EVSE

[Bill Snyder]

The code language says nothing of the sort. The language in 625.54 does not talk about hard wired equipment. It very simply says that if you install a receptacle to supply EV equipment that receptacle must have GFCI protection.

Once again the code does not require GFCI protection for EV equipment installed inside as long as it is hard wired. However as soon as you supply the EV equipment outside at a one or two family dwelling unit, on a circuit rated 50 amps or less GFCI protection is required. Nothing in Article 625 modifies the requirement in 210.8(F). Nothing in UL 2202 says that the equipment must not be supplied via a GFCI.

Nothing in any manufacturer's instruction or product listing standard can delete a requirement of the NEC.

Manufacturer instructions would be required to mention all the areas listed in the 2023 language where does it say GFCI protection not required if hardwired in only dry locations? I missed that reference.

 

[don_resqcapt19]

Manufacturer instructions would be required to mention all the areas listed in the 2023 language where does it say GFCI protection not required if hardwired in only dry locations? I missed that reference.

Again, nothing in the manufacture's instructions can delete a code requirement. Changes in code requirements can only be made via the code making process.

You are again mixing and matching code requirements to suit your agenda. The code language does not says that the EV charging equipment does not require GFCI in dry locations. There is a specific requirement, in 625.54, that requires cord and plug connected equipment to have GFCI protection. That means that, in general, hard wired EV equipment does not require GFCI protection. However there is another very specific requirement in 210.8(F) that will require EV equipment, supplied from a circuit rated 50 amps of less, and installed outside of a one or two family dwelling unit, to have GFCI protection.

Those are both very specific rules and do not interact with each other in any way.

 

[Dennis Alwon]

Manufacturer instructions would be required to mention all the areas listed in the 2023 language where does it say GFCI protection not required if hardwired in only dry locations? I missed that reference.

It doesn't say that per se. 210.8(F) states outdoor outlets 50 amps or less and single phase shall be gfci protected. So with or without a receptacle it needs gfci.

Inside a garage would not be under 210.8(F) but just 210.8. Now they are using the term receptacle so if the unit is hardwired then this section does not apply

(A) Dwelling Units.
All 125-volt through 250-volt receptacles installed in the locations specified in 210.8(A)(1) through (A)⁠(11) and supplied by single-phase branch circuits rated 150 volts or less to ground shall have ground-fault circuit-interrupter protection for personnel.

210.8(F) Outdoor Outlets.
All outdoor outlets for dwellings, other than those covered in 210.8(A)(3), Exception to (3), that are supplied by single-phase branch circuits rated 150 volts to ground or less, 50 amperes or less, shall have ground-fault circuit-interrupter protection for personnel.
Exception No. 1:
Ground-fault circuit-interrupter protection shall not be required on lighting outlets other than those covered in 210.8(C).
Exception No. 2:
Ground-fault circuit-interrupter protection shall not be required for listed HVAC equipment. This exception shall expire September 1, 2026.

 

[sgtsparky]

(1) If it is cord and plug connected, then yes per 2020 NEC 625.54. If it is hard-wired and installed outdoors at a dwelling unit on a branch circuit rated 50A or less, then yes per 2020 NEC 210.8(F). [I guess if you installed an isolation transformer at the dwelling unit to create a 2-wire 240V or 208V SDS, then you could supply an outdoor EVSE with the resulting circuit and not need GFCI protection.]

(2) Manufacturer's instructions never overrule the NEC. If the NEC requires X and the instructions say "do not do X" then the instructions are telling you not to install the equipment in jurisdictions subject to the NEC.

Cheers, Wayne

I would disagree #2 , 110.3? States the mfg instructions for listed equipment SHAll be used.
Many times I showed the UL listing and the instructions then the inspector approved

 

[Bill Snyder]

Again, nothing in the manufacture's instructions can delete a code requirement. Changes in code requirements can only be made via the code making process.

You are again mixing and matching code requirements to suit your agenda. The code language does not says that the EV charging equipment does not require GFCI in dry locations. There is a specific requirement, in 625.54, that requires cord and plug connected equipment to have GFCI protection. That means that, in general, hard wired EV equipment does not require GFCI protection. However there is another very specific requirement in 210.8(F) that will require EV equipment, supplied from a circuit rated 50 amps of less, and installed outside of a one or two family dwelling unit, to have GFCI protection.

Those are both very specific rules and do not interact with each other in any way.

IMHO 625.54 modifies chapter 2 and if CMP-12 says their equipment does not require class A protection when hardwired that would reign true regardless of location and the one I just installed all I had to show the AHJ was the manufacturer instructions and it passed so at least this false narrative of interpretation has not went very far.

 

[Bill Snyder]

It doesn't say that per se. 210.8(F) states outdoor outlets 50 amps or less and single phase shall be gfci protected. So with or without a receptacle it needs gfci.

Inside a garage would not be under 210.8(F) but just 210.8. Now they are using the term receptacle so if the unit is hardwired then this section does not apply

I am going to submit a public input that says the EGC can be used as a neutral and no EGC is required to be installed on hardwired equipment as long as Class A protection is installed because that was the substantiation for passing 210.8(F).

 

[wwhitney]

IMHO 625.54 modifies chapter 2 and if CMP-12 says their equipment does not require class A protection when hardwired that would reign true regardless of location

I agree with that hypothetical. But nothing in Article 625 says that EVSEs shall "not require class A protection when hardwired."

Cheers, Wayne

 

[don_resqcapt19]

IMHO 625.54 modifies chapter 2 and if CMP-12 says their equipment does not require class A protection when hardwired that would reign true regardless of location and the one I just installed all I had to show the AHJ was the manufacturer instructions and it passed so at least this false narrative of interpretation has not went very far.

It is permitted to do so, but there is no language in 625 that modified 210.8(F).

 

[don_resqcapt19]

I would disagree #2 , 110.3? States the mfg instructions for listed equipment SHAll be used.
Many times I showed the UL listing and the instructions then the inspector approved

At least 2/3s of the CMP 1 panel members do not agree.

110.3(B) ....
Informational Note No.2: The installation and use instructions may not reduce the requirements in the Code.

CMP 1 put this into the second revision, but it was removed by the Correlating Committee because the note as written contains a requirement, and Informational Notes are not permitted to contain requirements.
I expect this will appear as code text in the 2026 code.

 

[Bill Snyder]

I agree with that hypothetical. But nothing in Article 625 says that EVSEs shall "not require class A protection when hardwired."

Cheers, Wayne

It must be up to AHJ interpretation

 

[Bill Snyder]

It is permitted to do so, but there is no language in 625 that modified 210.8(F).

I think it's pretty clear the manufacturer's instructions don't see any technical merit with Class A protection when hardwired this whole nightmare will be over in 2026 and it will scale back the unnecessary expansion without technical merit or else CMP-2 will be the joke of the industry.

 

[don_resqcapt19]

I think it's pretty clear the manufacturer's instructions don't see any technical merit with Class A protection when hardwired this whole nightmare will be over in 2026 and it will scale back the unnecessary expansion without technical merit or else CMP-2 will be the joke of the industry.

I would be very surprised if there is any reduction of the GFCI requirements in the 2026. I expect that they will be expanded again.

 

[Bill Snyder]

I would be very surprised if there is any reduction of the GFCI requirements in the 2026. I expect that they will be expanded again.

Well get ready to eat some crow because you are wrong.

 

[don_resqcapt19]

Well get ready to eat some crow because you are wrong.

I stated an opinion, and it is impossible for an opinion to be wrong.

 

[jaggedben]

The jb in the picture below is an outlet

View attachment 2564544

FWIW (and I find it hard to tell if this has been said or what's still being argued about)...

In this picture the liquidtight is supplied by the installer so the outlet is at the EVSE. (Other EVSE manufacturers provide factory liquidtight whips so then you could say the outlet at the j-box, but I don't think this is an important difference.)

The OP provided a snapshot of some instructions for this same unit in post #5. Since this is a hardwired unit which includes GFCI protection, no additional GFCI protection (such as a circuit breaker) is required. If installed outside with a 50A breaker or less, then the EVSE itself satisfies the requirements of 210.8(F).

Thus, there is no conflict here between the manufacturers instructions and NEC requirements. In fact, if installed inside or with a 60A breaker, the unit exceeds NEC requirements.

 

[wwhitney]

In this picture the liquidtight is supplied by the installer so the outlet is at the EVSE. (Other EVSE manufacturers provide factory liquidtight whips so then you could say the outlet at the j-box, but I don't think this is an important difference.)

The OP provided a snapshot of some instructions for this same unit in post #5. Since this is a hardwired unit which includes GFCI protection, no additional GFCI protection (such as a circuit breaker) is required. If installed outside with a 50A breaker or less, then the EVSE itself satisfies the requirements of 210.8(F).

That is an interesting idea. You seem to be seeing the EVSE an an atomic whole. So since the EVSE may provide GFCI protection, and the outlet is located inside the EVSE, the outlet would then have GFCI protection.

I would say the outlet is a certain connection within the EVSE wiring connection, and that point needs to have GFCI protection. Since whatever protection the EVSE provides is only downstream of that, I would not say that protection could satisfy 210.8(F).

BTW, while EVSEs have long been required to provide "a listed system of protection against electric shock of personnel," that may not be a Class A GFCI. Nothing in Article 625 requires Class A GFCI protection. I tried looking at the EVSE listing standard to see what sort of protection is required (a lot of EVSEs do some sort of ground assurance test), and I don't recall the full details, but I came away thinking that indeed Class A GFCI protection is not the only option.

Of course, a specific EVSE could provide GFCI protection and say so in its manual. But that protection will be downstream of the outlet.

Cheers, Wayne

 

[jaggedben]

I think we've had this discussion before.

A hardwired EVSE isn't meaningfully different from a GFCI receptacle when it comes to article 100 definitions of an outlet or utilization equipment. The EVSE is like a super-glorified specialty receptacle. Both the GFCI receptacle and the hardwired EVSE 'utilize' relatively tiny amounts of current for electronic controls but the real load is plugged in (and outside the scope of the NEC). Whether one thinks the EVSE itself (or just the EV) is utilization equipment, one should have the same opinion about a GFCI receptacle. But no one would ever argue that a GFCI receptacle at the end of a wiring method doesn't satisfy 210.8 requirements, so no one should ever argue that an EVSE with built in GFCI protection can't also satisfy them.

The hairsplitting over where the outlet pretty meaningless, and 210.8 says nothing about it.

...

BTW, while EVSEs have long been required to provide "a listed system of protection against electric shock of personnel," that may not be a Class A GFCI. Nothing in Article 625 requires Class A GFCI protection. I tried looking at the EVSE listing standard to see what sort of protection is required (a lot of EVSEs do some sort of ground assurance test), and I don't recall the full details, but I came away thinking that indeed Class A GFCI protection is not the only option.

Is that quote UL or NEC?

I can see where if the EVSE GFCI function doesn't meet the 'protection of personnel' requirement according to some standard then it could fall short of the NEC requirement. But does that mean it has to be Class A? Expecting installers to translate the code language here is ... a bit much.

Of course, a specific EVSE could provide GFCI protection and say so in its manual. But that protection will be downstream of the outlet.

I don't agree about downstream but more importantly ... So what? See above. There's nothing in 210.8 about where the protection has to be installed and it's typically at or downstream of the end of the NEC wiring method. I think it can be anywhere so long as it's permanently installed.

 

[wwhitney]

A hardwired EVSE isn't meaningfully different from a GFCI receptacle when it comes to article 100 definitions of an outlet or utilization equipment. The EVSE is like a super-glorified specialty receptacle.

I happen to agree with that, and if you are happy to say that the outlet is at the end of the J1772 cord, then I totally agree that if the EVSE implements GFCI, that satisfies 210.8. I figure that was a technically correct but sufficiently fringe interpretation that I didn't bring it up. I assume it's far more common to treat the EVSE as the utilization equipment, rather than the EV.

Whether one thinks the EVSE itself (or just the EV) is utilization equipment, one should have the same opinion about a GFCI receptacle.

The difference is that the GFCI is in the wall, while the EVSE is surface mounted and "feels" different. But if you can argue that a pendant receptacle mounted in a box suspended from the ceiling is part of the premises wiring system, then you could argue that the whole EVSE is part of the premise wiring system. And in either case the outlet is at the point the user interacts with it.

Is that quote UL or NEC?

NEC 625.22

I can see where if the EVSE GFCI function doesn't meet the 'protection of personnel' requirement according to some standard then it could fall short of the NEC requirement. But does that mean it has to be Class A?

Yes, see the definition in Article 100.

I don't agree about downstream but more importantly ... So what? See above. There's nothing in 210.8 about where the protection has to be installed and it's typically at or downstream of the end of the NEC wiring method. I think it can be anywhere so long as it's permanently installed.

210.8(F) says the "outlet" has to be protected. Protection installed downstream of the outlet can't protect the outlet. So if the outlet is on the supply side of the EVSE, the EVSE can't protect the outlet. That would be like saying if you have a wall receptacle and you plug one of those portable GFCI dongles into it, now that wall receptacle is GFCI protected.

Cheers, Wayne

 

[wwhitney]

If you install the EV charger in a garage and hard wire it, there is no requirement for GFCI protection.

That's true for the 2020 NEC, but the 2023 NEC extended 210.8(F) to include garages, accessory buildings, and boathouses. So at a dwelling, a 50A or less EVSE in the garage will require GFCI protection under the 2023 NEC.

Cheers, Wayne

 

[jaggedben]

...

210.8(F) says the "outlet" has to be protected.

No it doesn't.

It simply says the outlet shall 'have' GFCI protection 'for personnel'. It does not call for protection of wiring and equipment.