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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

    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
  • 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!
  • 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

    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.

  • 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

    Sparkingchip:




    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 

     




    It sits in between the consumer unit and the charger, as it disconnects the circuit protective conductor downstream of it in the cable using SWA between this unit and the charger needs to be considered very carefully.


    Andy Betteridge

  • 0
    A large part of the compliance and the effort in  the technical file will not be under the HSE machinery at work  remit if it is intended for home use, but rather  falls under the rather quaint title of weights and measures, which is where the responsibility for enforcement of all the EMC and related legislation falls.

    Between them, the HSE and the various trading standards folk for each local authority are the UK's main  market surveillance authorities (MSA) . HSE looks mostly at the workplace, and trading standards the rest.


    As such local authority trading standards are the folk who can (but rarely do) demand  to see the maker's technical construction files  (TCF) or other proof of compliance in respect of those standards.

    (https://www.tradingstandards.uk/media/documents/news--policy/other/list-of-statutory-duties.pdf)



    It is largely left to those placing equipment on the marked to decide which of the various standards apply to their product, and then to sign some statement to say that they believe they do. Personally I have very little to do with the HSE, but my experience of trading standards is that they are not really well enough staffed with the right sort of folk and equipment for the modern role - inspections of market stalls selling dodgy burgers well kitted out perhaps, but subtleties about conducted  emissions from doubtfully CE marked kit, which is what we have here, most are likely to be rather on shaky ground.

    In many ways the regulatory regime is too fragmented and too complex to work as intended, so it is very 'wild west'.

  • 0

    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. 




    Agree with what Paul Skyrme said here - the Electrical Equipment (Safety) Regulations, along with all the other legislation based on EU Directives, will remain in force past the end of the Year - and even then, changes will be dependent on EU Directives.


    However, we can have different standards in the UK. The problem (other than free market movement), is that national deviations actually cost quite a lot of money for consumers - for example having a UK plug on an appliance costs between £2 and £10 per appliance over the cost of having a Shuko, or similar, and that's purely a supply and demand thing.



    The OP asks if chargers are fully compliant, and asks the manufacturers to certify this in the manner required to allow a CE mark.



    The OP was asking about the protective devices described in 722.411.4.1 (ii), (iv) and (v) - for which there is no current product standard for the device as a whole. This is explained fully in section 5.3.5.1 of the 4th Ed of the IET CoP for EV Charging Equipment Installation. I think another problem is that some manufacturers have proprietary technology, which they have spent a lot of time and money investing in, and is the subject of patent applications. They are not always willing to tell "just anyone" about their technology and how it works - and that causes a problem for installers.


    I guess there are also installers who doubt some of the claims being made, and hence this discussion thread?



    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.



    I guess the OLEV grant is another issue for discussion here?



    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!



    Yes, I think the real cost of installing EVSE safely is, in many cases, far in excess of the OLEV grant.

  • 0
    Manufacturers installation instructions can be rather scant when it comes to how to connect the electrical supply to an EV charger, this description of how to wire an EV charger is from a forty page installation manual, three paragraphs from the whole document. There certainly is not any discussion about using open PEN detectors or the actual requirements for earth rods.


    Supply

    The zappi device should be connected to a single-phase 230V or 240V nominal AC supply. The supply should be from a dedicated 32A or 40A circuit breaker.

    Earthing

    The unit must be earthed in accordance with local regulations, e.g. It may be a requirement to install an Earthing rod if the supply is PME.

    Cable Entry

    There is a grommet in the rear of the unit for through-wall cable installation. If however, the supply and/or sensors cables are surfaced mounted, there is space at the bottom right-side of the enclosure to drill holes for the cables. It is essential that correctly sized cable glands with a minimum IP65 rating are used.

    Zappi
  • Former Community Member
    0 Former Community Member

    gkenyon:



    Yes, I think the real cost of installing EVSE safely is, in many cases, far in excess of the OLEV grant.



    Would it be overly cynical to suggest installers who tick the right boxes to claim the grant and install eligible charge points seem to cost more by pretty much the value of the grant, when compared to buying a charge point and paying A.N. Other electrician to install it? Certainly having had one charge point installed through the grant I don't feel like I got value for money or that I would do so again even if I were able to (having moved and left that charge point behind).

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