REDII besluit energie vervoer kalenderjaren 2022 2030

Reactie

Vraag1

Ladies and Gentlemen,

due to significant challenges regarding profitable operation of charging infrastructure for battery electric vehicles, I appreciate the implementation of RED2 in the Netherlands. MAHLE chargeBIG developed a centralized large scale affordable and intelligent solution for battery electric vehicle charging. Due to requirements regarding electromagnetic compatibility, we use an advanced energy metering system instead of single MID meters. Our system is compliant with German metering regulation for charging infrastructure (Eichrecht). Due to the positive impact of such solutions I would like to address "Article 10., clause 1b." of the published draft regulation. In general, innovative solutions might not comply with the referenced metrology law, especially regarding MID marking, but will be similar or superior. In this respect I would like to point out "REGULATION (EU) 2019/515 on the mutual recognition of goods lawfully marketed in another Member State". With the common goal of CO2 reduction in mind, and RED2 being a very important vehicle for that, I would like to ask to extend "Article 10., clause 1b" also accepting “equivalent certified solutions complying with EU regulation EN 50470-1/-3 and WELMEC 7.2”
Please find attached a statement of NMi regarding our system.
Sincerely
Sebastian Ewert
Founder and Head of MAHLE chargeBIG

18.12.2020 12:14
chargeBIG metering solution
Today we have had a conversation, in which Mahle presented their chargeBIG metering solution for EV Charging. As indicated, this solution will receive the module B approval conform German law very soon.
We also discussed whether your instrument would fulfill the requirements, as laid down in the Dutch implementation of the new Renewable Energy Directive. Here one of the major requirements is that the instrument needs to meet the requirements for a regulated measuring instrument according to the Dutch Metrology Law.
My view is, that although your instrument doesn’t have an MID approval itself, soon it will have a module B approval conform the German law. Roughly speaking this is at a comparable level. The same harmonised standards (EN 50470-1/-3) and interpretation guides (like WELMEC 7.2) are used, for both the German national approval as well for an MID approval. As I result I think in principle your instrument should meet the stated requirements for the Dutch implementation of the Renewable Energy Directive.

Henri Schouten, NMi Certin B.V.

Bijlage