A new Ecodesign Regulation came into force in the EU on 1 July 2021 and there are important implications for machine builders. In addition, the rules in Great Britain are being aligned with those in the EU, and the Northern Ireland Protocol ensures the rules in Northern Ireland are the same as in the EU.
EU Regulation 2019/1781 on electric motors and variable speed drives replaces the existing ecodesign Regulation for electric motors. As well as the motors covered previously, the new Regulation specifies efficiency requirements for smaller motors of 0.12-0.75kW, larger motors of 375-1000kW, 60Hz motors and eight-pole motors. From July 2023, single-phase motors of 0.12kW or above are included.
Furthermore, the Regulation introduces efficiency requirements for VSDs rated at 0.12-1000kW.
There are various exceptions but this article explains the implications for machine builders, not the minutiae of the Regulation.
If a machine is placed on the market in the EU or GB from 1 July onwards, motors or VSDs within it must be ecodesign-compliant if they are within the scope of the new Regulation, regardless of where the machine is manufactured. When the machine is placed on the market, motors or VSDs within it are deemed to be placed on the market or put into service at the same time. Using non-compliant motors or VSDs is illegal.
A copy of the motor/VSD data sheet or manual must be supplied with the machine’s documentation and machine builders should retain a copy. While it would be incorrect to store the ecodesign documentation in the technical file (which relates to machinery safety), it would be logical to hold it in the same place.
Regulation 2019/1781 does not say for how long documentation should be retained but it makes sense to keep it for the same period as the technical file, which is usually ten years after the last product was placed on the market.
EU machine builders can retain the technical file themselves but non-EU machine builders must authorise a person established in the EU to compile the technical file. Many non-EU machine builders also need to appoint an Authorised Representative in compliance with 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.
Hold Tech Files Ltd is based in the Republic of Ireland and can be named as the person authorised to compile the technical file. The company has created a web-based portal for setting this up. In addition, Hold Tech Files can act as an Authorised Representative for non-EU machine builders.
To learn more, visit www.holdtechfiles.eu or email [email protected]
