POSITION | INFRASTRUCTURE | CHARGING AND REFUELLING
EU Consultation on the Revision of the AFIR Use the review to provide further impetus for accelerated and advance expansion in the EU.
July 31, 2026
BDI recommendations for the accelerated and advance deployment of charging and refuelling infrastructure in the EU Preliminary remarks With the Fit for 55 package, the EU has established the regulatory framework for climate-neutral mobility. However, it has failed to present the coherent, technology-open and competition-neutral overall approach required, including the framework conditions necessary for the successful transformation towards climate neutrality. A reliable path to transformation can be achieved through technology-open regulation that promotes both the shift towards alternative propulsion technologies and the shift towards climate-neutral fuels, while making use of bridging technologies. Moreover, all modes of transport depend on a mix of climate protection options to phase out fossil fuels from their existing fleets. The defossilisation of road transport is of central importance in this context: road transport is the main mode of transport for passenger and freight traffic in Europe and ensures efficient and resilient logistics chains for the EU economy. At the same time, road transport is the largest emitter of CO2 emissions in the transport sector. In addition, the automotive and supplier industries are of strategic importance for Germany and Europe as industrial locations. To safeguard the further ramp-up of alternative propulsion systems and renewable fuels needed to achieve European climate targets, the European Commission must focus on existing instruments and ensure competitive framework conditions. The two guiding instruments in this regard are the advance, comprehensive and demand-based deployment of charging and H2 refuelling infrastructure across the EU, as well as clear CO2 price signals. In addition to the strong focus on defossilising road transport, all modes of transport and their needs for Europe-wide, high-performance charging, refuelling and bunkering infrastructure must also be considered in order to safeguard the shift towards alternative propulsion technologies and renewable fuels, and to maintain European travel, transport and logistics chains. BDI therefore welcomes the fact that the European Commission has launched the consultation on the revision of the AFIR. As the legal framework for EU-wide minimum requirements for publicly accessible Petra Richter | Energy, Mobility and Environment | T: +49 30 2028-1514 | p.richter@bdi.eu | www.bdi.eu
EU Consultation on the Revision of the AFIR
charging and refuelling infrastructure across all modes of transport – covering all fuel options – the AFIR plays a central role in the transition. German industry had advocated for the revision to begin significantly earlier. The process must now be advanced swiftly. In particular, the European Commission must ensure that the already initiated revision of the CO2 fleet regulation for passenger cars and light-duty vehicles (LDVs) takes place together with the revision of the AFIR. The same applies to the revision of the CO2 fleet regulation for heavy duty vehicles (HDVs) announced for 2027. The level of ambition of the AFIR must be aligned for all vehicle categories with the stringent requirements of the fleet regulations. Interim assessment of the AFIR ▪
The European Regulation on the deployment of alternative fuels infrastructure (AFIR) is the central regulatory lever for the EU-wide ramp-up of publicly accessible charging and H2 refuelling infrastructure1 for road transport, as well as for the required charging, refuelling and bunkering infrastructure for aviation, shipping and rail transport.
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The reporting obligations of the Member States provide a sound basis for monitoring the EUwide ramp-up of charging and H2 refuelling infrastructure in road transport: –
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The deployment of passenger car charging infrastructure has accelerated significantly in the EU, and the available charging capacity has increased disproportionately. o
For example, in the first quarter of 2026, more than 1 million passenger car charging points (AC and DC charging points) were available across the EU. This corresponds to growth of more than 700% compared with 2020.
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All Member States, with the exception of Malta, exceed the EU minimum requirements for installed charging capacity per battery electric vehicle (BEV) and plug-in hybrid electric vehicle (PHEV), in some cases significantly.
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The development is positive in eleven countries where the share of electric vehicles in existing fleets is also above 5%, including Germany, France, the Netherlands, Sweden, Austria and Denmark.
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It is also evident that 14 Member States, including Italy, Spain and Poland, exceed the AFIR minimum requirements, while the market share of BEVs and PHEVs in the existing fleet remains below 5%.
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Currently, only Denmark reaches the market share of at least 15% for BEVs (passenger cars and LDVs) in the overall vehicle fleet specified in Article 3(2) AFIR, which may justify a reduction or elimination of the EU minimum requirement for charging capacity per BEV (sunset clause).
Regarding heavy duty vehicles, there is no dynamic development emerging in the EU-wide deployment of charging infrastructure. Electric trucks from various manufacturers are ready for mass production to ensure a rapid transition to electric vehicles, and since the latest
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In the following text, the statements – in line with the scope of the AFIR – refer exclusively to publicly accessible charging and H2 refuelling infrastructure for road transport. Any deviations from this are explicitly described in the text.
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EU Consultation on the Revision of the AFIR
amendment of the EU Road Charging Directive, Member States have had a key tool at their disposal to provide a strong incentive for the shift to electric propulsion.
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The advance deployment of the necessary initial charging infrastructure – including publicly accessible charging points as well as charging in depots and hubs – for smooth EUwide transport and logistics chains with zero-emission vehicles has made little progress since the AFIR entered into force.
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Sweden has the highest absolute number of publicly accessible charging points for HDVs.
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Overall, ten Member States have no publicly accessible charging points HDVs.
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A comprehensive network of publicly accessible charging infrastructure for HDVs along the Trans-European Transport Network (TEN-T) is not yet evident. For example, the centrally located Member State Hungary still has no corresponding infrastructure; at the same time, even a populous Member State such as Italy, with only 32 charging points, has only around one fifth of the availability found in much smaller Belgium.
With regard to European H2 refuelling infrastructure, the anticipatory deployment of an EUwide core network has not progressed to the required extent since the AFIR entered into force. o
In Germany, filling station operators have made substantial upfront investments in H2 refuelling infrastructure in recent years, while no sustainable vehicle offering and no fleet ramp-up of hydrogen vehicles (H2 vehicles) were apparent. As a result, Germany has the highest number of H2 refuelling points in Europe, with 81 publicly accessible 700bar and 47 publicly accessible 350-bar H2 refuelling stations. In some cases, existing H2 refuelling points had to be taken out of service due to insufficient utilisation.
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In relation to the number of H2 vehicles, utilisation per refuelling stations is highest in Poland.
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At the same time, 15 Member States still have no publicly accessible H2 refuelling stations on their territory. These include Member States centrally located on TEN-T corridors, such as Slovakia and Romania.
For the minimum requirements for aviation and shipping contained in the AFIR, as well as for the voluntary targets in rail transport, the European Commission does not provide comparable data.
BDI assessment ▪
Since it began to apply in April 2024 — replacing the preceding AFID Directive — the AFIR has generally proven itself as a regulatory instrument for the EU-wide deployment of passenger-car charging infrastructure.
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The existing system of capacity- and distance-based deployment targets for charging and H2 refuelling infrastructure in road transport should be maintained. It provides an appropriate framework that takes account of different charging needs.
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EU Consultation on the Revision of the AFIR
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Charging infrastructure operators, e-mobility service providers and H2 refuelling stations operators have in some cases made substantial upfront investments as first movers in anticipatory deployment. To safeguard the investments already made, a swift solution is needed, for example through compensation mechanisms addressing the first-mover disadvantage.
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From the perspective of automotive manufacturers and suppliers, as well as other sectors such as providers of complete solutions and components for charging infrastructure or companies in the logistics and transport industry, the publicly accessible and private or corporate charging and H2 refuelling infrastructure that currently exists or is planned across the EU is not sufficient to support an ambitious ramp-up of electric and hydrogen-based vehicles for all vehicle categories: passenger cars, light duty vehicles and heavy duty vehicles. –
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Charging infrastructure for heavy duty vehicles: o
In view of the European climate targets and the CO 2 fleet targets, advance deployment of publicly accessible charging infrastructure for HDVs in Europe is indispensable. However, the current stock shows that the ramp-up is still at an early stage: in the second quarter of 2026, there were only 2,159 publicly accessible charging locations across the EU with at least one charging point of at least 350 kW.
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For the market ramp-up of zero-emission HDVs to succeed and for cross-border transport and logistics chains to be reliably safeguarded, significantly more ambitious AFIR minimum requirements for charging infrastructure for HDVs are needed.
Charging infrastructure for passenger cars and light duty vehicles: o
Significant overachievement of EU minimum requirements for charging infrastructure alone is not proof that a functioning mass market for e-mobility exists.
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Demand for electric vehicles across the EU is not developing to the expected extent.
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Regarding the strong increase in new registrations of BEVs and PHEVs in the EU in recent months, it remains to be seen whether this will develop into a long-term trend.
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Over the next roughly two years, it will be crucial to achieve a significantly accelerated ramp-up for basic coverage in those Member States whose share of electric vehicles is below 5% of the existing fleet. A so-called sunrise clause should be introduced for this purpose.
H2 refuelling infrastructure: o
In a small number of Member States, substantial investments in H2 refuelling infrastructure were already made in the past, some of which had to be dismantled again due to insufficient utilisation.
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For a technology-open approach, it remains appropriate to ensure a demand-based European core network of H2 refuelling stations. This requires targeted incentives for the Member States concerned in order to ensure the rapid deployment of the missing H2 refuelling infrastructure.
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EU Consultation on the Revision of the AFIR
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In addition, the AFIR minimum requirements should be geared more strongly towards comprehensive, high-performance hydrogen supply that can be used across user groups.
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In conclusion, the AFIR in its current design does not provide a sufficient impetus for the EU-wide deployment of charging and H2 refuelling infrastructure required by an accelerated market rampup of zero-emission vehicles. A key prerequisite for achieving the extremely ambitious requirements of the two CO2 emission standards2 and the European climate protection targets is therefore not in place.
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For this reason, the revision of the AFIR must include a readjustment for all vehicle categories to bring them in line with the strict provisions of the CO2 fleet regulation.
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A targeted addition to improve geographic coverage is sensible and should be implemented through the introduction of targets for urban nodes, logistics hubs and tourist destinations.
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The EU and the Member States are called upon to accompany the increase and supplementation of the AFIR minimum requirements with stronger purchase incentives tailored to the respective buyer markets. Recent years have repeatedly shown that the ramp-up of zero-emission vehicles is successful in those Member States that offer targeted bundles of instruments.
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It is important to monitor the further deployment of charging and refuelling infrastructure closely. With the transition to a functioning mass market for e-mobility, the deployment of charging and H2 refuelling infrastructure must also take place on a market-economy basis. Until the mass market is reached, needs-based deployment across the EU remains a basic prerequisite for the success of e-mobility.
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Aviation, shipping and rail sectors:
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The AFIR should create concrete, Europe-wide harmonised technical requirements and interoperable infrastructure standards in order to avoid additional costs caused by national special solutions.
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What is needed is a technology-open, coherent approach aligned with other European legislation that takes account of electrification, hydrogen and drop-in and non-drop-in fuels, including the logistics and refuelling infrastructure required in each case. For aviation in particular, the requirements of ReFuelEU Aviation and EU emissions trading must be taken into account to ensure a coherent approach.
The call for more ambitious minimum requirements for charging and refuelling infrastructure does not automatically entail a call for undifferentiated funding programmes. Rather, the European Commission and the Member States are called upon to remove obstacles to further deployment and to define and reliably implement targeted funding priorities. Short-term changes harm all sectors involved in their business decisions. A particular focus for safeguarding market-based investments must be placed on:
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Even the urgently needed reduction of the CO2 emission standards in the CO2 fleet regulation and a technologically open approach to the currently ongoing revision of CO2 emission standards for cars and LDVs, as well as the planned revision for HDVs, do not change this fundamental assessment.
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EU Consultation on the Revision of the AFIR
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in road transport, charging and H2 refuelling infrastructure for zero-emission HDVs
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the specific needs for charging, refuelling and bunkering infrastructure in aviation, shipping and rail transport so that they can meet their climate protection requirements
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Member States in which the ramp-up of zero-emission vehicles is below the EU average
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the availability of grid connections and grid capacity
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the removal of constraints, including availability of space and bureaucratic obstacles such as permitting procedures
Priorities for the revision of the AFIR Readjust the framework conditions for the deployment of charging and refuelling infrastructure and shorten the review interval In the revision process, the European Commission is called upon to review the framework conditions for the anticipatory deployment of charging and refuelling infrastructure and to adjust them wherever no market momentum is yet evident. Achieving the agreed climate targets and the AFIR ambitions alone will require greater efforts across all modes of transport and targeted adjustments to the AFIR. The EU must create the necessary conditions by: ▪
accelerating the consultation process and starting the AFIR revision before the end of this year
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adding a long-term planning horizon beyond 2030 for all modes of transport
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realigning and expanding the existing monitoring system: –
shorten the review interval, which has so far been five years: o
to an annual review for road transport
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to three years for aviation, shipping and rail because of the longer development and investment cycles.
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ensure transparent and Europe-wide comparable reporting by the Member States
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establish comparable national coordination structures for charging infrastructure in all Member States and link them with European monitoring through the European Alternative Fuels Observatory (EAFO)
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publish data on the ramp-up of infrastructure for aviation, shipping and rail transport in the Member States
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supplement data on publicly accessible charging and refuelling infrastructure with information on locations, capacities and operational readiness
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EU Consultation on the Revision of the AFIR
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introduce EU-wide, low-bureaucracy monitoring for privately and commercially operated charging infrastructure receiving EU public funding.
ensuring incentives for Member States regarding adequate financing for all modes of transport: –
for publicly accessible charging and refuelling infrastructure, secure financing at least at the target level set out in the AFIR
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supplement funding for private charging and depot charging
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continue and strengthen EU co-funding, for example through the Alternative Fuels Infrastructure Facility (AFIF).
creating additional framework conditions for a rapid expansion of charging and refuelling infrastructure through stronger incentives for Member States, as well as by promoting close coordination among different policy areas and cross-sector cooperation: –
strengthen grid operators so that high-capacity grid connections can be provided through fast permitting procedures as a central prerequisite for the ramp-up of charging infrastructure
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increase the availability of renewable energy sources
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increase the availability of space for charging and refuelling infrastructure
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support the consistent reduction of bureaucratic hurdles.
Balance the advance deployment of charging infrastructure with the ramp-up of electric vehicles ▪
Charging infrastructure operators and e-mobility service providers have already made substantial investments as first movers in existing charging infrastructure. Depending on the use case, the revenues generated in some cases do not even cover operating costs. Any further delay in reaching a mass market for electric vehicles exacerbates this problem.
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At the same time, advance deployment is indispensable during the market ramp-up phase. For the further ramp-up of e-mobility, the European Commission and the Member States face the challenge of resolving this dilemma.
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The highly ambitious requirements of the two CO 2 fleet regulations and the achievement of EUwide climate targets require a significantly accelerated ramp-up of electric vehicles in all Member States.
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The success of the climate-neutral transformation of the European automotive industry and the refinery industry as key branches in Europe is also of central importance for preserving industrial value creation and the many interconnections with other industries.
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A solution to this challenge must be found without delay and in close dialogue with the industry. Possible approaches include: –
compensating the first-mover disadvantage
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EU Consultation on the Revision of the AFIR
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close annual monitoring of the further ramp-up and, where necessary, immediate readjustment
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additional monitoring of private passenger car and truck depot charging infrastructure
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a more differentiated analysis of the different use cases and, where appropriate, the derivation of more differentiated minimum requirements.
Align AFIR targets for charging infrastructure for heavy duty vehicles with the CO2 fleet regulation and supplement them in a targeted manner The revision of the AFIR requirements must take place in close coordination with the revision of the CO2 fleet regulation for HDVs. The revision of the CO2 fleets regulation was originally planned only for 2027. It should be brought forward to this year, with the exception of the review for trailers. Annual monitoring of the AFIR targets with options for readjustment must be carried out. For the further market ramp-up phase of electric HDVs, the minimum requirements of the AFIR must be supplemented and, in some cases, increased: ▪
higher total charging capacity per location along the TEN-T comprehensive network as well as in urban and peri-urban areas
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introduce binding minimum requirements for the addition of locations for the Megawatt Charging System (MCS)3
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enshrine in Article 4 (1) AFIR from 2030 the obligation to install a 1 MW charging point, in addition to the requirement for a charging point with a charging capacity of 350 kW
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higher regional coverage in urban and peri-urban areas and around logistics hubs, since expanding charging infrastructure at the hub locations themselves is often limited by site-specific constraints
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a higher number of available charging stations at truck parking areas with suitable driver rest areas and sufficient clearance height
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design charging infrastructure for HDVs in such a way that the operational requirements of electric coaches and long-distance buses are also adequately taken into account, particularly at suitable transport nodes, in tourist regions and along the TEN-T network.
Align AFIR targets for charging infrastructure for passenger cars and light duty vehicles with the CO2 emission standards and ensure basic coverage in all EU Member States The current AFIR minimum requirements do not ensure that basic coverage with publicly accessible charging infrastructure is established in all Member States. In addition, the AFIR must be aligned with the continued high level of ambition of the CO2 emission standards for passenger cars and LDVs,
3 The European Automobile Manufacturers’ Association (ACEA) estimates that up to 35,000 publicly accessible MCS charging
points will be needed to service the 400,000 electric HDVs by 2030. Link: Decarbonising heavy-duty road transport: State of the enabling conditions - ACEA - European Automobile Manufacturers' Association
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EU Consultation on the Revision of the AFIR
which is currently under revision, and reviewed through annual monitoring. If necessary, short-term corrective action must be taken. ▪
For the next roughly two years, focus on the rapid establishment of comprehensive and needsbased charging infrastructure in all Member States and address in particular Member States with a low market share of electric vehicles.
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For Member States whose market share of BEVs, range-extended electric vehicles (REEVs) and PHEVs is below 5% of the total fleet, a supplementary provision should be introduced (sunrise clause). Below the 5% threshold, a binding basic coverage level should apply, for example measured by publicly accessible charging capacity or publicly accessible charging points per 100,000 registered passenger cars and LDVs. –
The aim is to rapidly ensure basic coverage with publicly accessible charging infrastructure for electric vehicles in these Member States.
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This would ensure that even in early market ramp-up phases, visible and reliable charging infrastructure is created that reduces range anxiety and encourages consumers to switch to electric vehicles.
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Maintain the existing sunset clause (Article 3(2)) at 15%.
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In addition, increased capacity- and distance-based minimum requirements are needed: –
higher total charging capacity per electric vehicle (BEV and PHEV) in order to reflect the charging needs of vehicle owners without access to private charging solutions, who account for a growing share in the current phase of the market ramp-up.
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a higher number of charging stations in the TEN-T core network and TEN-T comprehensive network, as well as obligations for charging stations in urban areas and at transport nodes.
Readjust AFIR targets for H2 refuelling infrastructure With regard to the AFIR minimum requirements for H2 refuelling infrastructure, no demand-based core network is yet emerging. ▪
Focus targeted incentives on those Member States that currently do not meet the AFIR minimum requirements.
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A shortened peak-load window should be defined for the AFIR minimum capacity of 1 t/day. In the future, high-performance H2 refuelling infrastructure must be able to provide the full daily quantity within a significantly shorter peak-load window of around ten hours. The current AFIR minimum capacity of 1 t/day refers to 24-hour operation, which does not correspond to actual demand.
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Further adjustments are also required: –
higher minimum requirements for comprehensive H2 refuelling infrastructure for gaseous (350 bar and 700 bar) and liquid hydrogen
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a uniform definition of H2 refuelling stations across user groups
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EU Consultation on the Revision of the AFIR
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future-proof design of H2 refuelling stations for all vehicle classes.
Address the provision of refuelling stations for RED-compliant renewable fuels ▪
Address the provision of refuelling stations for vehicles operated exclusively with RED-compliant renewable fuels4 in the AFIR revision. This would support the VEEF approach (vehicles exclusively running on eligible fuels, VEEFs) set out in the Automotive Package and at the same time strengthen demand for these fuels. The AFIR revision should introduce a mechanism that addresses the ramp-up of refuelling stations and dispensers for 100% renewable fuels. In doing so, the EU should also set targeted incentives for Member States to remove obstacles to the deployment of these dispensers in national legislation. –
Pursuant to Recital 11 of Regulation (EU) 2023/851, the European Commission is tasked with developing a concept for vehicles operated exclusively with renewable fuels 5.
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These vehicles are indispensable for a technology-open approach to the defossilisation of road transport and rightly play an important role in the context of the EU Automotive Package.
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Such a mechanism can specifically strengthen demand for renewable fuels in road transport and make an important contribution to the shift to low-carbon and climate-neutral fuels in transport.
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All renewable fuels within the meaning of the Renewable Energy Directive (RED) qualify as eligible fuels.
Take account of needs in the aviation, shipping and rail sectors
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In the aviation, shipping and rail sectors, the deployment of alternative drivetrains, including direct electrification and hydrogen applications, as well as renewable fuels, must be enabled through corresponding charging, refuelling and bunkering infrastructure at airports, seaports and inland ports as well as rail hubs, and supplemented by accompanying measures, including financial incentives.
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In aviation, airports should be gradually developed into integrated energy hubs, taking account of their specific stakeholder structure. For this purpose, the AFIR should create a technologyopen European planning framework that safeguards the ramp-up of alternative aviation technologies through high-performance electricity grids, hydrogen infrastructure, storage solutions, and logistics and refuelling areas. –
take account of stationary airport applications, including mobile ground power systems as well as battery-electric and hybrid-electric aircraft
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link grid connections and grid expansion with the technology ramp-up at an early stage
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take hydrogen infrastructure into account from provision through to refuelling
RED-compliant renewable fuels include all renewable fuels as defined in the Renewable Energy Directive (RED). Similarly, this obligation also applies under Recital 17 of the CO2 Fleet Regulation for HDVs.
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EU Consultation on the Revision of the AFIR
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take differentiated account of the site profiles of hubs, regional airports, cargo airports and smaller airports
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enable alternative fuels, including Sustainable Aviation Fuel (SAF), Power-to-Liquid (PtL) as well as drop-in and non-drop-in fuels.
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Member States’ progress in meeting the AFIR minimum requirements for stationary electricity supply at airports, for shore-side electricity supply in seaports and inland ports, and for liquefied methane in seaports should be publicly available, analogous to the information provided for road transport.
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Accompanying measures and financial incentives must be strengthened for the further deployment. In maritime transport, it is important to take into account that different deployment speeds can have direct effects on route planning, costs and emissions reduction.
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With regard to the rail sector, the AFIR’s current approach of voluntary consideration should be further developed into minimum requirements. Rail hubs and combined transport terminals must be expanded for the use of all alternative drivetrains and renewable fuels. This requires a sufficient number of charging stations for battery-powered trains, hydrogen refuelling stations and refuelling stations for other renewable fuels where direct electrification of railway lines is not possible.
Advance private charging, avoid unnecessary hardware costs, and increase price transparency and competition ▪
The European Commission is called upon to ensure consistent implementation of at least the 1:1 requirements of Article 14 of the Energy Performance of Buildings Directive (EPBD) for the deployment of private charging infrastructure in the Member States, in addition to the AFIR, through additional incentives and close monitoring.
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Avoid hardware changes for payment methods at charging stations:
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Payment at charging stations must be easily accessible, secure and user-friendly.
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If there is further harmonisation of methods for ad-hoc payment for charging at charging points with a capacity below 50 kW, it should be ensured that manufacturers are not required to provide specific hardware solutions, in particular physical card readers. This would make charging infrastructure unnecessarily more expensive and thus hinder deployment. The AFIR should remain technology-open and enable digital, secure and user-friendly payment solutions.
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The existing provision in Article 5(1) AFIR should be maintained and, at most, linguistically clarified in order to provide clarity regarding the use of QR codes.
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To this end, the illustrative reference to dynamic QR codes should be deleted without replacement. It provides no added value and has in the past caused considerable uncertainty as to which technical solutions are permissible.
Strengthen price transparency as a central element for the acceptance of e-mobility: users should be able to clearly identify the costs incurred before starting the charging process.
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EU Consultation on the Revision of the AFIR
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The transparency requirements provided for by the AFIR make an important contribution in this regard. The aim should continue to be a user-friendly and, as far as possible, Europewide consistent presentation of prices, while taking account of existing market mechanisms and established information channels. This would also make it immediately clear in other European countries what costs are incurred for charging electric vehicles.
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The undefined legal terms introduced by the AFIR with regard to the appropriateness, comparability and discrimination of prices should be specified as part of the AFIR revision, for example in the recitals. A swift, Europe-wide uniform rule would strengthen price transparency and competition at the same time.
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Blocking fees can help ensure the availability of public charging points. The AFIR should clearly distinguish them from pure parking or reservation fees and provide user-friendly framework conditions, for example by linking them to the completion of the charging process and allowing appropriate grace periods.
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EU Consultation on the Revision of the AFIR
Imprint BDI – Federation of German Industries Breite Straße 29, 10178 Berlin www.bdi.eu T: +49 30 2028-0 Lobby register number: R000534
Editors Petra Richter Senior Manager Energy, Mobility and Environment T: +49 30 2028-1514 p.richter@bdi.eu Olivier Hummel Senior Representative Energy, Mobility and Environment T: +32 2 792 1011 o.hummel@bdi.eu
BDI document number: D 2348
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