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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
    The standard for EVSE is BS EN 61851-series.


    That doesn't include for protective equipment as described in 711.411.4.1 (iii), (iv) or (v) at present.
  • Former Community Member
    0 Former Community Member

    Sparkingchip:

    I will jump to the next question, as the British and Harmonized Standard consists of many parts does saying it’s compliant with part one mean it fully complies with the whole standard?


    It seems that many chargers are assembled with components that individually comply with separate BS and EN Standards, but when assembled as a complete unit don’t comply with a standard covering the actual intended use of the complete assembly.


    Andy Betteridge 


     






    CE + CE ≠ CE

    That is the CE mark on individual parts when assembled into the whole does not result in the whole being automatically CE marked.

    Think about it in the same way as an installation under BS 7671.

    All of the individual parts may well be compliant with their relevant standards, but, once installed, the combination certainly does not meet BS 7671 in some circumstances.

  • 0
    Which was JP’s original issue, obtaining a declaration from the manufacturer for the complete assembly, not a folder full for the individual components.


    How many parts are there to the complete BS EN? I found eighteen search results on the BSI website, but not all are current and the numbering goes up to at least twenty four, so presumably the manufacturer are supposed to declare they have mixed and matched in an appropriate manner.


    Andy Betteridge
  • Former Community Member
    0 Former Community Member
    The valid parts of the 61851 series that you will find currently listed on the BSI website are 5 parts.
    Part 1 is the general requirements which all devices must comply with, unless those general requirements are overruled by a specific requirement in another part which applies to their design of charger.
    The other parts are -21-1, -22, 23 & -24.
    -22 & -23 are mutually exclusive, one is for a charge point that delivers AC, the other DC respectively.
    -24 deals with the charger to vehicle comms.
    -21-1 deals with conducted EMC.
    Thus taking a charger which supplies AC to the car, and has charger to car comms, I would expect to see parts 1, 21-1, 22, & 24 listed on the DoC.

  • 0
    Thanks, if I saw a declaration of conformity for an electric vehicle chargerI would not know what it is supposed to say on it!


    I would just be looking for the key features.


    Andy Betteridge 


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


    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.

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