CROSS-STANDARD public interest · EV charger

China-to-Bulgaria EV Charger Compliance Gap Matrix

AI-compiled from official public sources — cross-checked by multiple AI models, not human-verified. Informational only; see disclaimer. Public-interest, source-linked comparison of common China EV charger documentation against Bulgaria (BDS/EWRC/ESO) and EU CE framework expectations, including IEC 61851, IEC 62196-2 Type 2/CCS2 compatibility, AFIR obligations, electrical protection-device requirements, and national installation rules.

Dataset 2026-06-11 Last verified 2026-06-15 8 rows

Compliance Gap Matrix

Gap matrix
Compliance item Common China baseline Bulgaria (BDS / EWRC / ESO) Gap / action Source + verification date
AC Charging Connector Standard (Type 2) — Bulgaria China uses GB/T 20234.2 for AC charging, which defines a physically distinct 7-pin connector incompatible with IEC Type 2. GB/T plugs cannot mate with EU Type 2 sockets.GB/T 20234.2-2015 (AC EV charging connector, China) EU public AC recharging points are subject to AFIR (Regulation (EU) 2023/1804) requirements for connector availability. AFIR Annex II specifies Type 2 for normal-power AC recharging points. IEC/EN 62196-2 describes the Type 2 technical connector design; the legal obligation is AFIR, while the IEC/EN standard is the technical specification route. Bulgaria as an EU member state is directly bound by AFIR, which entered into force 13 April 2024.IEC 62196-2 (Type 2 AC connector)
EN 62196-2
Regulation (EU) 2023/1804 (AFIR), Art. 4 & Annex II
Directive 2014/94/EU (AFID) [superseded by AFIR]
Hardware connector is physically incompatible. A Chinese EV or EVSE designed only around a GB/T AC interface cannot interoperate with EU public Type 2 AC infrastructure in Bulgaria without a physical inlet/socket and control-interface redesign. The connector body, pin count, and locking mechanism all differ. Any adapter strategy for public infrastructure must be checked against AFIR and Bulgarian local safety rules rather than treated as a substitute for compliant connector design.[INFORMATIONAL] Non-compliant for EU/Bulgarian public charging interoperability as-is if the product only supports GB/T AC. EU public AC infrastructure must meet AFIR connector requirements, and IEC/EN 62196-2 Type 2 is the technical specification used for that route. GB/T AC interfaces are not a substitute for AFIR-compliant Type 2 compatibility in Bulgaria. Bulgarian Institute for Standardization (BDS)2026-06-15 · reference
DC Fast-Charging Connector Standard (CCS Combo 2) — Bulgaria China uses GB/T 20234.3 for DC fast charging, defining a physically distinct 9-pin connector incompatible with CCS Combo 2. The pin layout, communication protocol (CAN vs. PLC), and inlet shape all differ.GB/T 20234.3-2023 (DC EV charging connector, China) EU public DC recharging points are subject to AFIR (Regulation (EU) 2023/1804) requirements for connector availability. AFIR Annex II specifies Combo 2 for high-power DC recharging points. IEC/EN 62196-3 describes the CCS Combo 2 technical connector design; the legal obligation is AFIR, while the IEC/EN standard is the technical specification route. Bulgaria is directly bound by AFIR as an EU member state.IEC 62196-3 (CCS Combo 2 DC connector)
EN 62196-3
Regulation (EU) 2023/1804 (AFIR), Art. 4 & Annex II
Directive 2014/94/EU (AFID) [superseded]
Hardware connector is physically incompatible. Chinese EVs or EVSE with only a GB/T DC interface cannot fast-charge at Bulgarian/EU CCS2 public stations without hardware and communication-stack redesign. The vehicle/charger communication stack (GB/T 27930 CAN vs. ISO 15118 / DIN 70121 PLC pathways in common EU CCS practice) also differs, compounding the incompatibility beyond the physical plug.[INFORMATIONAL] Non-compliant for EU/Bulgarian public DC charging interoperability as-is if the product only supports GB/T DC. EU public DC infrastructure must meet AFIR connector requirements, and IEC/EN 62196-3 CCS Combo 2 is the technical specification used for that route. GB/T DC interfaces are not a substitute for AFIR-compliant Combo 2 compatibility in Bulgaria. Bulgarian Institute for Standardization (BDS)2026-06-15 · reference
ESO Grid Connection — 230/400 V 50 Hz Bulgarian Network China domestic charger installations are commonly documented under GB/T 18487.1-2023, GB/T 20234 connector standards, GB/T 27930-2023 for DC communication, and local grid-operator acceptance. China domestic supply is 220 V single-phase / 380 V three-phase at 50 Hz. The shared 50 Hz frequency does not mean voltage equivalence: Bulgaria's 230/400 V requires input-voltage, protection-threshold, thermal, and metering validation beyond the China baseline.GB/T 18487.1-2023
GB/T 20234.2-2015
GB/T 20234.3-2023
GB/T 27930-2023
China local grid operator project-acceptance requirements
Bulgaria's electricity supply is operated by a combination of distribution network operators (DSOs) under the regulatory oversight of the Energy and Water Regulatory Commission (EWRC / КЕВР) and transmission coordination by the Electricity System Operator (ESO). The low-voltage context is 230 V single-phase / 400 V three-phase at 50 Hz. That is the same frequency as China but a different nominal voltage from China's 220/380 V baseline. Grid-connected EV charger projects should be treated as site-specific electrical installations requiring DSO supply-capacity review, protection coordination, metering, earthing, harmonic and power-quality review, commissioning, and written project acceptance before energisation.ESO (Electricity System Operator) network connection rules, Bulgaria
EWRC (Energy and Water Regulatory Commission) electricity-sector oversight
IEC 61000 series — electromagnetic compatibility and power quality
IEC 61851-1 — EV conductive charging system general requirements
Bulgaria low-voltage grid — 230 V single-phase / 400 V three-phase, 50 Hz
Exporters must confirm that the charger covers 230 V single-phase / 400 V three-phase at 50 Hz, not only China's 220/380 V settings. Protection thresholds, leakage-current devices, metering accuracy, harmonic emissions, supply-capacity calculations, earthing, surge protection, and commissioning documents should be prepared for DSO/ESO review in Bulgaria. Load management and demand limits should be agreed with the local DSO before shipment. Bulgarian-language technical documentation is expected for local regulatory and DSO acceptance processes.[INFORMATIONAL] Bulgaria-ready EVSE needs DSO/ESO project acceptance and explicit 230/400 V 50 Hz validation. Do not describe the voltage as matching China: only the 50 Hz frequency matches, while nominal voltage differs from China's 220/380 V baseline. Prepare Bulgarian-language documentation for regulatory and DSO acceptance submissions. Electricity System Operator (ESO), Bulgaria2026-06-15 · reference
CE Conformity Assessment — LVD, EMC, RED (if wireless) — Bulgaria In China, EV chargers require China Compulsory Certification (CCC) under the GB/T and GB standards regime. Key standards include GB/T 18487.1 (AC charging system) and GB/T 20234 series (connectors). CCC is a mandatory third-party certification through designated bodies (CABs); it does not involve self-declaration and is structurally different from CE's conformity-based model.GB/T 18487.1-2015 (AC EV charging system)
GB/T 20234.1-2023 (general requirements for connectors)
GB/T 20234.2-2015 (AC charging interface)
GB/T 20234.3-2023 (DC charging interface)
CCC certification (CNCA mandatory)
EV chargers sold in Bulgaria must bear the CE marking, demonstrating conformity with all applicable EU legislation. Bulgaria implements EU directives directly as an EU member state. Wired AC/DC chargers typically fall under LVD (2014/35/EU) and EMC Directive (2014/30/EU); chargers with wireless communication (e.g., Wi-Fi, Bluetooth for smart charging) additionally require conformity with RED (2014/53/EU). Conformity is generally established by manufacturer self-declaration supported by a technical file. Harmonised EN standards are voluntary routes to presumption of conformity, not mandatory legal requirements in themselves. Bulgarian market surveillance is conducted by the Commission for Consumer Protection and the State Agency for Metrological and Technical Surveillance (DAMTN).Directive 2014/35/EU (LVD)
Directive 2014/30/EU (EMCD)
Directive 2014/53/EU (RED)
EN 61851-1 (AC EV charging)
EN IEC 61851-21-2 (EMC for off-board EV chargers)
EN 55032 / EN 55035 (EMC emissions/immunity)
Regulation (EU) 2019/1020 (market surveillance and product compliance)
Chinese manufacturers must obtain CE marking via EU-recognised conformity assessment routes (self-declaration under harmonised EN standards or notified-body involvement for certain RED equipment). CCC certification is not recognised in Bulgaria or the EU and does not substitute for CE. Manufacturers must generate EU-specific technical documentation, test reports referencing EN standards, and an EU Declaration of Conformity — none of which are produced as part of the CCC process. An EU Authorised Representative must be appointed if no EU importer is established. Bulgarian market surveillance authorities (DAMTN) may require Bulgarian-language documentation and labelling.[INFORMATIONAL] CE marking is mandatory before placing EV chargers on the Bulgarian market. CCC does not substitute for CE. Manufacturers must independently build EU technical files and, for wireless-enabled chargers, ensure RED compliance where applicable. Harmonised EN standards may support presumption of conformity but are not the mandatory legal obligation themselves. Energy and Water Regulatory Commission (EWRC), Bulgaria2026-06-15 · reference
EU Economic Operator / Authorised Representative — Regulation (EU) 2019/1020 — Bulgaria China has no direct regulatory equivalent requiring a domestic responsible operator for export-bound products. Chinese manufacturers exporting abroad appoint foreign distributors or agents commercially, but there is no statutory requirement to designate an EU-resident legal representative responsible for CE compliance and market surveillance cooperation.N/A — no direct Chinese equivalent Regulation (EU) 2019/1020 on market surveillance and product compliance requires that products placed on the EU market have an identifiable 'responsible economic operator' established in the EU. For products manufactured outside the EU, this means the importer or, if no EU importer, a mandated EU authorised representative (Art. 4). The responsible operator must hold the DoC and technical file or ensure they are accessible; cooperate with market surveillance authorities (including DAMTN in Bulgaria); and take corrective action if a product is non-compliant. This obligation applies to EV chargers as CE-marked electrical equipment sold in Bulgaria.Regulation (EU) 2019/1020, Art. 4 (responsible economic operator)
Regulation (EU) 2019/1020, Art. 5 (obligations of importers)
Regulation (EU) 2019/1020, Art. 8 (market surveillance obligations)
This is a structural gap with no Chinese regulatory analogue. A Chinese EV charger manufacturer shipping directly to Bulgarian customers must appoint an EU-established authorised representative before the first unit enters the Bulgarian/EU market. Without one, the product cannot legally be placed on the market under Regulation 2019/1020. The AR must be named on the product label or documentation. DAMTN in Bulgaria may conduct random market surveillance audits and can require product recalls if compliance cannot be demonstrated.[INFORMATIONAL] Chinese manufacturers without an EU importer must appoint an EU-established authorised representative before selling EV chargers in Bulgaria. This is a hard legal gate under Regulation 2019/1020 — no EU AR means the product cannot lawfully enter the Bulgarian/EU market, regardless of CE marking status. Energy and Water Regulatory Commission (EWRC), Bulgaria2026-06-15 · reference
OCPP, EMC, Radio Modules, and Power Quality — Bulgaria EV Chargers China DC fast chargers commonly use GB/T 27930-2023 CAN communication between the off-board charger and vehicle BMS. This is not OCPP back-office communication and is not the CCS2 communication direction. China-market chargers may also include China-specific payment, SIM, cloud, and operator integrations that need reconfiguration for Bulgarian operators, roaming, language, currency, and data interfaces.GB/T 27930-2023
GB/T 18487.1-2023
China operator-specific back-office protocols
China radio module approvals where applicable
Networked EV chargers in Bulgaria should be specified for OCPP back-office interoperability where a charge-point operator, commercial, or public-sector project requires remote monitoring, billing, diagnostics, or load management. Electrical and electronic emissions and immunity evidence should align with IEC 61000 EMC and power-quality standards, consistent with the EU EMC Directive 2014/30/EU requirements for CE marking. Cellular, Wi-Fi, RFID, payment, or smart-metering modules may trigger additional requirements under RED (2014/53/EU), Bulgarian communications authority spectrum regulations, cybersecurity frameworks, and data-interface standards under AFIR for publicly accessible recharging points.OCPP — Open Charge Point Protocol for networked EV chargers
IEC 61000 series — electromagnetic compatibility and power quality
IEC 61851-24 — digital communication between DC EV charging station and EV
Directive 2014/30/EU (EMCD) — mandatory for CE marking in Bulgaria
Directive 2014/53/EU (RED) — mandatory for wireless-enabled chargers
Regulation (EU) 2023/1804 (AFIR) — data and digital connectivity requirements for publicly accessible recharging points
Bulgarian communications authority spectrum and radio equipment requirements where applicable
Exporters must confirm the OCPP version, charge-point-management-system integration, remote diagnostics, load management, payment or RFID flow, SIM or communications module approval path (including Bulgarian spectrum authority requirements), and IEC 61000 EMC reports for the final Bulgarian configuration. For DC CCS2 products, GB/T 27930 must not be presented as the relevant communication evidence. Where AFIR applies (publicly accessible recharging points), data access, digital connectivity, and smart-charging obligations must be addressed. Bulgarian-language UI, instructions, and documentation are expected for local operators.[INFORMATIONAL] Bulgaria networked EV chargers should be validated for OCPP integration, IEC 61000 EMC and power quality, RED compliance for wireless modules, and local communications-module requirements under Bulgarian spectrum authority rules. GB/T 27930 alone does not satisfy OCPP, CCS2 communication, or back-office interoperability needs. Bulgarian Institute for Standardization (BDS)2026-06-15 · reference
Low Voltage Safety — EV Charging Equipment (General) — Bulgaria China commonly references GB/T 18487.1-2015 (Electric vehicle conductive charging system — General requirements), which is technically aligned with IEC 61851-1 but incorporates national deviations. It is enforced under the GB framework administered by SAMR/SAC. GB/T 18487.1 testing and certification by a Chinese CNAS-accredited lab is NOT recognised as equivalent to EN IEC 61851-1 testing under the EU LVD conformity assessment pathway applicable in Bulgaria.GB/T 18487.1-2015 — Electric vehicle conductive charging system — General requirements (SAMR/SAC) EV charging equipment placed on the Bulgarian market must comply with the Low Voltage Directive 2014/35/EU, ensuring it is designed and manufactured to be safe when correctly installed and maintained. Equipment must meet the Essential Safety Requirements (Annex I) covering protection against electric shock, insulation, overcurrent/overtemperature protection, and clearances. Harmonised standard EN IEC 61851-1:2019 (Mode 1–4 conductive charging, AC and DC, general requirements) provides a presumption of conformity. Bulgaria implements LVD directly as an EU member state with no confirmed national derogations as of mid-2026. Market surveillance is conducted by DAMTN (State Agency for Metrological and Technical Surveillance).Directive 2014/35/EU (Low Voltage Directive)
EN IEC 61851-1:2019 — Electric vehicle conductive charging system — Part 1: General requirements
Exporters should build an EU conformity file against the LVD essential safety requirements and may use EN IEC 61851-1:2019 testing as evidence for presumption of conformity. Existing Chinese GB/T 18487.1 test reports do not automatically substitute because scope, deviations, connector assumptions and documentation differ. A Notified Body is not mandatory for LVD; manufacturer self-declaration with a Technical File is the normal route. Documentation gap: EU Declaration of Conformity, CE marking, and instructions in Bulgarian language are all required for the Bulgarian market.[INFORMATIONAL] CE marking under LVD 2014/35/EU is mandatory before placing EV chargers on the Bulgarian market. EN IEC 61851-1:2019 is a voluntary harmonised standard that can grant presumption of conformity for general EV conductive charging; it is not the legal obligation itself. Chinese GB/T 18487.1 certification does not by itself satisfy the EU conformity assessment pathway applicable in Bulgaria; EU evidence against the LVD requirements is needed, along with Bulgarian-language instructions. Bulgarian Institute for Standardization (BDS)2026-06-15 · reference
Electrical Installation Safety — EV Charging in Buildings (IEC 60364-7-722) — Bulgaria China addresses EV charging installation primarily through GB 50966-2014 (Code for design of electric vehicle charging station) and GB/T 51313-2018 (Technical standard for electric vehicle charging infrastructure), administered by the Ministry of Housing and Urban-Rural Development (MOHURD). These cover site design and installation but differ from IEC 60364-7-722 in RCD type requirements, earthing system assumptions (TN-S vs. Chinese practice), and load management protocols. Chinese installation documentation is not accepted as evidence of compliance with Bulgarian electrical installation standards.GB 50966-2014 — Code for design of electric vehicle charging station (MOHURD)
GB/T 51313-2018 — Technical standard for electric vehicle charging infrastructure (MOHURD)
Bulgarian electrical installation law and DSO/installer rules govern the building-side circuits supplying EV charging points. IEC 60364-7-722 / HD 60364-7-722 provide the commonly adopted technical installation route covering protective measures (RCD type B or A+DC detection), wiring, earthing, and load management. These standards apply to the building-side installation infrastructure, not the charger product itself, but exported EV chargers should be compatible with these installation requirements so they can be accepted by Bulgarian installers and DSOs. Bulgaria as an EU member state implements HD 60364-7-722 through national adoption.IEC 60364-7-722:2018 — Low-voltage electrical installations — Part 7-722: Requirements for special installations or locations — Supply of electric vehicles
HD 60364-7-722:2018 (CENELEC harmonised document, adopted by EU member states including Bulgaria)
IEC 60364-7-722 / HD 60364-7-722 are installation standards governing fixed wiring and protection devices at the building side. However, exported EV chargers should declare compatibility with Type B RCDs or incorporate internal DC fault protection to allow Type A RCDs under Bulgarian/EU installation practice. A charger that requires installation conditions not achievable under Bulgarian electrical codes will fail field acceptance. Chinese charger datasheets often omit compatibility statements expected by Bulgarian installers and DSOs. Bulgarian-language installation instructions may be required.[INFORMATIONAL] IEC 60364-7-722 / HD 60364-7-722 govern building-side installation practice as adopted through Bulgarian national rules. EV chargers exported to Bulgaria should be compatible with the RCD and earthing requirements expected by installers and DSOs. This is distinct from product-level CE marking under LVD, but non-compatibility can block field installation in Bulgaria. Chinese installation standards (GB 50966 / GB/T 51313) are not substitutes. Bulgarian Institute for Standardization (BDS)2026-06-15 · reference

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