So, the manual was updated to recommend that users consult local wiring regulations ( In our case BS 7671) to assess whether an additional RCD is required. So does The absence of a recognized BSEN number means a non-compliance with BS 7671 ? Is this type of charger used where BS 7671 is not the prevailing wiring standard ? Confusing! But they then refer to BS 7671 stating  it complied with Reg 134.1.1 but like you said doesn’t comply with 722. So therefore, in my opinion it’s doesn’t comply ! 

I would happily sign an EIC with a Zappi at the end of a circuit without an upstream RCD, providing Zs was ok. MyEnergi is a UK success story with the Zappi being one of the best chargers on the market. If needs be stick it in the departures section and worry not one jot about it!

AMK said:

So does The absence of a recognized BSEN number means a non-compliance with BS 7671 ?

Not always ... Regulations 133.1.3 and 511.2 could be used, if the 'designer' is happy to provide the confirmation based on the manufacturer's declarations and instructions (and, perhaps as necessary , other information)?

Further, legislation such as the Electrical Equipment (Safety) Regulations does not mandate standards are used ... a technical construction file can be compiled and referenced by the manufacturer on the Declaration of Conformity ...

Even though they have this in their FAQs? https://www.myenergi.com/installers-centre/

text from link copied and pasted bellow.

“Does the zappi require any RCD protection?

Both 133.1.3 and 511.2 put the onus on the circuit designer not the manufacturer, this is also reliant on a declaration of conformity which as far as I can tell with regards to the RCD iin the UK s non existent. Would you not agree Mr Kenton?

134 mentioned in the original post specifically applies to “erection and initial verification” and not selection of protective devices. 

722 does apply to selection.

all of this makes me wonder if the person writing the statement for MyEnergi entirely understands how to read BS7671 as an informative document?

A recommendation to install a type A is OK, it would be the installation of  an upstream type B that requires an overdraft !
Mike

IronFreely said:

Both 133.1.3 and 511.2 put the onus on the circuit designer not the manufacturer

Yes, to satisfy themselves that the situation is no less safe than BS 7671. If the Designer is satisfied that the documentation provided by the manufacturer provides that assurance, the question simply becomes whether the Designer is able to rely on manufacturer's Declarations of Conformity that says they comply with relevant legislation such as the Electrical Equipment (Safety) Regulations.

Since DofCs are legal documents provided in accordance with specific legislation - for example the Electrical Equipment (Safety) Regulations - we need to look at what the legislation itself says. If we were to agree that there are no relevant standards for RCD functionality provided by a product in the manner intended by the manufacturer, then Regulation 37 of the Electrical Equipment (Safety) Regulations might be appropriate:

37(1) Where there are no designated standards, electrical equipment which complies with relevant international safety provisions is to be presumed to be in conformity with the principal elements of the safety objectives unless there are reasonable grounds for suspecting that the electrical equipment does not so comply.

There is always 'buyer beware' (caveat emptor) situation ... so due diligence to verify whether there are "reasonable grounds for suspecting that the electrical equipment does not so comply" before you specify it.

I make no comment about any individual specific product.

A While ago a priced to install a ROLEC 22kW charger installation, it was marketed as having built-in RCD protection, Open PEN protection etc. However, upon closer examination and a conversation with the manufacturer, it became evident that an RCD upstream was necessary. This came as a surprise to the wholesalers selling the product.

722 lists all the BS EN standards for the equipment to be installed. For example the RCDs required. Both BS EN 61008 and 61009 to have a used test device marked with a "T". If it has not got one then that is as an indication that the RCD protection fitted does not comply with those standards. Of course you can fit one of these non-compliance devices as a Departure as GK says above. But you have to take on the liability declaring it is no less safe than an approved device. Why an earth would you take on that liability when you can buy equipment that complies with all the standards required by 722 and other BS 7671 requirements? Also you might want to ask your Professional Indemnity insurers if they will indemnify you in the event of a claim.  

JP

Thanks John. Despite my awareness of regulatory requirements, I inadvertently omitted the inclusion of a RCD in my initial pricing. Upon unboxing the product, I noticed the absence of a test button, which prompted further inquiries. Consequently, I installed the RCD adjacent to the distribution board. While I acknowledge my oversight, it’s worth noting that the product had been marketed to me as fully compliant.