Earthing is the most technically critical aspect of EV charger installation, and it is governed by two separate regulations that are often run together. They are not the same rule.
| Regulation | What it says |
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| 722.312.2.1 | A circuit supplying charging equipment for electric vehicles shall not include a PEN conductor. On a TN-C-S supply the EV circuit must therefore originate downstream of the point at which the PEN is split into separate protective earth and neutral conductors. |
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| 722.411.4.1 | A PME earthing facility shall not be used as the means of earthing for the protective conductor contact of a charging point located outdoors, or that might reasonably be expected to be used to charge a vehicle located outdoors, unless one of methods (b) to (e) below is used. |
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The underlying problem: in a PME system the earth and neutral are combined in the supply cable as the PEN conductor. If that conductor breaks between the DNO transformer and the property, all metalwork connected to the PME earth can rise towards mains potential relative to true Earth. A person standing outdoors on damp ground while touching the vehicle or charger is directly in that path.
The permitted methods under 722.411.4.1
Method (a) was deleted by BS 7671:2018+A2:2022. Four methods remain, and an open-PEN device is only one of them:
| Method | Requirement |
|---|
| (b) Earth electrode | The main earthing terminal is connected to an installation earth electrode by a protective conductor complying with Regulation 544.1.1. The electrode resistance to Earth must be low enough that the voltage between the main earthing terminal and Earth cannot exceed 70 V RMS during an open-PEN fault. Where buried, that protective conductor must be no smaller than Table 54.1 requires. |
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| (c) Open-PEN device | A device that disconnects the vehicle from the live conductors and from protective earth within 5 s of the CPC-to-Earth voltage exceeding 70 V RMS. It need not operate if the voltage exceeds 70 V for less than 4 s. It must provide isolation, be selected per Table 537.4, and only be resettable once the voltage is back below 70 V RMS. |
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| (d) Voltage window | A device that disconnects within 5 s if the utilisation voltage at the charging point, line to neutral, goes above 253 V or below 207 V RMS. Resettable only once the voltage is back inside 207–253 V RMS. |
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| (e) Equivalent device | An alternative device to (c) or (d) that does not result in a lesser degree of safety. Equivalent functionality may be built into the charging equipment itself. |
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Downstream of a device provided for (c), (d) or (e), the protective conductors and exposed-conductive-parts must have no connection to the protective conductors or exposed-conductive-parts of any circuit not protected by the same device, and no connection to any extraneous-conductive-part.
Table A722 — enhanced disconnection times
Annex A722 is informative. It describes an optional enhanced safety provision in which the device disconnects faster the higher the detected CPC-to-Earth voltage, based on IEC TR 60479-5. These are not the baseline requirement — 722.411.4.1(c) still sets 5 s at 70 V RMS.
Table A722 — maximum disconnection times against the voltage between the circuit protective conductor and Earth| CPC-to-Earth voltage | 70 V | 100 V | 200 V | 400 V |
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| Max disconnection time | 1 s | 0.7 s | 0.2 s | 0.04 s |
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A TT island is not the easy answer
NOTE 3 to Regulation 722.411.4.1 warns that creating a TT earthing system for the charging equipment, or for the whole installation, as an alternative to using a PME earthing facility with one of methods (b) to (e) may not be an appropriate solution — because of the difficulty of providing sufficient separation from buried metalwork connected to the supply PEN conductor. Where you do go down this route, the separation distance has to be justified, not assumed.
Electrical separation — Regulation 722.413.1.2
BS 7671:2018+A4:2026 Regulation 722.413.1.2 limits the protective measure of electrical separation to the supply of one electric vehicle from one unearthed source, supplied through a fixed isolating transformer complying with BS EN 61558-2-4. An example arrangement for supplying a Class I charging point from a separated source is shown in Annex A722, Item A722.5 (Figure A722). Note that isolating transformers can draw high inrush currents, so the primary-side overcurrent device needs selecting accordingly.
For TN-S earthing systems, where the earth and neutral are separate throughout, the open-PEN risk does not arise and the earthing arrangement can be used directly for EV charging without these additional measures. TN-S supplies are far less common in the UK — most domestic supplies are TN-C-S (PME).
In the app
EV charger certificates with open-PEN verification
Elec-Mate's EV charger certificate template includes the open-PEN verification checklist from the IET CoP.