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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?
  • 0
    On the basis that as Paul said CE + CE ≠ CE


    If we take a consumer unit purpose made for supplying an EV charger with additional protective devices to protect against an open PEN and a match it with EV charger from a different manufacturer do we have yo get each manufacturer to say that their equipment is compatible and meet the requirements of BS 7671 when installed together? 


    Presumably if we are to follow the EV charger manufacturer installation instructions we need to get written approval for using alternative equipment to supply it.


    Andy Betteridge
  • 0

    Paul Skyrme:

    The law also requires compliance with the LVD, not the UK version, however, this is why they are identical as the UK way of meeting the LVD is via the EESR.




    EU law requires that member states implement Directives and this is usually done word for word.


    Member states' laws require that citizens obey their own laws.


    The result is that persons (including companies) of EU countries must follow EU laws.


    Now that UK has left EU, there is no longer an obligation to implement the latter's Directives and inevitably there will be divergence in future, but that is, as I have said, a political matter.

  • Former Community Member
    0 Former Community Member

    Chris Pearson:

    I think that it is unhelpful to talk of (EU) Directives when we ought to consider UK Regulations, i.e. the UK laws which implement the directives, which as members of the EU, UK was obliged to do.


    There is guidance in respect of the Low Voltage Directive here.


    Whether the UK will adopt EU Directives in future remains to be seen - that is a matter of politics!




    It is irrelevant which you quote they are identical at this point in time.

    The law also requires compliance with the LVD, not the UK version, however, this is why they are identical as the UK way of meeting the LVD is via the EESR.

    There is a lot more detailed guidance than that out there also.


    I spend almost all my working days on compliance assessing compliance with either the MD or the LVD these days via either the EHSR's or the Harmonised Standards giving assistance and guidance to both for manufacturers and end users.

  • 0
    I think that it is unhelpful to talk of (EU) Directives when we ought to consider UK Regulations, i.e. the UK laws which implement the directives, which as members of the EU, UK was obliged to do.


    There is guidance in respect of the Low Voltage Directive here.


    Whether the UK will adopt EU Directives in future remains to be seen - that is a matter of politics!
  • 0

    Sparkingchip:

    Isn’t supposed to mention BS EN 61851?


    Andy Betteridge 




     

    Or is it a consumer unit to connect a charger to rather than a charger itself?


    Andy Betteridge
  • Former Community Member
    0 Former Community Member

    davezawadi:

    The fact that cars supposedly comply with some BS EN standard is no longer relevant as we have left the EU. If BS wish to deviate from unsatisfactory standards, that is perfectly possible.  The OP asks if chargers are fully compliant, and asks the manufacturers to certify this in the manner required to allow a CE mark. This does not appear to be the case, so what standards they are supposed to meet is again irrelevant. In Britain for the rest of the year it is probably illegal to sell devices without the CE and fully compliant with all relevant standards. However the grant is probably being paid anyway, which is a disgrace. Next year the situation is far from clear, if we have escaped from our house arrest.


    It could be, and in fact is likely, that there are not many countries with this TNC-S problem, but that is no reason not to take action and do something. I feel that some enhanced version of TT, which can still be dangerous, is not the best way to go. In fact as we shall have to replace most of the street level electrical infrastructure anyway if we go largely electric, we should change the distribution system back to TN-S, as the additional cost would be tiny compared to the civil works needed for electric vehicles. Really I can see no downside of such a change, although I expect considerable push back from certain quarters not least political. It would certainly point out to everyone that electric vehicles and everything else are far from free, in fact very expensive indeed!




    Unfortunately Dave, your reference to the UK leaving the EU and the lack of relevance of those standards is incorrect.

    The last official guidance I was given is that the UK H&S law is not changing, the EU is not leaving ISO, nor the IEC as most of the EN standards are now coming through unchanged from ISO/IEC the UK leaving the EU is totally irrelevant when it comes to standardisation.

    The CE mark will still be acceptable in the UK up until the end of any transition period it seems, and the UKCA mark will slowly take over for UK only product.

    It is unlikely that global manufacturers will make high volumes of UK specific product if we deviate from the ISO & IEC standards, which will be almost impossible for us anyway as we have agreed to bide by the rules of membership of those organisations, which are nothing to do with the EU.

    Also, I believe that we are also not leaving CENELEC, or CEN, though I don't recall the exact details of that.

    Others on here may know more about the CEN/CENELEC status from memory than I do.

  • 0
    Isn’t supposed to mention BS EN 61851?


    Andy Betteridge
  • Former Community Member
    0 Former Community Member

    John Peckham:

    Andy


    Here is what a DoC looks like https://matt-e.co.uk/wp-content/uploads/2019/10/EU-Declaration-of-Conformity-OPEN-unit.pdf




    It's a shame the first standard listed on that is not published in the Official Journal as offering a presumption of conformity to the LVD...

  • 0
    Andy


    Here is what a DoC looks like https://matt-e.co.uk/wp-content/uploads/2019/10/EU-Declaration-of-Conformity-OPEN-unit.pdf
  • 0
    The fact that cars supposedly comply with some BS EN standard is no longer relevant as we have left the EU. If BS wish to deviate from unsatisfactory standards, that is perfectly possible.  The OP asks if chargers are fully compliant, and asks the manufacturers to certify this in the manner required to allow a CE mark. This does not appear to be the case, so what standards they are supposed to meet is again irrelevant. In Britain for the rest of the year it is probably illegal to sell devices without the CE and fully compliant with all relevant standards. However the grant is probably being paid anyway, which is a disgrace. Next year the situation is far from clear, if we have escaped from our house arrest.


    It could be, and in fact is likely, that there are not many countries with this TNC-S problem, but that is no reason not to take action and do something. I feel that some enhanced version of TT, which can still be dangerous, is not the best way to go. In fact as we shall have to replace most of the street level electrical infrastructure anyway if we go largely electric, we should change the distribution system back to TN-S, as the additional cost would be tiny compared to the civil works needed for electric vehicles. Really I can see no downside of such a change, although I expect considerable push back from certain quarters not least political. It would certainly point out to everyone that electric vehicles and everything else are far from free, in fact very expensive indeed!

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