CEN and CENELEC Position Paper on the European Commission s proposal for a Directive on the deployment of alternative fuels October 2013

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1 CEN European Committee for Standardization European Committee for Electrotechnical Standardization CEN Identification number in the EC register: Identification number in the EC register: CEN and Position Paper on the European Commission s proposal for a Directive on the deployment of alternative fuels October 2013 Executive Summary This document expresses the concerns of CEN and both recognized as European standardisation organisations under EU Regulation 1025/2012 on certain aspects of the proposed Directive on the deployment of alternative fuels infrastructure (COM(2013) 18), adopted by the European Commission on 24 January 2013 as document. Our concerns and proposed improvements concern Annex III of the proposed Directive. Introduction CEN and recognise the growing importance of environmental and sustainable development for current and future generations and therefore believe that standardization has a crucial role to play in order to support EU legislation and to help the Member States in the implementation of environmentally friendly measures. Therefore CEN and communities welcome the standardization objectives of the EU Clean Fuel Strategy initiative as launched by DG Move at the end of January 2013, especially the desire to develop standards for potential new technologies across Europe in the coming years. CEN and would however like to express some concerns regarding the provisions of Annex III of the proposed Directive, which contains a list of CEN and (and ISO and IEC) 'technical specifications'. Avenue Marnix Brussels - Belgium Tel: Fax: info@cencenelec.eu -

2 Comments 1. General comments on Annex III As a first general comment, CEN and would like to highlight the fact that through the mechanism of the future Directive, standards would be embedded directly in the regulatory context. This diverges from the principles set out by the New Approach philosophy where standards are not directly referred to in the European regulatory text itself but are recognised, through a separate act from the Commission, by its citation in the Official Journal. In addition, Annex III refers to dated standards. The citation of European standards with a specific year of publication in legislation 'freezes ' the state of the art at a specific year of issue of the standard and does not allow the legislation to evolve simultaneously with future standard editions reflecting the evolution of the state of the art. If the direct reference to standards is to be kept in Annex III of the Directive, CEN and would then recommend the use of undated references, which would de facto mean a reference to the latest version of the standard. Nevertheless, CEN and wish to remind the Commission that dated standards are necessary for vehicles, in order to be in line with Directive 2007/46/EC establishing a framework for the approval of and their trailers, and of systems, components and separate technical units intended for such vehicles. Proposal for amendment 1- Annex III, 1.1 and 1.2 Current content of COM(2013) 18 for electric vehicles shall be equipped, for standard EN standard EN for electric vehicles shall be equipped, for

3 interoperability purposes, with connectors of Type "Combo 2" as described in the relevant EN standard, to be adopted by interoperability purposes, with connectors of Type "Combo 2" as described in the relevant EN standard, to be adopted by Proposal for amendment 2 - Annex III, 2.1 Current content of COM(2013) Outdoor hydrogen refuelling points dispensing gaseous hydrogen used as fuel on board land vehicles shall comply with the relevant EN standard, to be adopted by 2014, and, pending the publication of this standard, with the technical specifications of the ISO/TS 20100:2008 Gaseous Hydrogen Fuelling specification Outdoor hydrogen refuelling points dispensing gaseous hydrogen used as fuel on board land vehicles shall comply with the relevant EN standard, to be adopted by 2014, and, pending the publication of this standard, with the technical specifications of the ISO/TS Gaseous Hydrogen Fuelling specification. As a second general comment, it is to be noted that there is currently a European standardization proposal for the revision of EN that would allow the insertion (if desired) of mechanical protection means of live accessible parts, commonly referred to as 'shutter' as requested by national installation rules in some European countries. The proposal, if approved, would allow the use of configuration type 2 with or without insertion of shutter (based on national laws/regulation), when installing charging points, always enabling interoperability of connectors of Type 2, all over Europe. To conclude this part, CEN and would like to emphasize the fact that in the field of urban electric mobility, a huge increase of light electric vehicles (LEV) is expected over the next 10 years. The charging power of such light vehicles is different from that required for other vehicles. 2. Annex III, items 1.1 and 1.2 CEN and noticed that the term 'connector' is used several times in Annex III, while for the recharging point it would be more appropriate to use the terms as given in EN Plugs, socket-outlets, vehicle connectors and vehicle inlets - Conductive charging of electric vehicles -- Part 2: Dimensional compatibility and interchangeability requirements for a.c. pin and contact-tube accessories i.e. socket outlet for charging stations without fixed charging cable and vehicle connector for charging stations with a fixed charging cable. This would underline the two different solutions at the charging point side.

4 Furthermore, it is to be noted that the electrical safety of the whole charging point is covered by EN 'Conductive charging system for electric vehicles - Part 1: General requirements' and is an integral part of the safety of charging points. EN is not mentioned in the text of the proposed Directive while it is fundamental to ensure the safety of the 'system' charging point with outlet type 2. Proposal for amendment 3 - Annex III, 1.1 and 1.2 Current content of COM(2013)18 points for electric vehicles shall comply with EN and shall be equipped, for interoperability purposes, with connectors of Type 2 socket outlets as described in standard EN :2012 which shall be provided, where required with a compatible socket outlet comprising additional safety shutter. Note 1: To that end, EN is currently being revised. Note 2: in addition to Mode 3, Mode 1 and/or Mode 2 of EN remain relevant charging modes. points for electric vehicles shall comply with EN and shall be equipped, for interoperability purposes, with socket outlets or vehicle connectors of Type 2 as described in standard EN :2012. for electric vehicles shall be equipped, for interoperability purposes, with connectors of Type "Combo 2" as described in the for electric vehicles shall comply with EN and EN (still under development) shall be equipped,

5 relevant EN standard, to be adopted by for interoperability purposes, with vehicle connectors of configuration FF as described in EN (Type "Combo 2") as described in the relevant EN standard, to be adopted by Note: other systems may be used to cope with existing vehicles 3. Technical specifications for petrol and diesel fuels containing biofuels The Fuel Quality Directive (Directive 98/70 and subsequent amendments) sets EUwide specifications for petrol and diesel used in cars, trucks, other vehicles and machinery in order to protect human health and the environment. EN 228 Automotive fuels-unleaded petrol- Requirements and test methods and EN 590 Automotive fuels- Diesel- Requirements and test methods are referenced in the Fuel Quality Directive. Member States should monitor compliance with the requirements of some of the provisions of the Directive using the test methods mentioned in these standards or equivalent ones. The standards have been developed as voluntary standards in order to allow compliance and to guarantee proper functioning of the engines and the logistics. The Fuels Quality Directive gives mandatory requirements on the environmental parameters and mandates when additional labelling is required. This is respected in the EN 228 and EN 590 fuel specifications. CEN and would therefore like to express their concern regarding the introduction of a reference to these two standards in Annex III (4.1 and 4.2) as legally binding standards. The market harmonization aspects are already sufficiently covered by the Fuel Quality Directive and the introduction of such a reference here could lead to confusion and possible inconsistencies between the provisions of the two Directives, should the Fuel Quality Directive be amended in the future. In addition, it should be noted that the use of the term biodiesel is not in line with the terms used in the Fuel Quality Directive. If points 4.1 and 4.2 were to be kept in the Annex, the term biodiesel should be replaced by the term Fatty Acid Methyl Ester (FAME), which is also the term used in EN 590. Furthermore, it should then be clarified what is meant with the term low-blend. Proposal for amendment 4 - Annex III, 4 Current content of COM(2013)18 4. Technical specifications for petrol and diesel fuels containing biofuels 4.1. Petrol containing low-blend bioethanol shall meet the standard EN Technical specifications for petrol and diesel fuels containing biofuels 4.1. Petrol containing low-blend bioethanol shall meet the standard EN228.

6 4.2. Diesel containing low-blend biodiesel shall meet the standard EN All fuel pumps serving petrol at standard EN All fuel pumps serving diesel at standard EN Diesel containing low-blend biodiesel shall meet the standard EN All fuel pumps serving petrol at standard EN All fuel pumps serving diesel at standard EN590. European Standards for petrol and diesel fuel (containing biofuels) and requirements for labelling should be in line with the Fuels Quality Directive (98/70 and subsequent amendments) About CEN and CEN (European Committee for Standardization) and (European Committee for Electrotechnical Standardization) are officially recognised organisations responsible for developing and defining standards at European level. These standards set out specifications and procedures in relation to a wide range of products and services. The members of CEN and are the National Standards Bodies and National Electrotechnical Committees of 33 European countries including all of the EU member states plus Iceland, Norway, Switzerland, former Yugoslav Republic of Macedonia and Turkey. CEN and also work to promote the international harmonisation of standards in the framework of technical cooperation agreements with ISO (International Organization for Standardization) and IEC (International Electrotechnical Commission). European Standards (ENs) are developed through a process of collaboration among technical experts nominated by business and industry, research institutes, consumer and environmental organisations and other societal stakeholders. These standards are recognised throughout all of the 33 countries covered by CEN and. For more information please see: