Compliance with the EU Network Code – Requirements for Generators
Briefing note for manufacturers, installers, developers and owners of new electricity generating equipment of all sizes.
The responsibility for compliance with European Commission Regulation (EU) 2016/631, The EU Network Code “Requirements for Generators” (RfG) (and hence with G98 or G99), is with the connection agreement holder who is generally the owner of the generation. Owners are required to make sure that generation equipment they purchase and install complies with the law.
When the RfG was initially drafted and passed into law by the European Commission, it was anticipated by legislators that 3rd party equipment certification bodies would provide the required confirmation of compliance to industry to ensure generation equipment connecting to electricity networks is compliant with the law. When the new requirements encompassed in G98 and G99 came into legal effect following the RfG implementation deadline on 27th April 2019, the industry in the UK did not at that time have any 3rd party equipment certification bodies offering these services to the market.
In the absence of a 3rd party equipment certification regime, ENA provides a repository, the ENA Type Test Register, where manufacturers can lodge their own declarations of compliance to G98 or G99 (www.ena-eng.org/gen-ttr). G98, which applies to domestic scale generation equipment rated at 16 amperes or less, requires that manufacturers must lodge their declarations of compliance in the ENA Type Test Register, but this is not mandatory under G99 for any generation equipment larger than 16 amperes.
Please note: The responsibility for the accuracy and validity of the product information held in the register is on the respective manufacturers who submit their compliance declarations to this register. ENA does not act as an equipment certification body and the presence of a manufacturer’s device on ENA’s Type Test Register does not indicate whether the device is compliant with the required specification or not. Generation connection customers are responsible for procuring and installing compliant equipment and are expected to undertake their own checks of the generation equipment held on the register.
The onus is on manufacturers to produce equipment that is compliant with the legal requirements, and upon request (from owners, installers, developers, and DNOs) be able to demonstrate this with appropriate evidence. ENA urge manufacturers to ensure that their generation equipment is demonstrably compliant, as it is in the interests of all their customers, including the supply chain of generation equipment to final owners.
ENA encourages all parties in the supply chain (owners, installers, developers and manufacturers) to maintain a dialogue seeking appropriate assurance and confirmation that generation equipment for the GB market is fully compliant with GB legal requirements. To support a dialogue with stakeholders and DNOs around the connection of generation, ENA hold a Distributed Energy Resources (DER) Technical Forum. This forum is open for all industry stakeholders to query the technical aspects of G99 and G99 with DNOs to garner a consistent understanding of the implementation by stakeholders and consistent application of the requirements by DNOs. For more information on the DER Technical Forum please click here:
Where generation owners have already bought and installed generation equipment that might be found to be non-compliant, the relevant DNO can be expected to bring this to the attention of the owner in due course, along with any obvious possible mitigations. However mitigations will be the responsibility of the owner and for the owner, installer and manufacturer to address in each case.
08 October 2019
European Commission Regulation (EU) 2016/631