Important Ecodesign Regulation reminder for machine builders

Hold Tech Files is alerting machine builders that on 1 July a new European Ecodesign Regulation comes into force. This has serious implications for machines placed on the market in the European Union (EU), if they incorporate electric motors or variable-speed drives (VSDs) within the scope of the new Regulation. The same rules apply whether the machine builder is based in the EU or elsewhere.

European Commission Regulation (EU) 2019/1781 lays down ecodesign requirements for electric motors and VSDs, effectively expanding on the rules in place previously. The aim is to improve energy efficiency and reduce carbon dioxide emissions.

Regulation 2019/1781 covers electric motors of lower and higher powers than before, and it introduces energy efficiency requirements for VSDs. There are limits and exceptions, but the important point is that machine builders need to be aware of the new rules and know how to comply.

Mirror legislation

UK legislation mirrors the EU ecodesign Regulation, so the same rules also apply in Great Britain (ie England, Wales and Scotland). Products placed on the market in Northern Ireland must comply with EU rules in accordance with the Northern Ireland Protocol.

In the EU and UK, machine builders will find they can no longer purchase non-ecodesign motors and drives, because it will be illegal for these to be placed on the market. Elsewhere, however, less stringent requirements may mean non-compliant motors and drives can still be obtained. Using these in a machine for the EU or GB would be illegal, because when the machine is placed on the market or put into use for the first time, motors or drives incorporated within the machine are deemed to be placed on the market or put into use at the same time.

In terms of machine design, it is a straightforward matter of specifying ecodesign-compliant motors and VSDs, and installing them in accordance with the manufacturer's instructions. Importantly, Regulation 2019/1781 also lays down requirements relating to documentation.

Ecodesign-compliant or exempt

A machine builder must be able to demonstrate that motors and drives are ecodesign-compliant or exempt. A copy of the relevant data sheets or manuals that came with the motors and drives must therefore be supplied with the machine.

While there is no provision in the Regulation for the machine builder to retain a copy of the ecodesign documentation, it would be prudent to do so. If a machine is CE marked to the European Machinery Directive or UKCA marked to the UK's Supply of Machinery (Safety) Regulations, there will be a technical file. This should only contain the specified items relating to machinery safety, so ecodesign documentation should be filed separately.

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) 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 compliance with the new EU Regulation 2019/1020 on market surveillance.

It would be simplest for non-EU machine builders to provide a copy of the ecodesign documentation to the person authorised to compile the technical file or the Authorised Representative, as appropriate.

An authorised person 

Hold Tech Files Ltd is based in the Republic of Ireland and can be named ona DoC as the person authorised to compile the technical file. "The company has created a simple self-service online portal where machine builders can sign a mandate, pay a fee and upload relevant files to a secure server," it states. This entitles the manufacturer to name Hold Tech Files on the DoC for up to ten years.

In addition, Hold Tech Files can act as an Authorised Representative for non-EU machine builders and retain ecodesign documentation on behalf of clients.