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I am hearing from my network of contractors, that have actually read the new 722, that they have been asking charging equipment manufactures for documentary proof to comply with Note 5 of 722.411.4.

They are getting knocked back for asking or in one case a Declaration that says the particular device complies with BS 7671. I think that is wrong to declare that as BS 7671 is an installation safety standard and not a product standard. I believe that as a minimum the equipment must comply with the Low Voltage Directive and be CE marked. I also believe that manufacturers have to issue a Declaration of Conformity. 

BS 7671 722 has numerous references to the various standards required such as BS EN 61851 that the equipment must comply with. I am thinking it may be illegal to offer the sale of equipment that does not comply with the Low Voltage Directive and is not CE marked?

I am hoping the countries top man of equipment safety standards, Paul Skyrme , sees this post and will come on and give us his expert view?

Has any forum member asked for a Declaration of Conformity from EV charging equipment manufacturers and received one?
  • Actually John, you are pretty much right.

    I could probably write until I get over the maximum word count!

    The fact of the matter is, that the device to be legal to be place on the market, which in itself is a specific definition, must be CE marked and compliant with the Low Voltage Directive (LVD).

    Forget BREXIT, the LVD is mirrored in UK law, and nothing about that is going to change.

    The manufacturer must issue a DoC, and if they are using standards to claim a presumption of conformity, then these standards must have been published in the Official Journal of the EU..

    That is they must be EN, EN ISO, or EN IEC.

    A standard that is BS only such as BS 7671 cannot be used to claim a presumption of conformity with the LVD.

    I tackled the manufacturer who I think you are referring to claiming conformity to BS7671 and they became very abusive by email.

    BS 7671 is NOT a product standard, and does NOT cover the requirements for products to be placed on the market.

    If a product is not being designed and built to a recognised product standard, then the Technical File, which must exist prior to affixing the CE mark for LVD compliance, must detail how the product meets the safety requirements of the LVD, by being as safe or safer than having followed the harmonised standard.

    A but like justifying a departure under BS 7671.

    If the manufacturers are placing these devices on the market or putting them up for sale, and they are not CE marked to the LVD, EMC, & EMF directives at least, and they do not have a TF in place to illustrate this, then they are breaking the law, and that is a criminal offence, not a civil one.

    They may also be putting the lives of the users at risk, and putting the livelihoods of their installers in jeopardy
  • Paul

    Thanks. Can. I ask please if a designer or contractor calls or emails a supplier and asks for a copy of the DoC for a device is the supplier under a statutory duty to provide it? Is this similar to COSHH data sheets which have to be provided to enable risk assessments to be carried out?

    I have 2 design jobs on the go at the moment, one site has a TN-S supply so not to much of a problem. The other site has a PME supply so I need to specify a charging point that is 722 compliant. Currently the site has 2 ordinary Masterseal sockets protected by Type AC RCDs that the MD and H&S manager plug their cars in to using " Granny leads".

    Has any forum member installed a VCP PME 722 compliant device that the supplier has provided a DoC for?

    How would you code a VCP connected to a PME supply without one of the 5 measures from 722 applied found on a Periodic Inspection.
  • The law states the the DoC, MUST accompany the product, so there should be no need to ask for it, it must be part of the “manuals/technical information” provided with the product.

    End of.
  • Paul

    Good to know that a DoC has to be supplied with the product but what about supplying it to me with my designers hat on so I can specify it for my design? I have got to do this this week!
  • I suspect that any reputable supplier would be very happy to supply a DoC up front to show that their equipment complies with the law. If anybody has seen one, please let us know so that we may make an informed decision as to which to obtain.

    Unfortunately, we are in such a muddle at the moment that nothing may be forthcoming from anybody.

    As for coding, I think C2.

  • John Peckham:


    Good to know that a DoC has to be supplied with the product but what about supplying it to me with my designers hat on so I can specify it for my design? I have got to do this this week!

    Any respectable suppliers should have the Doc available for download on their website, or send it upon request.

    If they don’t or can’t then I would simply be looking elsewhere, because I would be believing that the product was non compliant.

    As a designer, why would I want to be specifying a non-compliant product, and taking on the liability for that.

    As an installer why would I want to be installing a non-compliant product ant taking on the liability for that?

    If the information for the product doesn’t exist, or cannot be provided then the product isn’t legal for sale, simple.

  • Paul

    Thanks. I have no intention of specifying anything that is non-compliant to comply with my statutory duties and common law duties as a principle designer. Also I have no intention of certifying on the EIC that my design is compliant if I have specified a component that is not compliant.

    So far I have looked at one big market player that is not issuing a DoC that is compliant with the LVD. Another market player who's device does not contain an RCD compliant with 722.531.2.101 but has current coils that are connected to a printed circuit board.

    My search goes on.

  • John Peckham:

    How would you code a VCP connected to a PME supply without one of the 5 measures from 722 applied found on a Periodic Inspection.

    FI- Further investigation.

    Push it back onto the manufacturer and, possibly unfortunately, the Installer.

    Andy Betteridge 

  • Andy

    Down to the contractor I think as they should have provided an EIC that one or more individuals has designed the installation to BS 7671, installed the installation to BS 7671 and has been inspected and tested the installation for compliance with BS 7671 and those person(s) have certified compliance with their signatures.

    I would only FI an apparent non-compliance if I was unsure if the EV charging equipment was not compliant after I had made inquiries with the equipment manufacturer. Using an FI without making reasonable inquires because the inspector cannot make an effort is not exercising due diligence in my book.

  • I raised an observation about two interlinked hardwired smoke alarms made by two different manufacturers recently on an EICR, I did email one of the manufacturers who replied saying they were incompatible, so there was no point perusing it with the other manufacturer. So if anyone comes back and queries my report I can refer them to the manufacturer.

    If I do an EICR and there is an EV charger that appears to be unsatisfactory because of its design I should be able to refer to the manufacturer’s documentation provided for me to refer to along with the installation instructions and installation certificate, all of which will be made available to me by the person ordering the work or their agent, assuming it’s not stored adjacent to the consumer unit.

    However that’s how it’s really going to happen is it? So faced with a lack of information most people reach for their phone to have a look at the manufacturers website, now that’s really the place a copy of all the relevant documents should be immediately available.

    But it appears that isn’t going to happen either, so without documentation being handed to the inspector for reference or information on the manufacturers website the next alternative is to contact the manufacturer. So the inspector sends an inquiry by email, without receiving a reply with the required document the options really have all been used up.

    Presumably the EV charger is installed and presumably in use, compliance with the current edition of BS7671 cannot be confirmed, without being able to precisely identify an issue or indeed if there even is an issue the code can only be FI.

    Ten minutes seems a reasonable amount of time to spend trying to resolve this before coding it FI and failing the whole installation. Ask the person ordering the work for documentation, check on site for documentation, check the manufacturers website, email the manufacturer and read their reply.

    The person reviewing the EICR may not appreciate it being  coded FI, but actually they were the first person the inspector asked to supply the information, so maybe unwittingly become part of the problem, if asked for information they should provide it if they want a satisfactory report. Okay, they might not have realised they should have the information or may not have realised the importance of keeping it to hand.

    Ultimately if inspector cannot write a report without relevant manufacturers information concerning installed equipment it is not the inspectors job to source that information.

    There’s a bit of a denial culture when it comes to responding to requests for previous certification, EICRs and other information about electrical installations for which an EICR has been requested, many people appear to think they are being clever or “getting their monies worth” if they do not provide the inspector with any information at all as they will do “a proper job” rather than “just copying” the last report.

    Then they wonder why EICRs are so expensive.

    Andy Betteridge