One other and important thing to remember is there is no BS or BSEN standard for an O-PEN device.
This is on the cards but does not currently exist.
Most claim compliance to LVD etc, some also EMCD.
The lack of a standard for O-PEN is a very important point, but it is totally different from the CE marking aspect.
All a CE mark is showing is the manufacturer claims to meet the relevant EU directives. In this case I expect the only ones that apply are the LVD (for electrical power safety) and the EMCD (for surge protection and lack of radio frequency interference).
The lack of information and performance comparisons on who they work ought to be addressed!
I know some O-PEN devices follow the idea covered in amendment 1 (I think) that simply checks if the supply voltage is out of range implying an open PEN might be happening, but that is far from foolproof.
Others like the Zappi charger are, I believe, RCD-like but look at the unbalance on live and CPC combined, indicating that
something is going stray (which could be a live leak to true Earth as traditional RCD detect, or it might be a shock via elevated CPC potential from an open PEN fault, etc). However, that is not really meeting the ADS concept as it only will trip when something (or someone!) has completed the circuit, it would not disconnect simply on open PEN itself. Although you could combine that approach with the out-of-range sensing above for greater fault coverage.
And some (older?) chargers have earth rods, but I don't know it they use that to sense CPC to true Earth voltage and disconnect all conductors (live and CPC) rather like the old VOELCB, or they are basically just a "TT in a box" device with a RCD and the rod is providing the final charger circuit's means of earthing.
