Who still manufactures energy meters in Europe?
The place of manufacture has quietly become a compliance issue. What the regulations already say, and five things an OEM should verify before choosing a metering partner.
The question of 2026
At our stand at The Smarter E Europe 2026 in Munich in June, the most frequently asked question was not about accuracy class, protocols or price. It was: where is it actually manufactured?
Ten years ago, almost no one asked. Procurement compared datasheets and unit costs, and the answer to the manufacturing question was taken for granted. Today, that question has moved from the last page of the supplier audit to the first email. It comes from OEM engineers, technical procurement teams and, increasingly, quality managers preparing their certification files.
Something structural has changed, and this article explains how an OEM should interpret it. Because the honest answer to the title is: there are fewer energy meter manufacturers in Europe than catalogues suggest.
Twenty years of silent offshoring
Over the past two decades, the economics of electronics manufacturing has shifted most high-volume meter production outside Europe. In many cases, the brands remained European: the logos, sales offices and catalogues. The factories, moulds and often the firmware teams did not.
Trade statistics describe the outcome. None of this happened by accident. It was driven exclusively by a spreadsheet: unit cost, landed price, margin. For twenty years, those were the only columns that mattered. What the spreadsheet did not price in is everything that has since become costly: delivery-time risk, audit access, firmware provenance, and a growing layer of European regulation that assumes you can answer precisely where and by whom a device is manufactured.
A certificate has an address
Start with the regulation already in force, the Measuring Instruments Directive 2014/32/EU: a meter used for billing in the EU is not simply CE marked; it undergoes MID conformity assessment under Annex MI-003, with type testing against the EN 50470 series. For series production, the common routes are Module B (EU type examination) combined with Module D, or Module H1. Module D is the part most buyers have never read and certifies conformity to type based on quality assurance of the production process.
Under Module D, the manufacturer must grant the notified body access to manufacturing, inspection, testing and storage sites. The notified body approves the quality system governing production and continues to verify it through periodic surveillance audits. Site transfers relevant to conformity are assessed on site (WELMEC Guides 8.4 and 8.2 on the application of Modules D and H1).
Read that from the buyer’s perspective: the MID certificate on which your product’s billing conformity relies is not attached to a brand, but to a type and a manufacturing process, at a location that a third party physically verifies. Move the factory, and the assessment moves with it.
A certificate therefore has an address, and this is not a detail: when you integrate a MID meter into a charging station, heat pump or energy management system, your conformity chain runs through that address, whether you have seen it or not.
Regulation is catching up with geography
MID already works this way. The next layers extend the same logic from metrology to information.
NIS2, Directive (EU) 2022/2555, brings supply chain security within the risk-management obligations of essential and important entities: Article 21(2)(d) explicitly covers the security of relationships with direct suppliers. If your customers are utilities, charging operators or industrial operators within scope, questions about your suppliers’ security posture are no longer a courtesy, but part of their compliance. Italy was among the first major Member States to transpose the Directive (with Legislative Decree 138/2024), meaning suppliers based here have been operating within these requirements since 2024.
The Cyber Resilience Act, Regulation (EU) 2024/2847, goes further: for products with digital elements—and a connected meter is one—the CRA makes security a condition of market access, with obligations covering secure development, vulnerability management and updates throughout the product’s lifetime. The main requirements apply from 11 December 2027, while the reporting obligations under Article 14 apply from 11 September 2026. The first operational deadline is weeks away, not years. The practical questions imposed by the CRA require precise geographical answers: who writes the firmware, who can release an update, from where, and under which jurisdiction.
Then there is the Digital Product Passport, introduced by the Ecodesign Regulation (EU) 2024/1781, with product-group rules to follow through delegated acts. It requires structured and verifiable information on materials and supply chains. Provenance is therefore set to become a core part of the documentation.
Three regulations, one direction: where it is manufactured is no longer a marketing question, but a compliance question—yours, not just your supplier’s.
Five things an OEM should verify
If provenance is part of your compliance perimeter, it deserves the same discipline as any other specification. Here are five checks, in increasing order of depth, that an OEM should focus on:
- Where do final assembly and testing actually take place? Not where the brand is registered, but where the production line and test benches are physically located. Ask for the address.
- Under which MID module is the meter certified, and by which notified body? The certificate gives you the number; the module tells you how deeply the manufacturing process itself is verified.
- Who writes and maintains the firmware, and where? The ability to update is a security property. Under the CRA, it becomes a regulated property.
- Where are the moulds? Moulds and test equipment determine how quickly production can restart, move or scale. A supplier that does not control its own moulds does not fully control its delivery times.
- Can you visit? The simplest audit is still a day on site. A supplier whose factory, laboratory and R&D facilities can be visited is making a different promise from one whose supply chain is a diagram.
None of these questions is hostile; they are the same questions a notified body already asks. You are simply extending the audit to your own due diligence.
What we open up to verification
Herholdt Controls designs, tests and manufactures energy meters in a single technical facility in Milan. More than 60% of the team works in R&D. Specification, firmware, validation and production are located at one address, and our meters are MID-certified under Modules B + D by the Italian notified body IMQ, which verifies that address.
We will not publish a map of who manufactures what and where. That is your due diligence, using the five questions above. What we can do is answer in person: the laboratory is one floor above the production line. The door is open.
What all this means for an OEM
The lowest landed price and the lowest total risk are diverging, and European regulation is accelerating that divergence. The MID certificate you rely on is anchored to a verified manufacturing site, and you should know where it is. NIS2, the CRA and the DPP will progressively turn supply-chain opacity from an inconvenience into a liability. And the shortlist of suppliers able to answer five questions without hesitation is shorter than the market suggests.
Investigating early costs one email. Investigating late can cost a certification file.
