FAQ

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-Directive (= 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-Directive (= 2009/125/EC – replaced the EuP-Directive, 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. Regulation 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).

      4. Regulation 4/2014 amends regulation 640/2009; became effective on July 27, 2014.
      Amendment of the regulation affects altitude and temperatures.

      Directives that are edited by the EU represent a legal basis and have to be transposed into national law by the Member States. No specific technical obligations are given by the directives.
      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 regulation (EC) 640/2009, amended by regulation (EU) 4/2014, that became effective on June 16, 2011 and regulates minimum energy efficiencies.

  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 replacement of EuP by ErP required an adaptation of the EBPG. It was replaced by the Ecodesign Requirements for energy-related Products Act (Energieverbrauchs-relevante-Produkte-Gesetz, EVPG) (effective since November 25, 2011).

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

  3. What is the time schedule for implementing regulations 640/2009 and 4/2014?
      • since June 16, 2011, newly distributed motors must meet at least the requirements of efficiency class IE2
      • since July 27, 2014, new regulations for exceptions are effective (CR 4/2014)
      • since January 1, 2015, newly distributed motors with a nominal output power of 7.5 to 375 kW must meet at least the requirements of efficiency class IE3, or they must comply with efficiency class IE2 when they are operated together with an electronic speed control device.
      • as of January 1, 2017, newly distributed motors with a nominal output power of 0.75 to 375 kW must meet at least the requirements of efficiency class IE3, or they must comply with efficiency class IE2 when they are operated together with an electronic speed control device.
  4. Which types of motors are excepted from the regulation?
      • Motors that are designed to be operated while being completely immersed in liquids
      • Motors that are completely installed in a product, and whose energy efficiency cannot be assessed independently from this product
      • Motors with a special design for operation under the following conditions:
        • Installation above 4000 m asl (amended by CR 4/2014)
        • Ambient temperatures above 60° C (amended by CR 4/2014)
        • Maximum operating temperatures above 400° C
        • Ambient temperatures below -30° C (any motor), ambient temperatures below 0° C (aircooled motor) (amended by CR 4/2014)
        • Cooling liquid temperatures at the inlet of a product below 0° C or above 32° C (amended by CR 4/2014)
        • In potentially explosive atmospheres in line with directive 94/9/EC of the European Parliament and Council
      • Brake motors
  5. Who is affected by the directive / regulation?
      • Manufacturers of an energy-using product
      • Importers of an energy-using product
      • Distributors
      • Market supervision authorities
      • Consumers
  6. 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 (2009/125/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.

  7. How is the IEC standard 60034-30-1 different from regulation 640/2009?
      • The IEC 60034-30-1:2014 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 directives (EC) No 640/2009 and (EU) No 4/2014 regulates the minimum requirements for the European Union.
  8. Can the motor type DRS.. or any other 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 brake motor.
      • The drive is not labeled for continuous duty.
      • The power rating is below 0.75 kW.
      • It is a pole-changing motor type DRS with two different speeds.
      • Design measures are taken so that the motor type DRS.. can be used beyond the described temperature limits (-30°C … 60°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.
  9. Can the motor type DRE.. or any other IE2 motor still be sold in Europe after January 1, 2015?
    1. Yes, the regulation permits several exceptions, e.g.:

      • The drive is designed as brake motor.
      • The drive is operated on a frequency inverter and labeled "VSD use only" on the nameplate.
      • The drive ist not labeled for continuous duty.
      • The power rating is below 7.5 kW.
      • Design measures are taken so that the motor type DRE.. can be used beyond the described temperature limits (-30°C … 60°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.
  10. Is a drive with inverter-operated motor type DRS.. or any other IE1 motor exempt?
    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, it is not allowed to market motors type DRS..

  11. Is a drive with inverter-operated motor type DRE.. or any other IE2 motor exempt?
    1. Yes, operation of motor type DRE.. with an inverter is an exemption of regulation (EC) No 640/2009. The drive has to be labeled as “VSD use only”. The order processing has been adapted with regards to step 2 of CR 640/2009 to handle this option.

  12. 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.

  13. Can motor type DRS../DRE.. or any other IE1/IE2 motor still be sold to an OEM or end customer in the EU?
    1. Yes, motor types DRS../DRE.. (>7,5 kW without VSD-label) 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 motors type DRS.. 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 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.
      It was permitted to market motor type DRE.. until December 31, 2014. Since January 1, 2015 restrictions according to clause “What is the time schedule for implementing regulations 640/2009 and 4/2014?” are effective.

  14. Is it permitted to repair a motor type DT/DV/DRS.. or DRE.. and then re-install it?
    1. SEW may repair drives with motor types DT/DV/DRS.. or DRE.. and deliver these repaired drives back to the customer also after June 16, 2011/ January 1, 2015. The extent of the repairs is not specified.

  15. Can a replacement drive still be delivered as motor type DT/DV/DRS.. or DRE..?
    1. Replacement drives will be considered as a new deal and have to comply with regulation 640/2009.
      Since January 1, 2015 restrictions according to clause “What is the time schedule for implementing regulations 640/2009 and 4/2014?” have to be considered.

  16. Can a drive that was delivered before a particular effective date still be installed in a system?
    1. Yes, if the initial distribution (delivery) of the drive by SEW-EURODRIVE was made before the particular effective date. 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.

  17. 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.

  18. 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
      • S9 continuous duty with non-periodic load and speed variations
      • 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 motor type DRS.. for duty type S3 / 75%. These motors are not affected by the regulation. The sales price of the motor type DRS.. S3 are usually higher than those of corresponding S1 motor type DRE..

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