EU Ecodesign Press statement

What does the new Ecodesign Regulation mean for machine builders?

A new Ecodesign Regulation comes into force in the European Union (EU) in 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 will be 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.

Solution

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.

Contact details

Alan Scott

e-mail: alan.scott@laicon.us

Cell: 407-716-1963

Note – About Hold Tech Files Ltd

5401, S. Kirkman Road, Suite 310
Orlando
Florida 32819
USA

NOTE – Hold Tech Files Ltd is a company based in the Republic of Ireland that holds Technical Documentation within the EU on behalf of manufacturing companies based outside the EU. For companies that sell to the UK as well, files can be held in the UK by Hold Tech Files’ UK-based subsidiary. www.holdtechfiles.eu

New European Directives – Are you ready?

In accordance with the New Legislative Framework (NLF), there are several forthcoming changes to existing European New Approach Directives – Are you ready?

Three (3) of the updated EU Directives that are most likely to impact Machine Builders are:-

The Low Voltage Directive 2006/95/EC, is to be superseded by 2014/35/EU with effect from 20th April 2016.

The Electromagnetic Compatibility (EMC) Directive 2004/108/EC, is to be superseded by 2014/30/EU with effect from 20th April 2016.

The Explosive Atmospheres (ATEX) Directive 94/9/EC, is to be superseded by 2014/34/EU with effect from 20th April 2016

Staff at Laicon Inc., would be happy to answer any questions that you may have pertaining to these forthcoming changes, please contact us on 407-926-6185, or at info@laicon.us

CE Training in conjunction with TUV SUD UK & Kent State University

FLYER – CE Training with Kent State University & TUV SUD UK

Laicon Inc. are pleased to announce the forthcoming 3 Day CE Marking course, to be conducted by TUV SUD UK Training Officer (David Corr) and hosted by Kent State University, on 2nd, 3rd & 4th December 2014.

This 3 Day CE Training course will help US Manufacturers, who export to Europe, to better understand how to meet the legislative requirements that are defined by the EU New Approach Directives – http://www.newapproach.org/Directives/DirectiveList.asp

The CE Training course focuses on the Machinery Safety Directive (Mechanical & Electrical), includes back ground information pertaining to CE Marking, Risk Assessment methodology, EN Standards Training and an interactive discussion on the aspects of CE requirements; as well as a ‘take home’ distance learning program that allows the students to ‘practice’ their new found skills on a Virtual Reality Machine/Complex Assembly.

Certification will be provided by Kent State University and will include ‘hours’ towards PE continuous annual Training requirements.

Please see the attached Flyer for registration details.

City of Mentor International Trade Program Presents

ITAC Flyer 2014          Alan Scott is pleased to announce that he shall be presenting at the forthcoming ‘City of Mentor International Trade Program’, on Tuesday 20th May 2014, at the LaMalfa Centre/Holiday Inn Express, Heisley Rd. in Mentor, Ohio.

The discussions will be presented by various section experts and will cover International Trade topics, such as the European RoHS & WEEE Directives, CE compliance to the European Machinery, Low Voltage & EMC Directives and the CCC Marking process for China certification.

Case-Studies, Q&A sessions and break-out groups will be made available to attendees, to further discuss their own specific equipment with the Presenters.

Please follow the Link to make enquiries about attending this particular Workshop.

We hope to see you there.

International Standards Update Seminar

Alan Scott (of Laicon Inc.) is pleased to announce that he shall be presenting at the “International Standards Update” Seminar, hosted at the Wingate Hotel, West Chester, Ohio on Friday 1st March 2013.

This Seminar has been organized by Kathy Marshalek, of Wright State University, to discuss International Safety Mark requirements, including discussion on CE, UL, CSA & CCC.

Alan Scott shall be presenting on Basic CE Marking Theory, including topics such as:- What is CE? What is the significance of CE? How do we comply? What are EHSR’s? Which standard should I use? How do I compile a Technical File?

Other Presenters include John Liu of F-Squared Laboratories, Sylvia Mohr of the US Mission to the EU and Kimberly Kirkendall of International Resource Development Inc.

Recommended attendees include any US Manufacturers who export to Europe, Chine and/or Canada, including their Design Engineers, Project Engineers, Legal Departments and Technical publication Departments. For further information on this Seminar, please contact Kathy Marshalek at Kathy.Marshalek@wright.edu or contact Alan Scott directly on 1-407-716-1963 or atalan.scott@laicon.us

Laicon takes part in ITAC seminar

Alan Scott of Laicon Inc. was pleased to be a part of the recent Seminar event hosted by the International Trade Assistance Centers (ITAC) at the College of Business (Cleveland State University) on the 15th Nov 2012. Alan provided a 1 hour presentation on ‘Basic CE Requirements for the European Market’ that was warmly received by the attendees.

The workshop covered certifications from around the globe that are needed for international trade and the program was geared towards project managers, engineering professionals, compliance executives, and legal departments to better understand the rules for CE Marking in accordance with the various EU Directives; as well as requirements for CSA and UL certifications and how to successfully apply for Chinese certification.

The Seminar included typical case studies to help companies best position themselves to comply with today’s global marketplace, with a Q&A Session on completion of the Presentations.

For further information on similar events, please contact Alan Scott on 1-407-716-1963 or atalan.scott@laicon.us

EN 13849 – Are You Ready?

As many Companies will already be aware, the European Commission are withdrawing EN954 with effect from Dec 31st 2011.

In lieu of EN954, any Machine being placed within the EEA (European Economic Area) from 1st Jan 2012 onwards, will require their Safety Related Parts of Control Systems (SRP/CS) to be compliant and validated to either EN13849 orEN62061.

Although EN13849 & EN62061 have already been around for a number of years, it has always been generally accepted that EN954 was the ‘easier‘ Standard to comply with when CE Marking Machinery (if not always the mostappropriate standard).

However, now that the ‘EN954 option’ will no longer be available to any person(s) exporting Machinery to Europe, in my opinion, the new trend appears to be leaning more towards utilizing the EN 13849 Series of EN Standards for CE compliance of the Safety Related Parts of Control System i.e. EN13849-1 and EN13849-2.

What does this mean to Manufacturers here in the USA?

If you are an OEM exporting to Europe, OrIf you are a company who modifies existing Machinery for export to the European Market, Or… If you are transferring Machinery to a European Partner or European Sister Company, Or… If you are a 3rd Party who is responsible for importing Machinery into Europe; you will need to ensure that your Safety Related Control System (and Safety Parts of the Control System), meets with the requirements of either EN13849 or EN62061.

What is EN13849 & EN62061?

Upon initial review, these two EN Standards may appear to be somewhat complex in their content and meaning, but in essence their purpose is to replace the outdated principles reflected within EN954. As technology has advanced over the years so too has the requirement to keep pace with this new technology; subsequently, it was identified that there was a necessity for more ‘relevant’ EN Standards, pertaining to the subject of SRP/CS.

Historically, Machinery Builders have utilized EN954 to identify the appropriate ‘Control Category’ for their Machines Safety Related Parts of the Control System (SRP/CS) i.e. Cat 1, Cat 2, Cat 3 & Cat 4. Now, however, Machine Builders will need to decide if they wish to achieve CE Compliance via EN13849 (Which introducesPerformance Levels (PL) in place of Control Categories i.e. PLa, PLb, PLc, PLd & PLe)….OR…. If they wish to achieve CE Compliance via EN62061 (Which introduces Safety Integrity Levels (SIL) in place of Control Categories i.e. SIL1, SIL2 & SIL3).

It is worth noting that EN13849 is generally accepted as a direct replacement for EN954 as it covers any source of Energy (e.g. Electrical, Hydraulic, Pneumatic), whereas EN62061 is for the more complex Safety Related Electrical, Electronic and Programmable Electronic Control Systems (i.e. Of an Electrical nature only). It is also of note that EN13849 is broken down into two parts; EN13849-1 (General Principles for Design) and EN13849-2 (Validation).

How can Laicon Inc help you?

Laicon Inc is pleased to announce that they can offer their clients an initial EN13849-1 Machine Assessment to determine the Performance Level required (PLr) of their Machinery SRP/CS, as well as a full EN13849-2 Validation Service to confirm, verify and validate that the PLr has in fact been achieved. These Validation Report Documents need to be made available / incorporated into the Machinery Technical Construction File (TCF). Please click on the “EN13849 Assessment and Validation Services” Link, under the CE Marking Section on the left hand side of our Home page for further details.

Let us help you to get it right!

Should you require further information pertaining to EN13849 (or EN62061), or if you are interested in discussing the methodology of the Validation Services for these EN Standards, please contact Laicon Inc at info@laicon.us or enquiries@laicon.us or contact myself directly at  alan.scott@laicon.us. For further information on our other Services, please call us on 407-926-6185. Thank You.

Laicon Inc conducting Presentation

Laicon Inc conducting Presentation on RoHS, WEEE, REACH and new Machinery Directives, at ITAC CE Marking Seminar, on Wednesday 6th October 2010.

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