Themenserie eichrechtskonformes Laden: Wie Hotelbetreiber und Anbieter von Ferienunterkünften Ladestrom abrechnen können

The basic hardware and software requirements for calibration laws have already been presented in detail in the introduction of the series. For existing stations that don’t yet have the necessary measurement systems, the operator must submit a specific, customised retrofitting plan to the responsible national calibration authority.

However, there are also charging stations that are not subject to the calibration requirements, for example when the electricity is given away for free at the station or is charged according to a flat rate. There are more exceptions and pitfalls in the multitude of different charging scenarios, which we will go into in depth in this multi-part series. In the third part of our series, we explain to hotel operators and providers of holiday apartments and condominiums how they can bill their guests for charging their electric cars in a legally compliant way.


Guests charging at a hotel

If publicly accessible charging infrastructure is built at a hotel, all the requirements of the charging station ordinance and the calibration laws apply if charging there requires payment. Legal calibration-compliant charging stations are also required in exclusive, closed off parking spaces for hotel guests if the electricity must be paid for. A presumably simple solution such as a daily flat rate for the use of a charging station is not permissible, because that is not consistent with the Price Indication Ordinance. This ordinance only allows flat rates on a monthly or yearly basis.

It would be permitted, however, to require a fee for the parking space and to provide the electricity for electric cars free of charge. The fees for using the parking spaces for electric cars could however not be any more expensive than those for conventional vehicles.

If a hotel guest is there on business however, that is a B2B relationship. In these circumstances, a session fee (a set fee per charging session) would also be an option, explains attorney Dr. Katharina Vera Boesche, head of the Legal group “IKT für Elektromobilität” (IKT for Electric Mobility), a research and technology programme funded by the German Federal Ministry for Economic Affairs and Energy (BMWi).

Learn more about our charging solutions, which are specially tailored to the needs of hotels.

Holiday houses and apartments

Even exclusive parking spaces in holiday houses and apartments require a charging system that is compliant with calibration law if the electricity needs to be invoiced. “However, the requirements for direct sales may be fulfilled if the operator of the charging station and the consumer, in this case the renter of the holiday home, acknowledge the measurement result of an MID-certified electricity meter at the end of the stay. Then this solution would be sufficient,” says Boesche. An appropriate fee would then be paid for each kilowatt hour of electricity consumed.

The simplest option for hotels and providers of holiday accommodations is to provide the electricity for free as part of the rental fee where possible, as is done for hairdryers, electric kettles and lights. Then there wouldn’t be any need for the effort and additional costs involved in setting up and operating charging facilities that are compliant with calibration law. In addition, the facility would then be more interesting for the steadily rising number of electric car drivers. In the end, this solution may even be cheaper in general, especially for smaller operators. The electricity needed to drive 100 kilometres in an electric car actually only costs an average of only about €5-6.

In Part 1 of our series, we deal with the topic of charging company cars at work and at home as well as at charging stations on company premises. In Part 2 of our series, apartment owners, homeowner associations and real estate companies will learn everything they need to observe to provide legally compliant charging.

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