Questions and answers concerning the ErP Directive 2009/125/EC and the motor regulation 640/2009
  1. Which directives and regulations of the EU are relevant?
    1. 1. EuP (= 2005/32/EC - passed on July 6, 2005):
      Requirements for eco-friendly design of energy-using products (EuP = Energy using Products) - also known as eco design directive

      2. ErP (= 2009/125/EC - revised version of EuP, in effect since Oct 21, 2009):
      Requirements for eco-friendly design of energy-related products (ErP = Energy related Products)
      Detailed information about the ErP directive can be found here:
      http://www.ebpg.bam.de/de/richtlinie/index.htm (in German)

      3. EuP directive 640/2009 (regulation for motors, in effect since July 22, 2009):
      Requirements for eco-friendly design of electric motors and the use of electronic speed control. They also apply when the motors are installed in other products (e.g. machines).
      Specific obligations for the affected user groups (see below) only arise with the passing of implementation measures for a specific product group (e.g. electric motors).
      The implementation measure for electric motors is the minimum efficiency regulation that will become effective on June 16, 2011.

  2. How is the directive translated into German law?
    1. The above EuP (=2005/32/EC) directive has been translated into German law with the Energy-using Products Act (Energiebetriebene-Produkte-Gesetz, EBPG) (effective since March 7, 2008).

      The Federal Ministry for Economics and Technology (BMWi) is responsible for the implementation of the law.

      The replacement of EuP by ErP requires an adaptation of the eco-design directive (= 2009/125/EC) – EBPG was also adapted over the course of 2010.

  3. Who is affected by the directive / regulation?
      • Manufacturers of an energy-using product
      • Importers of an energy-using product
      • Market supervision authorities
      • Consumers
  4. Who is responsible for coordination and market surveillance?
    1. At the federal level, the German Federal Institute for Materials Research and Testing (BAM) coordinates the translation of the European directive (2005/32/EC) into German law between the EU Commission, the German government and affected manufacturers and associations.

      • Market surveillance in Germany: Different authorities or ministries in different federal states; the relevant authority can be found in the ICSMS database (European Market Surveillance System) (www.icsms.org)
      • Market surveillance in all other EU countries: You can also search authorities by country here: www.icsms.org
        Note: The national sites of the ICSMS platform are currently filled to very different degrees.

      If a manufacturer is proven to have violated the ErP directive, the manufacturer will have to fulfill requirements set by the authorities, ranging from correcting the violation (e.g. replacement of affected motors) to a paying a fine. All arising costs (e.g. technical inspection of motors, motor replacement) must be paid by the affected manufacturer.

      The investigation and punishment of violations are subject to a margin of discretion of the responsible supervisory body, which can vary throughout the EU.

      All investigated and punished violations are to be documented and published on the ICSMS platform for the entire EU in the future.

  5. How is the IEC standard 60034-30 different from regulation 640/2009?
      • The IEC 60034-30:2008 standard defines efficiency classes for motors and thus provides a globally uniform specification. It does not stipulate whether motors must achieve a certain efficiency class,
      • which is why the above EuP directive 640/2009 regulates the minimum requirements for the European Union.
      • Note that the scope of the EuP directive 640/2009 is more limited than the scope of IEC 60034-30:2008
  6. Can the DRS motor or IE1 motor still be sold in Europe after June 16, 2011?
    1. Yes, the regulation permits several exceptions, e.g.:

      • The drive is designed as DRS brakemotor.
      • The drive is not labeled for continuous duty.
      • The power rating is below 0.75 kW.
      • It is a pole-changing DRS motor with two different speeds.
      • Design measures are taken so that the DRS motor can be used beyond the described temperature limits (-15°C … 40°C). The extended temperature range can include the described limits, e.g. -40°C ... +40°C, thanks to special ball bearing grease, metal fan, and other seals.
  7. Is a drive with inverter-operated DRS motor or IE1 motor exempt in Europe?
    1. No, operation with an inverter is not a sufficient reason for the drive to be exempt from stage 1 of the regulation. When the drive is labeled for mains operation, it must meet the regulation requirements. If no other exception can be claimed, such a drive must be designed as IE2 or DRE as of June 16, 2011, 12:01 a.m.

  8. Is a gearmotor exempt from the regulation in Europe?
    1. No, the gearmotor is not exempt in Europe. Gearmotors must also comply with the requirements of the regulation. The only exception are motors that are completely integrated in a machine. The efficiency of such motors cannot be measured without the machine, e.g. a pump in which the stator of the motor is integrated in the pump housing.
      In a gearmotor, the motor is mounted to the gear unit, which means it can be measured separately and is thus affected by the regulation.

  9. Can a DRS motor or IE1 motor still be sold to an OEM or end customer in the EU?
    1. Yes, a DRS motor can be sold to customers if this motor is intended for export outside the EU. This must also be observed by the end customer.
      SEW does not need any written documents from the customer; an oral statement is sufficient. These DRS motors have no CE label on their nameplate. As a result, they may not be used in the EU or be re-imported to the EU. The delivery to a European customer who exports the products is not considered an initial distribution in the sense of the ErP directive. SEW will point out this non-usability within EU-Europe also in the quotation and in the order confirmation.

  10. Is it permitted to repair a drive and then re-install it?
    1. SEW may repair drives with DT/DV or DRS motors and deliver these repaired drives back to the customer also after June 16, 2011. The extent of the repairs is not specified.

  11. Can a drive that was delivered before June 16, 2011, 12:01 a.m., still be installed in a system?
    1. Yes, if the initial distribution (delivery) of the drive by SEW-EURODRIVE was made before June 16, 2011, 12:01 a.m. The date on the delivery note is decisive. Our customers can install such a drive in their plants, deliver it and start it up whenever and in whatever way they want.
      Even the resale of the drive is not affected by the date.

  12. Why are brakemotors exempt (in Europe)?
    1. The EU Commission is following a suggestion of the Italian representative and assuming that a brakemotor is used in start/stop operation.
      This repeated starting of a brakemotor consumes more energy than could be saved during the operation of an energy-efficient motor.

  13. What is not considered continuous duty?
    1. The regulation states that motors in continuous duty are affected. This is no technical description. This is interpreted according to IEC 60034-1 as follows:

      • S1 continuous operation, or
      • S6 continuous duty with intermittent loads, or
      • S3 intermittent duty with a cdf of 80% or more

      This S3 cyclic duration factor is stated in the standard with an example duration of 10 min. This basically means that the motor must not reach its steady-state temperature during the first cycle, but only after it has been started and stopped several times with breaks in between. AC motors virtually reach their thermal limit within 2-3 hours. The specification of 2 hours is a rough time frame for the maximum cycle duration of S3. The 80% limit ensures that this is really motor operation with standstill phases.

      SEW-EURODRIVE offers the DRS motors for duty type S3 / 75%. These motors are not affected by the regulation. The sales price of these DRS S3 motors is usually higher than that of the corresponding S1 motor in DRE design.