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!

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?

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

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

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.

And that is what this is all about. Products being marketed in a way that makes you believe it’s fully compliant when perhaps they could be a bit more up front about technicalities so that the installer/designer can make an objective and informed decision at point of purchase.

The big question here would be, if following an incident could the installer/designer argue that they bought the product in good faith believing the RCD protection was sufficient? The problem of liability isn’t an issue until the unexpected and unfortunate happens.

IronFreely said:

The big question here would be, if following an incident could the installer/designer argue that they bought the product in good faith believing the RCD protection was sufficient?

No, that's not the question.

The question is, whether a court would find that the designer ought to be able to rely on the information provided by the manufacturer (or importer). For this purposes, as I posted previously, the principle of "caveat emptor" would of course apply; however, if the information is on the Declaration of Conformity in pursuance of relevant legislation, I think the legislation itself says that "presume it conforms unless there is reason to believe otherwise" occurs.

Not every one of us in this Forum are legal professionals, so at that point those of us who are not have to "duck out".

It's really complex, because you have cited "no test button" - but the test facility is only required if you are using the product standard for the RCD functionality, which I think we have already agreed is plainly not possible in this case ... so you can't rely on a provision of a standard in respect of "button" vs "self auto test" to determine whether the legislation is met (and also whether it's at least as safe as BS 7671).