Proposal for smart EV chargers

Our proposal is to require EV chargers supplied in New Zealand to be ‘smart’

We are seeking feedback on a proposal to require that new EV chargers supplied in New Zealand must have smart functionality. This would not mean that consumers would be required to install and utilise a smart EV charger. EV owners would continue to have the option of using portable 3-pin charging, or any charging unit they have already purchased.

This is an initial consultation on options (section 3) to inform a decision on whether to regulate. If the government decides to regulate, there will be further consultation on specific requirements.

Where possible, we seek to align with international approaches. Arrangements between the New Zealand and Australian governments means that New Zealand should endeavour to coordinate with the Australian Government on EV charging. A summary of international approaches to regulating EV chargers is annexed.

There are also international obligations related to technical barriers to trade (TBT) arising through New Zealand’s membership of the World Trade Organisation (WTO) and commitments under free trade agreements (FTAs) that need to be complied with. A TBT WTO notification will be issued for this proposal with a 60-day consultation period.

Any new requirements would not apply to charging units imported into or manufactured in New Zealand before the new requirements come into force, and would not apply to charging units already installed. They would also not apply to second hand charging units.

Amendments to the Energy Efficiency and Conservation Act will enable this proposal and wider work to address demand flexibility in the energy system

Legislation already exists to allow Minimum Energy Performance Standards (MEPS) and labelling requirements to be set for energy-using products and services, including vehicles.

These regulation making powers are set out in the Energy Efficiency and Conservation Act 2000 (the EEC Act), which provides the statutory basis for promoting energy efficiency, energy conservation, and the use of renewable energy in New Zealand.

The Government announced policy decisions in November 2024 to deliver a more effective regime that can respond to the latest market developments and support a smarter electricity system, and work is underway on an amendment bill to give effect these decisions.

The proposed changes will enable regulation beyond energy efficiency to include other factors necessary to enable demand flexibility, such as interoperability between devices and service providers in the electricity system. The amendments will enable demand flexibility capability requirements for EV chargers to be set.

This proposal would complement existing work to promote smart charging

Work has already been undertaken to support the uptake and use of smart EV chargers, including through providing the following guidance and consumer information.

Voluntary Publicly Available Specifications (PAS):

• Residential EV charging PAS – provides guidance for consumers on good practice for charging their EV at home, including information on efficiency and smart EV charging (last updated in June 2023 by EECA and Standards NZ).
  SNZ PAS 6011:2023(external link) — Standards New Zealand
• EV chargers for commercial use PAS – provides guidance on good practice for commercial EV charging stations, including WorkSafe requirements and NZ Transport Agency guidance (last updated in June 2023 by EECA and Standards NZ).
  Electric vehicle chargers for commercial use(external link) — Energy Efficiency & Conservation Authority
• EV Smart Charger Approved List – a list of approved residential and commercial electric vehicle chargers that meet efficiency and smart charging requirements.
  EV Smart Charger Approved List(external link) — Energy Efficiency & Conservation Authority

FlexTalk pilots:

• FlexTalk 1.0 installed two-way smart EV charging functionality on three electricity networks to test real-time two-way connectivity with EV chargers in homes and businesses. It was designed to ensure the trial was reflective of the way network companies need to be able to “see and control” smart EV chargers (using a smart device software platform) and provided a cost-effective exemplar of how a New Zealand-wide system could function going forward.
• FlexTalk 2.0 is underway to add other smart consumer technologies to the platform created under 1.0 (e.g., hot water, heat pumps, and home energy management systems), creating exemplars of ‘smart homes’ of which smart EV chargers are a key component.

Pricing options will also be crucial to smart charger uptake and use

Electricity market settings play a crucial role in supporting the uptake of smart charging – requiring chargers to be smart will not alone ensure the benefits are realised. Price signals play an important role in shifting electricity use away from times of high demand or peaks.

EECA’s research has demonstrated that simple off-peak plans are available to 69% of EV owners, through their home electricity retailer.^[1] Among those EV owners that have access to off-peak power, nearly all (96%) of them utilise it for charging some, or most of the time, indicating that many owners are already capitalising on savings without a smart charger.

Our future electricity system is expected to become more dynamic due to more variable renewable generation, distributed energy resources (such as rooftop solar and batteries), flexible end-use products and increasing electrification. Greater savings will be achievable in future if there are more innovative or dynamic pricing options in the market, and this would encourage consumers to invest in a smart charger to take full advantage of the benefits.

The Energy Competition Task Force^[2] is exploring proposals to better reward consumers for shifting electricity consumption (or injecting back into the grid). These proposals include requiring retailers to offer at least one time-varying consumption (and injection) plan which could give more choice to encourage businesses and households to change how they use electricity (i.e., shift their charging away from peak periods due to cheaper electricity).

Smart EV chargers are ‘connected’ devices that could be vulnerable to cyber threats

Consumers need to be confident that using an EV charger will not compromise their security or ability to charge, and the security and resilience of the wider electricity system must be protected. Network owners also need to be confident that the risk of cyber-attacks is managed to reduce the threat to network stability and disruption.

The use of V2X could broaden the implications of exposure to cybersecurity risks.

Cybersecurity is managed across the electricity system using a best-practice approach. Device-level requirements could be a way to provide confidence to consumers and network owners, but there is currently no specific regime in place to regulate this.

Great Britain has had the following requirements relating to cybersecurity for EV chargers since the second phase of its smart charger regulations came into force on 30 December 2022:

• encryption of all communications
• the ability for electric vehicle and charge point owners to be able to change the settings (with the option to easily delete their personal data if they wish), including the ability to set a unique password
• the ability for chargers to check periodically if there are any security updates available
• measures to protect the hardware from physical damage, including tampering.

The process evaluation of Great Britain’s smart charger regulations found that there was a lower level of compliance with these requirements (relative to the first phase requirements). The evaluation also found that the phased introduction of these requirements helped stakeholders in their implementation, although it was noted that they needed even more time overall to transition to all of the new requirements.

We are seeking views and information to build our understanding of this issue and whether there is a case for device-level requirements to manage cybersecurity risks associated with smart EV chargers.

Footnotes

[1] Residential smart EV chargers and demand flexibility(external link) — Energy Efficiency & Conservation Authority

[2] The Taskforce brings together regulatory experts from the Commerce Commission and the Electricity Authority with observers from the Ministry of Business, Innovation and Employment to assess how well the market is delivering efficient investment and affordable electricity.

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