Measurement Canada is looking for input into its proposed approach for allowing the continued use and oversight of level 3+ electric vehicle (EV) charging devices – also called direct current fast chargers (DCFC) – that are already deployed in the Canadian marketplace.
In parallel with other jurisdictions across the world and in consultation with international metrological organizations, industry, associations and other stakeholders, Measurement Canada is establishing specifications for the design, manufacture, performance and use of EV charging devices in the Canadian marketplace. It is also preparing to make these specifications available in the near future.
The Electricity and Gas Inspection Act requires that all measuring devices used in the sale of electricity on the basis of a unit of measurement, such as the kilowatt-hour (kWh), be type‑approved by Measurement Canada for use in trade in Canada. Consequently, EV charging devices equipped with a metering function that is used to establish a charge (i.e. bill) for the energy consumed by an EV during a recharging event will be required to be approved for such use.
Even though EV charging devices already deployed across Canada and used for commercial transactions are designed and built according to various international specifications and best practices, they have not yet been approved by Measurement Canada for use in Canada. As of October 2022, there are over 1,367 level 3+ (DCFC) EV charging sites across Canada (with over 3,464 level 3+ (DCFC) charging ports. In addition, the Government of Canada committed close to $300 million over four years to build new recharging infrastructure for zero-emission vehicles (see the Fall Economic Statement 2020), which is fuelling growth in this marketplace sector and continued expansion of the EV charging network across Canada.
The proposed policy approach described below applies to level 3+ (DCFC) EV charging stations used in Canada to deliver and receive electricity during a recharging event. It does not apply to level 1 or level 2 EV charging devices or devices used primarily for charging electric vehicles in a residential setting, such as townhouses or single-family homes or multi-unit residential complexes like apartment buildings and condominiums.
To assist early adopters of EV technology, foster continued growth in the clean fuel sector, and support government-wide clean fuel initiatives, Measurement Canada must establish an oversight policy to allow the continued use of the large population of EV charging devices already in the Canadian marketplace, until such a time as owners and operators are able to upgrade them and submit them for type approval and verification, or replace them with type‑approved devices.
Once EV charging device specifications are established, EV charging station operators will be allowed to sell electricity on the basis of a measured quantity (kWh), and not on the basis of time or per charge, as they do today. However, given the large number of EV chargers already put into service in Canada, we are seeking a solution which will allow for the continued use in the marketplace of these devices without imposing immediate pressure on businesses and consumers to meet the new specifications. Additionally, we must manage the approval and verification process for this large population of devices using a measured, risk-based approach in order to address future resource demands on our organization.
One way to facilitate this transition is through the use of a temporary dispensation issued in accordance with the Electricity and Gas Inspection Act. The dispensation would provide a well defined and gradually implemented roadmap to full compliance with new specifications. Alternatively, EV charging station operators may choose to take immediate measures to ensure their devices fully conform to the new EV charging device specifications, therefore avoiding participation in the temporary dispensation program. Any EV charging device that is not subject to the temporary dispensation or the verification process will be considered not legal for trade after implementation of the policy.
In considering various options for allowing the continued use of currently deployed EV charging devices, we must ensure that the chosen approach is fair, transparent, and workable for all stakeholders. In particular, we must take into account:
- the industry's expectations regarding the implementation and consistency of the approach, in particular as it compares to strategies adopted by other jurisdictions that have started type-approving EV charging devices;
- the potential burden on the industry, including the added time frame and cost of investment associated with upgrading EV charging devices to meet the new specifications;
- the resource impact on Measurement Canada and its ability to approve the devices and conduct the required verifications, while continuing to carry out its mandate across other sectors of the marketplace;
- the regulatory risks that would be introduced, such as a lack of enforcement authority, along with any residual risks and their long-term impact on businesses and consumers; and
- how it may affect business, investor and consumer confidence in the accuracy of EV charging devices.
Temporary dispensation for level 3+ (DCFC) electric vehicle charging devices put into service before January 1, 2025:
- Any EV charging device put into service before January 1, 2025, is eligible for a temporary dispensation from the verification and sealing required under the Electricity and Gas Inspection Act. This dispensation is subject to terms and conditions and will remain in effect until, no later than January 1, 2030, the device is verified as complying with applicable Measurement Canada specifications or removed from service.
- Any EV charging device put into service on or after January 1, 2025, must comply with applicable Measurement Canada specifications and is not eligible for a temporary dispensation under the Electricity and Gas Inspection Act.
- Starting on January 1, 2030, all EV charging devices are required to be verified as complying with applicable Measurement Canada specifications.
- Prior to January 1, 2025, owners or operators of eligible level 3+ (DCFC) EV charging stations wishing to continue using non type-approved EV charging devices to sell electricity on the basis of kilowatt-hours (kWh) must apply for a temporary dispensation for those devices as well as a certificate of registration in accordance with requirements of the Electricity and Gas Inspection Regulations. They must also provide Measurement Canada with a list of both Canadian type-approved and non type-approved EV charging devices they currently have deployed in the Canadian marketplace.
- Until January 1, 2030, owners or operators of eligible level 3+ (DCFC) EV charging devices who have been granted a temporary dispensation may use those devices without the required verification or sealing, under certain terms and conditions (see Appendix A for a list of proposed terms and conditions).
- The temporary dispensation expires on January 1, 2030.
- The temporary dispensation will be cancelled if, at any time during the dispensation period if any of the following applies:
- an EV charging station owner or operator fails to meet the terms and conditions set by Measurement Canada;
- the EV charging device is relocated or removed from service; or
- a new certificate of registration is issued; at which time the owner or operator must reapply for temporary dispensation within the prescribed timeline or have the EV charging device verified in accordance with the EV charging device specifications.
Temporary dispensation notes
- A temporary dispensation is a regulatory instrument authorized by section 9.2 of the Electricity and Gas Inspection Act. It is used to grant permission to put into service, without verification or sealing, any meter or any class, type, or design of meter on a temporary basis. Temporary dispensations are subject to the terms and conditions specified by the President of Measurement Canada and are in force for a specified period.
- At any point, owners or operators of EV charging devices that are subject to a dispensation may have them verified for compliance with applicable Measurement Canada specifications. If their devices are found to be in full compliance, their participation in the temporary dispensation program will end.
Appendix A – Proposed terms and conditions
The proposed terms and conditions of the temporary dispensation include, but are not limited, to the following:
- EV charging station owners or operators must ensure that for the duration of the temporary dispensation, each eligible level 3+ (DCFC) EV charging device, at a minimum:
- supplies electricity to the purchaser within an acceptable limit of error of ±3% and has been tested (evidence to be provided upon request) using an acceptable method and standard as defined by Measurement Canada;
- is installed with a metering system capable of measuring the delivered energy;
- uses the watt-hour, or any multiple or submultiple of the watt-hour, as the unit of measurement for the sale of electricity;
- is equipped with a means to display legally relevant information that is either connected to an integral, remote or non-connected system (e.g. remote register) or any information storage system such as the Cloud network;
- displays increments of significant figures;
- includes and displays the billing structure showing the unit price of electricity sold or billed and the different categories of billing type. Where the device's display is not capable of presenting this information, a placard showing this information must be posted in a visible location on the device;
- provides a means to display the software and firmware version; and
- includes a placard stating that the device does not meet the full requirements of the applicable Measurement Canada specifications.
- EV charging station owners or operators must put in place a process for dealing with customer complaints that, at a minimum:
- records complaints from purchasers;
- makes inquiries with the purchaser who made the complaint and of any person who could reasonably be expected to have knowledge relevant to the matter;
- examines any records related to the EV charging devices that are the subject of complaints;
- tests the EV charging devices that are the subject of a complaint if the initial attempt for resolution is not satisfied by the concerned parties;
- documents the results of the tests and provides a copy of the results to the purchaser who made the complaint;
- makes records available to Measurement Canada upon request; and
- institutes corrective measures to address any failure to meet the terms and conditions of the temporary dispensation, discovered as a result of the complaint investigation process.
Measurement Canada is looking for your input into our proposed approach for allowing the continued use and oversight of level 3+ (DCFC) EV charging devices already deployed in the Canadian marketplace.
Please send your comments and details of any suggested changes to our proposed approach to email@example.com.
This consultation will close on December 9, 2022.
If you have any questions regarding this consultation, please send us an email at