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The Building Electromobility Infrastructure Act (GEIG) - what do real estate owners, prospective buyers and project developers have to consider

20/06/2022

Locations

Germany

1. Background and brief info

The GEIG serves to implement the EU Buildings Directive 2018/844, Article 8 (2) to (6). It requires building owners to provide Charging infrastructure with Charging points for electric vehicles for certain parking spaces located in or on buildings. The GEIG was promulgated in the Federal Law Gazette on 24 March 2021 and has been in force since 25 March 2021.

The aim is to accelerate the expansion of the Charging infrastructure for electromobility in the building sector. The GEIG does not apply to
  • non-residential buildings (= office buildings, administrative and industrial buildings) owned by small and medium-sized enterprises (= less than 250 employees and an annual turnover of no more than EUR 50 million or an annual balance sheet total of no more than EUR 43 million) and predominantly used by these enterprises themselves;
  • Major renovation projects where the cost of Charging and Pipeline infrastructure in the existing building exceeds 7 percent of the total cost of renovating the building (Economic Viability Clause);
  • public buildings if they are already subject to comparable requirements;
  • projects for which the building application or the application for building approval or the building notification was submitted before the entry into force of this Act (25 March 2021) - but which were not completed before the entry into force of the GEIG, as they are otherwise not to be treated as a "project" but as an existing building.
 

2. Legal framework

The main contents of the regulation are the obligation to provide one:
  • "Pipeline infrastructure"
=
The entirety of all cable runs for accommodating electrical and data cables in buildings or in the spatial context of buildings from the parking space via the metering point of a connection user to the protective elements. It includes a suitable cable routing for electrical and data cables that comply with the applicable electrical, construction and data technology regulations. It also includes the necessary space for the metering point.
 
  • "Charging point"
= A facility that is suitable and intended for charging electric vehicles and at which only one electric vehicle can be charged at a time. Relevant minimum requirements that must be observed during installation are, in particular, the Ordinance on Charging Columns (LSV), the DIN regulations specified therein, and Section 19 (2) of the Low Voltage Connection Ordinance (NAV).

 

a. Impact on different building types
The equipment required by the GEIG depends on the type of building and the number of existing or planned parking spaces.
 
Type of building Number of parking spaces Required equipment
Residential building new construction More than 5
  • Pipeline infrastructure for electromobility for every parking space
Non-residential buildings new construction More than 6
  • Pipeline infrastructure for electromobility for at least every third parking space
  • At least one Charging point
Major renovation of existing residential buildings More than 10
  • Pipeline infrastructure for electromobility for every parking space
Major renovation of existing non-residential buildings More than 10
  • Pipeline infrastructure for electromobility for at least every fifth parking space
  • At least one Charging point
Existing non-residential building More than 20
  • At least one Charging point, as of 1 January 2025
Existing mixed-use buildings More than 10
  • Depending on the predominant type of use
Mixed-use buildings new construction (predominantly residential) More than 5
  • See "New residential buildings"
Mixed-use buildings new construction (predominantly non-residential) More than 6
  • See "New non-residential buildings"

For the purposes of the GEIG, a "Major renovation" occurs if more than 25 percent of the surface of the building envelope undergoes renovation and the renovation measure includes the car park or the electrical infrastructure of the building or car park.

This concept is also decisive for the above-mentioned Economic Viability Clause, which exempts some renovations from the application of the GEIG. A detailed examination is required to determine which cost items of a renovation can be used to justify the Economic Viability Clause. The explanatory memorandum to the law must be taken as a basis. This describes a "Major renovation" as a "measure on those components of the building envelope through which the thermal energy demand of the building is directly influenced. These are primarily measures on the heat-transferring enclosure surface, such as the exterior wall or the roof. Such a measure on the exterior wall would be, for example, a renewal of the exterior rendering of the facade. Merely repainting the exterior wall or purely repairing plaster in damaged areas would not be a major renovation in the above sense".

 

b. Concentration possibilities
In order to ensure that the supply of parking spaces with Charging infrastructure and Charging points can be designed as efficiently as possible, the GEIG provides for possibilities to concentrate Charging points.

On the one hand, the owner of several non-residential buildings can collectively install the total number of Charging points to be installed in one or more of his properties, provided that the existing or expected demand for Charging infrastructure in the properties concerned is thereby taken into account. This option also applies to building owners who are obliged to install a Charging point - i.e. primarily in the case of new construction or Major renovation of a non-residential building with a corresponding number of parking spaces.

On the other hand, developers and owners of buildings that are spatially connected can reach agreements on the joint provision of parking spaces with Charging infrastructure or Charging points in order to fulfil their aforementioned obligations - the so-called neighbourhood solution. The involvement of third parties, in particular energy supply companies, is explicitly permitted.

The term "Charging infrastructure" used here must be distinguished from the term "Pipeline infrastructure" explained above. Charging infrastructure in this sense means the sum of all electronic connection, measuring, control and regulation equipment, including overcurrent and overvoltage protection devices, which are necessary for the installation, operation and control of Charging points for electric mobility.

 

3. Conclusion / Evaluation

The GEIG implements a requirement from the EU Buildings Directive for the development of Charging and Pipeline infrastructure for electromobility in the building sector. It is intended to accelerate the expansion of this infrastructure, but not to place too great a burden on owners and builders.

Depending on the type of building and the number of existing or planned parking spaces, owners and developers are obliged to equip these parking spaces in a certain way. In most cases, this obligation is limited to the installation of conduits for electric cables. Charging points are only to be installed in special cases.

In the case of intentional or reckless infringements (= administrative offence), those concerned must expect a fine of up to EUR 10,000.00.

 

Contact

If you have any questions on this topic, please do not hesitate to contact Robert Frühling.

Robert Frühling
Associate
+49 40 87 88 698 295
robert.fruehling@fieldfisher.com
 

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