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Draft Ecodesign Regulation for Motors

APPLiA, EHI and EPEE have carefully reviewed the draft Ecodesign Regulation for Motors that the Ecodesign Regulatory Committee will discuss on 14 January 2019.


Our associations would like to emphasise two remaining concerns that have not been addressed and that need to be taken into consideration in view of the setting of an optimal framework for ecodesign requirements for motors:

 ‘Cascading’ is endangering freedom to innovate without any benefit for either consumers or the environment – Alternatives to cascading exist;

 Spare parts should be exempted from the requirements to guarantee longer product lifetimes and prevent waste generation.

1. Cascading’ is endangering freedom to innovate without any benefit for either consumers or the environment – Alternatives to cascading exist

a. Cascading is endangering freedom to innovate without any benefit for either consumers or the environment

APPLiA, EHI and EPEE consider that regulating parts integrated into products that are already themselves covered by ecodesign measures (also known as the “cascading” or “double regulation” principle) is endangering freedom to innovate without any benefit for either consumers or the environment. Imposing the choice/use of specific parts in the design process would draw on resources that the producer could use to invest in alternative innovative and more energy efficient technical solutions. By allocating resources where more efficiency can be achieved, the consumer receives an affordable and more efficient product.

Dictating the selection of specific parts, for products that already comply with ecodesign requirements, does not deliver any significant additional environmental benefit. Instead it imposes constraints that will certainly add costs. In most cases, there is no return on investment for the consumers and innovation/freedom of manufacturers to design is hampered.

We understand that in view of making efficient use of their resources, Market Surveillance Authorities are unlikely to test an individual part if they found the final product to be compliant with ecodesign requirements. This could lead to a competitive advantage for product manufacturers outside of the EU as – in the absence of dedicated market surveillance – they would probably freely choose between parts and thereby focus on the final product’s energy efficiency while optimizing the most suitable and cost effective combination of parts without regard to the minimum energy efficiency requirements for those parts.

b. A potential solution: exclude bespoke motors
In light of the above, we believe that parts for products which are already regulated by ecodesign requirements, should be excluded from ecodesign measures. However, we appreciate that parties in favour of regulating parts fear that excluding parts integrated into other products covered by ecodesign regulations could turn into a loophole as Market Surveillance Authorities may have difficulties in assessing whether or not a part is intended to be integrated into a final product regulated under ecodesign.


APPLiA, EHI and EPEE have worked on a practical solution to address this perceived loophole, based on a distinction between “catalogue” parts – available off the shelf – and “bespoke” parts – built to fit a specific application. We propose to exclude bespoke parts integrated into products that are already themselves covered by ecodesign measures from Ecodesign Regulations, whilst catalogue parts – which represent by far the largest share of parts – would remain within the scope.

We recommend exempting a bespoke motor that has the following characteristics:

1. Is designed and manufactured to meet a detailed environment-related specification supplied by, or developed in conjunction with, a particular final product manufacturer or developed and produced by the final product manufacturer itself and indelibly and univocally marked for this purpose
2. Is not placed on the market as a general product
3. Is the result of a unique commercial relationship between the part manufacturer and the final product manufacturer or is developed and produced by the final product manufacturer itself
4. Is integrated into final products that are regulated under Ecodesign
5. Is clearly marked as bespoke motor
6. Is assessed in reviews of regulation and preparatory studies of products integrating motors and it is demonstrated that the improvement potential is limited or not existing.
+ Bespoke motors made according to the specifications of an equipment manufacturer generally carry the brand name of the equipment manufacturer

2. Spare parts should be exempted from the requirements to guarantee longer product lifetimes and prevent waste generation

According to the draft Regulation (article 4.2.(m)), ”motors placed on the market not later than 1 July 2029 as substitutes for identical motors integrated in products and placed on the market no later than 1 July 2022” are exempt from the efficiency requirements.

The availability of spare parts for maintenance and repair brings significant environmental benefits as it guarantees longer product lifetimes and prevents waste generation, which is one of the core elements of the EU’s Circular Economy Action Plan and the EU waste hierarchy. It is also crucial that spare parts are available for refurbishment and remanufacturing.

In order to promote resource efficiency as of now, it is key that EU product policy rules allow original spare parts on the market during the lifetime of the products they are integrated into (“repair as produced” principle).

 

APPLiA, EHI, EPEE