A new Ecodesign Regulation came into force in the European Union (EU) on 1 July 2021 and there are important implications for machine builders placing machines on the market in the EU. In addition, the UK Government is legislating to align the rules in Great Britain with those in the EU. The Northern Ireland Protocol, which was agreed when the UK left the EU, means the rules in Northern Ireland are the same as those in the EU.
What is the new Regulation?
The new EU Regulation on electric motors and variable speed drives (EU) 2019/1781 repeals and replaces the existing Regulation on ecodesign for electric motors (EC) No 640/2009. Machine builders should be familiar with the old Regulation, which covered single-speed, three-phase 50Hz or 60/60Hz induction motors with two to six poles, a rated output of 0.75 to 375kW and a rated voltage of up to 1000V. Based on continuous duty operation, motors had to have energy efficiency classes of IE3 or IE2 if powered via a variable-speed drive (VSD).
In addition to the motors covered by the previous Regulation, the new Regulation lays down efficiency requirements for smaller motors of 0.12 to 0.75kW, larger motors of 375kW to 1000kW, 60Hz motors and eight-pole motors. From July 2023, the rules also encompass single-phase motors rated at 0.12kW or above.
Furthermore, the new Regulation introduces energy efficiency requirements for variable-speed drives rated at 0.12kW to 1000kW.
There are various exceptions, such as motors that do not operate continuously, motors integrated within other products such that their energy efficiency cannot be tested independently, motors with integrated VSDs and motors designed for use in extreme operating conditions. However, this article seeks to explain the implications for machine builders, not the minutiae of the new Regulation.
Which machines must use ecodesign motors and drives?
If a machine is placed on the market in the EU or GB from 1 July 2021 onwards, any motor or VSD incorporated within the machine must be ecodesign-compliant if it falls within the scope of the new ecodesign Regulation. This is the case whether the machine is manufactured in the EU, UK or anywhere else in the world. If the machine is placed on the market, then any motors or VSDs within it are also deemed to be placed on the market or put into service at the same time.
In the EU and GB, the supply of non-compliant motors and VSDs will soon dry up because it is no longer legal for them to be sold except as like-for-like replacements. However, in other regional markets there may be less stringent energy efficiency requirements and machine builders in those regions will have access to non-compliant motors. Using these motors in machines sold to the EU or GB would be illegal.
What documentation is required?
Machine builders will be familiar with the European Machinery Directive and the UK equivalent, the Supply of Machinery (Safety) Regulations, but these only cover machinery safety, not environmental issues; ecodesign has nothing to do with the Machinery Directive. Although the technical file might seem the obvious place to file the relevant paperwork demonstrating a machine’s motors and VSDs are ecodesign-compliant, in fact the technical file should only contain the information required by the machinery safety regulations.
According to ecodesign Regulation 2019/1781 Annex I (for motors) and Annex II (for VSDs), the product information must be visibly displayed on (a) the technical data sheet or user manual supplied with the motor/VSD; (b) the technical documentation for the purposes of conformity assessment; (c) free access websites of the manufacturer of the motor, its authorised representative or the importer, and; (d) the technical data sheet supplied with products in which the motor/VSD is incorporated.
It follows that if a motor or VSD is incorporated within a machine, a copy of the relevant data sheet or manual should be supplied with the machine’s documentation.
What to do with the documentation?
As well as supplying the relevant motor/VSD paperwork with the machine’s documentation, machine builders should also retain a copy. While a copy of the motor/VSD data sheet or manual should not be included within the technical file, it is logical to store it with the technical file.
There is nothing in Regulation 2019/1781 that says for how long documentation should be retained but it would make sense for a machine builder to retain it for the same period as for the technical file, which is usually ten years after the last product was placed on the market.
Machine Builders in the EU can retain the technical file themselves but non-EU machine builders must name a person established in the EU on the Declaration of Conformity (DoC) or Declaration of Incorporation (DoI) as being authorised to compile the technical file. Furthermore, from 16 July 2021 many non-EU machine builders will need to appoint an Authorised Representative in order to comply with EU Regulation 2019/1020 on market surveillance. It would be simplest for non-EU machine builders to provide a copy of the motor/VSD documentation to the person authorised to compile the technical file or the Authorised Representative as appropriate.
Hold Tech Files Ltd is based in the Republic of Ireland and can be named on a DoC or DoI as the person authorised to compile the technical file for machinery, partly completed machines and safety components. The company has created a simple web-based portal where machine builders can sign a mandate, pay a fee and upload relevant files to a secure server. The manufacturer is then entitled to name Hold Tech Files on the DoC or DoI for a period of up to ten years. This period can be extended, the files modified or updated, and more products added, all via the self-service portal.
In addition, Hold Tech Files can act as an Authorised Representative for non-EU machine builders.
Follow the links to find out more about naming Hold Tech Files Ltd on the DoC or DoI as being authorised to compile the technical file and appointing an Authorised Representative. Alternatively, visit www.holdtechfiles.eu or email [email protected]
