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EV CHARGING EQUIPMENT

John Peckham
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?
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  • Former Community Member
    0 Former Community Member
    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
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  • Former Community Member
    0 Former Community Member
    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
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