Time is running out for Ecodesign compliance

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Tighter energy efficiency rules for electric motors and drives, in force from July 2021, could have serious consequences for unwary OEMs, as Jukka Hannuksela explains
July 1 2021 sees the implementation of new, stricter and broader-reaching requirements set by the EU’s Ecodesign Regulation 2019/1781 together with the amending Regulation 2021/341. Unless they are fully aware of the implications, OEMs specifying low-voltage motors and drives in their products risk missing, misunderstanding or misinterpreting important details. This could potentially lead to them producing unsaleable equipment.
With the following advice I aim to clarify matters. I would also stress that moving to more efficient motors, ideally in combination with variable speed drives (VSDs), improves the performance of machinery and reduces operating costs. At the same time, of course, it benefits the environment – which is the purpose of the regulation.
The regulatory changes, relating to low-voltage induction electric motors rated at under 1,000 V AC, will be made in two steps. Step 1, from July 1 2021, raises mandatory minimum efficiency levels, expands the range of motors covered, and for the first time includes VSDs. Step 2, from 1 July 2023, widens the scope further and introduces even higher efficiency standards for some motor categories. Outside the EU, post-Brexit UK will adopt the same regulation – by a different name – and some other countries are likely to follow its principles.
The regulation specifically covers 3-phase, single-speed motors, with frequencies of 50, 60 or dual 50/60 Hz, used for direct online (DOL) operation in continuous duty. 

Step 1 – July 1 2021

At step 1, a minimum level of IE3 (International Efficiency class 3) becomes mandatory for:
Motors with power ratings from 0.75 to 1,000 kilowatt (kW)
Motors with explosion protection of types Ex ec, Ex db,  or Ext – previously exempt
Motors with IC418 cooling (Totally Enclosed Air Over, TEAO)
Brake motors with external brake – previously exempt
For 3-phase motors with lower power ratings, from 0.12 to 0.75 kW, which were not previously covered, the mandatory minimum efficiency level becomes IE2.
Importantly, the regulation can no longer be met by the option of an IE2 motor with a VSD.
Various types of motor are exempt. Examples include motors limited to – or specifically designed for – use with VSDs, or with an integrated VSD. Also exempted are electric vehicle traction, mining Ex, nuclear safety, 1-phase, multi-speed and submersible motors, to name but a few.
AC drives must also now comply with IE2. The regulation covers 3-phase standard drives (single AC output with diode input rectifier) with power ratings from 0.12 to 1,000 kW. It excludes the following drive types: regenerative, low-harmonic, multiple AC output, 1-phase, medium-voltage, DC, integrated and traction. Drive cabinets which have already been conformity-assessed need not be reassessed.

Step 2 – July 1 2023

At step 2 there is no further change for drives, but the IE2 standard is applied to two extra motor classes. These are 1-phase motors and Ex eb explosion protection motors, with ratings from 0.12 to 1,000 kW in both cases. In addition, a new ‘super-premium’ efficiency level, IE4, is introduced for 3-phase, single-speed motors with 2, 4 or 6 poles, rated between 75 and 200 kW. Brake and Ex motors are exempt from IE4 compliance.

Some clarifications

It should be noted that the regulation applies to motors and drives separately, and there are no efficiency levels specified for power drive systems. Specifiers who have previously gained in efficiency by matching an IE2 motor with a VSD must now use IE3 motors. The efficiency tables for the missing 60 Hz ratings are now introduced in the amending Regulation 2021/341.
If a motor is marked with a rating for other duty types than continuous, but is nevertheless capable of being operated at the rated power in continuous duty, it must comply with the regulation.
From July 1 2022, output power losses from a motor must be determined at a series of operating points for speed versus torque, as set out in the regulation. If the motor is unsuitable for operation at any of these points, ‘not applicable’ should be indicated. Similar procedures will apply to drives, for which power losses must not exceed the maximum permitted by the IE2 efficiency level. If a motor is unsuitable for use with a VSD, this should be stated in its product information.
The responsibility is always on the machine builder to ensure that all the requirements for relevant information are covered in the documentation they provide with their machines.

Compliant, non-compliant or exempt?

Motors and drives placed on the market before the regulatory changes on July 1 2021 and 2023 will be exempt from the new rules. In this context, only manufacturers and importers can ‘place an item on the market’. If a manufacturer or importer sells it for the first time to a distributor or end-user before those July deadlines, it is considered to be placed on the market. It can then be sold to another distributor, or from a distributor to an end-user, even if it does not comply with the new standards. There is no grace period for equipment brought from outside the European Economic Area (EEA) and placed on the market after July 1 2021. Furthermore, allowing for transportation and customs delays, manufacturers in the US and China intending to place products on the market after July 1 2021 should be using compliant components well ahead of that date.

The regulation makes an allowance for the delivery of motors according to the existing Regulation 640/2009 as substitutes for identical motors integrated in existing products. More specifically, this is allowed if the product requiring a replacement motor is placed on the market before July 1 2021 and according to the Regulation 2019/1781 before July 1 2023, and the replacements are placed on the market before July 1 2029. The motor or its packaging, along with its documentation, must clearly state that it is to be used exclusively as a spare part for the specified product.
It is important to note that in order to qualify for CE marking, and for placing on the European market, motors must comply with two other EU directives as well as the energy efficiency requirements. Without meeting all three directives, there is no CE mark.
A motor cannot be CE-marked if it falls below the IE standard now applying to its type. Motors in manufacturer stocks which met the previous IE requirements but do not meet the relevant new standards must have their CE marks removed. Those without CE marks can still be exported to some countries outside the EU, provided they meet local requirements.
Motors exempt from the new regulation may be CE-marked if they comply with the other directives, but no IE class will be indicated. An example would be a motor specified to operate exclusively with a VSD, which cannot be used directly online. In this case an EU Declaration of Conformity (DoC) should be prepared to clarify which directives and harmonized standards apply to it.

Stay ahead of the regulation

Buyers should be wary of pushing the boundaries of interpretation or looking for loopholes in the regulation, as the market surveillance authorities (MSAs) enforcing it may judge things differently. In fact, there are good arguments in favour of choosing motors with a higher efficiency than the mandatory minimum level. They will give customers better performance, save on energy bills and continue to comply well into the future.
Even greater savings are possible when a highly efficient motor is coupled with a VSD. VSDs control the operation of motors in a way that maximises efficiency. In particular, they can precisely adjust a motor’s speed and torque to meet a system’s changing needs. This allows a pump, for instance, to deliver exactly the right flow at any moment, rather than running at a constant speed which may often be unnecessarily fast. By avoiding excessive speeds, VSDs also reduce wear, mechanical stress and damage in machinery – saving on maintenance, repair and downtime expenses, and extending equipment life.
On top of all those benefits, saving energy contributes to carbon footprint reduction. Industry is thought to account for around 37% of the world’s energy use and 24% of global CO2 emissions – and roughly 70% of the electricity it consumes goes into electric motor systems. For any business with strong corporate responsibility ideals, there is huge potential for helping the environment by not only complying with the latest regulation but going beyond it.
Jukka Hannuksela is Head of Global Standards and Compliance at ABB IEC LV Motors

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