���� � ��� ���� ��� ���� �� �� � � ��� ��� ���������� ��� � ������ ���� ���� � � �� � ����������������������� ���������������������������� �������������� �������������������������������������������� National programme for alternative transport fuels infrastructure Tuuli Ojala, Eero Hokkanen, Niina Honkasalo Ministry of Transport and Communications Helsinki 2025 Publications of the Ministry of Transport and Communications 2025:2 Ministry of Transport and Communications CC BY-NC-ND 4.0 ISBN pdf: 978-952-243-755-6 ISSN pdf: 1795-4045 Layout: Government Administration Department, Publications Helsinki 2025 Finland Publication distribution Institutional Repository for the Government of Finland Valto julkaisut.valtioneuvosto.fi https://julkaisut.valtioneuvosto.fi/ Description sheet 3 February 2025 National programme for alternative transport fuels infrastructure Publications of the Ministry of Transport and Communications 2025:2 Publisher Ministry of Transport and Communications Author(s) Tuuli Ojala, Eero Hokkanen, Niina Honkasalo Group author Ministry of Transport and Communications Language English Pages 154 Abstract It is stated in the Programme of Prime Minister Petteri Orpo’s Government that the Government and the business community will jointly draw up an action plan to expand the distribution network of alternative fuels along the main routes. The EU regulation on the alternative fuels infrastructure (AFIR), applied from 13 April 2024, specifies targets for the extent of the distribution infrastructure for alternative transport fuels that are binding on the Member States as well as technical and functional requirements for the infrastructure. According to the regulation, each Member State must also prepare a national policy framework for the development of the market as regards alternative transport fuels and the deployment of the relevant infrastructure. The national programme for the alternative transport fuels distribution infrastructure has been prepared as a response to national targets and the targets set out in the AFIR regulation. The programme contains an updated review of the market for alternative transport fuels and their distribution infrastructure as well as an assessment of the outlook for these fuels in road, rail and water transport and aviation. The programme sets out the objectives and measures for the development of the distribution infrastructure. Keywords road transport, water transport, rail transport, aviation, fuels, recharging ISBN PDF 978-952-243-755-6 ISSN PDF 1795-4045 Reference number LVM/31178/2023 URN address https://urn.fi/URN:ISBN:978-952-243-755-6 https://urn.fi/URN:ISBN:978-952-243-755-6 Kuvailulehti 3.2.2025 Kansallinen liikenteen vaihtoehtoisten käyttövoimien jakeluinfraohjelma Liikenne- ja viestintäministeriön julkaisuja 2025:2 Julkaisija Liikenne- ja viestintäministeriö Tekijä/t Tuuli Ojala, Eero Hokkanen, Niina Honkasalo Yhteisötekijä Liikenne- ja viestintäministeriö Kieli englanti Sivumäärä 154 Tiivistelmä Pääministeri Petteri Orpon hallituksen ohjelman mukaan yhdessä elinkeinoelämän kanssa laaditaan toimenpideohjelma liikenteen vaihtoehtoisten käyttövoimien jakeluverkon laajentamiselle pääväylillä. 13.4.2024 alkaen sovellettava EU:n jakeluinfra-asetus (AFIR) sisältää jäsenvaltioita sitovia tavoitteita vaihtoehtoisten käyttövoimien jakeluinfrastruktuurin kattavuudelle sekä asettaa infrastruktuurille teknisiä ja toiminnallisia vaatimuksia. Jakeluinfra-asetus edellyttää myös kansallisen toimintakehyksen laatimista liikenteen alan vaihtoehtoisten polttoaineiden markkinoiden kehittämiseksi ja tarvittavan infrastruktuurin käyttöönottamiseksi. Kansallinen liikenteen vaihtoehtoisten käyttövoimien jakeluinfraohjelma on laadittu kansallisiin ja EU:n jakeluinfra-asetuksen tavoitteisiin vastaamiseksi. Ohjelma käsittää liikenteen vaihtoehtoisten käyttövoimien markkinan ja jakeluinfran nykytilan sekä arvion tulevaisuuden näkymistä tie-, rautatie-, vesi- ja lentoliikenteessä. Ohjelmassa esitetään tavoitteet ja toimenpiteet jakeluinfran kehittämiseksi. Asiasanat tieliikenne, rautatieliikenne, lentoliikenne, vesiliikenne, polttoaineet, lataus ISBN PDF 978-952-243-755-6 ISSN PDF 1795-4045 Asianumero LVM/31178/2023 Julkaisun osoite https://urn.fi/URN:ISBN:978-952-243-755-6 https://urn.fi/URN:ISBN:978-952-243-755-6 Presentationsblad 3.2.2025 Det nationella programmet för distributionsinfrastrukturen för alternativa drivkrafter Kommunikationsministeriets publikationer 2025:2 Utgivare Kommunikationsministeriet Författare Tuuli Ojala, Eero Hokkanen, Niina Honkasalo Utarbetad av Kommunikationsministeriet Språk engelska Sidantal 154 Referat Enligt regeringsprogrammet för statsminister Petteri Orpos regering utarbetas tillsammans med näringslivet ett åtgärdsprogram för att utvidga distributionsnätet för alternativa drivkrafter på huvudlederna. EU:s förordning om distributionsinfrastruktur (AFIR) började tillämpas den 13 april 2024 och innehåller mål som är bindande för medlemsstaterna och som gäller omfattningen av distributionsinfrastrukturen för alternativa drivmedel. Förordningen ställer dessutom tekniska och funktionella krav på infrastrukturen. Förordningen om distributionsinfrastruktur kräver också att nationella verksamhetsramar utarbetas för att utveckla marknaden för alternativa bränslen och ta i bruk den infrastruktur som behövs. Det nationella programmet för distributionsinfrastrukturen för alternativa drivmedel har utarbetats för att motsvara de nationella målen och målen i EU:s förordning om distributionsinfrastruktur. Programmet omfattar marknaden för alternativa trafikbränslen och nuläget för distributionsinfrastrukturen samt en bedömning av framtidsutsikterna för vägtrafiken, järnvägstrafiken, sjötrafiken och flygtrafiken. I programmet presenteras målen och åtgärderna för att utveckla distributionsinfrastrukturen. Nyckelord vägtrafik, järnvägstrafik, flygtrafik, sjötrafik, bränslen, laddning ISBN PDF 978-952-243-755-6 ISSN PDF 1795-4045 Ärendenummer LVM/31178/2023 URN-adress https://urn.fi/URN:ISBN:978-952-243-755-6 https://urn.fi/URN:ISBN:978-952-243-755-6 Contents 1 Introduction.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 1.1 Programme background and preparation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 1.2 Alternative transport fuels.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 1.2.1 Production of alternative fuels and availability for transport. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 1.3 Transport fuel transition from the perspective of security of supply.. . . . . . . . . . . . . . . . . . . . . 16 1.4 Safety of alternative fuels. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 2 Road transport.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 2.1 Using the flexibilities of the AFIR and regional distribution of road transport alternative fuels infrastructure.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 2.2 The current state and expected development of the electric vehicle fleet and recharging infrastructure.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 2.2.1 Electric vehicle fleet.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 2.2.2 Publicly accessible infrastructure.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 2.2.3 Recharging infrastructure with restricted access.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 2.3 The current state and expected development of the hydrogen vehicle fleet and refuelling infrastructure.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 2.3.1 Hydrogen vehicles.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 2.3.2 Hydrogen refuelling infrastructure.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49 2.4 Current state and expected development of methane-fuelled vehicles and their refuelling infrastructure.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 2.4.1 Methane-fuelled vehicles.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 2.4.2 Methane refuelling infrastructure.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54 2.5 National targets for road transport distribution infrastructure.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58 2.6 Measures to develop road transport distribution infrastructure.. . . . . . . . . . . . . . . . . . . . . . . . . . . 63 2.6.1 Support, regulation and other policy steer for distribution infrastructure.. . . . . . . . . . . . . . . . . . . . . . . . 63 2.6.2 Support, regulation and other policy steer for the renewal of Finland’s vehicle fleet.. . . . . . . . . . . 72 2.6.3 Information steering, research and information exchange.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75 2.7 Recharging infrastructure and flexibility of the energy system. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81 2.8 User-friendliness and accessibility of distribution infrastructure.. . . . . . . . . . . . . . . . . . . . . . . . . . 83 3 Rail transport.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88 3.1 Railway electrification and electrical traction.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88 3.2 Other alternative rail transport fuels. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93 3.3 Targets and measures for rail transport. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 94 4 Maritime and inland waterway transport.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98 4.1 Shore-side electricity supply in ports. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 100 4.1.1 Current state of maritime ports and expected state in 2030.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 102 4.2 Distribution of liquefied methane.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 106 4.3 Other alternative waterborne transport fuels. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 107 4.3.1 Battery electric ships in Finland. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 107 4.3.2 Other new marine fuels.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108 4.4 National targets for maritime and inland waterway transport distribution infrastructure.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 110 4.5 Measures to develop maritime and inland waterway transport distribution infrastructure.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 113 4.5.1 Support, regulation and other policy steer for distribution infrastructure.. . . . . . . . . . . . . . . . . . . . . . . . 113 4.5.2 Information steering, information exchange and research.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 117 5 Air transport. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 120 5.1 Aircraft ground power supply at airports.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 123 5.1.1 Requirements of the AFIR and use of flexibilities.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 123 5.1.2 Satisfaction of the ground power requirements at airports.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 124 5.2 New aviation propulsion technologies.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 125 5.2.1 Sustainable aviation fuels. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 126 5.2.2 Electricity. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 128 5.2.3 Hydrogen.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 131 5.3 National targets for air transport distribution infrastructure.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 133 5.4 Measures to develop air transport distribution infrastructure.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 134 5.4.1 Support, regulation and other policy steer for distribution infrastructure.. . . . . . . . . . . . . . . . . . . . . . . . 134 5.4.2 Information steering, information exchange and research.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 139 6 Availability of infrastructure between different modes of transport and across borders.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 141 6.1 Promoting synergies between modes of transport in the development of distribution infrastructure. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 141 6.2 Promoting continuity across borders. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 142 7 Alternative fuels infrastructure in Åland.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 144 7.1 Road transport.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 144 7.2 Maritime transport.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 145 7.3 Air transport. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 147 Appendix: Mandatory targets and flexibilities in the AFIR .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 148 8 Publications of the Ministry of Transport and Communications 2025:2 1 Introduction 1.1 Programme background and preparation According to the Programme of Prime Minister Petteri Orpo’s Government, the Government will collaborate with the business community to draw up an action plan to expand the distribution network of alternative fuels along Finland’s main routes. The Alternative Fuels Infrastructure Regulation (AFIR)1, which is applied from 13 April 2024 onwards and which repealed the Directive on the deployment of alternative fuels infrastructure2, includes targets mandatory for Member States on the coverage of the alternative fuels infrastructure and sets certain technical and functional requirements for the infrastructure. The AFIR also requires the drawing up of a national policy framework for the development of alternative fuels markets in the transport sector and for the deployment of the required infrastructure. This Programme was drawn up to meet the abovementioned national targets and the targets set out in the AFIR. The mandatory targets set out in the AFIR for Member States apply to the publicly accessible distribution infrastructure of the Trans-European Transport Network (TEN-T network). The targets relate to the road transport fuel distribution infrastructure of the TEN-T core and comprehensive networks and urban nodes, and at safe and secure parking areas. Requirements are set for shore-side electricity supply at TEN-T inland and maritime ports, ground power supply at TEN-T airports, and methane supply at TEN-T maritime ports. A summary of the AFIR requirements is in the Appendix. The European Council, Parliament and Commission reached an agreement on reforming the TEN-T Regulation3 in December 2023. Among other matters, the new Regulation increases the number of Finnish roads, urban nodes 1 Regulation (EU) 2023/1804 of the European Parliament and of the Council on the deployment of alternative fuels infrastructure, and repealing Directive 2014/94/EU. 2 Directive 2014/94/EU of the European Parliament and of the Council on the deployment of alternative fuels infrastructure. 3 Regulation (EU) 2024/1679 of the European Parliament and of the Council on Union guidelines for the development of the trans-European transport network, amending Regulations (EU) 2021/1153 and (EU) No 913/2010 and repealing Regulation (EU) No 1315/2013. 9 Publications of the Ministry of Transport and Communications 2025:2 and ports included in the TEN-T network. The TEN-T Regulation also includes heavy- duty vehicle distribution infrastructure requirements that apply to multimodal freight and passenger terminals combining two or more modes of transport. The Directive4 on the energy performance of buildings requires buildings to have recharging points for electric vehicles. For the part of electromobility infrastructure, the Directive has been implemented in Finland with the Act on Equipping Buildings with Electric Vehicle Charging Points and Charging Point Capabilities and Automation and Control Systems (733/2020). The reformed Directive was adopted in the spring of 2024. The deadline for national implementation is two years after the directive enters into force. Finland’s alternative fuels infrastructure will be built at the existing transport fuel distribution stations or alongside them. It will supplement the existing distribution infrastructure as the selection of propulsion systems gradually becomes more diverse. The renewal of Finland’s vehicle fleet is rather slow and several fuel options will need to be provided for many years to come. In addition, the Finnish Defence Forces and authorities have special fuel needs that must be met. Currently, the distribution of fuels that are becoming obsolete (98 E5) has been ultimately ensured with legislation (Government Decree 883/2022, section 13). Finland’s approach to building the alternative fuels infrastructure is that it should be market-driven to the largest extent possible. However, at the early stages of the development, national and EU funding has also been seen as necessary accelerants for building the infrastructure. In addition to regulation and financial support, other means for promoting the deployment of the distribution infrastructure and the market for alternative fuels include research and pilot projects, information steering, and exchanging lessons learned. Previous work related to distribution infrastructure of fuels, reports from agencies and information from stakeholders were used in the preparation of this Programme. In March 2023, the Ministry of Transport and Communications published the Programme to improve the distribution infrastructure for new fuels in road transport in Finland by 2035. The programme was created by a national distribution infrastructure working group.5 In spring 2024, to support the programme work, the Finnish Transport and Communications Agency Traficom updated certain reports 4 (EU) 2018/844 5 https://julkaisut.valtioneuvosto.fi/handle/10024/164799 10 Publications of the Ministry of Transport and Communications 2025:2 on the progress of building a national distribution infrastructure6. The background work for the national implementation of the transport initiatives of the EU Fit for 55 package was also used in the preparatory work. For rail transport, the report on the propulsion systems of rail transport7 drawn up by the Finnish Transport Infrastructure Agency provides an up-to-date summary on the propulsion systems of rail transport. In February–April 2024, the Ministry of Transport and Communications, the Finnish Transport and Communications Agency Traficom and the Finnish Transport Infrastructure Agency organised ten workshops with an extensive group of stakeholders on the development of a market for alternative fuels and the related distribution infrastructure, the measures related to these, and the ongoing and required measures. Written statements could be submitted on the draft Programme from 11 June to 8 September 2024, and a total of 91 statements were submitted. 1.2 Alternative transport fuels The clean energy transition of transport requires the replacement of fossil fuels with emission-free energy. The transition to alternative fuels requires the creation and development of new value chains, and not only the introduction of a set of alternative fuels. The boundary conditions for the transition to alternative transport fuels are determined by (1) the availability and price of the new fuels; (2) the renewal rate of the fleet (transport equipment), which affects the demand for alternative fuels; and (3) the deployment of distribution infrastructure for alternative fuels. The introduction of alternative fuels is also associated with new safety requirements related to the use, distribution and storage of the fuels as well as a need to provide training for the users of the fuels. For example, the lower energy density of alternative fuels (e.g. gaseous hydrogen) is also a challenge for the development of feasible technologies for air and waterborne transport. In road transport, electricity, gas (methane) and hydrogen are examples of alternatives to fossil fuels. Their introduction requires the renewal of vehicle fleets and building new fuel distribution infrastructure. Greenhouse gas emissions from 6 Tieliikenteen vaihtoehtoisten käyttövoimien jakeluinfrastruktuuri 2023 [Road transport alternative transport fuels infrastructure 2023, only in Finnish]. https:// www.traficom.fi/sites/default/files/media/file/Traficom_Muistio_Tieliikenteen_ jakeluinfra_2023_12042024.pdf 7 Alternative driving forces for rail transport. Publications of the FTIA 48/2024. Abstract available in English. https://www.doria.fi/handle/10024/189112 https://www.traficom.fi/sites/default/files/media/file/Traficom_Muistio_Tieliikenteen_jakeluinfra_20 https://www.traficom.fi/sites/default/files/media/file/Traficom_Muistio_Tieliikenteen_jakeluinfra_20 https://www.traficom.fi/sites/default/files/media/file/Traficom_Muistio_Tieliikenteen_jakeluinfra_20 https://www.doria.fi/handle/10024/189112 11 Publications of the Ministry of Transport and Communications 2025:2 road transport can also be reduced by using liquid biofuel and, in the future, with synthetic fuels produced from fossil-free sources. Such synthetic fuels are suitable for combustion engines and can be distributed as mixed in fossil fuels or instead of fossil fuels. Finland also has ethanol-fuelled vehicles. Ethanol is available at service stations in the form of E85, a fuel mixture with 85% bioethanol and 15% petrol. In rail transport, electrification of rail lines and using electrical traction are the most common alternative to fossil fuels. Biofuels and renewable synthetic fuels can also be used with newer equipment in particular. There are some battery electric trains in use outside Finland. They are primarily used in places where electrifying railways is not possible. Hydrogen-fuelled trains are currently in the pilot stage. In maritime and inland waterway transport in the Baltic Sea Region, biofuels and renewable synthetic fuels, hydrogen or electricity will most likely be introduced as energy sources in the near future. Liquefied biomethane, biomethanol and biodiesel are examples of waterborne transport biofuels. For the most part, these fuels can be used with the existing fleet. Several alternative fuels are currently being studied and developed for the use of shipping, but for some of the new fuels, the road to extensive commercial use is still long. As some of the alternative renewable fuels are still in the development stage, natural gas has a vital role as a cleaner fuel for maritime transport. For short sea shipping, battery electric and battery hybrid solutions are expected to become more common in the coming years, which will increase demand for shore-side electricity at some ports. In air transport, sustainable aviation biofuels are most significant for reducing carbon dioxide emissions. Sustainable aviation fuels can be mixed with fossil aviation fuel, which makes them suitable for use with the current equipment and infrastructure. Sustainable aviation fuels – which include synthetic fuels in addition to biofuels – are expected to become important for the reduction of aviation emissions. Electricity and hydrogen are new alternative aviation fuels that also require new distribution infrastructure and equipment. Electricity could become a viable solution for small aircraft on short-distance flights. More product development is required for hydrogen to become common. In the long term, it is expected to play a significant part. 1.2.1 Production of alternative fuels and availability for transport Finland is on the way of becoming self-sufficient on a yearly basis for the part of electricity production in 2024. According to advance information, 94% of electricity production in Finland in 2023 was covered by fossil-free production, 12 Publications of the Ministry of Transport and Communications 2025:2 meaning renewable energy sources and nuclear energy. The share of renewable energy sources was 52% of the electricity production. Prime Minister Petteri Orpo’s Government aims at doubling the production of clean electricity. If electrification progresses as predicted in the new baseline projection for greenhouse gas emissions from domestic transport, electricity consumption of transport would increase to 4.2–4.3 TWh by 2030.8 This would be around 4% of the 2030 electricity consumption in the policy scenario of Finland’s latest climate and energy strategy.9 As the share of weather-dependent production has increased, price fluctuation has become stronger. The price of electricity has been negative at times, but at other times it has been dozens and momentarily even hundreds of cents per kilowatt- hour. For transport however, electricity is clearly the most affordable propulsion system in terms of operating costs. Finland’s electricity grid comprises the main grid, high-voltage distribution networks and distribution networks maintained by dozens of electricity companies of varying sizes. Electricity networks are dimensioned according to the expected peak consumption. If recharging electric vehicles increases peak consumption, electricity grids must be scaled up. For example, the power required by recharging pools for road transport equipment can require upgrading electricity networks and, in some locations, building a new electrical substations. Scaling up networks may also be required at ports and airports if shore-side electricity and ground power use increase and rechargeable equipment is introduced. The delivery times of electricity connections vary from some months to years, and there can be significant differences in costs depending on the location and the selected implementation method. Combined with the other electricity needs of a modern society, electric transport significantly increases the need to invest in power grids. 8 Baseline scenarios for energy and climate policy package towards zero emissions (only abstract available in English), https://julkaisut.valtioneuvosto.fi/bitstream/ handle/10024/165717/VNTEAS_2024_26.pdf 9 National Climate and Energy Strategy (2022; only abstract available in English). https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/164321/TEM_2022_53. pdf?sequence=1&isAllowed=y The work to update the strategy has been started and it is expected to be finished in mid-2025. https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/165717/VNTEAS_2024_26.pdf https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/165717/VNTEAS_2024_26.pdf https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/164321/TEM_2022_53.pdf?sequence=1&isAllowed=y https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/164321/TEM_2022_53.pdf?sequence=1&isAllowed=y 13 Publications of the Ministry of Transport and Communications 2025:2 Some 140,000–150,000 tonnes of hydrogen are produced in Finland annually (4.7–5.0 TWh). For now, fossil raw materials, mainly natural gas, is used in 99% of hydrogen-only production.10 In order to achieve significant positive environmental effects, hydrogen production would need to be fossil-free, meaning hydrogen would need to be generated using electrolysis and renewable or nuclear electricity. According to the Programme of Prime Minister Petteri Orpo’s Government, Finland aims to significantly increase the production of fossil-free hydrogen to account for 10% of the EU’s clean hydrogen production. There are both national and EU financial support instruments for hydrogen production. According to the International Council on Clean Transportation ICCT, the EU average at-the-pump price of renewable hydrogen produced with solar or wind power was approximately 11 euros per kilogramme of hydrogen, when the cost-competitive price is estimated to be less than 6 dollars per kilogramme.11 This could be achieved by 2030. In air transport, the price of liquid hydrogen is currently almost four times the price of fossil aviation fuel. The price difference is expected to level out to match the current price of aviation fuel by 2050. The availability of sustainable raw materials for biofuels is limited. Sectors needing fractions produced from biomass and competing over them include air, maritime and road transport, the energy industry, the chemical industry, and several new circular economy businesses. The most significant challenges to scaling the production of biofuels for air and maritime transport are related to the limited number of production plants and supply chains as well as the commercialisation of the raw materials and their prices. The advantage of long-chain hydrocarbon fuels made with hydrogen and carbon dioxide, or synthetic e-fuels, is that the availability of their raw materials is not similarly limited, although there could be competition in acquiring point-source and biobased carbon for the production of hydrogen. Like biofuels, synthetic fuels can be used with the engines of the existing fleet and distributed through the existing distribution infrastructure. Investments in clean energy production and 10 National Climate and Energy Strategy (2022; only abstract available in English). https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/164321/TEM_2022_53. pdf?sequence=1&isAllowed=y The work to update the strategy has been started and it is expected to be finished in mid-2025. 11 Cost of renewable hydrogen produced onsite at hydrogen refueling stations in Europe, The ICCT, 2022 https://theicct.org/publication/fuels-eu-onsite-hydro-cost-feb22/ https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/164321/TEM_2022_53.pdf?sequence=1&isAllowed=y https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/164321/TEM_2022_53.pdf?sequence=1&isAllowed=y https://theicct.org/publication/fuels-eu-onsite-hydro-cost-feb22/ 14 Publications of the Ministry of Transport and Communications 2025:2 hydrogen industry, and the available biobased carbon dioxide generated by the forest and energy industries improve Finland’s potential to produce renewable synthetic fuels from hydrogen. However, producing e-fuels requires large quantities of energy12, which increases the production costs of these fuels. The most natural applications of e-fuels are the modes of transport and transport tasks that cannot directly be electrified. In this too, the high price of the fuels is a challenge. The price of hydrogen is lower than that of further processed synthetic fuels because of its simpler production process, but using hydrogen as fuel requires new equipment and infrastructure, unlike synthetic fuels. Methane can be fossil (natural gas) or renewable biogas made with household, retail and industry waste, municipal sewage sludge, and waste and leftovers from agriculture. Biomethane suitable for transport is purified biogas from which most traces of other gasses than methane have been eliminated. According to Statistics Finland, in 2021, around 156 GWh of biomethane was produced in Finland, which is around 17% of the total production of biogas and biomethane. In 2022, this increased to 210 GWh (+35%) and the share to 22%. Most of the biomethane produced in Finland is used by the transport sector. In 2022, the biomethane consumption of the Finnish transport sector was 322 GWh (meaning biomethane was also imported) and the consumption of fossil methane only 44 GWh, of which 37% was used by shipping. Most (98%) of the methane used in road transport was biomethane. The greenhouse gas emissions of fossil methane use are similar to those of petrol and diesel, but its air pollution emissions are considerably lower. The life cycle carbon dioxide emissions of clean biomethane are relatively low. In particular, the life cycle emissions of biomethane produced with manure are very low, even negative. Methane can be stored as compressed (CNG, CBG) or as liquefied (LNG, LBG). A larger amount of methane can be stored if it is liquefied, which is why liquid methane is a potential alternative for heavy-duty road transport and waterborne transport in particular. 12 Several publications have found that five times more energy is required for using e-fuels in passenger cars than what is required for electric vehicles (see e.g. https:// www.isi.fraunhofer.de/en/presse/2023/presseinfo-05-efuels-nicht-sinnvoll-fuer-pkw- und-lkw.html, https://theicct.org/go-big-or-go-home-with-e-fuels-and-hydrogen/ https://www.isi.fraunhofer.de/en/presse/2023/presseinfo-05-efuels-nicht-sinnvoll-fuer-pkw-und-lkw.html https://www.isi.fraunhofer.de/en/presse/2023/presseinfo-05-efuels-nicht-sinnvoll-fuer-pkw-und-lkw.html https://www.isi.fraunhofer.de/en/presse/2023/presseinfo-05-efuels-nicht-sinnvoll-fuer-pkw-und-lkw.html https://theicct.org/go-big-or-go-home-with-e-fuels-and-hydrogen/ 15 Publications of the Ministry of Transport and Communications 2025:2 According to data from the Finnish Biocycle and Biogas Association, 42 new biogas and biomethane production plants will be built or are planned to be built between 2024 and 2027 in Finland. The production capacity of these plants is 1.2 TWh of which more than 90% is liquefied biomethane for trucks and ships. In road transport, the at-the-pump price of biomass-based biomethane was between 1.8 and 1.9 euros per kilogramme in 2022–2023. Calculated according to the Commission Implementing Regulation (EU) 2018/732, the comparison price of biomethane was approximately 7.5 euros per 100 kilometres in the autumn of 2022. Only the comparison price of electricity was lower. The price of natural gas climbed higher than ever in 2022 as a result of Russia’s aggression against Ukraine. Synthetic methane can be produced from hydrogen and the carbon dioxide in the air (power-to-gas, e-methane). In order to call synthetic methane renewable or fossil-fee, the electricity used to produce the methane and the hydrogen produced for the methane production must also be renewable or fossil-free. Like raw natural gas or biogas, synthetic methane must be further processed to make it suitable for use as a vehicle fuel. The price of such synthetic methane is expected to be higher than that of biomass-based methane. Renewable methane can also be produced from wood or other biomass with thermochemistry. Several production plants for synthetic methane are planned to be built in Finland in the 2020s. P2X Solutions Oy’s production plant for green hydrogen and synthetic fuel produced from renewable sources will be completed in Harjavalta in 2024.13 Gasum Oy and Nordic Ren-Gas signed a long-term sale and purchase agreement in January 2024, under which from 2026 onwards, Gasum will purchase the entire production of the Nordic Ren-Gas production plant that will be completed in Tampere and distribute it to its own customers. The plant uses Finnish wind power and biobased carbon dioxide captured at existing power plants for its methane production. The transmission network company Gasgrid Finland Oy is responsible for gas transmission. Gas is available through a fixed gas grid at around 40 localities in Finland. There are currently no plans to expand the gas grid to new areas. Instead, Gasgrid is collaborating with companies and research institutions in the field to investigate how the emerging hydrogen economy should be taken into account when the gas grid is developed and whether there is a need for a separate hydrogen grid. 13 https://p2x.fi/category/ajankohtaista/ https://p2x.fi/category/ajankohtaista/ 16 Publications of the Ministry of Transport and Communications 2025:2 The production of alternative fuels is a fundamental requirement for the fuel transition of transport. Production needs and targets are discussed in more detail in other programmes such as the new energy and climate strategy to be published in 2025, which will be prepared by the Ministry of Economic Affairs and Employment. The industrial policy strategy currently being prepared will discuss promoting the production of clean hydrogen, among other matters. 1.3 Transport fuel transition from the perspective of security of supply Finland’s current security of energy supply is largely based on stockpiling imported fossil fuels. The National Emergency Supply Agency (NESA) maintains a reserve of imported fossil fuels in government storage to the extent that Finland always has a stockpile of imported fossil fuels to cover five months’ worth of the average regular consumption. In Finland, importers of crude oil, oil products and natural gas must keep a stockpile corresponding to the volume imported in two months on average. The road transport sector is the largest consumer of liquid fuel in Finland. Currently, securing the critical functions of maritime transport is also important for preparedness. The transport fuel transition will change the volumes of fuel used and also have an effect on security stockpiles and the security of supply. It is technically possible to replace renewable fuels used in modern combustion engines with fossil fuels. For this part, the good storability of fossil fuels creates opportunities for preparedness. However, legislation requires an increase in the distribution of alternative fuels and their use in transport. Fossil fuels do not help with the security of fuel supply for electrical engines, hydrogen fuel cell engines, or other possible new engine types. This means that alternative fuels also require new types of preparedness. A vehicle and ship fleet using alternative fuels requires the expansion of stockpiling to alternative fuels and – as part of a larger effort to ensure the security of supply for an increasingly electric society – ensuring the resilience of power grids and preparation for disruptions in electricity supply. This requires a distribution of responsibilities between public and private operators. The security of electricity supply is a much larger issue with rail transport, the local bus transport sector and the increasingly electric road transport sector than with air and maritime transport. Currently, around 8% of Finland’s passenger car fleet is 17 Publications of the Ministry of Transport and Communications 2025:2 electric (incl. plug-in hybrids) and most new buses deployed to local bus transport are electric. In the baseline projection of greenhouse gas emissions from transport, the share of electric passenger cars is expected to increase to around a third of the entire fleet by 2030. The fuels currently stockpiled could still be used for other types of vehicles in the fleet. Evolving battery storage options could provide local solutions for the security of electricity supply for electric vehicles. In air and maritime transport, the long travel distances limit the role of electricity. In waterborne transport, battery electric and battery hybrid solutions could be viable especially in road ferry and commuter ferry traffic as well as short-sea shipping. The fleet of craft in air and maritime transport will be mostly based on current technologies in the future as well and will therefore be covered with the current fuel stockpiling systems for an extensive period. The fuel transition has only just started in heavy-duty road transport as well. The Energia 2030 and Logistiikka 2030 programmes of the National Emergency Supply Agency include reviewing Finland’s transport security of supply solutions as required by the energy and fuel transitions. Securing fuel supply for the Finnish Defence Forces, the Police of Finland and other authorities in emergencies is a special issue that must be discussed separately and with the appropriate experts. The energy transition will improve Finland’s self-sufficiency for the part of fuels for the transport sector. Electrification reduces the total energy consumption of the transport sector and the use of imported fuels because of its higher energy efficiency. Renewable biobased fuels will also replace fossil fuels and the use of imported fuels insofar as the biofuels are produced in Finland (e.g. the biomethane used in transport is mostly produced in Finland and ethanol partly). Hydrogen produced with domestic renewable electricity and renewable synthetic fuels (e-fuels) can replace imported fuels in the future. The benefit of synthetic fuels is that the availability of their raw materials is less restricted than that of biofuels, and they are suitable for heavy-duty road transport, maritime transport and air transport alike (see section 1.2.1). 1.4 Safety of alternative fuels The safety of the fuel transition in the transport sector should be examined from the perspective of the possible risks associated with the new fuels in terms of fire safety and toxicity and how these risks could be mitigated with regulation and guidance, 18 Publications of the Ministry of Transport and Communications 2025:2 for example. This is discussed below and measures related to this perspective are presented in this Programme. In addition, the perspective of securing the performance of vehicles used in critical tasks should be considered. The authorities must consider these questions when they procure vehicles and they are also related to the above-described emergency stockpiling of fuel (section 1.3). The challenges the fuel transition poses to certain duties have been recognised in EU regulation, and defence equipment is entirely excluded from EU’s new road transport fossil fuels emissions trading, for example. Electric vehicle lithium-ion battery fires have caused concern because of their intensity and the toxic gasses they produce and because they are difficult to extinguish. Statistically however, electric vehicle fires are considerably rarer than combustion engine vehicle fires, and electric vehicles have not been found particularly susceptible to catching fire. Still, emergency services must be prepared to extinguish electric vehicle fires and their knowledge of these fires must be increased. The Finnish Association of Fire Officers has published instructions on fighting such fires. Introducing battery electricity to air and waterborne transport in the future will also require the development of firefighting and rescue practices. Several other means of transport (such as bicycles and scooters) and equipment also have lithium-ion batteries. Among others, the Finnish Safety and Chemicals Agency Tukes and insurance companies have published instructions on how to avoid and extinguish battery fires. In the future, risk management and reporting obligations will be extended to operators of electric vehicle recharging points to improve cyber security. This is done pursuant to the EU cyber security Directive, or the NIS2 Directive, which entered into force in January 2023. The obligations under the NIS2 Directive must be met from 18 October 2024 onwards and the legislative proposal for the national implementation of the Directive was submitted to the Finnish Parliament in May 2024. The obligations are cross-sectoral and in the energy sector, also cover electricity, gas and hydrogen distribution, for example. In Finland’s national legislation, the foundation of the regulation related to gas technology and gas safety is the Act on the Safe Handling and Storage of Dangerous Chemicals and Explosives (390/2005). More detailed provisions and requirements are laid down in the Government Decree on safe handling of natural gas (551/2009; ‘Natural Gas Decree’), and the Government Decree on the supervision of the safe handling and storage of dangerous chemicals (685/2015). Requirements for gas equipment are laid down in the Act on Gas Appliances 19 Publications of the Ministry of Transport and Communications 2025:2 (502/2018). The Government Decree on safety requirements for the safe handling and storage of dangerous chemicals (856/2012) is applied to industrial operations involving the manufacture, further processing or use of different gases. The Finnish Gas Association has published design instructions with the Finnish Safety and Chemicals Agency Tukes for natural gas and biogas refuelling stations. The design instructions include basic instructions on the placement of refuelling stations as well as technical requirements and instructions on markings, inspections, use and maintenance. The most significant aspect affecting the design and costs are the safe distances required between the refuelling stations and other buildings or roads, for example. From the perspective of safety, it is vital to identify the effects of an accident at a station to its surroundings in land use planning and the placement of stations. If a large amount of methane (liquefied methane LNG or LBG) will be stored at a station or if methane (biogas) will be produced at a station or near it, an accident would most likely affect a larger area and this must be prepared for. Such higher- capacity refuelling stations also require greater safe distances. Stations with a smaller capacity are easier to place in locations with other services and uses as well. To ensure the problem-free placement of gas refuelling stations in the settlement structure, continuing communication with the municipality’s building supervision authority is required to ensure that instructions are clear and that projects progress as smoothly as possible. Safe refuelling of liquefied methane also requires the provision of training to the drivers of vehicles. Improving the safety of hydrogen distribution is a current issue. The legislation on the industrial use and storage of dangerous chemicals (390/2005, 856/2012) applies to hydrogen refuelling stations. The Ministry of Economic Affairs and Employment has started a project that examines the safety requirements that are required to make the technical processing of hydrogen safe. The purpose of the project is to support the development of legislation. The Finnish Safety and Chemicals Agency Tukes published instructions on the promotion of safe hydrogen distribution at the start of 2024. Fuels still in the early stages of development are also associated with new perspectives that must be considered. One of these is ammonia, which is being developed into a fuel for maritime transport. Ammonia is toxic, which poses a challenge when used in waterborne transport and requires special attention in 20 Publications of the Ministry of Transport and Communications 2025:2 terms of safety measures. At ports located near city centres or habitation centres, special attention must be paid to safety when deciding on the placement of the distribution infrastructure for ammonia and other new fuels. In air transport, the strong safety and security culture in the field will mostly likely be an asset to considering the risks associated with new fuels. The type-approval process of a new aircraft usually takes several years from submitting the type-approval application to being granted the type-approval. For example, hydrogen aircraft or aircraft using 100% biofuel have not yet been type-approved. Electric and hydrogen aviation are associated with new risk factors that traditional aviation is not associated with. These include risks related to battery and fire safety. Hydrogen being highly combustible and explosive requires safety measures that may extend the turnaround time of aircraft at airports. With hydrogen, the most dangerous stages of the process are related to refuelling, when hydrogen leaks are possible, for example. Attention must be paid to air space safety as well if the number of manned and unmanned aircraft increases as electric aviation becomes more common. Regulation for electric and hydrogen aviation is currently in the works. Today, electric and hydrogen aviation are primarily subject to existing regulation, which is based on the assumption that all aircraft have a combustion engine of some type. 21 Publications of the Ministry of Transport and Communications 2025:2 2 Road transport 2.1 Using the flexibilities of the AFIR and regional distribution of road transport alternative fuels infrastructure The EU AFIR provides some flexibility for Member States in terms of the targets for the recharging infrastructure in the TEN-T road network for passenger cars and vans in sections of the TEN-T road network with lower traffic volumes (see Figure 1). In addition, it is required that the deployment of the infrastructure cannot be justified with socio-economic benefit. The AFIR includes flexibility from the targets for the recharging infrastructure of electric heavy-duty road transport vehicles laid down in Articles 4 and 6 as well as the capacity requirement for the hydrogen refuelling infrastructure if sections of the TEN-T road network with lower traffic volumes (see Figures 1 and 2). Finland will utilise the flexibilities for the part of the targets for the recharging infrastructure in the TEN-T road network for passenger cars and vans, the recharging infrastructure of electric heavy-duty road transport vehicles, and the capacity requirement for a hydrogen refuelling infrastructure. Taking advantage of the flexibilities is necessary because of the special characteristics of transport in Finland, such as long distances and thin traffic flows. When the distribution infrastructure is developed, it must also be remembered that in areas with higher demand, meeting the minimum targets of the AFIR will not cover the needs of transport, and, conversely, an infrastructure for alternative fuels is also required outside the TEN-T network. More information on the flexibilities is in the Appendix. 22 Publications of the Ministry of Transport and Communications 2025:2 Figure 1.  Average daily passenger car and van traffic volume in the TEN-T road network in 2022. Image: Finnish Transport and Communications Agency Traficom. 23 Publications of the Ministry of Transport and Communications 2025:2 Figure 2.  Average daily heavy-duty traffic volume on main roads in 2022. Image: Finnish Transport and Communications Agency Traficom. Finland has nationally important main roads outside the TEN-T network as well that are presented in Figure 3. The needs of the transport sector require the building of a sufficient alternative fuels infrastructure also along these roads as well, even though they are not covered by the AFIR. 24 Publications of the Ministry of Transport and Communications 2025:2 Figure 3.  Arterial road network of Finland. Image: Finnish Transport Infrastructure Agency. In Finland, vehicles using alternative fuels are mostly electric passenger cars. Significant geographic differences exist in how popular alternative fuels are. At the end of December 2023, the share of alternative fuels from Finland’s vehicle fleet was JyväskyläJyväskylä SeinäjokiSeinäjoki VaasaVaasa KokkolaKokkola YlivieskaYlivieska KotkaKotka KouvolaKouvola MikkeliMikkeli PieksämäkiPieksämäki JoensuuJoensuu KuopioKuopio LappeenrantaLappeenranta ImatraImatra HelsinkiHelsinki RiihimäkiRiihimäki HankoHanko LahtiLahti TampereTampere TurkuTurku PoriPori OuluOulu KajaaniKajaani KemiKemi RovaniemiRovaniemi Savonlinna Kitee Inari Ivalo Sodankylä Kemijärvi Kuusamo Pudasjärvi Suomussalmi Vartius Kuhmo Nurmes Lieksa Äänekoski Rauma Arterial roads Other main roads Vt 9 Vt 9 Vt 5 Vt 6 Vt 6 Vt 9 Vt 15 Vt 7 Vt 7 Vt 2 5 Vt 12 Vt 12 Vt 3 Vt 1 Vt 9 Vt 8 Vt 12 Vt 2 Vt 4 Vt 4 Vt 4 Vt 4 Vt 4 Vt 4 Vt 4 Vt 29 Vt 21 Vt 9Vt 3 Vt 8 Vt 3 Vt 8 Vt 8 Vt 19 Vt 18 Vt 5 Vt 5 25 Publications of the Ministry of Transport and Communications 2025:2 largest in the regions of Uusimaa (14.8%), Southwest Finland (8.9%) and Pirkanmaa (8.5%). The smallest alternative fuel shares were in Kainuu, Lapland and North Karelia (Figure 4). Figure 4.  The share (%) of passenger cars using alternative fuels in Finnish regions in December 2023. Most of the vehicles using alternative fuels are electric (plug-in hybrids and fully electric). Image: Finnish Transport and Communications Agency Traficom. 26 Publications of the Ministry of Transport and Communications 2025:2 In addition, according to the VATT Institute for Economic Research and the Finnish Environment Institute14, electric vehicles are most common in larger habitation centres in Finland. There are relatively more combustion engine vehicles in more rural areas, where as plug-in vehicles are considerably more prevalent in inner urban areas. 2.2 The current state and expected development of the electric vehicle fleet and recharging infrastructure 2.2.1 Electric vehicle fleet Finland’s vehicle fleet is slow to renew and sales of new vehicles were particularly low (less than 90,000 new vehicles per year) in 2022 and 2023, when expenses were increased. Most Finns purchase their vehicles as used (around 600,000 used vehicles purchased per year). However, the growth of Finland’s electric vehicle fleet has significantly accelerated. At the end of December 2023, there were 83,762 fully electric vehicles and 135,106 plug-in hybrids in service in Finland, which is a total of 218,868 electric passenger cars (8% of the entire fleet). For now, most electric vehicles are plug-in hybrids, but in recent years, the share of fully electric vehicles of purchased new vehicles has increased. In 2022, 14,530 fully electric vehicles were registered for the first time, and in 2023, the figure was 29,535. For plug-in hybrids, 16,168 vehicles were first registered in 2022 and 18,087 vehicles in 2023. A total of 8,646 used fully electric vehicles were imported in 2022. In 2023, this figure was 10,066. A total of 12,675 plug-in hybrids were imported in 2022 and 14,484 in 2023.15 According to the latest transport baseline projection (WEM, 2024)16, there will be approximately 925,000 electric vehicles in Finland in 2030 (Figure 5). The projection takes into account the materialised vehicle fleet growth rate and the CO2 limit values applied to EU manufacturers. However, the projection is associated with a significant number of uncertainties. The growth of the Finnish electric vehicle 14 https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/165604/VNTEAS_2024_14. pdf?sequence=1&isAllowed=y 15 https://tieto.traficom.fi/en/statistics/ passenger-cars-registered-first-time-new-and-imported-used-power-source 16 Baseline projection of greenhouse gas emissions from transport WEM 2024. https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/165604/VNTEAS_2024_14.pdf?sequence=1&isAl https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/165604/VNTEAS_2024_14.pdf?sequence=1&isAl https://tieto.traficom.fi/en/statistics/passenger-cars-registered-first-time-new-and-imported-used-p https://tieto.traficom.fi/en/statistics/passenger-cars-registered-first-time-new-and-imported-used-p 27 Publications of the Ministry of Transport and Communications 2025:2 fleet significantly slowed in 2024 and a significant change to the development is required to reach the targets. A new transport policy scenario will be created in connection with drawing up the new national energy and climate strategy. Figure 5.  Development of Finland’s fleet of electric passenger cars in 2016–2023 and 2035 projection (vehicles used in traffic: The Finnish Transport and Communications Agency Traficom, projection: VTT Technical Research Centre of Finland, 2024). In total, there are approximately 2,750,000 passenger cars in Finland. The number of electric vans has also increased (Figure 6). In 2022, around 6% of registered vans were electric vans. In 2023, the share of electric vans of all new vans was 14.5%. At the end of 2023, there was a total 3,500 electric vans in traffic (around 1% of all vans). 0 200 000 400 000 600 000 800 000 1 000 000 1 200 000 1 400 000 1 600 000 1 800 000 20 16 20 17 20 18 20 19 20 20 20 21 20 22 20 23 20 24 20 25 20 26 20 27 20 28 20 29 20 30 20 31 20 32 20 33 20 34 20 35 PHEV, petrol PHEV, diesel BEV Development of the electric passenger car �eet in 2016-2023 and 2035 projection 28 Publications of the Ministry of Transport and Communications 2025:2 Figure 6.  Development of Finland’s fleet of electric vans in 2016–2023 and 2035 projection(vehicles used in traffic: The Finnish Transport and Communications Agency Traficom, projection: VTT Technical Research Centre of Finland, 2024). In total, there are approximately 350,000 vans in Finland. At the end of 2023, there were around 700 electric buses. In local transport of Finnish cities, new buses are now primarily electric. With the current development, the share of diesel-fuelled buses will significantly reduce in local transport in the following five years, because the majority of the remaining diesel equipment will reach the end of their life cycle and new buses procured by local transport operators are primarily electric buses. This development is supported by the environmental focus in public procurement and the opportunity to recharge the buses at the depot. The climate-based financial support for public transport in urban areas, which ended in 2023, also contributed to the procurement of electric buses. The progress of the fuel transition of inter-city and charter transport has been slower. Diesel equipment is expected to be a significant part of Finland’s bus fleet still in the 2030s (Figure 7). Small electric buses are expected to become more common in the next few years in the service transport of cities, for example. In 2023, nearly 60% of all buses registered for the first time were still diesel-fuelled. 0 20 000 40 000 60 000 80 000 100 000 120 000 20 16 20 17 20 18 20 19 20 20 20 21 20 22 20 23 20 24 20 25 20 26 20 27 20 28 20 29 20 30 20 31 20 32 20 33 20 34 20 35 PHEV, petrol PHEV, diesel BEV Development of the electric van �eet in 2016-2023 and 2035 projection 29 Publications of the Ministry of Transport and Communications 2025:2 Figure 7.  Development of Finland’s fleet of electric buses in 2016–2023 and 2035 projection(vehicles used in traffic: The Finnish Transport and Communications Agency Traficom, projection: VTT Technical Research Centre of Finland, 2024). In total, there are approximately 11,000 buses in Finland. The fuel transition will primarily occur in transport subject to licence, and the majority of Finland’s bus fleet is used in this type of transport. There are only few electric trucks in service in Finland currently, as the number was 70 at the end of 2023 (Figure 8). However, the share of electric trucks has been increasing, and electricity is gaining popularity in goods transport in urban areas in particular. In the initial stages, there is also potential in regular short-distance transport. The selection of electric trucks has expanded to heavier vehicles as well, but their prices are still high compared to corresponding diesel vehicles. In the current situation, in practice, using electric trucks requires investments in recharging in the vehicle owner’s facilities, which increases the costs for making the transition. According to the baseline projection, there will be 2,400 electric trucks in Finland in 2030. Plenty of potential was seen in the electrification of heavy-duty transport vehicles in discussions at the workshops that were organised in preparation of this Programme.​Therefore, it was decided that a target exceeding the baseline projection could be set for electricity, meaning around 4,800 trucks by 2030.This is in line with the background information of the latest transport emissions policy scenario. 0 1 000 2 000 3 000 4 000 5 000 6 000 7 000 20 16 20 17 20 18 20 19 20 20 20 21 20 22 20 23 20 24 20 25 20 26 20 27 20 28 20 29 20 30 20 31 20 32 20 33 20 34 20 35 PHEV, petrol PHEV, diesel BEV Development of the electric bus and coach �eet in 2016-2023 and 2035 projection 30 Publications of the Ministry of Transport and Communications 2025:2 Figure 8.  Development of Finland’s fleet of electric trucks in 2016–2023 and 2035 projection (vehicles used in traffic: The Finnish Transport and Communications Agency Traficom, projection: VTT Technical Research Centre of Finland, 2024). In total, there are approximately 90,000 trucks in Finland. 2.2.2 Publicly accessible infrastructure Recharging infrastructure for passenger cars and vans The number of publicly accessible recharging points for recharging passenger cars and vans has increased rapidly in Finland (Table 1), particularly for the part of high- power recharging points. 0 1 000 2 000 3 000 4 000 5 000 6 000 7 000 8 000 20 16 20 17 20 18 20 19 20 20 20 21 20 22 20 23 20 24 20 25 20 26 20 27 20 28 20 29 20 30 20 31 20 32 20 33 20 34 20 35 PHEV, petrol PHEV, diesel BEV Development of the electric truck �eet in 2016-2023 and 2035 projection 31 Publications of the Ministry of Transport and Communications 2025:2 Table 1.  Number of publicly accessible recharging points in Finland at the end of 2023 according to the data of the Finnish Transport and Communications Agency Traficom. Category Sub- category Maximum power output Number of points Change March– December 2023, % Number of recharging stations Change March– December 2023, % 1 Alternating current AC Basic recharging point (AFIR: Medium- speed AC recharging point, triple- phase) 7.4 kW ≤ P ≤ 22 kW 9,199 17% 2,220 13% 2 Direct current DC Slow DC recharging point P < 50 kW 32 -6% 26 -14% Fast DC recharging point 50 kW ≤ P< 150 kW 911 26% 496 32% Level 1 – High-power recharging point (AFIR: Ultra- fast DC recharging point) 150 kW ≤ P< 350 kW 1,688 85% 429 66% Level 2 – High-power recharging point (AFIR: Ultra- fast DC recharging point) P≥ 350 kW 163 806% 29 480% Total 11,993 25% 2467 17% 32 Publications of the Ministry of Transport and Communications 2025:2 The geographical coverage of public recharging points for electric vehicles is relatively good in Finland. According to a summary by the Finnish Transport and Communications Agency Traficom17, at the end of 2023, the nearest recharging station (which can have multiple recharging points) was within less than 100 kilometres everywhere in Finland, and within less than 50 kilometres in most of Finland. In Southern and Western Finland, the closest recharging station was always within 25 kilometres (see Figure 9). The recharging points with the highest power output are usually found in cities and along roads with the high traffic volumes, and their number has significantly increased. High-power recharging points have also been built in the areas in Northern and Eastern Finland with less coverage where the distance to the closest high-power recharging point was previously more than 50 kilometres. Recharging stations with at least 50 kW recharging points are available within 100 kilometres everywhere in Finland, with the exception of the most northern parts of Utsjoki and Inari (Figure 10). Recharging stations with at least 150 kW recharging points are also available within 100 kilometres everywhere in Finland, with the exception of the most northern parts of the municipalities of Utsjoki and Inari and the most eastern parts of the municipalities of Salla and Savukoski (Figure 11). The Finnish Transport and Communications Agency Traficom has examined whether the AFIR targets are met in Finland in the current situation (see also the Appendix) and what additional infrastructure is required to meet the minimum requirements.18 Firstly, the AFIR requires that the recharging infrastructure provides at least 1.3 kW for each fully electric vehicle in the Member State’s fleet and 0.8 kW for each plug-in hybrid. According to Traficom’s assessment, the total power output of the recharging infrastructure for passenger cars and vans in Finland was around 650,000 kW at the end of 2023, or nearly three times the AFIR minimum total power output requirement. If Finland’s fleet of electric vehicles grows according to the newest baseline scenario (WEM), the total power output must be 922,500 kW 17 Tieliikenteen vaihtoehtoisten käyttövoimien jakeluinfrastruktuurin tila 2023. [State of the road transport alternative fuels infrastructure in 2023; in Finnish only] Finnish Transport and Communications Agency Traficom. https://www.traficom.fi/sites/default/ files/media/file/Traficom_Muistio_Tieliikenteen_jakeluinfra_2023_12042024.pdf 18 Tieliikenteen vaihtoehtoisten käyttövoimien jakeluinfrastruktuurin tila 2023. [State of the road transport alternative fuels infrastructure in 2023; in Finnish only] Finnish Transport and Communications Agency Traficom. https://www.traficom.fi/sites/default/ files/media/file/Traficom_Muistio_Tieliikenteen_jakeluinfra_2023_12042024.pdf https://www.traficom.fi/sites/default/files/media/file/Traficom_Muistio_Tieliikenteen_jakeluinfra_20 https://www.traficom.fi/sites/default/files/media/file/Traficom_Muistio_Tieliikenteen_jakeluinfra_20 https://www.traficom.fi/sites/default/files/media/file/Traficom_Muistio_Tieliikenteen_jakeluinfra_20 https://www.traficom.fi/sites/default/files/media/file/Traficom_Muistio_Tieliikenteen_jakeluinfra_20 33 Publications of the Ministry of Transport and Communications 2025:2 in 2029 to satisfy the AFIR requirements. According to the scenario, the share of electric vehicles would exceed 15% that year, at which point the AFIR allows ceasing the application of the power output requirement. This means that the total power output would have six years to increase by 1.4 times from the current level (from 650,000 to 922,500), even though it has already increased by 1.7 times from 390,000 in less than a year (Traficom’s 2023 review). Secondly, the AFIR includes coverage requirements for passenger car and van recharging (minimum power + maximum distance). The mandatory targets pertain to 2025 and 2027 for the part of the TEN-T core road network and 2027, 2030 and 2035 for the part of the TEN-T comprehensive road network. Finland’s current recharging infrastructure already meets the 2025 core network coverage requirements for a passenger car and van recharging infrastructure. With the current infrastructure, 72% of the road length meets the 2027 core network requirements. In the situation at the end of 2023, more infrastructure was required on national road 4 south of Lahti, north of Jyväskylä, and south and north of Oulu. The infrastructure is constantly improved and a new recharging pool was opened south of Lahti (Mäntsälä) in 2024. Considering the flexibilities related to traffic volumes (see section 2.1.2), at least five more recharging pools serving both directions of traffic are required. It should also be noted that in the section of the core network that already meets the 2027 requirements, the requirements are met on 98% of the road length without using the flexibility provided in case of low traffic volumes. The situation of satisfying the AFIR requirements is constantly evolving as distribution infrastructure operators open new locations. The current comprehensive TEN-T network infrastructure already satisfies the AFIR 2027 passenger car and van infrastructure requirements considering the national flexibilities of the AFIR. To meet the 2030 requirement, at least 11 recharging pools serving both directions of traffic would need to be built. To meet the 2035 requirement, at least 27 passenger car and van recharging pools serving both directions of traffic would need be built (compared to the situation at the end of 2023). From the perspective of meeting the AFIR requirements, the situation of the Finnish recharging infrastructure serving passenger cars and vans is promising. However, as 2030 approaches, it must be ensured that there will not be any coverage gaps even in the sections of the TEN-T road network with lower traffic volumes. In Finland, appropriations have not been allocated to a national aid instrument for building a passenger car and van recharging infrastructure since 2023, because the 34 Publications of the Ministry of Transport and Communications 2025:2 infrastructure is expected to be built with a market-based approach, as is largely the case. Rapid renewal of the vehicle fleet in the 2020s is required in order for providing recharging services to be profitable throughout Finland. In addition to infrastructure compliant with the AFIR requirements, lower powered public recharging points are important for the viability of electric driving. The benefits of slower recharging include lower investment costs, avoiding spikes in electricity consumption and more affordable prices. In addition to parking spaces and yards of residential buildings and workplaces (see below), it would therefore be reasonable to build slower recharging points in other locations where vehicles are parked for extended periods, such as long-term parking facilities or street- side parking spaces reserved for nearby residents. The challenge for recharging operators is to make providing slower recharging a viable business. The solution to this could be restricting recharging during the day and allowing overnight recharging in the same parking space. In addition to slower overnight recharging, recharging with a 50-kW output during a stop of a few hours has been found a good solution for motorists. 35 Publications of the Ministry of Transport and Communications 2025:2 Figure 9.  Locations and coverage of publicly accessible passenger car and van recharging points at the end of 2023, all recharging stations. Image: Finnish Transport and Communications Agency Traficom 36 Publications of the Ministry of Transport and Communications 2025:2 Figure 10.  Locations and coverage of recharging stations serving passenger cars and vans at the end of 2023; stations with at least 50 kW recharging points. Image: Finnish Transport and Communications Agency Traficom. 37 Publications of the Ministry of Transport and Communications 2025:2 Figure 11.  Locations and coverage of recharging stations serving passenger cars and vans at the end of 2023 in Finland; stations with at least 150 kW high-power recharging points. Image: Finnish Transport and Communications Agency Traficom. 38 Publications of the Ministry of Transport and Communications 2025:2 Recharging infrastructure for heavy-duty vehicles Electric buses and trucks used for goods transport are currently largely dependent on a recharging infrastructure that is private, such as depot recharging or recharging at facilities owned by the companies or their customers. A publicly accessible infrastructure is required to expand the range of transport, enable transport along irregular routes, and for the companies that cannot invest in a recharging infrastructure of their own, for example. The AFIR requires heavy-duty transport recharging infrastructure coverage throughout the TEN-T road network by 2030 (minimum power output and maximum distance). In addition, the AFIR sets percentual intermediate targets for the heavy-duty transport recharging infrastructure (minimum power output and maximum distance) for 2025 and 2027. Infrastructure is also required in the ‘safe and secure parking areas’ and ‘urban nodes’ as defined in the TEN-T Regulation. More details on the requirements are in the Appendix. Finland’s first publicly accessible recharging station for heavy-duty vehicles was opened in Tampere in the autumn of 2023. The recharging pool has one recharging station whose 360-kW power output is shared by two recharging points that can both deliver a maximum recharging output of 360 kW. The station also has a 450- kW battery for storing electricity. According to the information collected by the Finnish Transport and Communications Agency Traficom based on experiences of operators in the field, at least some 20 of the current recharging points at publicly accessible passenger car and van recharging stations in different locations would be suitable for recharging common trucks in terms of their functions and scale. The challenges for using the current passenger car and van stations for recharging heavy-duty vehicles include space and the total power output of the stations. The recharging service provider can also limit recharging heavy-duty vehicles at such stations because of the service provider’s business-related reasons. In the coming years, the challenge will be to ensure that a recharging infrastructure for heavy-duty transport is built in Finland so that it meets the needs of the transport sector on one hand and the AFIR requirements on the other. Building a public infrastructure must be profitable for the companies building it, which means it is most sensible to build infrastructure in places where demand is expected. The improvement of the infrastructure also requires that the land owners (the State, municipalities and private parties) and the capacity of the power grid enable the building of a recharging infrastructure. 39 Publications of the Ministry of Transport and Communications 2025:2 The Ministry of Transport and Communications carried out a needs assessment in 2022–202319, according to which the locations for heavy-duty transport recharging stations with the most potential in terms of demand are along national road 4 in the TEN-T core network and along national roads 3, 5 and 9 in the TEN-T comprehensive network. According to the assessment, the most significant recharging need in the core network is on national road 4, which serves as a key route for south-north transport. According to the needs assessment, to meet the service needs, the most natural solution would be to build the recharging infrastructure at current service stations/filling stations or at the truck stops planned to be built. When deciding on the placement of stations, it should also be considered whether a single recharging pool could serve both north-south and east-west-bound traffic. In addition to recharging during longer journeys, consideration should also be given to how much transport occurs in the largest cities and the fact that several shorter-distance transports are made in a single day within the same area. This means that more recharging infrastructure – exceeding the minimum requirements of the AFIR – is required in the areas of large cities. In urban nodes, public recharging infrastructure can be used in local transport, goods transport departing and arriving in the urban nodes, and long-distance bus traffic. For security of supply, it is also important that more than one recharging station is built with reasonable distances. The megawatt recharging standard currently being prepared creates a need to update existing recharging stations or build entirely new stations for the use of heavy-duty transport. Megawatt recharging makes recharging services faster and therefore enables mid-journey recharging even during shorter stops. Megawatt recharging is expected to become more prevalent as we approach the 2030s. Several Finnish operators have stated they have recharging projects for the needs of heavy-duty traffic in the works. The development of Finland’s recharging infrastructure can be assessed with decisions on public national infrastructure aid, even though a decision is not always a guarantee that a station will be built. Based on previous experience, the project realisation rate can be some dozens of percents of the projects that receive aid. Funding was applied for building recharging points 19 Report on charging infrastructure for heavy goods vehicles. Identified needs. [only abstract available in English] Publications of the Ministry of Transport and Communications 2023:1. 40 Publications of the Ministry of Transport and Communications 2025:2 suitable for heavy-duty vehicles in Finland in the latest call for proposals of the Connecting Europe Facility for Transport focusing on alternative fuels infrastructure held in September 2024. Based on the decisions for national infrastructure aid approved by the Finnish Energy Authority, recharging infrastructure suitable for heavy-duty transport will be built in the near future at dozens of new sites. Figure 12 shows the locations of the 45 stations at which there are plans to build high-power recharging points suitable for heavy-duty vehicles. Of these, 12 of the TEN-T network stations located in different parts of Finland meet the 2025 AFIR heavy-duty transport power output requirements based on the applications. Because the AFIR power output requirements for recharging pools will significantly increase as we near the end of the decade, the scalability of the stations built now (space, grid capacity) is important for meeting the AFIR requirements for coming years. Because the information in the applications is limited and in the lack of information on other possible recharging infrastructure projects, assessments on meeting the AFIR requirements are associated with considerable uncertainty. In the best- case scenario, the abovementioned projects will help Finland to meet the AFIR requirements for the nearest years to a large extent if the projects are realised. However, satisfying the 2030 targets will require considerably expanding the public infrastructure, because at that time, at least 70 recharging pools meeting the power output requirements will be required (depending on the location). 41 Publications of the Ministry of Transport and Communications 2025:2 Figure 12.  Recharging stations for heavy-duty vehicles (1 station) and recharging stations that have been granted an aid decision by the Finnish Energy Authority but that have not yet been built (45). Image: Finnish Transport and Communications Agency Traficom. 42 Publications of the Ministry of Transport and Communications 2025:2 2.2.3 Recharging infrastructure with restricted access The ability to recharge an electric vehicle at home has been found to play an important or even decisive part in the decision to purchase an electric vehicle and therefore also in electric driving becoming more common.20 Similarly, the ability to recharge a vehicle at work can be significant in making electric driving smooth for people with a long commute and people who do not have the opportunity to recharge their vehicle at home. For now, heavy-duty vehicles are recharged in Finland primarily with infrastructure to which access is restricted. For the bus services of cities and large transport companies with regular routes, the primary recharging method may be their captive recharging infrastructure in the future as well. Slow recharging is also easier to implement with a captive infrastructure than a public infrastructure, which helps reduce spikes in electricity consumption from the power grid. Finland does not systematically collect information on the number of recharging points with restricted access, so only indicative assessments can be made. The implementation methods and opportunities of home recharging vary depending on the type of building and the location of the apartment. Around 40% of Finns live in detached houses or semi-detached houses.21 If these households have an electric vehicle, it is likely that the owner of the vehicle will arrange recharging at home. Around half of the permanent homes of Finns are in apartment buildings. The parking spaces of an apartment building can be located in the yard of the building or as enclosed spaces in the basement of the building or in a car park, in which case the costs of building recharging points can be high or it can require complex decision-making processes. In closely-built city centres, a building’s parking spaces may be on the side of a street, in which case the city decides on the expansion 20 This has been proved, for example, by a 2019–2020 survey by the Finnish Information Centre of Automobile Sector on the use and recharging methods of plug-in electric vehicles. 21 Statistics Finland, Dwellings by type of building, occupancy and year of construction, 2021 https://pxdata.stat.fi/PxWeb/pxweb/fi/StatFin/StatFin__asas/statfin_asas_ pxt_116f.px/table/tableViewLayout1/ https://pxdata.stat.fi/PxWeb/pxweb/fi/StatFin/StatFin__asas/statfin_asas_pxt_116f.px/table/tableViewLayout1/ https://pxdata.stat.fi/PxWeb/pxweb/fi/StatFin/StatFin__asas/statfin_asas_pxt_116f.px/table/tableViewLayout1/ 43 Publications of the Ministry of Transport and Communications 2025:2 of the recharging infrastructure. Whether a housing company mostly has owner- owned apartments or leased apartments can also affect whether a recharging project is started. New and renovated residential buildings that have four or more parking spaces are subject to the minimum requirements for building recharging points and recharging capacity laid down in the Finnish ‘Recharging Point Act’22, which implements the Energy Performance of Buildings Directive. Existing buildings with more than 20 parking spaces must have at least one recharging point by the end of 2024. In the preparations for the Finnish Recharging Point Act, it was estimated that the Act would result in around 326,000 cable ducts for recharging points and around 92,000 basic recharging points to be built in Finland by 2030.23 In addition to infrastructure built for residential buildings, these figures include infrastructure to be built in other new or renovated buildings, such as retail and office buildings. The requirements for recharging points and recharging point capabilities were updated for the recast Energy Performance of Buildings Directive, but assessments on the number of cable ducts and recharging points resulting from the Directive have not yet been made. In practice, building a faster recharging infrastructure than required in the Recharging Point Act could be required from new properties. For example, the lot handover terms and conditions of the City of Helsinki require that a third of the future building’s parking spaces will have installed recharging points for electric vehicles, even though the Recharging Point Act only requires recharging point cable ducts to be built and a single recharging point for buildings with more than ten parking spaces (two points for more than 50 parking spaces, and three for more than 100 spaces if the recharging points have the regular power output). 22 Act on Equipping Buildings with Electric Vehicle Charging Points and Charging Point Capabilities and Automation and Control Systems (733/2020) 23 Hallituksen esitys eduskunnalle laeiksi sähköajoneuvojen latauspisteistä ja latauspistevalmiuksista rakennuksissa sekä rakennusten automaatio- ja ohjausjärjestelmistä ja maankäyttö- ja rakennuslain 126 §:n muuttamisesta [Government Proposal to Parliament on Acts amending the Act on Equipping Buildings with Electric Vehicle Charging Points and Charging Point Capabilities and Automation and Control Systems and section 126 of the Land Use and Building Act; only in Finnish], HE 23/2020 vp. 44 Publications of the Ministry of Transport and Communications 2025:2 According to a 2023 renovation survey by the Finnish Real Estate Federation24, renovation projects for building recharging points were among the most common renovation projects in 2023–2024 in the terraced house and apartment building housing companies that responded to the survey. Recharging points were the most often mentioned renovation project planned to be implemented in the five- year period from 2024 to 2028 both for the terraced house and apartment building housing companies. However, the general outlook for renovation is now poorer because of the higher level of interest rates. A recharging point aid granted by the Housing Finance and Development Centre of Finland was available in 2018–2023 for building recharging points for existing buildings. A total of 18.5 million euros was allocated to residential building aids and 1 million euros to office building aids in the 2023 state budget. No new funding was allocated to these 2024. Most of the recharging point projects of existing housing companies (not new buildings) can be expected to have taken advantage of the aid from Housing Finance and Development Centre of Finland, which can be used to generate an indicative assessment of the infrastructure that has been built or will be built in the near future for existing terraced houses and apartment buildings that are not new or renovated. The aid for apartment buildings has helped to build around 85,000 recharging cable ducts. The Finnish Electrotechnical Trade Association maintains statistics on the number of recharging installations suitable for basic recharging and outdoor electrical outlets suitable for recharging sold in Finland based on a survey targeting companies. The statistics do not have information on the types of the properties on which these are installed. The sales and development figures of basic recharging equipment (3.7– 22 kW) provide indicative information on the prevalence of home and workplace recharging. The statistics do not include all equipment sold, for example equipment purchased online. More than 40,000 pieces of recharging equipment were sold in 2022. Especially the sales of the more powerful 22 kW equipment increased from the previous level. In 2023, the increase in the sales of recharging equipment slowed compared to the previous year but was still 9.5% higher than in 2021. A total of 35,048 pieces of equipment were sold. The sales of basic 11 kW equipment 24 https://www.kiinteistoliitto.fi/media/i0xdfumk/korjausrakentamisbarometri2023.pdf (in Finnish only). Https://www.kiinteistoliitto.fi/media/i0xdfumk/korjausrakentamisbarometri2023.pdf 45 Publications of the Ministry of Transport and Communications 2025:2 grew 16.2% from the previous year. The Finnish Electrotechnical Trade Association considered that one reason for the increase could be the increased need for home recharging equipment. Different ‘half public’ solutions have been born as intermediate alternatives to a publicly accessible recharging infrastructure for heavy-duty vehicles. One such solution is that a transport company that has built a recharging infrastructure for its own use shares the infrastructure with other operators on an agreement basis or makes its infrastructure available to others needing recharging during certain hours of the day. In the latter case, the infrastructure could be considered publicly accessible as required by the mandatory AFIR targets. Finland also has several small transport companies whose trucks could be recharged at home. No state funding has been allocated to support heavy-duty vehicle recharging points with restricted access. Depot recharging of buses was previously supported under the aid programme for transport infrastructure. The European Investment Fund’s guarantee programme can be taken advantage of in promoting depot recharging projects. 2.3 The current state and expected development of the hydrogen vehicle fleet and refuelling infrastructure 2.3.1 Hydrogen vehicles In road transport, hydrogen can be used in vehicles equipped with a fuel cell and an electric motor. Heat and clean water vapour are produced as side products. In principle, hydrogen could be used as fuel for a regular combustion engine as well in which case the combustion would produce water instead of carbon dioxide emissions. However, the efficiency of such vehicles is poorer than that of fuel cell vehicles. At the end of December 2023, there were two hydrogen passenger cars in use in Finland. There were no hydrogen vans, trucks or buses. It is unlikely that hydrogen passenger cars and vans become common, because the selection of electric passenger cars and vans is rapidly increasing in different price ranges, used vehicles are becoming increasingly available and the availability of the 46 Publications of the Ministry of Transport and Communications 2025:2 recharging infrastructure is already rather good. In the 2022 automobile sector fuel projection, it was estimated that there would be around 2,300 hydrogen passenger cars and around 500 hydrogen vans in Finland in 2030. The newest baseline projection of greenhouse gas emissions from transport (2023) has 20 hydrogen passenger cars and 27 hydrogen passenger vans (Figures 13 and 14). Figure 13.  Development of Finland’s fleet of hydrogen passenger cars in 2016–2023 and 2035 projection(vehicles used in traffic: The Finnish Transport and Communications Agency Traficom, projection: VTT Technical Research Centre of Finland, 2024). In total, there are approximately 2,750,000 passenger cars in Finland. 0 100 200 300 400 500 600 20 16 20 17 20 18 20 19 20 20 20 21 20 22 20 23 20 24 20 25 20 26 20 27 20 28 20 29 20 30 20 31 20 32 20 33 20 34 20 35 Development of the hydrogen-fuelled passenger car �eet in 2016- 2023 and 2035 projection 47 Publications of the Ministry of Transport and Communications 2025:2 Figure 14.  Development of Finland’s fleet of hydrogen vans in 2016–2023 and 2035 projection(vehicles used in traffic: The Finnish Transport and Communications Agency Traficom, projection: VTT Technical Research Centre of Finland, 2024). In total, there are approximately 350,000 vans in Finland. Hydrogen is expected to have a role in the future especially in demanding transport tasks for which battery electricity is not suitable. In addition to heavy-duty goods transport tasks, hydrogen could be used as fuel for long-distance buses in the future. There are uncertainties and worries over the profitability of the large investments required in order for hydrogen to become more common, which is why a significant increase in its prevalence as a transport fuel in Finland in the near future is unlikely. Currently, only a few manufacturers manufacture fuel cell trucks.25 The range of heavy-duty hydrogen vehicles is expected to develop from the current state of mostly demonstration activities, and the actual supply of hydrogen trucks is expected start in the latter half of the 2020s.26 25 https://www.acea.auto/files/Getting_ZeroEmissionTrucks_on_the_road.pdf 26 https://www.acea.auto/figure/interactive-map-truck-hydrogen-refuelling-stations- needed-in-europe-by-2025-and-2030-per-country/ 0 200 400 600 800 1 000 1 200 1 400 1 600 1 800 20 16 20 17 20 18 20 19 20 20 20 21 20 22 20 23 20 24 20 25 20 26 20 27 20 28 20 29 20 30 20 31 20 32 20 33 20 34 20 35 Development of the hydrogen-fuelled van �eet in 2016-2023 and 2035 projection https://www.acea.auto/files/Getting_ZeroEmissionTrucks_on_the_road.pdf https://www.acea.auto/figure/interactive-map-truck-hydrogen-refuelling-stations-needed-in-europe-by-2025-and-2030-per-country/ https://www.acea.auto/figure/interactive-map-truck-hydrogen-refuelling-stations-needed-in-europe-by-2025-and-2030-per-country/ 48 Publications of the Ministry of Transport and Communications 2025:2 The supply of hydrogen trucks is expected to first be targeted at the markets of the United States and Central Europe. As the distribution station network expands, it is likely that some manufacturers may be able to supply a small number of hydrogen trucks to the Finnish market as well and rather quickly. Importer estimates on when the manufacturers they represent will start the series manufacture of fuel cell trucks and their import to Finland vary from 2025 to 2029. The prices of fuel cell trucks are around two to three times the prices of diesel trucks and roughly at the same level than the prices of fully electric trucks. The prices of regular diesel trucks are usually between 150,000 and 250,000 euros. In research literature, the price range of hydrogen trucks is estimated to be 200,000– 600,000 USD.27 The total cost of ownership (TCO) of hydrogen vehicles is still clearly higher today than that of diesel, gas, or electric trucks. The development of the TCO significantly depends on the range of hydrogen vehicles and the price of hydrogen fuel, which is currently high. In the new baseline projection of greenhouse gas emissions from transport (WEM, 2024) it is assessed that in 2030, there will be just under 200 hydrogen trucks (Figure 15) and no hydrogen buses in Finland. Considering the domestic production of green hydrogen from renewable sources and the expected growth in the range of vehicles as well as the infrastructure that is expected to be built (see below for more details), it is still reasonable to set national targets exceeding the baseline projection for the number of hydrogen buses and trucks in 2030: 100 hydrogen buses and 500 hydrogen trucks. Hydrogen buses would primarily be used for long- distance services. 27 Sharpe & Basma, Meta-study of purchase costs for zero-emission trucks. The ICCT 2022. https://theicct.org/wp-content/uploads/2022/02/purchase-cost-ze-trucks-feb22-1.pdf https://theicct.org/wp-content/uploads/2022/02/purchase-cost-ze-trucks-feb22-1.pdf 49 Publications of the Ministry of Transport and Communications 2025:2 Figure 15.  Development of Finland’s fleet of hydrogen trucks in 2016–2023 and 2035 projection (vehicles used in traffic: The Finnish Transport and Communications Agency Traficom, projection: VTT Technical Research Centre of Finland) In total, there are approximately 90,000 trucks in Finland. 2.3.2 Hydrogen refuelling infrastructure There are currently no operational public hydrogen refuelling stations in Finland. The AFIR requires that EU Member States ensure that by 2030 there are publicly accessible hydrogen refuelling stations designed for a minimum cumulative capacity of one tonne per day with a maximum distance of 200 kilometres between them along the TEN-T core road network. In areas with less traffic, the capacity requirement may be halved. In addition, the stations must be equipped with at least a 700-bar dispenser (see the Appendix). In addition, Member States must ensure that by 2030, there is at least one publicly accessible hydrogen refuelling station in each urban node. A positive funding decision has been issued from the national infrastructure aid programme for four planned public hydrogen refuelling stations. EU funding for a distribution infrastructure has also been granted for hydrogen refuelling stations. (See Figure 16.) If realised, these