48A WattZilla products and NEC compliance

DucRider

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Thought I'd break this out and start a new thread as questions have come up in a couple of other threads/forums as to their 48A products and NEC Article 625 compliance.

The NEC code (2017 & 2020) limits plug-in EVSEs to 50A receptacles. Two products from WattZilla (WallWatts 48 and Black Mamba 48) appear to ship with a 14-60P and would not be code compliant in the US. Their website does mention that the WattZilla can be hardwired, but not the Black Mamba. The documentation and installation instructions for those products does not show or even mention hardwiring or a pigail option in place of the 14-60P.

Both models claim that they comply with Article 625 of the NEC, which clearly they do not. I had a long phone conversation with Frank Gangi of WattZilla, and he claims that they will not ship a 48A version of either of these products to a US address before first calling them and asking if they want the pigtail for hardwiring or the 14-60P. He acknowledged that they do not explain during that call that the 14-60P only meets Canadian safety standards and not US, but says it should be the choice of the consumer and they are not legally obligated to explain electrical code or potential safety hazards. It reiterated that it was not illegal to sell the "Canadian spec" version in the US and that it was completely safe even though it's use violates the NEC and therefore almost all electrical codes in the US.
From the "Safety" section under the "Features" tab on their website:
1594767881905.png


The product brochures/installation instructions contain the same info:
https://www.wattzilla.com/pdfs/Wall-Wattz-Installation-and-Operation-Guide.pdf
Safety Features
WallWattz supports all the safety features required (and a few more) by standards documents for EV charging from standard SAE J1772, NEC and UL including:
UL2251 Standard for Plugs, Receptacles and Couplers for Electric Vehicles
UL2231 Standard for Personnel Protection Systems for Electric Vehicle (EV) Supply Circuits
SAE J1772™ Electric Vehicle Conductive Charge Coupler Standard
NEC Article 625 Electric Vehicle Charging System Equipment

WallWattz is a wall-mounted J1772 charger available in three models:
WallWattz Model 40 requires one independent, properly fused and/or breakered 50 Amp circuit that can be plugged into a 240 VAC outlet 14-50R. WallWattz Model 48 requires one independent, properly fused and/or breakered 60 Amp circuit that can be plugged into a 240 VAC outlet 14-60R.
WallWattz Model 75 requires one independent, properly fused and/or breakered 100 Amp circuit that features a six-foot wire (whip) that can be directly wired directly into an electrical panel.
Doesn't say anything about units shipped to the US coming standard with a pigtail and requiring that a 14-60P be requested by the customer.

https://www.wattzilla.com/pdfs/Black-Mamba-Installation-and-Operation-Guide.pdf
Safety Features
Black Mamba supports all the safety features required (and a few more) by standards documents for EV charging from standard SAE J1772, NEC and UL, including:
UL2251 Standard for Plugs, Receptacles and Couplers for Electric Vehicles
UL2231 Standard for Personnel Protection Systems for Electric Vehicle (EV) Supply Circuits
SAE J1772™ Electric Vehicle Conductive Charge Coupler Standard
NEC Article 625 Electric Vehicle Charging System Equipment
To Charge a Vehicle Using Black Mamba:
1. Plug Black Mamba into a properly grounded 240v 14-50R (Black Mamba Model 40 with 40 Amp output) or 14-60R (Black Mamba Model 48 with 48 Amp output) electrical outlet.

I think that the safety claims are deceptive, and cast some doubt on the other certifications they list. Frank insists he sits on several UL boards and that their products meet all UL and CUL requirements. He also states that UL reviewed their documentation and that the UL approved the statement that their 14-60P products comply with Article 625 of the NEC. I don't know if UL certification reviews all safety claims and the various codes behind them in documentation and on websites before they allow their symbol to be used, but it seems doubtful to me.

I have no idea why their site and documentation makes no mention of a pigtail on 48A products. His response was "there is lots of information that is not in our documentation nor on the site". I think it would be useful for those customers in the US looking to have a code compliant install to know that they will be getting a hardwired unit with a pigtail and not a 14-60P and be able to plan accordingly. Frank disagrees and says it is no problem since they call before shipping.

He claims that using a 14-60 on an EVSE poses no significant safety hazard, but does not think that the claim that they comply with US safety standards when they do not is an issue and at one point said the NEC was wrong to limit plugs to 50A. My beef is not on whether it is safe or not, but with their claim of compliance that is blatantly false.

Do they make a good product? Very likely. Are they completely straightforward and trustworthy? Not in my book. They said basically it was the customers responsibility to verify that the specs on their units do indeed meet the safety standards they claim. NEC compliance is easier to verify than the UL certifications. He insisted that it was clear on the web site that the Canadian versions would not meet US Code, and that the customer would have to specifically request the 14-60P or they would be shipped the pigtail. I looked again after the phone call and could find no mention anywhere of this policy.

It has come up in multiple forums that I am active on where people have looked at the Wattzilla site and insisted that a 14-60P meets the NEC because it is stated clearly on the website that it does. It is often then asked how they can get away with selling it in the US, and the answer is just as Frank asserted - " it is not illegal for us to sell a product that does not meet NEC". Is it false or deceptive advertising? Perhaps.

It is important to note that this affects only the 48A versions of the WallWatts and Black Mamba as they are the only products that ship with a 14-60P.

Caveat Emptor.
 

ajdelange

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All this just makes my head spin. Yesterday in another thread I posted an article from NEC 2020. Here it is again. The reason I am posting it again is because the bottom got cut off:

625.png


The relevance of this to the current subject lies in the definitions of (A), (B) and (C).

(A) refers to a unit that is intended to travel with the car. Examples would be Tesla's UMC, Rivian's equivalent, whatever form that may take, and the 40A BlackMamba.

(B) refers to a unit that is attached to a supporting structure but can be removed without the use of tools for easy relocation. The only example I can think of is the Black Mamba as you can get wall brackets for it.
bracket.png


(C) refers to units that are attached to the structure and which require tools to remove. Examples of this would include the Tesla HPWC (including the one with the 14-50P plug which they no longer make), the EVSE sold on Amazon (that aren't clearly portable) and all the WattZilla offerings except the Mamba.

Anything of Type (C) must be hard wired. Thus none of the Wattzilla plug equipped units (except the 40 A Mamba) are compliant with NEC 2020. But then neither are the Juice Box or Charge Point or any of the dozen or so other plug in wall chargers offered on Amazon that require a screwdriver to get off the wall.

Then we have Juice Box's installation instructions advising that receptacles installed for use with their plug in units should not be on GFCI protected circuits because their equipment has that protection built in as required by
PPS.png


But that recommendation violates
GFCI.png


So anyone who installs a Juice Box per its manufacturers instructions is technically in violation of 625.54? Looks as if there are dozens of non code compliant installations going into American residences every day.

Dammit Jim, I'm an engineer, not a bloody lawyer. I try to do what works, seems safe, is compliant with the code to the extent that it can be and if not is never seen by an inspector. I have a Wattzilla 48 A BlackMamba which I can plug into a NEMA 14-50R which is not on a GFCI breaker. This receptacle was not installed for the connection of EVSE and so requires no protection other than a normal 50A breaker and proper size wire. I can plug the Black Mamba into it and charge my car at 48A from it. Is this a code violation? I don't think so because the code generally does not concern itself with what may be plugged into premises wiring but rather tries to insure that premises wiring meets certain standards. This receptacle does meet those standards. But 625.54 does indeed impose requirements on a receptacle if it is installed for charging vehicles. But there is no prohibition against taking your Tesla UMC into your bedroom, plugging it into a 120V outlet there and running the cable out the window to your car to charge it. There is no code violation there (as long as the bedroom outlet was wired properly) and I don't see, therefore, a violation in plugging a 48A charger into a properly installed 50A outlet sans GFCI either.

As an engineer I understand the difference between intermittent and continuous loads and the reason why EVSE circuits need to be derated. As such I can reason that if I want to charge from that receptacle at 48 A I should do it for periods less than 3 hr. And etc. The problem with my approach is that the even cleverest of fellows are sometimes hoist with their own petards. Just to be clear I do not charge my car with the BlackMamba. It goes with the car on trips into remote areas so I can charge from any 14-30, 14-50 or 14-60 receptacle should the need arise but it hasn't so far. This is usually in Canada where the unit is, AFAIK, completely compliant (except for a small mod - which Frank would not do).

So I am willing to cut him some slack. But, like everyone else I'd like the advertising and promotional material to be a bit less disingenuous.

As a final comment I'll point out that 625.44(B)(3) requires "A non locking, 3 pole, 4 wire grounding-type receptacle outlet rated 250V, single phase, 30 or 50 amperes" and that the NEMA 14-30R and 14-50R obviously meet those specs. But so does the 14-60. All 3 are actually 60A receptacles. The only difference between 14-30, 14-50 and 14-60 is a pin that is not used in Level 2 EVSE - the neutral pin. Thus the plug/receptacle we are thinking disqualifies the 48 A Watzillas from NEMA 2020 compliance is disqualified because of a pin that isn't used. I think this gives Mr. Gangi some ammunition.

My bottom line in all this is always the same. Get an electrician who knows what he is doing (I realize that this is not as easy as it sounds - it took me years to find one) and who knows what the inspectors in your area want (and I don't mean 20 dollar bills folded into matchbook covers).
 
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ajdelange

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Lawyer hat on here:

The NEC code (2017 & 2020) limits plug-in EVSEs to 50A receptacles. Two products from WattZilla (WallWatts 48 and Black Mamba 48) appear to ship with a 14-60P and would not be code compliant in the US. Their website does mention that the WattZilla can be hardwired, but not the Black Mamba...

Both models claim that they comply with Article 625 of the NEC, which clearly they do not.
It occurs to me that the question in not "Is this EVSE compliant with NEC?" but rather "Can this EVSE be installed such that it is compliant with NEC?". The WallWatts 48 can be installed such that it is compliant with NEC if it is hard wired (which it can be).

The BlackMamba 48 is a different story. There is no way it can be described as other than portable or fastened in place and thus cannot be plug installed in compliance as there is a plug limit of 50 A for portable or fastened in place EVSE.
 

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Anyone have any thoughts on the pros/cons of the red coiled charging cable offered as a factory upgrade to the Wall Wattz? Or thoughts in general on the cables used on the WattZilla products? They seem pretty substantial, are they still relatively flexible - especially in cold weather where they may get a bit stiffer (I know, wrong time of year to ask)?

Also, it's a bit disappointing that the Wall Wattz residential warranty is only 1 yr whereas cheaper "smart charger" alternatives from ChargePoint and JuiceBox offer 3 yr residential warranties.
 
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