Suitability of the Measuring Instruments Directive for all meters:
The Measuring Instruments Directive (MID) regulates all meters, including advanced smart meters for measuring energy, weighing instruments, and exhaust gas analyzers. In our view, regulating all meters under the same framework may, at worst, hinder the advancement of a renewable energy–based electricity system, as the directive imposes overly detailed technical requirements. This could prevent the necessary development for harnessing innovation and flexibility. We therefore urge a critical review of whether the current scope of the directive is appropriate considering future developments.
Display requirement in smart meters:
Regarding electricity meters, we believe that the requirement to equip the electricity meter with an integrated display is not necessary in locations where smart energy metering is used.
The Electricity Market Directive (EU) 2019/944 Article 20 (a):
“Smart metering systems must accurately measure actual electricity consumption and be able to provide end customers with information on actual usage time. Verified historical consumption data must be made easily and securely available and visible to end customers upon request and at no additional cost. Unverified near real-time consumption data must also be made easily and securely available to end customers at no additional cost via a standardized interface or remote connection, to support automated energy efficiency programs, demand response, and other services.”
Electricity metering is regulated by other EU regulations, such as the Electricity Market Directive (EU) 2019/944 Articles 20, 21, and 24. If a Member State has smart metering in accordance with Article 20, with data management regulated by Article 21, the requirement for an integrated display in those meters is unnecessary. In Finland, the installation of second-generation smart meters is currently on going.
It should also be noted that Article 24 of Directive (EU) 2019/944 addresses interoperability requirements and data access procedures, which has led to the publication of Commission Implementing Regulation (EU) 2023/1162 on interoperability requirements and non-discriminatory and transparent procedures for access to metering and consumption data.
In-service inspections
We consider it essential to maintain the required level of accuracy in the regulatory framework to ensure the reliability of meters. However, we regard in-service inspections as both irrelevant to include in the directive and inadvisable without thorough impact assessments. Should such inspections be introduced in the revision of the Measuring Instruments Directive, the assessment must take into account the type of measurement, operating conditions, direct and indirect impacts, the overall effect on measurement reliability, and include comprehensive cost-benefit analyses. Given the relatively short technical lifetime of meters, mandatory in-service verification is not appropriate; reliability should be ensured at the manufacturing stage. Any in-service inspections should remain voluntary rather than obligatory.
