Following the publication of the proposed amendment of the MID Directive 2014/32/EU (the ‘MID’) on 29/11/2024 by the European Commission [1] more than twenty years after its first publication, it is useful to highlight the novelties that will involve all the players in the world of legal metrology and to consider some interesting topics, not before a quick nod to the directive itself and the reasons behind its amendment.
Introduction
Before moving on, a quick mention of the purpose and content of the MID Directive 2014/32/EU: it regulates the harmonization of the legislations of European Union Member States regarding the making available on the market of measuring instruments.
In practice, it is a document that allows for a single certification, valid in all the European Member States (which have transposed the directive itself), for measuring instruments that are used in legal metrology, in order to ensure transparency, fairness, and security in fiscal and trade transactions against a measurement.
The directive not only specifies the essential requirements of all the instruments indicated and those specific to each of them, but also the administrative procedure for obtaining the certification through the conformity verification, as well as the responsibilities of all the actors involved.
To date, the measuring instruments considered are: water meters, gas meters (residential and light industrial), volume conversion devices (c.d. EVCD, Electronic Volume Conversion Device), active electrical energy meters (AC meters), thermal energy meters, measuring systems for the continuous and dynamic measurement of quantities of liquids other than water (including dispenser of fuel, not compressed), automatic weighing instruments, taximeters, material measures of length, capacity serving measures (e.g. the line measure in drinking glasses or jugs), dimensional measuring instruments (e.g. for postal parcels) and exhaust gas analysers (also important for vehicle inspections).
Reasons
The reasons behind the proposed amendment of the MID can be summarised as follows.
Twenty years of technological progress and political-environmental changes have necessarily led to the emergence of new measuring instruments (e.g. electric vehicle charging stations) and parts of them, or an extension of their use (e.g. the increased use of compressed gases as alternative fuels for vehicles and also in distribution networks).
The need for a single harmonised European legislation for these new instruments or uses, and no longer 27 national legislations. Thus, the possibility of obtaining a single certification and being able to enter the 27 European Member States with the following advantages: reduction of certification costs for economic operators, subsequent reduction of production costs for the benefit of consumers, improvement of the functioning of the single European market.
The need to accelerate the twin, green and digital, transition in line with the objectives of the European Green Deal and of the New Industrial Strategy for Europe.
The need for an effective and practical implementation of the AFIR Regulation (EU) 2023/1804 on the establishment of an infrastructure for alternative fuels, including electricity, hydrogen and biofuels.
Significant news
The significant news introduced by the proposed amendment concern two aspects: 1) the limited update of the scope of the MID; 2) the consequent limited update of the essential and specific requirements for new measuring instruments or their wider use, in order to harmonise them throughout European Union.
This is a targeted technical amendment and not an administrative one, which means that it does not affect the modalities of certification in general and accreditation, the responsibilities of economic operators, etc.
The updating of the scope of the directive introduces into it the measuring instruments that are ‘new’ for harmonised European legislation, which are outlined in the table below.
It has to be remembered that the current text submitted by the European Commission is a proposal, so it is not yet the final text of the new MID, although the technical-normative orientation is already well outlined.
| New type of instrument or system | New specific annex | Updated specific annex |
|---|---|---|
| Measuring systems for electric vehicle supply equipment (EVCS) | Annex Va MI-003a Conformity assessment procedures: B+F or B+D or H1. | |
| Measuring systems for compressed gas dispensers (hydrogen and natural gas/CNG) | Annex VIIa MI-005a Conformity assessment procedures: B+F or B+D or H1 or G. | |
| Smart electrical energy meters and for direct current (DC meter) | Annex V MI-003 | |
| Gas calorific value determining devices (GC o CVDD) | Annex IV MI-002 New Part IIa | |
| Thermal energy meters for cooling applications | Annex VI MI-004 |
Concerning the expected timelines for the entry into force of the future officially amended directive (not this proposal), they are:
– 12 months for Member States to adopt and publish the legislative provisions necessary to comply with the future directive;
– 24 months for Member States to apply the provisions adopted by themselves.
It should be noted, however, that reasonable transitional arrangements are specified for measuring instruments that have already been certified and placed on the market under the current MID and before the date of application of national measures for transposition of the future directive. Whether they will be confirmed in the final text needs to be verified.
Considerations
The novelties listed inevitably give rise to a number of considerations of various kinds that are shared in this article, starting to pave the way for the change that will affect all legal metrology players involved.
| 1. AFIR Regulation (EU) and legal metrology |
| If until now the connection between Regulation (EU) AFIR 2023/1804 and legal metrology is implicit, it is now clear and official that the AFIR regulation necessarily has an impact on some measuring instruments: first of all, electric vehicle charging stations (EVCS) and then compressed gas dispensers (hydrogen and natural gas/CNG). Both are proposed as new instrument-specific annexes to the future MID, so that there will be a single harmonised European legislation that will enable the infrastructure for alternative fuels to be put in place effectively and quickly. |
| 2. A new type of measuring system |
| Whereas until now only one measurement system (that of the continuous and dynamic measurement of quantities of liquids other than water, Annex VII MI-005) is explicitly considered in the MID, the proposed amendment also introduces the measurement system for electric vehicle supply equipment (EVCS). Thus, this new system may also be composed of ‘parts’, using the modular approach according to Welmec Guide 8.8. |
| 3. The acronym for electric vehicle charging stations |
| While up to now, various acronyms are used to abbreviate the electric vehicle charging stations (EVCS – Electric Vehicle Charging Systems or Stations; EVFS – Electric Vehicle Fueling Systems; EVSE – Electric Vehicle Supply Equipments), in the proposed amendment that officially includes these measurement systems in the European legal metrology, the acronym indicated is EVSE. This acronym is precisely that used in the OIML G22 Guide, which, once converted into a recommendation, will most likely become the normative reference document for these measurement systems. |
| 4. No more national type approval certificates for EVCSs and compressed gas dispensers |
| While until now it is necessary to obtain a national type certificate in each Member State (where applicable [2]) for electric vehicle charging stations and for compressed gas dispensers (hydrogen and natural gas/CNG), the new proposed amendment finally introduces the possibility of obtaining a single certification (MID) valid for entry into each European Member State, again after the transposition of the new MID directive by the State itself. This will undoubtedly be a very important change, if confirmed by the final text. Of course, if a manufacturer already has some type approval certificates or test reports for these instruments, depending on the certification body that issued them, he can easily convert them by obtaining the MID module B [3]. |
| 5. Direct current electricity meters (DC meters) with MID certification |
| While until now it is unclear whether DC electricity meters are included in the MID or not, with the new proposed amendment, they are finally officially included in the MID, with the goodwill of all certification bodies, Member States and, above all, manufacturers, who will no longer have any obstacles in the European market. |
| 6. Gas chromatograph (GC or CVDD): associated measuring instrument |
| Whereas until now the gas chromatograph (GC or CVDD) has been required to comply with the OIML Recommendation R140, the new amendment proposal finally provides for an explicit, single, European certification for this measuring instrument as well. The current text defines the gas chromatograph as an ‘associated measuring instrument’, so it seems that from a certification point of view, it is not considered as an instrument with its own full MID certification, but as an associated part of another instrument (volume conversion device-EVCD and/or gas meter). This means that, if the current text is confirmed, the gas chromatograph will have its own part certification (Evaluation or Parts certificate) according to the modular approach of Welmec Guide 8.8. |
| 7. Accreditation for MID certification of new measuring instruments |
| If the introduction of the new or more widely used measuring instruments [4] is confirmed by the final text of the new MID, it will be necessary for certification bodies that wish to be notified bodies for their certification to obtain the related specific accreditation. Some certification bodies are already ready, others will be adapted and new ones will certainly emerge [5]. |
| 8. Regulation of periodical verification for new measuring instruments |
| If the introduction of new or more widely used measuring instruments [6] is confirmed by the final text of the new MID, it will be necessary for each Member State to also regulate the whole matter of their periodical verification. On this aspect, there is still a lot of work to be done, especially for measuring systems for electric vehicle supply equipment (today called EVCS) and for compressed hydrogen dispensers. |
Conclusions
In conclusion, after years of waiting and difficulties of various nature for manufacturers of new or already widely used measuring instruments, we are finally approaching the harmonisation of their certification in Europe with consequent benefits for everyone, consumers included. At the same time, however, this will entail a very important and not so obvious change, for which we need to prepare ourselves intelligently now in order to seize the great technological, business and sustainability opportunities.
Notes
[1] See European Commission, Internal Market, Industry, Entrepreneurship and SMEs, Single market and standards, Single market for goods, Building blocks of the single market, Legal metrology, Measuring instruments.
[2] Not all European Member States have a dedicated legislation for legal metrology certification of electric vehicle charging systems (EVCS).
[3] To learn more about this topic, write to Dr Alessandra Bendistinto alessandra.bendistinto@certificationcrossing.com.
[4] Measuring systems for electric vehicle supply equipment (EVSE), measuring systems for compressed gas dispensers (hydrogen and natural gas/CNG), smart electrical energy meters and and for direct current (DC meter), Gas calorific value determining devices (GC or CVDD), Thermal energy meters for cooling applications.
[5] See note [3].
[6] See note [4].
Resources
European Commission, Internal Market, Industry, Entrepreneurship and SMEs, Single market and standards, Single market for goods, Building blocks of the single market, Legal metrology, Measuring instruments.
