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“As well as covering the supply of batteries on their own, the EU BR also covers batteries that are
incorporated within other products, including machinery”
used batteries for reuse or repurposing. These sections of the EU BR will not be of interest to machine builders and SIs. Furthermore, the rules relating to due diligence policies only apply to economic operators with an annual turnover in excess of €40 million, so the majority of machine builders and SIs need not prepare due diligence policies.
OBLIGATIONS Machine builders and SIs exporting to the EU need to comply with a number of EU BR rules and requirements. First, the ‘producer’ (which includes machine builders or SIs incorporating batteries within their products) must register with the relevant competent authority in each member state where they are selling products. Next, the producer must prepare a Declaration
of Conformity (DoC). The DoC must be translated into the language of the member state in which the product is placed on the market; it shall be drawn up in electronic format but must be provided in paper format upon request. However, if a product is subject to more than one EU act requiring a DoC, then one DoC shall be drawn up listing all the relevant acts complied with. For example, a machine DoC relating to the Machinery Directive (or, from January 2027, the new Machinery Regulation) should incorporate the EU BR DoC. Since 18 August 2024, rechargeable
industrial batteries with a capacity greater than 2kWh (and LMT and EV batteries) must be accompanied by a document containing values for the electrochemical performance and durability parameters. Another requirement is that if a product
incorporates portable batteries, it must be accompanied by instructions and safety information relating to the use, removal and replacement of the batteries. The instructions and safety information must also be available permanently online on a publicly available website. There are various requirements relating to documentation that come into force at different dates in the coming years. For machine builders and SIs incorporating standard industrial batteries, it will be a matter of collating the documentation from the battery supplier and adding it to the technical documentation for the batteries (as part of the machine’s technical documentation). Examples of battery documentation for rechargeable industrial batteries >2kWh are: carbon footprint declaration from 2026; carbon footprint performance class
Feature
MACHINE BUILDING, FRAMEWORKS & SAFETY FEATURE
from 2027; and maximum life cycle carbon footprint threshold from 2029.
TAKE BACK AND COLLECTION Under the new EU BR, producers must put in place a take back and collection system and inform end users of the arrangements when batteries are ordered. Producers of industrial batteries (and SLI and EV batteries) are required to accept and take back from end-users, free of charge, all waste batteries for their respective category. Note that this obligation to take back batteries is not restricted to batteries that producers have sold to customers, and it is regardless of the battery’s brand, chemical composition or condition. As an alternative, the EU BR permits producers
to join a take back scheme operated by an appropriate producer responsibility organisation – and this is likely to be a better option for most machine builders and SIs. Waste industrial batteries that have been collected can either be passed to the producer responsibility organisation or handed back to the producer. Regardless of whether a machine builder or SI joins a producer responsibility organisation, they must report annually on the numbers of batteries sold and collected, and what has happened to them (e.g. handed back or processed for repurposing). Waste portable batteries must also be
collected. However, given the prevalence of portable batteries, it is most likely that machine builders and SIs can fulfil their obligations via a producer responsibility organisation. Nevertheless, producers are obliged to report annually on the numbers of batteries sold and collected.
ECONOMIC OPERATORS In line with the EU’s New Legislative Framework (NLF), the EU BR covers the roles and responsibilities of economic operators. Of particular interest to machine builders and SIs will be EU authorised representatives (EUARs), who can be mandated to perform certain tasks on behalf of the producer. As a minimum, the mandate must cover the following: retention of the DoC, technical documentation, verification report, approval decision and audit reports for at least ten years; provision of information and documentation requested by national authorities; and co-operation with national authorities on action taken to eliminate risks posed by batteries covered by the mandate. Furthermore, where batteries present a risk, EUARs are obliged to notify the market surveillance authorities immediately. Hold Tech Files is based in the Republic of
Ireland and can act as an EUAR for machine builders and SIs located outside the EU. The company operates a self-service online portal where customers can sign a mandate, pay a fee and upload relevant files to a secure server. Hold Tech Files then reviews the documentation and, if acceptable, sends the customer a report stating that the company is prepared to act as an EUAR. This entitles the customer to name Hold Tech Files on the DoC. Customers can choose to pay for ten years or annually.
Hold Tech Files
www.holdtechfiles.eu APRIL 2025 DESIGN SOLUTIONS 25
IMPROVING ELECTRIC DRIVE SYSTEM PERFORMANCE
In many industrial applications, electric automation can deliver efficiency, consistency and precision. But, oversights during design and specification can cause serious problems. So Festo has listed some things to think about: 1. Vibration: When selecting a linear axis, specifiers refer to the manufacturer’s datasheet to obtain information regarding the correct power and torque parameters. However, environmental conditions such as vibrations must also be factored in as these can result in a much shorter actual life time than predicted. More accurate predictions of component
lifetime can be achieved by applying a specific factor to the load, as a function of the expected vibration, during the calculations. This factor lies between 1³ and 2³ and indicates the strength of the impact of the vibrations on the lifetime. The datasheet for each component will state how the impact of vibrations on the service life can be calculated. 2. Ensure full lubrication: Electric automation components are sometimes required to make repeated very short and precise movements which can pose problems with effective lubrication as it can lead to components sticking or failing. For example, a ball screw drive has a grease reservoir that ensures the drive is continuously lubricated during operation. In applications in which only a very limited stroke length is used, the balls in the ball screw assembly hardly move at all and so are not coated with any new grease. In such cases, an extended stroke, or ‘lubrication stroke’, should be made periodically. Ideally, this action would be programmed into the machine software. Lubrication requirements must be considered during the design phase to ensure that a movement over a longer stroke length is possible. 3. Thermal performance: The thermal model of the motor and drive plays an important role in correct drive selection. Heating and cooling cycles are typically influenced by whether the application requires the electric drive to operate continuously or intermittently. In applications with intermittent operation, the components have time to cool down. This has a positive impact on their service life, which means it is often possible to select a less powerful version than for continuous operation. Festo’s Electric Motion Sizing tool helps specifiers and machine builders to factor this in. Festo has gathered more tips and compiled them into a free guide called Ten Most Commonly Made Errors With Electric Axes:
www.festo.com/common_errors_electric_axis
Festo
www.festo.com/gb
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