Since we are talking about EuP IM's.... I have no skin (I think) in the EPS question, but I have been reviewing the motor IM Reg 640/2009. My company makes large, high tech, production equipment so we are always concerned about regs that apply to components in larger systems even if that larger system is not directly in the reg scope.
This motor IM seems to be one of those that apply to components of larger systems, as it's scope is the placing on the market and the putting into service of motors "including where integrated in other products" [Art1.1]. But then as quickly this regulation seems to take this back by excluding "Motors completely integrated into a product (for example gear, pump, fan or compressor) of which the energy performance cannot be tested independently >from the product." [Art 2.b] So if motors "completely integrated into a product" are exempt, does this leave only motors "partially" integrated (whatever that might be) or not integrated at all? Then what's the point of the original "including where integrated into other products."? Also in Annex I.2 there are 12 points of information for motors that must also be visibly displayed on "the technical documentation of products in which motors are incorporated." [Anx I.2.b] How should this be understood in light of the Article 2.b exemption? To put forward a hypothetical, if I make a disk drive platen coating machine that happens to incorporate a motor in scope of this IM if it were placed separately on the market (i.e. pole count, voltage, etc.. are all in scope), do I have any obligations under this regulation or not? The motors I envision could be in any number of places; - compressors for refrigeration systems - fan motors - Hoists integrated for lifting operations during maintenance - Motors in robotic platen handlers - driving vacuum pumps Perhaps the banner for these questions should be "IM confused!" Lauren Crane Product Regulatory Analyst Corporate Product EHS Manager Applied Materials Inc. Austin, TX 512 272-6540 [#922 26540] - external use - Save paper and trees! Please consider the environment before printing this e-mail. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]>
