Frequently asked questions – Temporary dispensation program for electric vehicle supply equipment

General information

Application and registration process

Terms and conditions of the temporary dispensation

Technical Information

General information

1. What is the temporary dispensation program for electric vehicle supply equipment (EVSE)

Measurement Canada's temporary dispensation program allows already deployed EVSE to continue to be used without verification and sealing in accordance with the requirements of the Electricity and Gas Inspection Act (EGIA). The temporary dispensation will remain in effect until the devices are removed from service or type approved by Measurement Canada, or when it expires on January 1, 2030, whichever comes first.

2. What is the difference between a type approval and an attestation of accuracy?

Type approval is a formal process whereby EVSE devices undergo comprehensive evaluation and testing by Measurement Canada to ensure compliance with its specifications. This process is required for devices to be used in trade measurement applications.

In contrast, an attestation of accuracy is a document provided by the device manufacturer or owner as confirmation of their device's accuracy and operational reliability as established through the manufacturer's recognized evaluation program. The attestation serves as evidence that the device meets the requirements of the temporary dispensation until full regulatory compliance, including type approval, is enforced at the end of the dispensation period.

3. How did Measurement Canada come up with the different options for consideration for the program?

Measurement Canada arrived at the different options through consultation and collaboration with industry stakeholders, associations, other international jurisdictions, consumers and interested Canadians.

4. Why does Measurement Canada support the transition to kWh billing?

One of the legal units of measure for the sale of electricity listed in the EGIA is the watt-hour or any multiple or submultiple of the watt-hour. Measurement Canada is aware of the need for fair and transparent energy transactions and supports the development of a system that incorporates measured kWh billing at commercial EVSE stations. However, in consideration of the investment costs associated with the potential need to upgrade to makes and models of EVSE that are capable of measuring electricity delivered to an electric vehicle (EV), billing based on time or a flat rate will continue to be an available option for EV charging transactions until December 31, 2029.

5. How will the temporary dispensation be applied?

The temporary dispensation will be issued to EVSE owners, on a per device and location basis, and not by manufacturer or device type. Owners must apply for the temporary dispensation in order to participate in the program.

6. How long will the temporary dispensation last?

The temporary dispensation for level 1,level 2 and level 3+ EVSE is scheduled to end December 31, 2029, or when the EVSE has been verified or removed from service.

7. Will there be an extension of the temporary dispensation?

There are currently no plans to extend the temporary dispensation for level 1, level 2 and level 3+ EVSE beyond December 31, 2029.

8. Was a permanent dispensation or exemption considered?

Permanent dispensation was considered alongside the three proposed options for a temporary dispensation. It was determined that having non-verified EVSE in service for an indefinite period of time was too high of a risk to consumers. In addition, as the typical life cycle of an EVSE is anticipated to be 8 to 10 years, the proposed time frame for the dispensation is considered appropriate.

9. Are non-commercial settings exempt from this program?

No, effective October 2023, requirements and regulations for EVSE that use energy-based billing in non-commercial settings became a part of this temporary dispensation program.

10. Does this program also address level 3+ or direct current EVSE?

Yes, effective February 2023, the EVSE temporary dispensation program also became applicable to level 3+ or direct current EVSE.

11. Will there be any changes to the terms and conditions of the program after its implementation?

The terms and conditions may be subject to change, with notification, during the period of this program. All devices granted temporary dispensation must comply with the terms and conditions for the period of the temporary dispensation or until either removed from service or verified as fully conforming according to EVSE specifications. The latest terms and conditions of the program can be found on Measurement Canada's website.

12. Will it be possible to verify and seal EVSE through the Measurement Canada accreditation program after the temporary dispensation program ends?

Currently, the accreditation program does not extend to EVSE.

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Application and registration process

13. Who is responsible for applying for a temporary dispensation for EVSE?

Owners, or registered representatives of the owner, are responsible for applying for a temporary dispensation for their devices.

14. Do I need to register as a contractor before being considered for this temporary dispensation program?

Contractor registration is a mandatory requirement as per the EGIA and is not exempted via the temporary dispensation program. To streamline the process, successful applicants to the temporary dispensation program will automatically receive a certificate of registration, issued by Measurement Canada, prior to the end of the dispensation.

15. I am an owner who has installed an EVSE to supply charging services to public users for billing. What is required now that the EVSE is operational?

Owners using a billing structure that is not based on legal units of measure delegated under subsection 3(1) of the EGIA and whose EVSE does not have the capacity to measure because they do not have an internal meter, may continue to operate the EVSE according to manufacturer recommendations.

Owners wishing to implement a billing structure using a legal unit of measure delegated under subsection 3(1) of the EGIA will need to apply for temporary dispensation of the device and refer to the guidance document on applying for a temporary dispensation for further information.

16. How do I submit EVSE information to apply for temporary dispensation?

The guidance document on the temporary dispensation program will assist applicants in completing the application form and providing all the required information. The completed Application for the Temporary Dispensation – Electronic Vehicle Charging Devices and all required supporting documentation can be submitted by email to mcdispensation-dispensemc@ised-isde.gc.ca or by mail to:

Measurement Canada

Energy Directorate

9177 Langelier Blvd.

Montréal, Quebec H1P 3K9

17. If a contractor withdraws the devices from the temporary dispensation program, can they reapply at a later date?

Owners of level 1 and level 2 EVSE device may apply for the program any time before January 1, 2028.

18. How do I know if Measurement Canada has on file an attestation of accuracy for my device?

To verify whether Measurement Canada has received an attestation of accuracy for your EVSE and is eligible for the Temporary Dispensation Program, consult Appendix B of the guidance document on applying for a temporary dispensation.

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Terms and conditions of the temporary dispensation

19. What happens if an EVSE fails to meet the terms and conditions of the temporary dispensation?

Devices failing to meet any requirements or provisions set forth in the terms and conditions may be subject to further assessment on an individual basis and may be removed from the temporary dispensation program. Owners unable to meet the requirements due to the malfunction of a device or damage to a device that prevents its testing, will be given an opportunity to repair the device and have it reassessed. Alternatively, the device may be removed from service.

20. What information is required on the placard?

A placard is required to be posted only on EVSE included in the temporary dispensation program. The placard will need to contain information that is important to the users of the EVSE, such as the status and billing structure of the device. The information that is required on the placard can be found in the guidance document on applying for a temporary dispensation.

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Technical Information

21. When I use an EV charging station, why am I billed based on time and not kWh?

Measurement Canada is working with all stakeholders to develop the framework for EV charging stations to bill using the unit of kilowatt-hours (kWh). Once completed, owners and operators will be given the option to bill using either conventionally endorsed units of measure or the unit of kWh. All EVSE owners and operators who are granted a temporary dispensation will be required to inform users of how many kWh are delivered per transaction.

22. Will Measurement Canada be providing test procedures for EVSE that are granted a temporary dispensation?

Measurement Canada will not be providing test procedures for EVSE devices qualified under the temporary dispensation program. It will be the responsibility of the owner to demonstrate that the terms and conditions of the dispensation have been met to standards acceptable by the Agency.

23. How can I be confident that the EV charging station I am using is accurate?

Before any EVSE is allowed into the temporary dispensation program, the accuracy of the EVSE must either be tested by the owner or attested to by the device manufacturer. Measurement Canada is currently developing specifications and marketplace surveillance procedures to further ensure that electric vehicle chargers meet the minimum standards required for measurement accuracy and reliability. Any concerns about the accuracy of the EVSE shall be directed to the owner or operator of the device for the duration of the temporary dispensation.

24. How can I feel confident that no one has tampered with the EVSE, altering the accuracy of the device?

Measurement Canada is currently working with manufacturers to develop a program for new EVSE requiring that all charging stations are sealed to prevent tampering. For EVSE already installed in the marketplace and subject to the temporary dispensation, they will be temporarily exempt from sealing requirements for the duration of the program. Any EVSE suspected of being tampered with should be reported to the device owner or operator.

25. There has been a significant increase in the cost per charge for a public use EVSE. Can Measurement Canada resolve this issue?

Measurement Canada is not responsible for setting electricity rates. The Agency's role is to ensure that any measuring device used for trade is accurate, including EVSE. For issues regarding electricity rates or cost per kWh, users will need to contact their provincial or territorial ombudsman or the EVSE service provider. EV charging station operators are free to set the price they see fit to deliver a charge to all vehicles, in compliance with provincial regulations for the sale of electricity.

26. Why does my vehicle display register less kWh than what I am billed by the EV charging station?

There are inherent energy losses between the charging station and the EV battery during charging which may result in a difference between the delivered energy registered by the charging station and what was registered by the vehicle's onboard display. Onboard vehicle displays and energy monitoring systems are currently not considered as approved measurement devices and are to be used for reference purposes only.

27. Can I file a formal complaint or dispute with Measurement Canada about suspected inaccurate measurement related to EVSE?

In accordance with the terms and conditions of the temporary dispensation, any complaints related to the accuracy of EVSE authorized for use under the temporary dispensation must be handled by the EVSE owner. For more information, please refer to the guidance document on applying for a temporary dispensation.

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