How Measurement and Calibration Law Affects EV Charging Infrastructure

A White Paper Based on the Legal Situation in Germany("Eichrecht")

Table of Contents

1 Executive Summary 
1.1 About the Author
1.2 Acknowledgements
1.3 Your Input Is Appreciated
1.4 Limit of Liability and Disclaimer of Warranty
2 Introduction
3 Legal Bakckground
3.1 Metrology and Calibration Law in General
3.2 The Effect of Legal Regulations on EV Charging Infrastructure and Stakeholders
3.3 Restrictions for Time-Based Billing
3.4 Obligations for Charging Station Manufacturers
3.5 Obligations for Charge Point Operators
3.6 Obligations for E-Mobility Service Providers
3.7 Implications for the B2B Relationship Between CPOs and EMSPs
3.8 Summary – Necessary Setup Between CPO and EMSP
4 A Word on Secure User Identification
5 Interim Solutions for Existing Charging Stations
6 Solutions Compliant With Calibration Law
6.1 Transparency Software
6.2 The ”innogy” Solution
6.3 Storage and Display Module in the Charging Station – SAM
6.4 Further Solutions
7 Available Products on the Market
8 Integration of Digital Signatures in OCPP
9 Certification Programs

Abbreviations

BNetzA Bundesnetzagentur (Federal Network Regulatory Authority)
CPO Charge Point Operator
EMAID E-Mobility Account Identifier
EMSP E-Mobility Service Provider
EnWG Energiewirtschaftsgesetz (Energy Industry Act)
EV Electric Vehicle
EVSEID Electric Vehicle Supply Equipment Identifier
LSV Ladesäulenverordnung (Charging Station Regulation)
MessEG Mess- und Eichgesetz (Measurement and Calibration Law)
MessEV Mess- und Eichverordnung (Measurement and Calibration Regulation)
MID Measuring Instruments Directive
MsbG Messstellenbetriebsgesetz (Metering Point Operation Act)
OCPP Open Charge Point Protocol
PAngV Preisangabenverordnung (Price Indication Regulation)

1 Executive Summary

The complexity surrounding calibration law regulations, commonly referred to as ”Eichrecht”
in Germany, for electric vehicle (EV) charging infrastructure presents new challenges for the
e-mobility industry. This white paper aims to equip major stakeholders – charging station manufacturers, charge point operators (CPO), and e-mobility service providers (EMSP) – with a
background of the current regulatory landscape and legal obligations of each stakeholder, as well
as a framework to establish a transparent and tamper-proof billing process for vehicle owners
using the charging stations.
Overall, the current regulatory landscape has made it harder for stakeholders, with a domino
effect on hotels, fast-food, retail chains and even car dealers, to make a case for investment in
EV charging infrastructure. Recent amendments to the German Measurement and Calibration
Law (MessEG) requires stakeholders to provide accurate measurements around the supply of electricity, time taken to charge an EV, and data security. Recent laws have also come into effect
around time-based billing, where pricing models must be based on kWh instead of a session fee,
which otherwise may result in costly fines if not complied. Yet, monthly or yearly flat rates are
currently still considered valid time-based pricing models.
This white paper breaks down the specific legal obligations of each key stakeholder as described
above according to the following parameters:
■ Meter – including display, supplementary systems such as a computer or smartphone app,
and on-site maintenance.
■ Data Security – including digital signatures, data storage, and access.
■ Invoicing and billing – including tariff components, charging session details, and verification
of the data records’ authenticity and integrity.
Unfortunately, calibration law fails to offer any implementation recommendations to ensure
that charging systems are in compliance. This paper continues to provide a framework for key
stakeholders to implement charging infrastructures that satisfies the regulatory criteria, based on
best practices. This is mapped out in three solutions:
■ Transparency Software – a workflow that allows the customer to verify meter values independent
of time and location without depending on a mobile application.
■ The ”innogy” Solution – a complete system certification with a mobile application.
■ Storage and Display Modules – a memory and display module installed in the charging
station.
Finally, any implementation of the above solutions should be tested and certified by either
the German federal calibration authority Physikalisch-Technische Bundesanstalt (PTB), the VDE
Testing and Certification Institute, or the CSA Group.
Understanding the lay of the land of calibration law and adopting the solutions presented in
this paper will set up stakeholders with a successful EV charging system.

1.1 About the Author

Over the last decade, I have become a recognized expert in the e-mobility space. My accomplishments include co-authoring several international standards and technical specifications, such as ISO 15118-2, ISO 15118-20, Open Charge Point Protocol (OCPP) 2.0.1, and the VDE application guide VDE-AR-E 2802-100-1.
My company V2G Clarity was established in 2016, which partners with companies and research
institutions worldwide to integrate ISO 15118’s promising Plug & Charge feature into their products and innovations – be it through consultancy services, on-site training and online courses, or the ISO 15118 Manual. I also help companies around the globe reduce the effort of implementing ISO 15118-compliant solutions with the widely-used open-source implementation of ISO 15118, called RISE V2G.
ISO 15118 is a communication standard that governs the charging and billing process of EVs,
with a focus on data security. I strive to break down the complexity of this standard and promote
the convenience, security, and ease-of-use of electric vehicle charging to a global audience. ISO
15118 is in large part a small fraction of the value chain of charging and billing EVs, which
sparked a need for me to expand V2G Clarity’s expertise beyond ISO 15118 to cover the OCPP
2.0.1 communication protocol applied between charging stations and IT backends; as well as the
effects of the German measurement and calibration law on EV charging infrastructure.

1.2 Acknowledgements

The information presented in this white paper is primarily based on the work provided by
has·to·be and Smatrics. Both companies released insightful white papers on calibration law
for EV-charging infrastructure. These white papers are only available in German but they cover
fundamentally important knowledge about a legal matter that will soon affect many countries
worldwide. With this in mind, it seemed of utmost importance to offer this information in English
to expand the audience and availability of this content.
Specifically, the following resources were taken into account:
■ has·to·be white paper ”Eichrechtskonforme Ladeinfrastrukturen”
■ has·to·be Support Center with a Q&A section regarding calibration law
■ Smatrics white paper ”E-Mobilität und Eichrecht (Teil 2)”
I would like to express my gratitude for the two reviewers, Dr. Katharina Vera Boesche and
Martin Klässner, as they both contributed significantly to the quality and accuracy of this paper.
Dr. Boesche is a lawyer and renowned legal expert in the e-mobility industry. She is currently
head of the Section for Regulation and Regulatory Economics as part of the German federal
funding program “ICT for Electric Mobility II”.
Mr. Klässner is CEO of has·to·be, a leading service provider for transactions in the energy
industry and e-mobility sector. His company’s product,