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Removal of prohibition against switching protective earth neutral (PEN) conductors from Wiring Rules

Aidan Thornton made this Official Information request to Ministry of Business, Innovation & Employment

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From: Aidan Thornton

Background
MBIE is both the administrator for the Electricity (Safety) Regulations and contains Standards New Zealand

The Electricity (Safety) Amendment Regulations 2025 (ESAR25) were published 13 October 2025 and the amendments come into effect 13 November 2025.
Note: being an imminent public safety issue an accelerated processing time is requested.

Issue: PEN Conductor Protections Removed
ESAR25 r12 amends Schedule 2 of the Electricity (Safety) Regulations 2010 (ESR).

ESR Schedule 2 is amended to cite AS/NZS 3000:2018 (…Wiring Rules) subject multiple modifications. The issue raised here is the deletion of clauses 2.3.2.1.2 (b) & (c) from the Wiring Rules.

AS/NZS 3000:2018 clauses 2.3.2.1.2 (b) & (c) provide the only prohibitions preventing the extremely unsafe action that is the installation of switches, fuses or circuit breakers within an installation’s Protective Earth Neutral (PEN) conductor.
In the Multiple-Earthed Neutral system used by New Zealand, the neutral conductor of consumer mains is a PEN conductor.
Important note: the presence of fuses or independent switches/breakers in a PEN conductor can render the installation lethal under normal operating conditions (even with no faults present).

Question 1:
Please provide details of the management of change (or equivalent) procedure associated with this regulatory change (allowing a fuse, independent circuit breaker or switch within the PEN conductor), including requirements for:
• initiation of the process
• requirements analysis (ie justification for the proposed change)
• consultation with industry, the public, and other government entities
• due diligence
• review (internal, peer, and expert)
• detailed technical analysis
• risk/reward and benefit-to-cost-ratio analysis
• required signoffs or gating
• other necessary steps

Question 2:
Please provide all documentation associated with this regulatory change, including but not limited to the above items.

Question 3:
During due diligence prior to the release of ESAR25, what overseas jurisdictions were identified that allow the installation of fuses, switches, disconnects, and/or circuit breakers within Consumer Mains Neutral, Protective Earth Neutral, or Protective Earth conductors of equivalent or similar systems of supply?

End.

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From: NoReplyMinisterialServices
Ministry of Business, Innovation & Employment


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Kia ora Aidan Thornton,
 
On behalf of the Ministry of Business, Innovation and Employment I
acknowledge your email of 6/11/2025 requesting, under the Official
Information Act 1982, the following:
 
Question 1:
Please provide details of the management of change (or equivalent)
procedure associated with this regulatory change (allowing a fuse,
independent circuit breaker or switch within the PEN conductor), including
requirements for:
   • initiation of the process
   • requirements analysis (ie justification for the proposed change)
   • consultation with industry, the public, and other government entities
   • due diligence
   • review (internal, peer, and expert)
   • detailed technical analysis
   • risk/reward and benefit-to-cost-ratio analysis
   • required signoffs or gating
   • other necessary steps

Question 2:
Please provide all documentation associated with this regulatory change,
including but not limited to the above items.

Question 3:
During due diligence prior to the release of ESAR25, what overseas
jurisdictions were identified that allow the installation of fuses,
switches, disconnects, and/or circuit breakers within Consumer Mains
Neutral, Protective Earth Neutral, or Protective Earth conductors of
equivalent or similar systems of supply?
 
We will endeavour to respond to your request as soon as possible, and no
later than 4/12/2025, being 20 working days after the day your request
was received. If we are unable to respond to your request by then, we will
notify you of an extension of that timeframe. If you have any enquiries
regarding your request feel free to contact us via email to
[1][MBIE request email].
 
Nāku noa, nā
Ministerial Services
Strategy and Assurance
Ministry of Business, Innovation & Employment
15 Stout Street, Wellington 6011 |  P O Box 1473 Wellington 6140

References

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