The year 2022 was a time of gradual recovery from the COVID-19 pandemic for many Poles. The SARS-CoV-2 virus had a devastating effect on many industries, with a significant number of catering and hotel companies chafing under the weight of bankruptcy, some being forced to undergo restructuring procedures or even declare bankruptcy. The automotive industry is one of the sectors that was particularly damaged by the COVID-19 pandemic [1]. Due to the global health crisis, a significant number of car factories around the world had to temporarily halt their production. Analysis by Frost&Sullivan estimates that this state of affairs could have resulted in a 21-28% drop in vehicle supply compared to 2019 results [2]. In Europe, production losses amounted to more than 2 million vehicles, which had a negative impact on the industry, employees and the economy. In Poland, which is an important link in the European automotive supply chain, production losses amounted to more than 80,000 vehicles [2]. Such a drop in production affected many areas, including employment, sales, financial turnover and investment. While the COVID-19 pandemic caused many difficulties for the industry, at the same time it also provided the impetus to look for new ways to develop and modernise the automotive industry, for example by investing in digital and green technologies.

A summary of the past year in the electromobility segment was presented by the Polish Alternative Fuels Association (PSPA) in its report ‘Year 2022 in Polish electromobility’. The study contains basic data on the development of the market for electric passenger cars, proposed courses of action and a presentation of legal amendments to the regulations governing the electromobility sector [3].

A year of records in electromobility

 At the end of 2022, there were 62 135 registered electric cars on Polish roads, including delivery vehicles. This number represents an approximately 69% increase compared to 2021, which only confirms that the demand for ‘electrics’ in Poland is definitely growing. The number of electric passenger cars alone was 59,187, of which 22,413 were only registered in 2022. Over the course of two years, the number of electric cars in Poland has more than tripled, and this trend reflects the Europe-wide drive towards vehicle electrification – according to ACEA (European Vehicle Manufacturers Association), the first three quarters of 2022 saw some 717,000 registrations of new all-electric passenger cars in EU member states, an increase of 26% compared to the same period in 2021. The leading country in this respect for many years has been Germany, where more than 273,000 all-electric passenger cars were registered between January and September 2022. The decline in sales, for the first time since ACEA began conducting surveys, occurred in the hybrid segment, with new registrations down by around 9% compared to the previous year. The reasons for this can be traced to the growing sales of ‘full electrics’ and the general trend towards abandoning individual personal cars in favour of public transport [3]. According to Jan Wiśniewski, director of the Research and Analysis Centre of the Polish Alternative Fuels Association, “There are now more electric cars on Polish roads than, for example, in the USA in 2011, in Japan in 2012, in China in 2013, in Norway in 2014, in France or Germany in 2015, or in Spain or Italy in 2019. Of course, this does not mean that we will make up the difference between us and the above-mentioned countries in a few years, but global and European trends in the field of e-mobility allow us to assume that already by 2025 the number of newly registered electric cars in Poland will increase at least several times. Such a significant increase is encouraging, especially in the context of the current difficult situation in the automotive sector. The number of new passenger EV registrations in Poland increased by more than 22,413 units, or 36% more than in 2021. At the same time (based on PZPM data), the primary market in Poland, including internal combustion vehicles, saw a decline of almost 7%. ‘Difficulties with the availability of new cars make EVs an equivalent alternative for many buyers who have not previously considered buying an electric car’ [3].

The greatest number of electric cars in Poland have been registered in large urban centres, i.e. Warsaw, Poznań, Kraków or Wrocław [4]. The infrastructure in larger agglomerations is definitely more favourable for the users of electric vehicles, it is easier to find a charging station in cities, and the distances covered are definitely shorter, so the low range of a car is not a problem [5].

According to the authors of the cited report, the government’s ‘My Electric’ programme played a major role in the process of popularising ‘electrics’ among Polish drivers. The initiative has succeeded in increasing the number of registrations of electrically powered cars by providing attractive subsidy and support conditions for a wide range of beneficiaries. As of mid-November 2022, the National Fund for Environmental Protection and Water Management (NFOŚiGW) approved applications for a total of 1.3 thousand vehicles under a call addressed to individuals not running a business. Other calls approved applications for 4.9 thousand all-electric passenger cars (BEVs). In total, the number of 6.2 thousand BEVs covered by accepted applications represents approximately 10% of the total number of electric passenger cars and vans registered in Poland [3].

However, there has been increasing criticism of the ‘My Electric’ programme regarding the maximum price of a vehicle for which a subsidy can be granted, i.e. PLN 225,000. Due to rising inflation, the prices of all cars have definitely increased, and the quoted amount is now worth at least several tens of per cent less than when the programme was established [6].

EU electromobility regulations.

One element of the EU’s ‘Fit for 55’ package is AFIR, the Alternative Fuels Infrastructure Regulation, which is intended to oblige EU Member States to invest in building infrastructure for refuelling and charging points for vehicles powered by alternative fuels, including electricity [7]. The aim is to increase electromobility and reduce CO2 emissions into the atmosphere. According to EU Council data, transport generates almost 25% of all greenhouse gas emissions in the EU. During 2022, Poland recorded a record increase in charging infrastructure for electromobility Between January and November, 595 new public charging stations were installed, which is the highest in the history of Polish electromobility. Warsaw is leading the way with almost 10% of the charging infrastructure network[8].

According to the legal standards in the AFIR, by the end of 2030, charging stations for electric cars should be located at least every 60 km on trunk roads and hydrogen refuelling points should be located every 200 km on trunk roads, at least one at each junction designed to be able to dispense 1 tonne of hydrogen per day at a pressure of 700 bar [9]. The   AFIR also regulates, much more residually, liquefied methane charging points. However, the regulation goes beyond road transport and regulates electromobility at ports and airports. Under the EU’s proposals, at least 90% of passenger ships and container ships should have access to electricity at major seaports, while at inland ports, a minimum of one installation must provide shore power by 2030. Regarding airports, the regulation stipulates that all aircraft stands at terminals must be electrically powered by 2025 and remote stands by 2030. [10].

According to the authors of the report, one of the biggest threats to the development of the electromobility sector in Poland is the insufficient number of charging stations. According to J. Wiśniewski, “Currently, there are more than twice as many electric cars per charging point in Poland as there were just three years ago. There is no indication that this trend is going to reverse in the near future. Taking into account data from the International Energy Agency (IEA), there are currently a similar number of charging points in Poland (4,913) as in the UK in 2013, Germany in 2015, Spain in 2017, or Sweden in 2019. In the latter country, however, almost 14,000 points were already in operation at the end of 2021 – almost three times more than in our country today, despite being a country with a passenger car fleet that is more than five times smaller. Accelerating the expansion of infrastructure in Poland requires decisive action on the part of the public administration. The industry is not able to overcome the numerous systemic barriers on its own. Changes to the law are necessary” [3]. For this reason, the report includes proposed postulates for a law amending the regulations for the charging infrastructure sector. Among other things, the draft envisages changes to make it easier to acquire rights to land for grid investments or to allow those applying for connection to the public charging station network to choose the voltage level at which electricity will be supplied. This means that an entity interested in installing a charging station can choose the level according to individual needs and technical requirements. Such freedom of choice allows for greater flexibility in the design and installation of charging stations, which in turn will contribute to the development of electromobility and increasing the number of publicly accessible charging points in Poland.

A consequence of the rise in popularity of electric cars is a proportionately higher demand for components to power and store energy, which is then used to put the vehicles in motion. As reported by e-magazines.co.uk, ‘Benchmark Mineral Intelligence states in its study that the demand for lithium is growing rapidly. It turns out that the world will need more than 20 times as much lithium as was mined in 2021 by mid-century to meet demand for the element. Such projections are significantly influenced by countries’ decarbonisation policies, the strong development of electromobility and the growing energy storage market, including a projected more than 400 GW of installed energy storage capacity by 2030. Demand for lithium is growing because many energy storage and batteries for electric vehicles are based on this element – e.g. lithium flow batteries, lithium-ion batteries. Because of this situation, various measures are being taken to make Europe the second largest producer of lithium-ion batteries in the world by 2025!”[11]. In terms of regulation, it seems to be important to reach an initial agreement between the Council of the EU and the European Parliament on a regulation on batteries and waste batteries, repealing Directive 2006/66/EC and amending Regulation (EU) 2019/1020. The proposed changes aim to increase the level of competitiveness in the lithium-ion battery market, as well as to contribute to an increase in the percentage of recovery of raw materials, which are important for the said sector [3]. As highlighted by Maria Majewska, PSPA Bacteria Committee Coordinator, “The regulation is intended to promote a closed-loop economy. It will contain regulations for the handling of waste batteries. In addition, it will set out the objectives and obligations of producers with regard to their collection. For light transport vehicles, this is to be 51% by the end of 2028 and 61% by the end of 2031. On the basis of the pending regulations, on the other hand, the lithium recovery rate will be 50% by 2027 and 80% by 2031. The proposed share of recovered cobalt is to be 16%, lead 85%, and lithium and nickel 6% each.” [3]. Also noteworthy is the legislative work on the implementation of the new Euro 7 emission standard. According to Maciej Mazur, Managing Director of the PSPA, “Euro 7 is expected to guarantee much greater emission reductions than the previous standards for cars, vans, trucks and buses in real driving conditions and over a much longer period. All these vehicle categories will be covered by one set of regulations. Importantly, the new standards are to apply not only to pollutants from exhaust systems, but also from brakes and tyres. The same limits will apply regardless of whether the vehicle in question is powered by petrol, diesel, electricity or another type of alternative fuel. Of course, in many cases the limits will be significantly tightened. For example, under Euro 6, the nitrogen oxide emission limit for petrol-powered passenger cars was 60 mg/km and for diesel it was 80 mg/km. Under Euro 7 it will be 60 mg/km regardless of the propulsion type” [3].

The year 2022 was certainly an important time for the development of the electromobility sector in Poland. Records were set in the number of new electric car registrations, in spending on charging infrastructure and in the number of publicly available charging stations [11]. However, this does not mean that there will be any regression in 2023. As the authors of the report in question predict, the current year promises to be the best in the short history of electromobility in Poland to date. Nevertheless, it will still take some time for a real breakthrough in this sector to occur, especially due to the gradual implementation of the ‘Fit for 55’ package, especially the AFIR Alternative Fuels Infrastructure Regulation, which is expected to give a programme framework for the process of further development of electrification of mobility and communication in Poland [12]. Regardless of whether and in what form the Polish state will be obliged to implement the Community mechanisms regulating the infrastructure of electric vehicles, it should be borne in mind that appropriate measures, consistent with the idea of social dialogue and development, should be taken to ensure proper, rational regulation of the electromobility segment.


REFERENCES:

[1] https://knaufautomotive.com/pl/rozwoj-swiatowej-branzy-automotive-po-2021-roku-a-covid-19/

[2]https://pspa.com.pl/2020/informacja/elektromobilnosc-broni-sie-przed-covid-19/

[3] https://pspa.com.pl/wp-content/uploads/2023/01/PSPA_Rok_2022_w_polskiej_elektromobilnosci_Raport-3.pdf

[4]https://bank.pl/dlaczego-pojazdy-elektryczne-maja-sens-tylko-w-duzych-miastach/?id=309312&catid=27735&cat2id=25926

[5] https://www.milivolt.pl/mapa-stacji-ladowania/

[6]https://www.money.pl/gospodarka/moj-elektryk-rusza-program-doplat-do-samochodow-elektrycznych-w-leasingu-znamy-szczegoly-6705694547717088a.html

[7]https://www.rp.pl/prawo-w-firmie/art38269131-czy-polskie-prawo-jest-gotowe-na-afir

[8] https://poland.representation.ec.europa.eu/news/transport-bez-emisji-2023-02-17_pl

[9] https://www.consilium.europa.eu/pl/infographics/fit-for-55-afir-alternative-fuels-infrastructure-regulation/

[10] https://eur-lex.europa.eu/legal-content/PL/ALL/?uri=CELEX:52021PC0559

[11] https://e-magazyny.pl/aktualnosci/magazyny-energii/jak-wzrosnie-swiatowe-zapotrzebowanie-na-lit/

[11]https://greenwaypolska.pl/blog/general/elektromobilnosc-w-2022-roku-podsumowanie-od-green-way

[12] https://energetyka24.com/klimat/analizy-i-komentarze/fit-for-55-co-czeka-europe-komentarz

SOURCES:

– legal acts:

  1. Act of 11 January 2018 on electromobility and alternative fuels (Journal of Laws 2022, item 1083, as amended).
  2. Act of 25 August 2006 on the system of monitoring and controlling fuel quality (i.e. Journal of Laws 2022, item 1315, as amended).

– other:

  1. Aleksander Jagiełło – Electromobility in shaping the development of urban road transport in Poland; Gdansk University Publishers 2022.
  2. Kwiatkiewicz Piotr , Szczerbowski Radosław , Śledzik Waldemar – Electromobility. Infrastructure environment and technical challenges of intra-regional policy; FNCE 2020 ed.
  3. M. Frańczuk [in:] The Law on Electromobility and Alternative Fuels. Commentary, ed. F. Grzegorczyk, A. Mituś, Warsaw 2021,
  4. Pieriegud Jana , Gajewski Jerzy , Paprocki Wojciech – Elektromobility in Poland against the background of European and global tenations; published by CeDeWu Sp. z o.o. 2019 r.
  5. Polish Alternative Fuels Association – PSPA summary Year 2022 in Polish electromobility; Warsaw 2023.

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The project is carried out by Cardinal Stefan Wyszyński University in Warsaw.

Project name: Law of new technologies – drones, electromobility. Innovation, development, security.

The state-funded project was accepted for funding in the context of a competition launched by the Minister of Education and Science on 8 March 2021 as part of the “Social Responsibility of Science” programme.

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The aim of the project is to promote scientific research in the field of the law of new technologies by disseminating knowledge of the legislation on unmanned aerial vehicles – drones – in particular their operation, design, the obligations of operators and pilots, the obligations of public actors in the field of electromobility and the support mechanisms for users.

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