ORLEN’s Position on Amendments to Regulation (EU) 2023/1804 of the European Parliament and of the Council on the Deployment of Alternative Fuels Infrastructure

In response to the European Commission’s invitation to submit comments on the proposed amendments to Regulation (EU) 2023/1804 on the deployment of alternative fuels infrastructure (AFIR), ORLEN has prepared a position paper outlining its key proposals.

In its position, ORLEN emphasizes in particular the need to ensure that regulations are proportionate, technology-neutral, and feasible in practice, so as to support the decarbonisation of transport without undermining energy security and economic competitiveness.

Key barriers identified by ORLEN:

• Disproportionate data reporting obligations – high costs associated with implementing digital requirements (APIs, cybersecurity) for CNG/LNG/LPG infrastructure, which is transitional in nature.
• Risk of delays beyond operators’ control – structural constraints, i.e. in electricity grids and lengthy connection procedures create a risk of failing to meet AFIR targets.
• Inadequate approach to electric heavy-duty vehicle (eHDV) infrastructure – planned station deployment may not reflect actual market demand, resulting in high operating costs.
• Insufficient recognition of gaseous biofuels (bioLNG/bioCNG) – the lack of their explicit acknowledgement in AFIR limits the use of their emissions reduction potential (up to ~90%).

In light of the above, the Company has presented key recommendations and proposals that could contribute to a fair and appropriately phased achievement of AFIR objectives:

• Improving coordination between infrastructure development, energy grid planning, and administrative procedures.
• Accelerating and simplifying grid connection processes and ensuring the reservation of land for energy infrastructure.
• Maintaining technological neutrality by recognising the role of biomethane (bioLNG/bioCNG) in transport decarbonisation.
• Clarifying selected AFIR provisions, in particular with regard to:
  • user access and payment methods (QR codes, applications),
  • the definition of “smart charging”,
  • requirements for hydrogen infrastructure,
  • data reporting obligations and the use of European platforms.

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