I understand it, the electrical interlocking systems provides at least equivalent safety to mechanical shutters, and that's been generally accepted in the UK.

UK legislation isn't (to my mind) all that clear - there's no direct requirement for BS 7671 compliance in most situations - and anyway BS 7671 allows for non-compliances that don't lead to a reduction in safety (even if it might theoretically mean extra paperwork). Things like the The Plugs and Sockets etc. (Safety) Regulations  don't talk about shutters - but does refer to BS 1363 (which does require shutters) but that bit doesn't apply to appliances rated above 13A (arguably you could read it as round pin sockets need to comply with BS 546) but since the regs don't apply to plugs for appliances over 13A it feels a bit absurd to think that the matching sockets should. There's also the point of whether "ordinarily intended for domestic use" includes things outdoors associated with vehicles.

France was a bit of an oddity, as I understand it after generations of having unshuttered sockets they eventually wrote the requirement for shutters directly into legislation, rather than technical standards. So when EV came about, they were obliged to have mechanically shuttered sockets regardless (might have been a type 3 connector?), while everyone else went for unshuttered with electrical interlock. I've a feeling they might have amended their legislation by now and are moving over to ordinary type 2 connectors. Most of Europe now requires shutters on their new "ordinary" general purpose sockets now anyway.

   - Andy.

AJJewsbury said:

I understand it, the electrical interlocking systems provides at least equivalent safety to mechanical shutters, and that's been generally accepted in the UK.

I guess the argument would go that it might be equivalent if the interlocked switching arrangement is suitable for isolation.

However, let's take a step away from BS 7671, and talk about what BS EN IEC 61851-1 requires (as that's the standard this product is being made to).

The essence of Clause 8.1 of BS EN IEC 61851-1:2019 is that the equipment must meet at least IPXX/C (regards access to live parts) ... but that's not easy for socket-outlets and vehicle connectors. So Clause 8.1 goes on to say that, for Mode 3 outlets in all countries, socket-outlets on the EV charging equipment must meet at least IP XX/B, and they must have either shutters, or a means of isolation (there are two options to provide this) that operates automatically so that when the vehicle connector is removed, the power is disconnected.

Clause 8.1 then goes on to note that for residential and public locations, UK and France socket-outlets require shutters ... which can only come from the BS 7671 requirement in 553.1.201 ?

So, I think it's possible to interpret Clause 8.1 of BS EN IEC 61851-1:2019 in the following way for EVSE for France and the UK,:

• for residential and public charge points, if you fit a panel-mounted outlet, it should have shutters.
• for other locations, or If your EVSE has a tethered cable with a vehicle connector, the charger must have an interlocked means of isolation that operates automatically so the power is removed when the connector is not mated.

... and I guess that's the reason why Euan Taylor  is asking the question in the first place, because it's not 100 % clear ?

 gkenyon I think you have come full circle the same as I have done.

According to EN IEC 60529, an equipment marked IPXXB is protected against access with the finger, or rather the jointed test finger of 12 mm diameter, 80 mm length has adequate clearance from hazardous parts.

The standard Type 2 socket has a minimum protection of IPXXB, so fulfills the first part of Clause 8.1 requirement without any additional shuttering.

Even though our charger is Untethered it still has to have an interlock and a means of isolation. So while there is no plug in the socket (Both at the charger or at the car) no electricity is allowed to flow. So is then covering the second part of Clause 8.1

The only issue as you have said, is where the requirements state "for residential and public locations, UK and France socket-outlets require shutters" now we know this to be true for standard domestic sockets that are 13A or less, under the  BS 7671, but as per the  BS 7671 we also know that such as industrial types to BS EN 60309-2, are available in current ratings of 16, 32, 63 and 125A, but are not intended for household or similar use. Generally, these socket-outlets do not incorporate an integral shutter system.

I would argue that the Type 2 socket is not used for household use and that the EV Charger is "a circuit having special characteristics".

Given that section 553 in the BS7671 gives a table for Plus and socket-outlets for low voltage circuits, which only includes BS1363, BS546 and BS EN 60309-2. It looks like 62196 sockets are not covered in the requirement. But still, it feels too vague for me to be happy.

Does anyone know who would make the final decision on such a requirement? I have contacted the Office for Product Safety and Standards who overlook the Electric Vehicles (Smart Charge Points) Regulations 2021- https://www.legislation.gov.uk/uksi/2021/1467/contents/made but they have simply responded saying it is not within the remit of their enforcement area.

 gkenyon I think you have come full circle the same as I have done.

According to EN IEC 60529, an equipment marked IPXXB is protected against access with the finger, or rather the jointed test finger of 12 mm diameter, 80 mm length has adequate clearance from hazardous parts.

The standard Type 2 socket has a minimum protection of IPXXB, so fulfills the first part of Clause 8.1 requirement without any additional shuttering.

Even though our charger is Untethered it still has to have an interlock and a means of isolation. So while there is no plug in the socket (Both at the charger or at the car) no electricity is allowed to flow. So is then covering the second part of Clause 8.1

The only issue as you have said, is where the requirements state "for residential and public locations, UK and France socket-outlets require shutters" now we know this to be true for standard domestic sockets that are 13A or less, under the  BS 7671, but as per the  BS 7671 we also know that such as industrial types to BS EN 60309-2, are available in current ratings of 16, 32, 63 and 125A, but are not intended for household or similar use. Generally, these socket-outlets do not incorporate an integral shutter system.

I would argue that the Type 2 socket is not used for household use and that the EV Charger is "a circuit having special characteristics".

Given that section 553 in the BS7671 gives a table for Plus and socket-outlets for low voltage circuits, which only includes BS1363, BS546 and BS EN 60309-2. It looks like 62196 sockets are not covered in the requirement. But still, it feels too vague for me to be happy.

Does anyone know who would make the final decision on such a requirement? I have contacted the Office for Product Safety and Standards who overlook the Electric Vehicles (Smart Charge Points) Regulations 2021- https://www.legislation.gov.uk/uksi/2021/1467/contents/made but they have simply responded saying it is not within the remit of their enforcement area.

Euan Taylor said:

I would argue that the Type 2 socket is not used for household use and that the EV Charger is "a circuit having special characteristics".

I would put this a different way. It's not a 'general-purpose socket-outlet' and not a normal 'accessory". In terms of BS 7671, it may be more appropriate to talk about vehicle outlets and connectors as a special equipment connectors, because they incorporate control signals as well as power connections.

I also find it strange, regarding BS EN IEC 61851-1, that a vehicle connector on a tethered cable would not require shutters, but a panel-outlet does, given the IP rating is rather similar (you could poke a wire of a certain length in either to access the mains live conductor pins) - and perhaps you could use that as an interpretation that shuttered type 2 outlets are not necessary?

Therefore, I think it's possible to consider that the note in Clause 8.1 of BS EN IEC 61851-1 applies to standard socket-outlets (i.e. BS 1363-2, not dedicated vehicle outlets) requiring shutters.

I would put the question to the relevant British Standard committee, if you feel the requirements of the standard are confusing in this regard: standardsdevelopment.bsigroup.com/.../50001611