1. European and Economic Social Committee
Commission Implementing Regulation on a common methodology for alternative fuels price comparison. Implementation of Article (7.3) of Directive 2014/94/EUEU of t
European and Economic Social Committee
28 June 2018
TOWARDS A NEW CULTURE FOR URBAN MOBILITY

2. Requirements of the AFI Directive
Art 7.3 of the AFI Directive stipulates that "Where appropriate, when displaying fuel prices at a fuel station, in particular for natural gas and hydrogen, comparison between the relevant unit prices shall be displayed for information purposes". The Commission is empowered to adopt, by means of an implementing act, a common methodology for alternative fuels unit price comparison

3. A common methodology on Fuel Price Comparison
The purpose of the common methodology is to facilitate a comparison of conventional and alternative fuel prices in an easy manner in order to build consumer awareness about the relative prices of using different fuels for vehicles
The methodology for calculating a comparison of alternative fuel prices concerns conventional fuels and alternative fuels as specified in Art (2) of Directive 2014/94/EU

4. Preparatory Works: Definition of a common methodology
A study has been carried out by the German Energy Agency – DENA - proposing two methodologies, each with two variants, for fuel price comparison.
Methodology I: The price Euros/National currencies per 100 km is calculated taking into account both the energy content of the fuel and the vehicle energy efficiency on a well to wheel basis (first variant, based on EU Data) or the fuel consumption values (second variant) provided with the certificate of conformity of the vehicle based on the World Harmonised Light Vehicles Test Procedure - WLTP
Methodology II: The price is only based on the energy content of the fuel (Euros/National currencies per petrol litre equivalent – first variant - or Euros/National currencies per 10 Kwh – second variant)

5. Selection of the methodology
Methodology II (euros/national currencies per petrol litre equivalent or10 Kwh) appears not optimal because the efficiency of the respective technologies linked to the use of the different fuels in the vehicles is not considered, which means that the advantage of the use of more efficient vehicles(e.g. electric vehicles) is minimised. Methodology I in its variant 1 (euros/national currencies per 100 km based on EU data), appears also less suitable because the values of the JEC well-to-wheel is based on a modelling exercise and could create confusion to the consumers. Methodology I (variant 2 euros/national currencies per 100 km on the basis of the certificate of conformity) appears to be the most suitable because is based on fuel consumption values measured in the type approval procedure.

6. Preparatory Works: Testing Consumer Opinion
A consumer survey on fuel price comparison has tested the opinion of consumers on the two methodologies analysed.
The findings of the survey clearly show that consumers would favour the fuel price comparison to be made in euros-national currencies per 100 km, as this methodology appears to be the most clear and convenient.
It is suggested that a new price system at the filling station should be accompanied by online tools that would enable the consumer to obtain a more accurate picture of the fuel prices of vehicles with different propulsion systems.

7. The methodology selected: price per 100 km
The method is based on the fuel consumption per 100 km as indicated in the certificate of conformity of the vehicle and the price of the fuel in the conventional units.
• The figure of fuel consumption per 100 km given in the certificate of conformity is based on the vehicle energy efficiency and the energy content of the fuel
• If this figure is multiplied by the price of the fuel in the conventional unit, we have the price per 100 km for the car in question
Fuel price (€/ltr or kg)* ltr/100km or Kg/100km= Fuel price €/ 100km

8. Determination of the Price as amounts of applicable currency per 100 km
The fuel consumption value is based on the World Harmonised Light Vehicles Test Procedure (WLTP) starting from September 2017 for new type of vehicles and from September 2018 for all new vehicles. This test procedure replaces the currently used New European Test Cycle (NEDC)
As no values for fuel consumption are provided in the certificate of conformity of the vehicles regarding different biofuel blends with petrol or diesel, Member States may use their own data in order to determine such values
The methodology described, in order to be operational, requires a reference to average fuel prices. It would seem appropriate to calculate the average price of the relevant fuel per conventional unit over maximum the last calendar quarter prior to the time of calculation

9. A common methodology for Fuel Price Comparison
The use of the methodology described supposes that each Member State must established appropriate vehicle samples
Cars in that sample would need to have at least similar power and weight and should represent the use of conventional fuels and alternative fuels
The display is a matter for Member States.

10. A Common methodology for Fuel Price Comparison/Better Regulation
Use could be made of the opportunities offered by digitalisation such as online tools, which can be specified by Member States authorities, which could enhance the advantages of the methodology. This could allow users to obtain information relevant to all vehicle models
Thirteen feedbacks were received and published (Better Regulation portal).

11. The interpretation of Art 7
The interpretation of Art 7.3 in relation to the impact with the existing legislation
The display referred to in Article 7.3 of Directive 2014/94 does not aim at replacing the display of prices in the measurement units existing in the MS, but constitutes an element of "comparison" to be added for information.
As such, a display in the form of "Euros per 100 km "would not be questionable under Directives 98/6/EC (consumer protection in the indication of the prices), 2005/29/EC (unfair commercial practices Directive) and 2011/83/EU (consumers rights).
On the other hand, it would be contrary to the provisions of Directive 98/6 to replace the display, at the totem, in conventional units by a display of a price comparison.

12. Programme Support Action
The overall objectives are:
To support a consistent and harmonised implementation of article 7.3 in of the Alternative fuel infrastructure Directive in all Member States
To support Member States in making consumer information available in via digital tools (to be advertised also at filling stations)

13. Programme Support Action
The specific objectives:
To inform consumers, fuel suppliers, consumers organization and media on the methodology set out in the Commission Implementing Regulation
Definition of the contents, format and location of the fuel price information
To explore possible ways and locations to display the prices at the filling stations on the basis of the methodology adopted: Pilot test will be carried out in different filling stations (placed in urban areas and highways) at least in 9 Member States
To develop an on-line tool to display the fuel prices for all models of vehicles.
The elaboration of recommendations and/or guidelines to be addressed to Member States.
Participation: At least 9 MS. Budget: 2 MEUR

14. European and Economic Social Committee
Thank you for your attention! Antonio Tricas Aizpun