A recent legal development in Germany could have serious repercussions for the entire camping sector. Until now, electrical systems in campsites – such as power lines, transformers, and internal networks – were classified as simple “customer installations” and therefore exempt from the strict regulations governing electricity distribution networks.
However, everything changed after two landmark rulings: one by the Court of Justice of the European Union (CJEU) on 28 November 28 (C-293/23), and another by the German Federal Court of Justice (BGH) on 13 May 2025 (EnVR 83/20). The European judges ruled that the German provisions concerning “customer installations” have no basis in EU law and introduce unjustified exemptions. Consequently, the BGH confirmed that installations which, in practice, function as distribution networks can no longer be excluded from regulation.
In practical terms, this means that most German campsites could now be considered operators of regulated electrical networks, a change that entails heavy administrative, technical, and financial burdens designed for large energy companies, not small family-run businesses.
The current regulation
Germany’s Energy Industry Act (EnWG) distinguishes three main types of electrical infrastructure.
- General distribution networks, which are fully regulated and must comply with rules on separation, operational obligations, connection duties, and network access regulation.
- Closed distribution networks, which are partially exempt and apply only when no domestic consumers are supplied, or only a small number of people with an employment or similar relationship with the network operator. This condition excludes campsites.
- Finally, customer installations, a category that until recently included campsites and exempted their operators from the above regulatory obligations.
However, according to recent court interpretations, this classification can no longer apply to campsites, where there are many end users, both permanent and temporary guests. A “customer installation” is defined as a system that distributes energy within a limited area, connected to a grid or a generation source, without affecting market competition, and accessible to all users fairly and free of charge.
In campsites, though, the high number of users makes it impossible to meet this requirement: according to recent case law, any installation serving more than about 200 end users can no longer be considered a “customer installation”.
BVCD’s call for action
The potential impact of this reclassification is enormous. If a campsite with 200 or more pitches were to be regarded as a distribution network, its operator would face the same obligations as a full-scale energy provider, a level of bureaucracy and cost that could threaten the survival of many businesses.
Most campsites in Germany are small or medium-sized, family-run enterprises that simply cannot comply with such demanding regulations. For this reason, the German Federal Association of the Camping Industry (BVCD) has already sounded the alarm. In a joint appeal to policymakers, BVCD and its regional associations are calling for urgent legislative action to clarify and simplify the rules, to protect a sector largely made up of family-owned businesses.
“Camping companies cannot bear the same burdens as major energy utilities,” the Federation warns. “We need a national solution that protects the industry and ensures its future”. The government is therefore called upon to act quickly to prevent the new interpretation of energy regulations from putting Germany’s open-air tourism sector at risk.
Photo: Harry Strauss
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