Concerns about Tesla to non-Tesla charging adapters

[GSP]

It's all fine and dandy talking about altruistic causes and what should happen, but ultimately those HPWCs were donated for use by Tesla customers, not other EVs (Tesla deliberately donated separate J1772 for other EVs). When a Tesla owner pulls up to find another car charging using such an adapter (at 3-6x slower rate), I'm not sure they would be perfectly fine with that. And if Tesla hears complaints about it, I don't think Tesla will hesitate to assert their design patent / trademark rights in regards to the Model S connector/socket.

Don't forget that Telas sold a lot of those HPWC's to private businesses and individuals. They own them. If they want to charge other brands of EVs with them, Tesla would be very wrong to try to stop them.

Do even the donated HPWCs come with strings attached? Tesla likely only requires the recipients to install and maintain them, nothing more.

GSP

 

[stopcrazypp]

But are you saying it's perfectly fine for a Tesla to use a J1772 station with the Tesla adapter regardless of who the intended audience of that station was?

EDIT: Case in point: There is a shopping center near me with a HPWC and 2-J1772 stations. If the HPWC is occupied, can I use the J1772 station?

It is asymmetrical in that case since the Tesla would always be able to charge at a higher power and likely max out the J1772. Ultimately J1772 are intended to be used by everyone (including Teslas).

Installing a HPWC implies they intended Tesla usage given there is still yet no practical adapter and it is a proprietary connector. They could have installed three J1772 (1 20kW J1772 and 2 lower power J1772) if they intended them to be used by all EVs equally.

 

[TexasEV]

But are you saying it's perfectly fine for a Tesla to use a J1772 station with the Tesla adapter regardless of who the intended audience of that station was?

EDIT: Case in point: There is a shopping center near me with a HPWC and 2-J1772 stations. If the HPWC is occupied, can I use the J1772 station?

A public J1772 station doesn't have an "intended audience" of a specific make of car. A charging station with a proprietary connector does.

 

[stopcrazypp]

Don't forget that Telas sold a lot of those HPWC's to private businesses and individuals. They own them. If they want to charge other brands of EVs with them, Tesla would be very wrong to try to stop them.

Do even the donated HPWCs come with strings attached? Tesla likely only requires the recipients to install and maintain them, nothing more.

GSP

Tesla is unlikely to micromanage how the owners would like to use their HPWC. So the answer is no, I don't expect Tesla to prohibit that (other than perhaps suggestion if customers bring it up).

However, I'm talking about something more narrow, which is the cloning of the Model S socket in order to make an adapter to J1772 (the subject of this thread). We have examples of third party adapters between Roadster and Model S, but that still services Teslas exclusively. However, for Tesla to J1772, Tesla might assert their patent rights. I can see the B-Class and RAV4 EV getting away (as they used Tesla derived 10kW chargers), but if a Leaf uses it, I'm not sure.

There's also the example of the JESLA, but that is swapping the Tesla connector to J1772 and ultimately there are no design patent issues. Similarly, if a HPWC had the connector swapped to J1772, Tesla might not be able to do anything. However, using a cloned Tesla connector to J1772, Tesla does have design patents they can assert in that case.

 

[mknox]

It is asymmetrical in that case since the Tesla would always be able to charge at a higher power and max out the J1772. Ultimately J1772 are intended to be used by everyone (including Teslas).

Installing a HPWC implies they intended Tesla usage given there is still yet no practical adapter and it is a proprietary connector. They could have installed three J1772 (1 20kW J1772 and 2 lower power J1772) if they intended them to be used by all EVs equally.

Interestingly, the HPWC and J1772s in my scenario are all set for 32 amps delivered (40 amp breaker), probably due to building capacity. So there's no advantage to me to use one over the other.

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A public J1772 station doesn't have an "intended audience" of a specific make of car. A charging station with a proprietary connector does.

Like a CHAdeMO?

 

[stopcrazypp]

Like a CHAdeMO?

CHAdeMO used to be proprietary. It is no longer proprietary and was adopted as an international IEC standard in March 2014 (and as an open Japanese JIS national standard in late 2012). Back before that happened, people trying to reverse engineer it were worried about getting into legal issues, but now there is no such worry.

However, Tesla's connector is strictly proprietary at the moment with no indication of any effort to make it "open" or an industry standard.

 

[m6bigdog]

It makes total sense to have a Tesla-to-J1772 adapter. This will allow all of the facilities with HPWC destination chargers to be used with J1772 capable vehicles. It also gives a two EV household with a Tesla the ability to charge the non-Tesla using the HPWC.

However, the Tesla HPWC is specifically for use with a Tesla only, specifically stated: HPWC is not to be used with other vehicles and therefore using it on another vehicle will void the UL listing (the authorization that allows the code approval & installation) and I assume the Tesla warrantee.
Hence, I anticipate if this abuse of the Tesla HPWC product listing becomes common Tesla will either need to approve the use (revise the installation manual) or condemn the practice.
Stay tuned!!

 

[mknox]

However, the Tesla HPWC is specifically for use with a Tesla only, specifically stated: HPWC is not to be used with other vehicles and therefore using it on another vehicle will void the UL listing

Where is that stated? (Not saying it isn't... I just couldn't find the reference).

 

[gg_got_a_tesla]

Photo evidence: Tesla Adapter to J-Plug (on a Mercedes B-Class EV!)

There's indeed this warning on page 6 of the HPWC install guide:

The Wall Connector is designed only for charging a Tesla vehicle (excluding Tesla Roadster). Do not use it for any other purpose or with any other vehicle or object.

https://my.teslamotors.com/sites/default/files/blog_attachments/wall_connector_install_guide_northamerica.pdf

 

[mknox]

There's indeed this warning on page 6 of the HPWC install guide:

Thanks. I should have thought to look there. The install guide has a bunch of warnings, like this one:

That looks to me like its shouldn't be installed outdoors, because even dew forming on it would constitute "moisture" which it "must be protected from". I wonder how much of those warnings would ever be enforced.

 

[m6bigdog]

Thanks. I should have thought to look there. The install guide has a bunch of warnings, like this one:

View attachment 98586


That looks to me like its shouldn't be installed outdoors, because even dew forming on it would constitute "moisture" which it "must be protected from". I wonder how much of those warnings would ever be enforced.

It would seem that particular text is confusing to the user that does not typically evaluate the interior appearance of the wall charger: "Protect the WC... at all times. If any exist or appear to have entered, damaged, or corroded the Wall Connector, do not use...".
However, for the installer or electrical inspector (AHJ) this statement is telling them the Wall Charger should be protected before installation, during installation and the case should remain sealed while in use, therefore none of the referenced conditions (moisture, water, liquid, foreign objects, corrosion) are allowed inside or should never appeared to have entered the Wall Connector.

Having gone through a UL Listing review process (many comment and rewrite cycles) to meet the requirements of a UL Standard (EVSE UL2594), the UL standard review process can include adding text to the User/Installation Manual that seem redundant, confusing, obvious, unnecessary, etc, to the casual/critical reader or user but strategically necessary to get the manual accepted/approved. Kind of like the NEC, not an ideal document but at least it is accepted/approved!!
In Tesla's defense; you can be sure the Tesla Wall Connector Installation Manual is a collaborative effort with recommendation from several UL Standards reviewers and therefore is not a solely authored Tesla document.

As for enforcement:
1. Tesla cares, as if they do not enforce the current accepted/approved conditions of use requirements (i.e., build an adapter that allows using the WC to charging other manufacture cars) they could loose the current UL listing and the Wall Connector could no longer be installed/used under the NEC requirements. UL has the power to force a product recall!!
2. UL cares, as they have listed the product based on their product standards and Tesla's written instruction that define the installation requirement and conditions of use. UL has a follow-up program that reviews actual failures that are brought to their attention, unapproved modifications to the WC and conditions of use.
3. Insurance Co. cares, If something should happen (fire, electric shock, etc.) that is associated with the WC, the installation/conditions of use will be examined and any use outside the written conditions of use will most likely drive the insurance companies decisions on liability, so they will care!!
4. User's should care, however some would seem to project, they paid for it, it is theirs to do with as they please; however nothing is further from the truth..

 

[FlasherZ]

UL cannot force a product recall based on someone's misapplication of the device. Misapplication by an end-user does not cause the device to "lose its listing" in general and does not result in liability to Tesla.

Rather, it results in liability to the persons misusing the device. For example, the application of the adapter discussed here means that the HPWC's UL listing is not necessarily valid for the application as installed (arguable, although it would still meet the requirements of the UL standard for which the device is certified). This would seem to conflict with the NEC 2014 625.5 requirement that "all electrical materials, devices, fittings, and associated equipment shall be listed", meaning that NEC was violated. But more importantly, disregarding the whole issue of listing, it violates 110.5 which says that manufacturer's instructions shall be followed.

It is a myth that all appliances must be UL listed to attach it to the power grid. UL would love for you to believe that, but it's not true. In this case, it's only true insofar as the NEC attempts to have jurisdiction over EVSE equipment. You may be able to mount a successful defense that the EVSE (e.g., UMC) is part of the appliance and therefore is not subject to NEC. Not a good idea to try it, but you may be able to make that argument.

(I'm guessing that Tesla makes that very argument in its offering the UMC. Technically, it's EVSE and therefore would be subject to 625.5, but the UMC isn't listed. Seems like they're cleaning that up in Canada with the cUL listing there.)

 

[m6bigdog]

UL cannot force a product recall based on someone's misapplication of the device. Misapplication by an end-user does not cause the device to "lose its listing" in general and does not result in liability to Tesla.

Rather, it results in liability to the persons misusing the device. For example, the application of the adapter discussed here means that the HPWC's UL listing is not necessarily valid for the application as installed (arguable, although it would still meet the requirements of the UL standard for which the device is certified). This would seem to conflict with the NEC 2014 625.5 requirement that "all electrical materials, devices, fittings, and associated equipment shall be listed", meaning that NEC was violated. But more importantly, disregarding the whole issue of listing, it violates 110.5 which says that manufacturer's instructions shall be followed.

It is a myth that all appliances must be UL listed to attach it to the power grid. UL would love for you to believe that, but it's not true. In this case, it's only true insofar as the NEC attempts to have jurisdiction over EVSE equipment. You may be able to mount a successful defense that the EVSE (e.g., UMC) is part of the appliance and therefore is not subject to NEC. Not a good idea to try it, but you may be able to make that argument.

(I'm guessing that Tesla makes that very argument in its offering the UMC. Technically, it's EVSE and therefore would be subject to 625.5, but the UMC isn't listed. Seems like they're cleaning that up in Canada with the cUL listing there.)

IMHO, it is more complicated than who and what...
"UL cannot force a product recall based on someone's misapplication of the device" I didn't say that, however an end-user with a valid product complaint can start the ball rolling to a product investigation by UL.

Also, In this situation, the Tesla connector to J1772 adapter charging the Benz EV was at a Tesla Service Center and therefore an applied acceptance by Tesla of the adapter and misuse of the Tesla WC listing. Employee's car? employee's made the adapter? doesn't mater the facility is owned and operated by TMC and they will be held responsible for managing all activities onsite.
Beyond that, OSHA Safety Standards (29CFR1919 subpart S) have requirements for workplace safety and mandated use of only NRTL equipment in all but a very limited applications. However, a home brew non-listed electrical extension cord adapters are a BIG NO-NO!! With that, the adapter extends the EVSE cord beyond the NEC 25' limit and is essentially a series extension cord. The first question to ask is why not install an approved J1772 EVSE that can also charge a Tesla with the J1772 adapter?

As for plug-in portable/mobile consumer appliances/equipment such as the UMC, the US has yet to require an NRTL consumer product Listing (manufacture self-certified as safe is good enough) as it is not installed or fixed-in-place as part of the wiring or equipment approved by the AHJ and therefore not subject to the NEC.
IMHO, all electrical consumer and commercial equipment/appliances should be NRTL listed (consumer product safety certification), just for the independent product review and follow-up program.

As for who has jurisdiction? the NEC lists the relevant EVSE UL standards in 625 (rare note to the overarching UL standard) and has taken relevant physical compliance information from the UL standards to include in the NEC as a reference for the AHJ. When & if the UL Standards change Article 625 will change as the standard is the engineering for product safety and compliance. Many of the NEC Committee and Code Panel members are from UL as the safety standard and NEC must be consistent...
FWIW, the NEC is a document of how to install NRTL certified wire & equipment and therefore the equipment standards drive the complexity of the code.

Hence, the NEC is an electrical wiring and equipment installation code (enforcement) not the equipment standard (safety compliance). Therefore, the NEC refers to the approval by a Listing Laboratory (NRTL) to meet the equipment safety testing and certification standards for electrical wire and equipment to be installed (UL provides the larges compilation of consensus based safety standards in the world and most NRTL use the UL Standards).

 

[FlasherZ]

Hence, the NEC is an electrical wiring and equipment installation code (enforcement) not the equipment standard (safety compliance). Therefore, the NEC refers to the approval by a Listing Laboratory (NRTL) to meet the equipment safety testing and certification standards for electrical wire and equipment to be installed (UL provides the larges compilation of consensus based safety standards in the world and most NRTL use the UL Standards).

I don't understand your point, and it doesn't address mine.

My point was a simple one: the NEC generally has no jurisdiction over an appliance. There is a reasonable argument that EVSE can be considered part of the appliance, rather than part of the infrastructure. If found to be the case, NEC would have no jurisdiction and article 625 would have no teeth beyond the wiring methods necessary to connect to the appliance (EVSE), the same way it has only jurisdiction to dictate how a hardwired clothes dryer may connect but cannot dictate requirements for internals or safety features of the dryer. It doesn't matter how popular the UL is, or how expensive their standards are.

I admit that the NEC has jurisdiction to require listed wire, fittings, conduit, junction boxes, etc. as part of wiring methods - but extending 625.5 to require UL listing of EVSE is stretching it.

Off-topic - I'd also like to see listing requirements for consumer devices, but perhaps for a different reason. The UL runs a great extortion scheme selling its standards (I'm not referring to the testing service). Making listing a requirement to sell a product would result in the same effects as codifying NEC - the standards would be made available for free by codifying them as law. It would seriously shake up that extortion scheme and make it easier for products to come to market.

 

[Rocky_H]

the standards would be made available for free by codifying them as law.

You would think so, since that would be common sense, but that is still being fought in some jurisdictions. I have read of several cases where there are building codes and standards that are required and included by reference as law, but are not publicly available and have to be purchased at pretty high prices from the standards organization that writes and holds them. The purchase agreements for buying the document of building codes forbids copying or publishing them openly, as they consider them a private copyrighted document, even though they are also a law. This is incredibly wrong, and some have been trying to push this to court cases by buying and publishing these, in violation of their purchase agreements, because the law of the land should not be behind a paywall.

 

[AmpedRealtor]

But why do you think it would just be sitting there? It would probably be taken by a PiP or something almost as useless, then how would you feel if you chose to stay at that hotel because it had Tesla destination charging?

Well, I was more intending that it could be used when there wasn't a Model S needing a charge. It's definitely a good option for a two EV household where only one EV is a Model S. That way, one HPWC can charge both cars.

- - - Updated - - -

In theory Tesla has no problem with other manufacturers charging at Supercharger Stations provided that the battery is large enough to take that level of fast charging and if the manufacturer pays the "cost of admission". In my opinion the same principal would apply to HPWCs. That is, Tesla would not want other manufacturer's EVs that charge as low as 3.3 kW to be displacing Tesla owners at HPWCs that are capable of charging at up to 20 kW. As I mentioned upthread, I believe that Tesla would enforce their patent rights if sufficient numbers of adapters were being marketed for the purpose of tying up HPWCs with slow charging EVs from other manufacturers. As I stated earlier, Tesla is accelerating the adoption of other makes of EVs by donating J1772 chargers. They don't have to inconvenience their own customers by permitting the misuse of HPWCs via the use of an unlicensed adapter.

Larry

Most of what you posted above is your personal opinion, not the position of Tesla. I find EV class warfare unsavory.

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A public J1772 station doesn't have an "intended audience" of a specific make of car. A charging station with a proprietary connector does.

I paid for my HPWC, it was not donated. I should be able to buy an adapter for it because then I could allow Leafs, Volts, and other EVs to charge at my home. I hope someone develops such an adapter because it would be very useful by making the HPWC flexible to charge more than just a Tesla. Tesla could also sell HPWCs to Leaf and Volt owners, expanding the market for the HPWC. Why the heck not?

 

[stopcrazypp]

Most of what you posted above is your personal opinion, not the position of Tesla. I find EV class warfare unsavory.

That remains the position of Tesla, as per Elon recently:
"As I've said before, our Supercharger network is not intended to be a walled garden. It's intended to be available to other manufacturers if they want to use it. The only requirements are that the cars must [be able to take the power output] of the Superchargers, and then pay [whatever their proportion of usage is of the system.] We're actually in talks with some manufacturers about doing just that, and it will be exciting to share that news."
https://www.reddit.com/r/teslamotor...we_are_in_talks_with_some_auto_manufacturers/

Tesla's spokewoman also said the same more than a year ago:
"As Elon has repeatedly made clear...we are very open to have [electric vehicles] made by other manufacturers use Superchargers," said an email from Alexis Georgeson, spokeswoman for Tesla. "They’d just have to contribute to the capital cost, such as determining what percentage of the time their cars are using the Supercharger network and making a contribution proportionate to that. The issue of non-Tesla [electric vehicles] currently being unable to use Superchargers comes down to the fact that no other electric car can accept anything close to 135kw, which is the power level of Tesla’s Superchargers."
http://www.usnews.com/news/articles/2014/06/11/elon-musk-talks-teslas-supercharger-future

It makes zero sense to support a slow charging 50kW car with a supercharger network as that is not a good usage of resources, given the cost difference in the hardware vs a standard CHAdeMO charger. It's also going to be frustrating for Tesla owners to see that too. So the condition of using superchargers should force automakers to build something on par with what Tesla has released. In practical terms, a car that can handle the supercharger network distances will likely have a battery large enough to handle the power.

Tesla wants to use their technology to push automakers to make EVs viable for more people. Allowing them to continue to stagnate on 50kW charging speeds does not do that.

It is not class warfare either. There is no reason why an affordable EV can't have 100+kW charging given how rapidly battery costs are falling.

 

[mknox]

That remains the position of Tesla, as per Elon recently:
"As I've said before, our Supercharger network is not intended to be a walled garden. It's intended to be available to other manufacturers if they want to use it. The only requirements are that the cars must [be able to take the power output] of the Superchargers, and then pay [whatever their proportion of usage is of the system.] We're actually in talks with some manufacturers about doing just that, and it will be exciting to share that news."

We're not talking about Level 3 DC fast charging here (aka Superchargers). This discussion is about Level 2 charging. Just because Tesla uses the same port for both, it has no bearing on Level 2 charging.

 

[stopcrazypp]

We're not talking about Level 3 DC fast charging here (aka Superchargers). This discussion is about Level 2 charging. Just because Tesla uses the same port for both, it has no bearing on Level 2 charging.

I misunderstood your point then, I thought you bolded the supercharger part and was referencing that as only Larry's opinion.

 

[mknox]

I misunderstood your point then, I thought you bolded the supercharger part and was referencing that as only Larry's opinion.

No, but I can see where the confusion would come from. Some other EVs have separate ports for Level 1/2 and Level 3 (J1772 and CHAdeMO) and others have the SAE Combo Plug which will allow a J1772 to be inserted or a DC plug with the extra pins. Tesla uses an all-in-one port. Under discussion is whether Tesla Level 2 stations (i.e. HPWC) can be used on other EVs with an appropriate Tesla to J1772 adapter (i.e. the reverse of the adapter that comes with the car. Level 3 Supercharging would be a whole different matter.