Reporting obligation for wallboxes
According to §19 of the Low-Voltage Connection Ordinance (NAV), new systems in Germany must be registered with the responsible utility company or those with capacities above 12 kVA even have to be approved. The obligation to obtain approval applies not only to the construction of new plants, but also to expansions. Depending on local regulations, however, lower outputs may also be subject to notification. In any case, it is advisable to design the planning of the charging infrastructure with a view to the future right from the start and to coordinate this with the grid operator in good time. In this way, you will also find out whether there may be performance restrictions in the local network. In principle, the network operator can accept or reject the application for installation. Charging infrastructure may therefore only be installed once the electrician or end user has received approval. In the case of publicly accessible installations in accordance with the Charging Column Ordinance (LSV), there is also an obligation to notify the regulatory authority.
Publicly accessible charging stations
If the charging device is made public, i.e. accessible to third parties, the installation of the charging point should be reported to the Federal Network Agency (BNetzA) about four weeks before it is put into operation. If rapid charging points are also installed, the technical requirements in accordance with §3 (2) to (4) of the Charging Point Ordinance (LSV) must also be submitted.
"...When quick charging points are installed where alternating current charging is possible, each charging point must be equipped with at least type 2 couplings for reasons of interoperability. When setting up normal and fast charging points where direct current charging is possible, each charging point must be equipped with at least type 2 couplings for reasons of interoperability. Other applicable technical requirements, in particular requirements for the technical safety of energy installations in accordance with § 49 Paragraph 1 of the Energy Industry Act remain unaffected...".
In the event of a change of operator, decommissioning or public access, there is also an immediate obligation to notify the BNetzA, according to the Charging Station Ordinance.
What do I have to consider when "making publicly accessible" a loading device?
- Obligation to report the installation of the charging point about four weeks before use
- Excluded are charging capacities up to max. 3.7 kW
- Immediate obligation to report as soon as the charging point becomes publicly accessible, is taken out of operation or is changed operator
- Obligation to submit additional technical requirements for the establishment of fast loading points (LSV §3 paragraphs 2 to 4)
- Operation display during operation before LSV comes into effect must be reported subsequently
Why do I have to have my charger approved by my network operator?
The ramp-up of electromobility brings with it an increasing increase in load in parts of the low-voltage grid. Without the possibility of control and early detection of potential hazards by the network operator, the network can quickly become overloaded.
A better overview of the existing charging infrastructure, early network expansion and the possibility of controlling charging infrastructure in line with network requirements enable network operators to guarantee network security in the future.
In summary, the NAV thus regulates the relationship between the network operator and the subscriber. If the total rated power is less than 12 kVA (e.g. 11 kW), but more than 3.6 kVA (i.e. charging from 3.7 kW), the charging station is subject to registration in accordance with the Low Voltage Technical Connection Rules (VDE-AR-N 4100), chapter 4.1. If the total rated power is greater than 12 kVA (calculation example follows below), it is also subject to approval.
A summary of the Low Voltage Technical Connection Rules can be found here.
What do I have to consider before installing the loading device?
- Installation check from the electrician for specific installation plans
- Alternative 1: Below 12 kVA total rated power, the charging station must be registered
- Alternative 2: If the total rated power of 12 kVA per electrical system is exceeded, an additional approval requirement applies
- o Ex. 1: the installation of a charging device with 11 kW is only subject to registration
- o Ex. 2: the installation of two charging devices with 11 kW is subject to registration and approval
- Here kVA (kilovolt-ampere) corresponds to the rated apparent power, the conversion factor is cosΦ, the phase shift factor is used (from VDE-AR-N 4100) 0.95 to 1
- 11 kW/0.95=11.58 kVA < 12 kVA therefore only obligation to register
- The submission of the corresponding form to the responsible grid operator (usually by the electrician)
What happens when everything is requested?
- After receipt of the notification, the network operator has two months to respond
- In the event of refusal, the network operator must specify the time frame for possible remedial measures on his part or on the part of the subscriber (freely selectable form of communication)
Both before and after the change in the law, there were and still are sometimes very different reporting regulations on the part of the grid operators - from the approval of 4.6 or 11 kW and above to the general obligation to obtain a permit or even the cancellation of the permit.
This regulation is important so that the grid operator has an overview of which consumers are connected to the grid, can control them in a targeted manner or prepare the grid for electromobility by expanding it accordingly.
What about mobile charging stations?
Whether it is a stationary or mobile charging station is irrelevant for approval (see §19 NAV). There is also a reason for this - it makes no difference to the power grid whether your electric car is charged with 11 kW from a CEE socket or a wallbox. It is important that by reporting the charging station to the network operator, future potentials and risks can be better predicted with regard to the load profile of the low-voltage network. If you do not register your charging station, the effects on the power grid are more difficult to predict. For this reason, VDE AR N 4100, chapter 10.6.4 also states that network operators must be able to interrupt the load.
This can be done by means of a ripple control receiver and power contactor or a ripple control receiver and auxiliary contact in the charging device, thus preventing a widespread power failure in possible future scenarios.
The fact that the reporting of charging infrastructure is not centralised leads to little transparency, no uniformity and many isolated solutions on the part of the network operators with regard to the reporting obligation of charging infrastructure. This bureaucratic approach stands in the way of a rapid expansion of charging infrastructure. Instead, forms would have to be digitised and standardised nationwide in order to significantly shorten the cycles between application and statement.
With over 40,000 charging infrastructure products sold, The Mobility House has many years of expertise in the field of electromobility and charging solutions. The Mobility House experts recommend charging stations that can be controlled by the network operator, such as the KeContact P30 from the charging station manufacturer KEBA. The intelligent Charging and Energy Management system ChargePilot from The Mobility House has interfaces to the network operator, which means that larger charging parks can also be controlled by the network. Further information on the topic of controlled charging and ripple control receivers can be found here.
Do you have questions about your optimal charging solution? Please contact us!