Is a shutter needed on a Residential Type 2 Mode 3 EV charger?

Question

Hello, 
 
 I'm currently helping to bring an EV charging product to the UK market, it is already sold throughout Europe with no issue, but one line in the EN61851 is currently causing me a headache. 
 8. Protection against electric shock "NOTE 4 In following countries socket-outlets are equipped with shutters where they are mandatory in residential and public locations: FR, UK" 
 In my reading this Note refers to a standard Socket outlet (3 pin Socket Outlet, such as you would find in UK homes) which are all fitted with shutters on the Live and Neutral as per BS1363. This would be relevant in the situation where our charger was plugged directly into a 3 pin Socket, as per a Mode 1, or had a standard 3 pin socket on the unit, however this is not the case for us as we will either be wired directly into the electrical systems within the property, or using an interlocked &ldquo;commando / BS EN 60309-2&rdquo; socket. 
 The British standard BS 7671:2018+A2:2022 Regulation 553.1.201 states: &ldquo;Every socket-outlet for household and similar use shall be of the shuttered type and, for an AC installation, shall preferably be of a type complying with BS 1363.&rdquo; Socket-outlets in excess of 13A, 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. 
 Section 722 (Electric Vehicle Charging Installations) from the most current BS 7671:2018+A2:2022 
 There are 6 methods of connection that are acceptable for an AC charging point, we are using option 5, &ldquo;one type 2 socket-outlet or vehicle connector complying with BS EN 62196-2 for use with mode 3 charging&rdquo; 
 Further down we see 722.551.7.2 &ldquo;The socket-outlet or vehicle connector shall comply with BS EN 62196 series.&rdquo; 
 
 From all these points above and looking at the current products available on the market, I believe that the use of the standard BS EN62196 connector without a shutter is acceptable. However as shutters are available on the EN62196 range and given that the EV charger will typically be located in a domestic situation, all be it with a current above 13A (32A max single phase) is there a requirement for a shutter?

AJJewsbury · Accepted Answer

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.

Is a shutter needed on a Residential Type 2 Mode 3 EV charger?

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