From CPOs to compliance officers
The EU's Alternative Fuels Infrastructure Regulation (AFIR) entered binding application in April 2024, replacing the older directive-based framework. For the first time, every member state has a single set of binding minima covering the density of public charging infrastructure, the technical performance of stations, the user-experience of payments, and the openness of data.
For Germany specifically — already operating roughly 200 percent of its AFIR-mandated public DC capacity by mid-2025 — the regulation has shifted procurement from a question of whether to deploy chargers to which chargers can credibly meet the AFIR specification. EPCs and CPOs (charge-point operators) are now demanding compliance evidence as a baseline tender requirement.
The five things every buyer is checking
- Power class and density. AFIR requires that, by end-2025, every TEN-T core network rest area in the EU has at least 400 kW of cumulative DC power, with at least one 150 kW outlet per direction. By end-2030, this rises to 600 kW. Any 60 to 150 kW DC station ordered today must therefore be specified with the upgrade path or stack-deployment plan in writing.
- Ad-hoc payment without subscription. Article 5 mandates that every public DC station accept contactless card payment (or a QR-code-driven web payment alternative) without requiring app download, account creation, or subscription. Stations ordered without an integrated payment terminal are now non-compliant by default.
- OCPP 2.0.1 backend interoperability. While AFIR itself is technology-neutral, member-state implementations increasingly mandate OCPP 2.0.1 specifically, both for backend portability and for ISO 15118 plug-and-charge support.
- Data publication. Static data (location, power, plug type) must be published in a standardized format to the national access point. Dynamic data (availability, real-time price) must follow within set latency targets. CPO operations contracts now uniformly include data-feed clauses.
- Plug standards. CCS2 remains mandatory for new public DC stations in the EU. GB/T outlets are permitted as additional but not as replacement. Type 2 remains the standard AC connector.
The TÜV expectation
While AFIR itself does not specify a single test mark, German EPCs and grid operators almost universally demand TÜV-tested products with full CE LVD/EMC compliance, EN IEC 61851-1 (general charger requirements), and EN IEC 61851-23 for DC stations. Newer tenders increasingly add EN IEC 63110 (CSMS) and EN ISO 15118-2/-20 (vehicle-to-grid communications) as evaluation criteria even where not strictly mandatory. Our DC charger lines ship with TÜV test reports against the relevant EN standards as part of the pre-shipment documentation pack.
What this means for non-EU manufacturers
The AFIR era has effectively closed the German market to chargers that cannot demonstrate end-to-end compliance evidence. The good news: it has also created a clear, auditable specification that allows reputable manufacturers to compete on the merits. Pricing pressure is intense at the 60 to 120 kW commercial-station tier, but margins remain healthy at 240 kW and above where engineering complexity rewards scale.
For German EPCs and CPOs evaluating new supplier relationships, our standard tender response includes: certification matrix per SKU, OCPP 2.0.1 conformance test result (Pionix CTP or equivalent), payment terminal options (Nayax, Worldline, custom), CSMS integration references, and a full BOM-traceability statement satisfying upcoming EU battery passport requirements.
The 2027 horizon
AFIR's biggest impact is still ahead. The 2027-2030 milestones progressively raise the bar: every truck-suitable rest area on the TEN-T core network must have 1.4 MW of DC capacity, every urban node must meet density targets, and ISO 15118 plug-and-charge must be the default. Ordering today's chargers without a clear upgrade path to those requirements is, in effect, ordering early-obsolescence.
