to ensure interoperability. The regulation also requires Member States to set up long-term National Policy Frameworks (NPFs) for the development of the market as concerns alternative fuels and the planning of the deployment of relevant alternative fuels infrastructure and report on its implementation.
The objective of this public consultation is to allow the general public and stakeholders to express their views on the current state of play and on the need for additional policy action at European level. Under this initiative, the Commission is considering policy measures covering the following aspects:
Ensure sufficient recharging and hydrogen refuelling infrastructure for light-duty and heavy-duty vehicles across all regions; Ensure sufficient recharging and refuelling infrastructure for vessels and aircraft; Improve user aspects, in particular with regards to reasonable and transparent pricing of recharging and refuelling infrastructure for alternative fuels Ensure compliance of recharging and refuelling infrastructure for alternative fuels with technical requirements and standards Reduce the administrative burden related to the national planning and reporting.
This Public Consultation covers different transport sectors. Respondents are encouraged to reply to those sections of the public consultation that are of direct concern to them.

2 Views on the problems
The present initiative aims at addressing five distinct sets of potential problems, which are described below. The Commission intends to assess the appropriateness of various measures that address the potential problems identified.
Problem 1: AFIR sets different targets for the deployment of recharging and refuelling infrastructure for light-duty as well as for heavy-duty vehicles. However, as the targets are set at a national level there is a risk that infrastructure is not developing sufficiently and coherently in all regions across the EU.
Problem 2: AFIR sets deployment targets for electricity supply to stationary aircraft and for on shore power supply to vessels. However, AFIR does not set deployment targets for alternative fuels infrastructure for propulsion fuels such as electricity, hydrogen, ammonia or methanol and on shore power supply targets for inland navigation may fall short of market needs. There is a risk that market uptake of alternative fuel vessels and aircraft are delayed.
Problem 3: AFIR contains provisions that card payment must be accepted at recharging and hydrogen refuelling points and also contains various provisions aiming to ensure that prices are fair and transparent. However, despite such provisions, there is still a lack of full price transparency for the user and the risk to be exposed to unfair prices.
Problem 4: AFIR mandates common technical specifications for the areas referred to in Annex II of the regulation in order to ensure full technical interoperability of the recharging and refuelling infrastructure. However, the legislation does not include any monitoring mechanism which risks that not all standards are properly implemented. Furthermore, the regulation also sets out data sharing requirements on the infrastructure operators but access to data may still be difficult for data users through the National Access Points.
Problem 5: The regulation also contains planning and reporting obligations on Member States and the Commission to ensure that mandatory targets are being achieved. However, the current provisions are perceived by some stakeholders as overly detailed, thus leading to unnecessary administrative burden in the form of multiple reporting requirements. At the same time, no data is available on private charging, in particular for depot charging for heavy-duty vehicles, where most recharging sessions currently take place.


3.1. Target setting for recharging and refuelling infrastructure for light-duty vehicles (LDV) as well as for heavy-duty vehicles (HDV)

3.1.1 The mandatory targets for electric recharging infrastructure of light-duty vehicles (LDV) laid down in AFIR are not sufficient to achieve the objectives of the regulation to ensure a sufficient and coherent recharging infrastructure for LDV across the EU.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree Neutral
Somewhat disagree
Fully disagree
No opinion

3.1.2 The mandatory targets for electric recharging infrastructure of heavy-duty vehicles (HDV) laid down in AFIR are not sufficient to achieve the objectives of the regulation to ensure a sufficient and coherent recharging infrastructure for HDV across the EU.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree
No opinion

3.1.3 The mandatory targets for hydrogen refuelling infrastructure of road vehicles laid down in AFIR are not sufficient to achieve the objectives of the regulation to ensure a sufficient and coherent recharging infrastructure for hydrogen vehicles across the EU.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree No opinion



3.1.4 Would you like to provide additional comments/explanations in case specific targets for road transport are not sufficient?
1000 characters maximum:

Comments in supporting document.



3.2. Target setting for alternative fuels infrastructure for vessels and aircraft

3.2.1 The lack of mandatory targets for alternative fuels infrastructure for propulsion fuels for maritime vessels risks that the market uptake of alternative fuel maritime vessels is delayed.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree
No opinion


3.2.3 The lack of mandatory targets for alternative fuels infrastructure for propulsion fuels for aircraft risks that the market uptake of alternative fuel aircraft is delayed.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree No opinion
3.2.4 Would you like to provide additional comments/explanations in case specific targets for shipping or aviation are not sufficient?
Would you have suggestions about other solutions to reach the same results?
1000 characters maximum:

Comments in supporting document.


3.3. Price transparency and reasonable prices at publicly accessible recharging infrastructure

3.3.1 There is a lack of price transparency for recharging prices charged by operators of recharging points for recharging services paid for by payment card (debit/credit card).
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree
No opinion

3.3.2 Prices charged by operators of recharging points for recharging services paid for by payment card are not reasonable.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree
No opinion

3.3.3 There is a lack of price transparency for recharging prices charged by mobility service providers (MSP) for recharging services paid through apps or MSP cards.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree
No opinion

3.3.4 Prices charged by mobility service providers (MSP) for recharging services paid through apps or MSP cards are not reasonable.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree
No opinion
3.4. Compliance with standards and access to data

3.4.1 Compliance with technical specifications and standards mandated under AFIR is not ensured because of a lack of an appropriate compliance framework (e.g., certification scheme, common testing protocols).
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree
No opinion

3.4.2 Access to data provided by operators of recharging and refuelling points, for example on location of infrastructure, available power output and pricing, is not ensured for end users.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree
No opinion
3.5. Planning and reporting requirements

3.5.1 The current planning and reporting requirements by Member States and the Commission are excessive and lead to unnecessary administrative burden.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree
No opinion
3.5.2 There is currently a lack of information on private recharging infrastructure, in particular for depot recharging for heavy-duty vehicles.
To what extent do you agree that this is an important problem?
Fully agree
Somewhat agree
Neutral
Somewhat disagree
Fully disagree
No opinion
4. Views on possible policy measures
Below there are statements on a number of possible policy measures to address the problem areas.
The policy measures described below are without prejudice to the instrument used, and may entail a mix of legislative and soft law measures (including guidelines). Given the complexity and multifaceted nature of the problems, these approaches are not necessarily mutually exclusive.
Please rate the policy measures from 1 (not relevant) to 5 (most relevant). Not all of them need to be rated, not indicating a rating for one of the measures means that you do not have an opinion about the relevance of this specific policy measure.

4.1. Measures related to target setting for infrastructure for road vehicles
4.1.1 Adjusted target levels for recharging infrastructure for light-duty vehicles (LDV) to ensure a sufficient and coherent coverage of infrastructure across the EU while maintaining the dynamics of the recharging market.
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5
Setting of higher deployment targets for recharging infrastructure by increasing the power output that needs to be provided by publicly accessible recharging stations for each registered electric vehicle.
x




Setting of sub-targets at a regional level, to ensure regional coherence and a minimum infrastructure across all regions of the EU territory, including in cities.
x




Setting higher power output targets for recharging pools for LDV along the main EU transport corridors (TEN-T network).
x




Adding flexibility in the target setting for LDV recharging pools along the TEN-T network to better reflect actual demand in different segments of the TEN-T network.




x






4.1.2 Adjusted target levels for recharging infrastructure for heavy-duty vehicles (HDV) to ensure a sufficient and coherent coverage of infrastructure across the EU.
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1
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5
Setting higher power output targets for recharging pools for HDV along the TEN-T network.
x




Setting higher power output targets of individual recharging points within recharging pools (e.g. mandating a minimum number of Megawatt recharging stations within recharging pools dedicated for HDV).
x




Adding flexibility in the target setting for HDV recharging pools along the TEN-T network to better reflect actual demand in different segments of the TEN-T network.




x
Setting higher targets for recharging infrastructure for HDVs in urban nodes.
x




Setting higher targets for recharging infrastructure for overnight recharging of HDVs along the TEN-T network.
x




Introducing minimum criteria for a recharging point or recharging pool so it can be classified as a recharging point or pool dedicated to HDV. Those criteria can include for example provisions on layout dimensions and other criteria to ensure that dedicated recharging points/pools are fully usable by all trucks.


x



4.1.3 Adjusted target levels for hydrogen refuelling infrastructure for road vehicles to ensure a sufficient and coherent coverage of infrastructure across the EU.


1
2
3
4
5
Setting higher targets for hydrogen refuelling infrastructure along the TEN-T network.
x




Setting higher targets for hydrogen infrastructure in urban nodes.
x




Providing more flexibility in the target setting for hydrogen refuelling infrastructure to better reflect actual demand based on hydrogen vehicle uptake.




x
Setting capacity targets for individual refuelling stations not only in relation to the daily capacity but also in relation to how much hydrogen can be dispensed in e.g. one hour to allow refuelling of multiple trucks in a short timeframe.

x



Mandating that hydrogen refuelling points must provide gaseous and liquid hydrogen to ensure compatibility with all hydrogen vehicle technologies.


x




4.2 Measures related to deployment targets for shipping and aviation
This section is specific to inland waterway and maritime shipping as well as to aviation.
4.2.2 Measures to accelerate the deployment of alternative fuel infrastructure for maritime vessels in line with market needs.
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3
4
5
Expanding the scope of the regulation to setting targets for the deployment of shore side electricity supply for passenger or container ships of a minimum of 400 gross tonnes.
x




Expanding the scope of the regulation to setting targets for the deployment of shore side electricity supply for other ship categories than passenger and container vessels, such as tankers.
x




Setting of deployment targets for recharging and refuelling infrastructure for alternative propulsion fuels for maritime vessels.
x




Strengthening of Member States planning or the decarbonisation of the maritime sector with regards to the required alternative fuels infrastructure in ports. This can for example be achieved by adding further planning requirements for Member States under the National Policy Frameworks.


x



4.2.3 Measures to accelerate the deployment of alternative fuel infrastructure for aircraft in line with market needs.
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1
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3
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5
Setting of deployment targets for electric recharging infrastructure in airports for battery electric aircraft.


x


Setting of deployment targets for hydrogen refuelling infrastructure in airports for hydrogen-powered aircraft.

x



Strengthening of Member States planning or the decarbonisation of the aviation sector with regards to the required alternative fuels infrastructure in airports. This can for example be achieved by adding further planning requirements for Member States under the National Policy Frameworks.


X











4.3 Measures to improve user experience at publicly accessible recharging and hydrogen refuelling points
Users of alternatively fuelled vehicles should be able to refuel/recharge their vehicles easily and in an interoperable manner, having access to all relevant information. The regulation requires prices charged by recharging point operators to be reasonable, easily and clearly comparable, transparent and non-discriminatory. The questions below seek feedback on the user experience on these aspects.
4.3.1 Measures to improve price transparency at publicly accessible recharging and refuelling points.
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5
Mandate that ad hoc recharging prices must be displayed at every recharging station. Currently, this is only required for recharging points above 50 kW while for other recharging points the ad hoc price must be made clearly and easily available (e.g., in an app only).


x


Mandate that charge point operators may only charge an ad hoc price based on kWh, plus an occupancy fee at all recharging points. Currently this is only mandated for recharging points with a power output above 50 kW.


x


Mandate that mobility service providers may only charge a price based on kWh, plus an occupancy fee for recharging services at all recharging points.


x



4.3.2 Measures to ensure reasonable prices at publicly accessible recharging and refuelling points.
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1
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5
Mandate that national competent authorities regularly monitor and report on competition in the recharging market and on price developments.

x



Measures to ensure fair tender and concession practices at Member State level that promote more competition in the recharging market.
x




Regulatory measures intervening in the price setting of charge point operators.
x




Regulatory measures intervening in the price setting of mobility service providers.
x




Further specification in the recitals of the regulation what constitutes fair and reasonable prices as well as non-discriminatory price setting.



x


4.3.3 Other possible measures to improve user experience at publicly accessible recharging and refuelling points.
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1
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3
4
5
Mandate that payment card (credit/debit) must be possible at every recharging point through a payment terminal or NFC reader. Currently such terminals or readers are only required for recharging points above 50 kW, whereas for recharging points below 50 kW, payment card (credit/debit) can also be ensured through other devices using an internet connection such as a specific QR code.



x

Mandate that all new recharging points accessible to the public are capable of bidirectional recharging.
x




Measures to ensure that prices at publicly accessible recharging points reflect price developments at the electricity markets, which could lead to lower prices at times of overall low electricity demand and high renewable generation and to higher prices at times of overall high electricity demand.

x



Measures to ensure that recharging and refuelling points are accessible to persons with disabilities.



x


4.3.4 Are there any other measures to improve the user experience at publicly accessible recharging and refuelling points that should be considered?
500 characters maximum:

4.4 Measures on technical interoperability aspects
4.4.1 Measures to ensure full compliance with technical standards.
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5
Mandate a self-certification scheme for the manufacturers and/or operators of recharging and refuelling points on the basis of the conformance tests specified in the corresponding mandated standards.
X




Mandate manufacturers and/or operators of recharging and refuelling points to obtain a certification from a relevant national or European certification scheme.
X




Mandate national competent authorities to monitor the implementation of the technical specifications in the regulation and to sanction cases of non-compliance.
X





4.4.2 Measures to ensure data accessibility for end users.
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5
Development of further technical specifications to ensure that the National Access Points are better harmonised and fully functional for alternative fuels data.


X


Strengthening the role and technical functions of the Common European Access Point to facilitate EU-wide data accessibility.
X




Strengthening the coordination between National Access Points and the Common European Access Point to ensure all data are made accessible in a coherent manner.
X






4.5 Measures on administrative aspects
4.5.1 Measures to ensure fit for purpose planning and reporting.
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5
Reducing reporting requirements by Member States under Art 15.




x
Reducing the data sharing requirements under Art 18 as the data is in any case publicly available under eafo.eu.




x
Strengthening the planning requirements for Member States on recharging and refuelling infrastructure for HDV to include monitoring and reporting requirements on such infrastructure in private depots and warehouses.



x


4.6 Other Measures
4.6.1 Are there any other measures that should be considered for revising Regulation (EU) 2023/1804?
2000 characters maximum:
The requirement for the Identification Registration Organisation (IDRO) to issue and manage unique identification (“ID”) codes to identify at least operators of recharging points and mobility service providers should be reviewed. Under Regulation (EU) 2023/1804, the purpose of the ID code requirement appears to be to support the identification of relevant market actors within the broader data provision framework, including interoperable and harmonised data exchange related to publicly accessible recharging infrastructure. This requirement does not appear to fulfil a clear regulatory or practical purpose. The obligation to require and use such an identification code does not provide a benefit for the service providers nor does it create clear added value for end users. Identification code doesn’t simplify the use of recharging services, improve transparency or facilitate cooperation between market participants.

The requirement therefore is a formal administrative obligation rather than an effective tool for interoperability or data exchange. It imposes administrative burden on both public authorities and private entities without a public benefit. We therefore recommend that the Commission review the necessity and added value of the ID code requirement. In particular, the review should assess whether the requirement should be removed.

The use of alternative fuels like biogas ought to be given further importance in the greening of HDV-s. Targets set for liquefied methane expired in the end of 2024 but could be extended to 2030 or further with the caveat of ensuring biogas fuelling capability. This would enable to take steps to green the sector as currently available gas-powered vehicles can be made to run on biogas while the technology for electric and hydrogen HDV-s develops and becomes more widely/cheaply available.


4.6.2 You may also attach any document(s) to provide evidence to support your responses.