CHAdeMO Association has submitted comments in response to the European Commission’s call for evidence regarding the on-going AFIR (Alternative Fuels Infrastructure Regulation) review from the EU portal.
The Association believes that the current AFIR technical requirements (Annex II 1.3.3), which came into force last year and mandates the use of “Combo 2” connectors for ALL publicly accessible recharging points reserved for L-category electric vehicles not only fail to meet the industry’s needs but also hinder the development of charging infrastructure for small Category L EVs.
Background:
Despite comments from our Association (and other industry stakeholders), the European Commission’s Delegated Regulation (EU) 2025/655 of 2 April 2025 entered into force in June 2026, mandating the use of ‘at least “Combo 2” connectors for all public DC (normal-power and high-power) recharging points reserved for L-category electric vehicles’ in Europe starting January 2026.
Our views:
Such requirements for L-category charging do not meet the needs of the industry or the majority of users. CHAdeMO Association proposes separating standard-power and high-power DC charging points dedicated to L-category electric vehicles and mandating the international charging standard EN IEC 62196-6 (“Type 6”) for the former.
1) The “Combo 2” connectors (and inlets) are unsuitable for charging most L-category vehicles
・They are too large relative to vehicle size
・The voltage range (200V to 920V) is unsuitable for 48V battery voltage used in many L-category vehicles
・As they have both AC and DC parts integrated in one, an on-board charger (OBC) is required; such OBCs are large, heavy, and expensive
2) Consequently, public chargers for small L-category vehicles cannot be installed, which risks hindering the electrification of the category, as well as the development of large-scale delivery services and car-sharing fleets using such vehicles.
3) The international charging standard EN IEC 62196-6 (“Type 6”) connector for use in DC charging systems compliant with the international standard EN IEC 61851-25:2020 has already been developed by industry stakeholders, specifically designed for DC charging and optimized for L-category vehicles. This eliminates the need for an OBC, thereby reducing vehicle costs.
4) There is consensus among industry stakeholders. For example, ACEM also supports this solution.
Recommendation:
We propose that Combo2 be limited to high-power chargers, whilst adopting the CHAdeMO standard for normal-power DC chargers
The full text of our association’s comments can be viewed from the EU Portal: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/16672-Review-of-EU-rules-on-alternative-fuels-infrastructure/F33394569_en
An information package containing detailed information can be viewed from here: https://chademo.com/wp2021/wp-content/uploads/2026/04/CHAdeMOAssociation_info.pdf
As to the next step, public consultation is expected to begin at the start of the fourth quarter of this year. CHAdeMO intends to continue calling for standards that will help drive the electrification of L-category vehicles by collaborating with industry stakeholders.
