Already tested the charger? What Spain requires and what can be reused

“We’ve already tested our EV charging system. What additional evidence do we need to enter Spain, and can we use what we already have?”

For manufacturers entering the Spanish market, this is a key consideration. Existing accredited test reports may support the national conformity assessment process, potentially reducing the need for additional testing. However, acceptance depends on whether the evidence meets Spain’s specific requirements, including evaluation of the complete charging system rather than the electricity meter alone.

Spain’s metrological framework, established through Orden ITU/1475/2024 and Anexo XX to Orden ICT/155/2020, builds largely on OIML G22:2022 but includes additional national provisions.

So where can manufacturers reuse existing evidence, where might gaps remain, and what does this mean for those targeting multiple European markets?

How Spain treats existing test evidence

The Spanish Metrology Centre (CEM), responsible for assessing chargers against Spanish requirements, has clarified its approach to existing evidence:

• Accredited reports: test results issued under the ILAC MRA by laboratories accredited to ISO/IEC 17025 can be accepted, provided the tests comply with Spanish legislation.
• Review before retesting: where a manufacturer already holds test reports, CEM can review them before any new tests to see whether they can be taken into account.
• Software: WELMEC Guide 7.2 is considered when the manufacturer uses it to demonstrate software conformity.
• OIML G22 version: Spanish legislation refers to OIML G22 in its current applicable version.

CEM always makes its own assessment of whether a charger meets the requirements, so an accredited report is evidence, not approval. But it changes the starting point. The first step is to establish what existing reports show, not to commission a full new test programme.

Where existing reports usually fall short

Spain implements OIML G22:2022 almost entirely, so a G22-based evaluation addresses most requirements. Gaps typically arise from national additions and the scope of testing. For each, consider the following when reviewing an existing report:

The last three are design features as well as test items. Where a charger lacks them, testing alone does not close the gap, so it pays to check them first.

Three kinds of existing evidence, and how each is likely to fit

1. Accredited OIML G22:2022 reports. The closest fit. The work is mainly to confirm that the complete charger was tested and to close the national additions in the table above.
2. Accredited reports under other frameworks, such as German MessEG/MessEV or other national schemes, can still be considered where the tests match Spanish requirements. Expect more mapping because test conditions and methods can differ from G22.
3. A separately approved meter. A meter certificate documents the meter, but Spain assesses the complete charger. It does not replace system-level evidence.

Most manufacturers hold a combination of these reports. Mapping them against Spanish requirements, report by report, shows which tests remain.

A practical route: build on existing evidence

Manufacturers do not necessarily need to start testing from scratch. A structured review of existing evidence can help identify which requirements have already been addressed and where additional evaluation may be necessary.

1. Evidence review. Map each existing report to the Spanish requirements using the checks above.
2. Design check. Confirm the display, local data storage, and time synchronisation before testing, since these may require product changes.
3. Gap testing. Test only what remains, under ISO/IEC 17025 accreditation, so the results can be considered in the Spanish assessment.
4. Submission. CEM assesses the combined evidence.

This is where NMi’s work on the standard matters. NMi’s ISO/IEC 17025 accreditation includes OIML G22:2022 and the first committee draft of its successor. Our specialists actively contribute to the development of these international requirements, bringing direct knowledge of their technical interpretation and evolution.

This expertise supports the review of existing reports, identification of additional testing needs and evaluation of AC and DC charging systems. Software evaluation against WELMEC Guide 7.2 can also form part of the technical assessment.

The objective is to establish a coherent body of evidence that meets Spain’s requirements and identifies where results may also apply to other European markets.

Looking ahead: one body of evidence, multiple European markets

Spain is one part of an evolving European regulatory landscape. Germany continues to apply its established legal metrology framework under MessEG/MessEV (Eichrecht), while Directive (EU) 2026/706 extends the Measuring Instruments Directive (MID) to EV charging equipment from 10 October 2028. Internationally, work continues on the successor to OIML G22.

These frameworks are related but not interchangeable, so evidence built for one market will not automatically serve another. Building it deliberately with target markets in view makes it reusable where rules allow. NMi Certin is a notified body under the MID with a scope covering EV chargers, keeping that route in view alongside national ones.

Where to start

Begin with one charger and the existing reports. Review them against Spanish requirements to see what can be reused, what still needs testing, and whether design changes are necessary.

Request an evidence review for Spain.

Based on Orden ITU/1475/2024 (Anexo XX to Orden ICT/155/2020) and Directive (EU) 2026/706, as of publication. For information only; conformity assessment decisions remain with the competent authorities.