Amending the Measuring Instruments Directive

As an association that focuses on electromobility law, INSPIRE e.V. welcome the EU Commission's draft amendment to Directive 2014/32/EU with regard to charging points for electric vehicles in Annexes I and Va. We welcome the important step towards further standardisation of European calibration law with implications for AC and DC charging infrastructure.

Having reviewed the new proposal draft, we appreciate that many of our previous recommendations have been incorporated. However, we believe that further clarification on certain points could be beneficial. Remote Displays vs. Remote User Interfaces The term remote display appears frequently but remains ambiguous.

We are in favour of the proposal for a targeted amendment of the Measuring Instruments Directive (MID) as it would support the European Single Market. We therefore would welcome the adoption of the proposal. We would like to highlight the following points: Cable Replacement: We support a flexible approach that allows replacement without unnecessary re-verification.

Acting as a utility, aggregator and charge point operator, the EDF Group welcomes this technical update of the Measuring Instrument Directive in order to notably introduce harmonized requirements for EV charging stations. We have made some comments (mainly asks for clarification/definitions) and proposals for improvements in the attached file. They cover annexes I, III, IV.

VDE FNN is the body to set application rules and specifications for network operations in Germany. With a network of 450+ experts across the industry, we are the voice of manufacturers, operators and other relevant stakeholders in the German energy sector. We appreciate the progress in updating this essential regulation according to future industry needs.

Měřicí přístroje – technická aktualizace předpisů EU Připomínky HK ČR Hospodářská komora ČR vítá možnost vyjádřit se k Návrhu směrnice – COM (2024) 561 týkající se měřicích přístrojů – technická aktualizace předpisů EU a níže předkládá připomínky členů.

Filed in Czech · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CECAPI, the European coordinating committee representing the Associations of Manufacturers of Electrical Installation Equipment, would like to submit the following comments to the Public Consultation to harmonize metrology requirements for electric vehicle charging stations and hydrogen refilling stations.

The Austrian Federal Economic Chamber recognizes the importance of standardization regarding electrical-vehicle charging infrastructure, hydrogen refilling infrastructure and smart electricity and gas meters. In order to keep costs as low as possible and legal certainty as high as possible for economic operators, the regulations should only apply to new systems.

Hager Group welcomes the revision proposal of the measuring instrument directive to adapt them to current markets and technologic needs and consequently to avoid national regulations which acts against a well functioning single market.

EPTA, the European Power Tool Association represents 24 European manufacturers of electrical power tools with a strong production base in central Europe. Our members represent approximately 70.000 employees in Europe (170.000 worldwide) and around 90% of corded and cordless power tool sales in Europe (by value).

E.DSO welcomes the Commissions proposal and recognises the need for a technical update to the MID that addresses modern smart metering and EV supply equipment. However, we believe the proposal could benefit from additional clarifications and more balanced transitional measures.

ZVEI Statement Proposal for a directive of the European Parliament and of the Council amending Directive 2014/32/EU as regards electric vehicle supply equipment, compressed gas dispensers, and electricity, gas and thermal energy meters COM(2024)561 We have summarized below our comments on the proposed amendment made through the text COM(2024)561 and its annexes.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Firstly, we would like to thank the European Commission for the important work, support and cooperation to date on the electrification of the mobility sector. In brief, we support the proposed Annex Va on measuring systems for electric vehicle supply equipment. We greatly appreciate herein the opportunity to provide our feedback through the Have Your Say portal.

1. ("Regarding definitions, 3rd paragraph: 'Measurement system for supply equipment for electric vehicles...') Is this really a necessary definition? Will it cause a need for further requirements? if not delete "also" and or make it a note. _____ 2.

A specific comment: For the successful implementation of the revised Directive Proposal into practice, the Directive should not introduce retroactivity to existing charging infrastructure. At the same time, the obligation for MID certification should be established from a certain date in the future for all "newly manufactured" charging station, not for charging stations that have not yet been sold.

EVVE welcomes the proposal to amend the Measuring Instruments Directive to better reflect the technological evolution of measuring instruments essential for achieving the objectives of the European Green Deal. In particular, we support the proposed technical adjustments to Annex IV.

AEDIVE, Spanish Cluster for emobility (250 companies are members of AEDIVE) welcomes the work of the proposal of the European Commission for a Directive amending Dir 2014/32/EU as regards electric vehicle supply equipment, compressed gas dispensers, and electricity, gas and thermal energy meters commonly referred as the Measuring Instruments Directive (MID).

E-Mobility Europe (formerly AVERE), welcomes the work of the proposal of the European Commission for a Directive amending Dir 2014/32/EU as regards electric vehicle supply equipment, compressed gas dispensers, and electricity, gas and thermal energy meters commonly referred as the Measuring Instruments Directive (MID).

ChargeUp Europe welcomes the European Commissions proposal for targeted amendments to the Measuring Instrument Directive (Directive 2014/32/EU). If consistently and uniformly implemented by EU member states, the revised Directive would harmonize requirements for metering instruments of EV charging stations across the EU, ending fragmentation due to differing national rules and requirements, strengthening the Single…

Dear Policymakers, As a Belgian tech company driving the transition to electrification, we provide a highly scalable and innovative fleet charge cost management solution that is fully agnostic of the EVSE used. We welcome the proposed revisions to the Measuring Instruments Directive (MID) and appreciate the opportunity to contribute.

Ladies and Gentlemen, in order not to jeopardise compliance with Annex I, Clause 8.2 of the MID, I propose that the text in Annex Va, Clause 4, point (b) be expanded as follows: "if those parts are intended to be replaceable while the measuring system for EVSE is under seal, ensure, that they are: identified in the type approval certificate as replaceable; marked with information about the cable characteristics…

Hello, as representatives of European industry and specifically manufacturers of electrical equipment, we warmly welcome the proposal of MID targeted amendment. We particularly support updates to electric vehicle chargers and thank the Commission for including some of industry feedback to the consultation process.

We appreciate the opportunity to comment on the proposal for the Measuring Instruments Directive COM(2024) 561 final (hereinafter also referred to as the proposal) and state the following: Regarding electricity meters, we believe that the requirement in section 10.5 of Annex I of the MID to equip the electricity meter with an integrated display is not necessary in locations where smart metering is used.

bev.gv.at Bundesamt für Eich- und Vermessungswesen Abt. Präs/1 - Recht und allgemeine Verwaltung BMAW Abt. VI/4 Metrologie, Vermessung, Geoinformation Stubenring 1 1010 Wien Mag. [name removed] [email removed] [phone removed] Schiffamtsgasse 1-3, 1020 Wien UID: ATU384 732 00 IBAN: [bank details removed] BIC: BUNDATWW Geschäftszahl: 2024-0.918.876 2024-0.889.230-2-A - Maß- und Eichgesetz, Arbeitsgruppe für…

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The VDDW welcomes the inclusion of cooling meters in the scope of the MI-004 Thermal Energy Meter. This will be beneficial for industry by reducing the double certification burden and for consumers by avoiding unnecessary costs. The VDDW expresses concerns about the extension of the scope of legal metrology from the current generation of measured values to the repetition of measured values.

Filed in German · English published by the European Commission

Netbeheer Nederlands welcomes the long awaited amendement of the MID. However, the new article 10.6 in Annex I is not fully clear or confusing. The wording "By way of derogation from points 10.1. and 10.5" leads us to asume that a physical display on the measuring instrument is no longer mandatory if either solution a or b as described in article 10.6 is implemented.

Tesla Europe strongly supports harmonization of requirements for recharging points under the Measuring Instruments Directive (MID). Currently, the lack of unified metering standards across the EU has resulted in inconsistent national laws and market fragmentation, undermining the single market.

Elia Group, encompassing electricity transmission system operators Elia (Belgium) and 50Hertz (Germany), welcomes the Commission's proposal for amending the Measurement Instrument Directive (MID) proposed by the Commission. This update is critical for enhancing access to data from both smart meters and behind-the-meter assets, which is essential for consumers, market players and system operators.

Opinion on amendment MsbG, here: §30-35/§6 MsbG in conjunction with §5 or § 12 HeizkV basically welcome the fact that the draft makes more predictable into the business model. However, there are no fundamental aspects which, on the one hand, strengthen the necessary role of the wMSB. The complexity of implementation should also be minimised.

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2025-02-26 Pág. 1 de 2 Comments on the Proposal for a Directive amending Directive 2014/32/EU as regards electric vehicle supply equipment, compressed gas dispensers, and electricity, gas and thermal energy meters and its Annexes Comments on the text of the Proposal for a Directive amending Directive 2014/32/EU Articles 2 and 3 Timeline for the application of the revised Directive To facilitate industry adaptation…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Enel Group welcomes the proposal to amend the current Measuring Instrument Directive-MID to cover the evolving needs of the energy sector in line with the objectives of the European Green Deal. Our company would like to share some improvements to the current text to increase regulatory certainty.

Alfen supports the European Commission's proposal to amend Directive 2014/32/EU, known as the Measuring Instruments Directive (MID), regarding electric vehicle supply equipment, compressed gas dispensers, and electricity, gas, and thermal energy meters.

The Cyber-Complex Foundation, as a non-governmental specialised organisation, would like to draw the Commission’s attention to the proposed entry in the Annex to the Proposal for a Directive of the European Parliament and of the Council amending Directive 2014/32/EU as regards charging infrastructure for electric vehicles, compressed gas meters and electricity meters, gas meters and heat meters. Annex I, point 10.6.

Filed in Polish · English published by the European Commission

EnBW AG (Energie Baden-Württemberg AG) is part of the ongoing research project "ChaNGe (Inductive Charging - Next Generation)", funded by the German government. One of the goals of this project is to measure the losses to enable public charging with billing for wireless charging, from which we expect a market breakthrough soon.

PTPiREE is an association of the largest Polish distribution system operators, which together own more than 19 million electricity meters. We would like to draw the Commission’s attention to some of the draft provisions in the Annexes to the Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directive 2014/32/EU as regards charging infrastructure for electric vehicles, compressed gas…

Filed in Polish · English published by the European Commission

AQUA Metering welcomes the integration of cooling meter to the scope of MI-004 Thermal Energy Meters. This will be beneficial for the industry by reducing double certification efforts and beneficital for consumers by reducing unnecessary cost.

Caruna welcomes the Commissions (EC) proposal to update the Measuring Instruments Directive (MID) to match the latest technological developments. As a DSO, we own and operate our customers smart electricity meters and see that advancing the smart meter roll-out should be a priority.

- LEM appreciates the attempt to make sure that the MID fosters innovation and promotes the implementation of the twin transition. In the proposed technical amendment to Directive 2014/32/EU, LEM welcomes the clear statement that DC as well as remote displays are well within the scope of the MID.

BRUSA is a manufacturer of inductive charging systems for electric vehicles. Our system is currently being prepared for public charging, hence the recast of MID is directly impacting our product. We strongly support the allowance of using a remote display to indicate the measurement results, as proposed for MID Annex I, 10.6. (b).

We are concerned about the wording of the transitional arrangements for existing national certificates in article 2 of the proposal. Article 2 states "national certificates, covering measuring instruments that fall in the scope of 2014/32/EU from ... and that have been placed on the market before...((application date))..., shall remain valid until..." .

This and the previous call for evidence suggest that the amendment was technical and limited in scope. Manufacturers and users of other instruments are made to mistakenly believe that they were not affected. For instance, the absence of feedback should not be read as restaurants accept the ban on drinking glasses, fundamentally changing the centuries-old and well-accepted modalities of their business.

The measuring guidelines/regulation should also be applicable on time registration devices for charging infrastructure. There are many situations where end user cost is also based on a time component. At this moment there is no guarantee at all that that measuring is done correct. At least the registration device (clock) should be certified.

Detailled comments are made into the here attached pdf file. Those concerns elements identified in the following areas: Appendix I - We reccomend to add the Water and Heat meter to take full advantage of the digitalization standardization work ongoing which would benefit from the MID amendment alignement.

The Directive 2014/32/EU on measuring instruments (the Measuring Instruments Directive, or MID) was adopted in 2014 to replace Directive 2004/22/EC and seeks to harmonise various types of measuring instruments across the EU. However, its scope and associated essential requirements have remained almost unchanged for more than 20 years.

Technical aspect: the biggest problem is if it is required retroactively even for states that simply don't have it. There it is no longer a question of economics, but rather of feasibility (and meaningfulness). Economic aspect: based on the price offer, we have information that an electricity meter with MID certification costs over EUR 5.000 for 2 inputs (ie 1 station with 2 cables). But that's not all.

Hager group welcomes a targeted revision of the measuring instrument directive to adapt them to current markets and technologic needs and consequently to avoid national regulations which acts against a well functioning single market.

BEUC, the European Consumer Organisation, welcomes this initiative. The issues mentioned in the call for evidence directly affects consumers, especially when it comes to (public) charging stations for electric vehicles.

Good day, As manufacturer of flow meters that are intended for gas metering and compressed gas mobility applications, we embrace the initiative of the EU to extend the MID directive. Please find the response of Emerson to the call for evidence in the file attached. Please feel free to get in touch if there are any questions. Good luck with the next steps in this process, Maarten Brugman Emerson Measurement Solutions

Enedis delivers electricity to more than 38 million consumers, covering 95% of the French metropolitan territory through the deployment of more than 37 million smart meters. By the end of 2023, 1,8 million EV charging points were directly or indirectly connected to the French public distribution grid. We have therefore become an important data operator over the years.

ChargeUp Europe welcomes the targeted technical amendment of the MID to update and expand its scope and the annexes setting technical requirements of measuring instruments to the EV charging infrastructure. As recognised by the European Commission in the call for evidence, the current MID is unfit to keep up with the technological progress that occurred in the last decades as it covers mainly smart metering and i)…

VDE FNN is the body to set application rules and specifications for network operations in Germany. With a network of 450+ experts across the industry, we are the voice of manufacturers, operators and other relevant stakeholders in the German energy sector. We welcome the Commissions initiative to update the MID.

We support clear, transparent, correct, reliable and understandable information and measurement results for the EV driver. We also support a good single EU market. We see unified standards for metering across Europe as very important. The risk that every country would define its own standard for metering is a nightmare for manufacturers and operators.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

To whom it may concern Please find attached our evidence and proposal on the initiative for the technical update EU rules on measuring instruments for electric mobility charging stations and smart meters. Best regards [name removed] (CTO, decsarbon1ze GmbH)

As a Charge Point Operator (CPO) in the electric vehicle (EV) charging sector. We support the goal of harmonizing metering standards across the EU, as it is essential for the consistent and efficient scaling of EV charging infrastructure. However, we believe it is crucial that the standardization process leads to both cost reductions and simplified technical requirements.

Zaptec Charger AS support unified regulatory framework to ensure fair competition, enhances consumer protection, and foster innovation across member states. Where the directive lack requirement for specific metrology principle, we see the need for fast update to cover these.

Comments on the Call for Data for the MAD initiative: specific technical update of EU legislation. AFME supports the start of the update of the MID Directive to update its wording to incorporate harmonised essential requirements for measuring systems of electric vehicle supply equipment (charging stations for electric vehicles).

Filed in Spanish · English published by the European Commission

ZVEI statement Measuring instruments – technical update of EU rules Key comments from the perspective of the electrical and digital industry The MID should remain as stable as it is today and demand more clarification of the current MID across countries! ZVEI proposes that it should be an optional provision if the meter may or may not have a display.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dear Sir/Madam, please find enclosed the opinion of the S.A.F.E. e.V on the update of the MID. If you have any further questions, please do not hesitate to contact us. Dr [name removed] Director of [email removed] S.A.F.E. e.V. Association for the promotion of research and consumer protection in the field of electromobility Karl-Marx-Allee 71 10243 Berlin

Filed in German · English published by the European Commission

Thank you for the opportunity to express our opinion. Electric Vehicle Supply Equipment (EVSE) is not just a component but a crucial enabler in the transition from fossil fuel vehicles to electric vehicles (EVs). It is the backbone that supports the necessary charging infrastructure.

The Charging Industry is welcoming adaptation of MID to better reflect electric vehicle charging stations and DC metering in particular. It is necessary to bring certainty and stability to the EV charging industry. Especially, the proposed approach to cable swapping is very much appreciated as a pragmatic and reasonable way to allow the necessary repair of cables. Please find further comments in the attached file.

As an association focusing on the right of electromobility, INSPIRE warmly welcomes DG GROW’s intention to further harmonise European calibration law with implications for AC and DC charging infrastructure (EVSE). It is essential that the roll-out of calibration-compliant charging infrastructure takes place in a uniform manner across Europe. This is also in the interest of vehicle users who move across borders.

Filed in German · English published by the European Commission

LEM TECH FRANCE (being part of the LEM Group) fully supports the feedback from Agentur für Messwertqualität und Innovation e.V. (F3497056). In the current regulation tendencies regarding energy meters for E-mobility in the EU, we see everything from gold plating of standards (like additional EMC requirements that are most probably useless) over watering down basic metrology requirements that are proven since many…

I was participating to the standardisation in CENELEC of the Energy Metering System on board of trains which resulted in the EN 50463 series. As Chair of the Italian National Committee CEI CT 9, which deals with the railway field, and in my position of Techical Advisor of the Italian Railway Industries Association,I received observations from the users of the herein above referred series of norms.

DEFA AS supports harmonised technical requirements, in principle, but is concerned about the implementation. We urge the EC not to propose detailed and technology-specific requirements for EVSE, as we believe this could have negative effects on harmonization, development, and the green transition. DEFA AS supports Norwegian Metrology Service /Justervesenet (Norway) response.

We at EU DSO Entity appreciate the initiative to update the MID. To unlock the full potential of smart metering technology it is essential to adjust technical requirements for metering devices, moving from a device-centric to a holistic view of metering as an entire system environment.

Add in Annex V: Electrical energy meters, including railway meters, for both active and reactive energy measurements. CENELEC has published a standard on this subject, which is called: EN50463: 2017 consisting of 5 parts. I have this comment as the Convenor of the CLC TC9X WG11 working group that has produced this standard and is also transferring it to IEC

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We fully support the position of Agentur für Messwertqualität und Innovation. The initiative is detrimental to the implementation of the fit for 55 goals. It is neither targeted nor technical. At present, MID is world renowned for being the open to technical progress while guaranteeing a very high level of consumer protection and confidence. The reason is the limitation to performance requirements.

VSL Thijsseweg 11 2629 JA Delft The Netherlands European Commission Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs - H.2 Machinery and Equipment Your reference Our reference Date 18/10/2024 Subject Response to the call for evidence for the initiative “Measuring instruments – targeted technical update of EU rules” Dear Sir / Madam, As the National Metrology Institute of the Netherlands…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dealing with smart meters in the EU Directive MID Dr. Pavel Klenovský, Czech Metrology Institute (CMI) This comment to the targeted amendment of the EU MID, being now processed at the EU level, is basically meant to address the situation of smart electrical energy meters, however it can be extended to cover all the smart meters.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Equans Infra and Mobility B.V. is a leading player in the Dutch e-mobility sector with a focus on operating and managing charging infrastructure for electric vehicles. With more than 15.000 charging stations in the Netherlands, we are actively working on the energy transition and improving future charging solutions.

Filed in Dutch · English published by the European Commission

Our company CESAME-EXADEBIT is a calibration and mandatory verification service provider in the field of gas flow metering, a metrological institute by delegation for this field by LNE the french National Metrology Institute, and also a partner of the European Network Metrology (EMN) Energy Gases of Euramet, the European association of National Metrology Institutes.

Charge Amps AB supports the efforts to harmonize the requirements for MID in charging stations. However, this must be done with caution to avoid increasing costs for end customers and to encourage innovation while maintaining the original goals of accuracy and preventing tampering with measurements.

Dear Sir, Madam, We support an EU-wide single scheme for smart meters and e-mobility charging infrastructure, as well as the rules related to hydrogen metering. However, the proposed changes in the area of smart meters are not sufficient to achieve the planned objectives of the revision of the MID and to further modernise electricity meters. The MID only applies to active energy.

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The Austrian Federal Economic Chamber recognizes the importance of standardization regarding electrical-vehicle charging infrastructure, hydrogen refilling infrastructure and smart electricity and gas meters. In our opinion therefore it would be essential for such an undertaking to carry out a valid impact assessment in advance to present the possible effects for all stakeholders.

Caruna welcomes the Commissions plans for a technical update on the Measuring Instruments Directive to match the latest technological developments for the clean transition. Caruna agrees with the EC that the current MID is not fit for purpose when it comes to technological progress. We agree with the EC that the role of smart metering is crucial when considering well-functioning electricity markets.

The proposal is sure to have substantial and unintended, very harmful side effects. It will adversely affect European manufacturers, users of measuring instruments and consumers. It will further slow down the roll out of smart grids and EV charging infrastructure, and reduce consumer protection, thereby harming the "fit for 55" goals. It must not be implemented without impact assessment and cost benefit analysis.

In relation with EVCS . For EVCS harmonized regulation, we believe that due to the specifically a separate annex should be developed. With this aim in the year 2021 the EURAMET Project LegalEVchrage was created with the participation of several NMIs, included CEM, fully interested in this matter.

Měřidla – technická aktualizace pravidel EU (MID) – připomínky Hospodářské komory ČR Hospodářská komora vítá možnost vyjádřit se k výzvě k předložení informací týkající se měřidel – technická aktualizace pravidel EU (MID). Níže posílá připomínky členů: Připomínky: • • • • • • V materiálu se jedná o pokračování již běžící aktivity z předchozího volebního období Europarlamentu.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

GraphDefined is a small Open Source software and consulting company specializing in complex, interconnected, and often regulated data exchange. As such, we see numerous opportunities to enhance the current declarative framework of the Measuring Instruments Directive (MID).

This amendment, which introduces harmonised metrology requirements for electric vehicle charging stations and hydrogen charging stations, is highly appreciated and also updates the requirements for smart meters for public services (e.g. gas and electricity meters). In this regard, Endesa attached comments for consideration by the European Commission itself.

Filed in Spanish · English published by the European Commission

Dear Metrology team at the EU Commission (WgMI), UTU Oy is a Finnish company operating in Nordic EV charging market. We develop, manufacture and sell AC charging product portfolio especially for condominiums and SME companies.

AQUA is the Association of European Manufacturers of smart water and thermal energy meters. AQUAs 16 members are constantly investing in new technologies to meet industry needs for more frequent and accurate measurement information. Ten countries are represented in AQUA, out of 27 EU members.

To: European Commission Directorate-General Internal Market, Industry, Entrepreneurship and SMEs H.2 Machinery and Equipment From: The Norwegian Metrology Service Date: October 14 2024 The position of The Norwegian Metrology Service on the call for evidence Measuring instruments – targedted technical update of EU rules The Norwegian Metrology Service support harmonization of metrological regulation contributing the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Europäische Kommission GROW H2 Zsuzsanna Dákai Per E-Mail: Duisburg, den 14.10.2024 Bü/Hi Stellungnahme zur beabsichtigten technischen Aktualisierung der MID Sehr geehrte Damen und Herren, Sehr geehrte Frau Dákai wir sind als spezialisierte Rechtsanwaltskanzlei in Deutschland insbesondere im Bereich des Umweltund Technikrechts tätig und beraten unter anderem verschiedene Mandanten zu Fragen des Messund Eichrechts…

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please find in the attached file the Position of the german national committee DKE/K461 Messeinrichtungen und -systeme für Elektrizität (("Measuring devices and systems for electricity") of the DKE (German Commission for Electrical, Electronic and Information Technologies) at DIN and VDE.) regarding the Measuring Instruments Directive Targeted Technical Amendment.

When initiating a technical amendment to the Measuring Instruments Directive, not only road vehicles but also rail, shipping and aviation vehicles must be taken into account in the context of a vehicle refuelling infrastructure. In addition, the transport of compressed gases using trailers and other mobile means of transport must also be taken into account.

The Hessen Eichdirektion is responsible for the implementation of the Measuring Instruments Directive in the federal state of Hessen, Germany. We have noticed that both industry and enforcement are problematic if there are different legal requirements for measuring hydrogen.

Filed in German · English published by the European Commission

Adjusting the MID 2014/32/EU to add the relevant annexes for EV charging and H2 for mobility is a common-sense step to future. It will not only narrow and reduce unfair competition between retailers (especially close to borders between two EU member states), but it will simplify business as cost of distributing equipment (EV chargers or H2 dispensers) will not have unwanted/unfair/unexplainable burden differences on…

1.Definitions: Gas meter: Gas meters dont measure energy. The output of a gas meter is volume or mass and afterwards the energy converter device calculates the energy. 2.Part III: - The calorific determining device: > Either is locally installed and sends signal to Energy Conversion Device Cancel the word directly because in some cases a converter or a verification system has to be installed.

Please take the ‘EICHRECHT’ rules as a basis for the ‘EICHRECHT’. All hardware with MID meters from various manufacturers in Europe have now been built on these rules. Once again, additional regulation and possibly new requirements are slowing down the rollout of charging infrastructure.

Filed in Dutch · English published by the European Commission

As BBNM e.V. ("Federal Counselling Association new Mobility r.A.") we are primarily involved in the topic of charging infrastructure for electromobility in conjunction with renewable energies (photovoltaics, SmartHome, ...). We see a great need in metering not only to record data, but also to merge processes digitally and in a legally compliant manner.

Firstly, BE felt it was a pity that the Member States had not been able to have access to the text of the proposal. BE therefore sent its comments on the general presentation of the content of the amendment to the MID of 9 September 2024. The comments are based on the elements provided during this presentation, as it was not possible to analyse the text of the proposal in more depth.

The EVRoaming Foundation supports accessibility of charging infrastructures, including clear, transparent, correct, reliable and understandable information towards the EV driver. We also support a good open market. For both standards are important. We see unified standards for metering across Europe as very important step in this.

Tesla Europe supports and welcomes the idea of harmonized requirements for recharging points under MID, as long as the aim is to make national legislation redundant: the absence of harmonised requirements for metering solutions for recharging points leads to diverging national legislation and a fragmentation of the single market and shall therefore be converged with national legislations.

Easee ASA shares the support for harmonised technical requirements, in principle, but is concerned about the implementation. A fragmented market is preferable to the implementation of making compliance everywhere similar, but stricter. That would lead to a barrier to entry for new innovative companies, worse and more expensive products for consumers, and ultimately delaying the green transition.

While I understand the desire for a streamlined regulatory framework, I believe that separate rules for measuring systems in electrical-vehicle supply equipment could ultimately hinder innovation and market competition. If electrical-vehicle supply equipment could utilize meters approved according to Annex V, it would significantly reduce the regulatory burden for manufacturers.