Europgen engages with the most pressing issues relating to the generating set industry and Europe’s energy infrastructure.

At the present time there are a number of core topics of interest and concern. Europgen employs experts from across our membership associations and their respective companies to understand and communicate these topics through our Working Groups system.


Current topics of interest include:

1        Regulation overview

The European Union has issued a new regulation on implementing Directive 2009/125/EC with regard to small, medium and large power transformers. The European Union has issued a new regulation No 548/2014 on implementing Directive 2009/125/EC with regard to small, medium and large power transformers.

This regulation establishes eco-design requirements for placing on the market or putting into service power transformers with a minimum power rating of 1 kVA used in 50 Hz electricity transmission and distribution networks or for industrial applications.

The Commission study showed that energy in the use phase is the most significant environmental aspect that can be addressed through product design. Significant amounts of raw materials (copper, iron, resin, aluminum) are used in the manufacturing of transformers, but market mechanisms seem to be ensuring an adequate end-of-life treatment, and therefore it is not necessary to establish related eco-design requirements. Annex I on Ecodesign requirements of EU regulation 548/2014 therefore establishes two tiers of energy-efficiency requirements (from July 1, 2015, and from July 1, 2021) as well as product-information requirements.

2        Rationale

2.1       Point 2 of Article 1 (Subject matter and scope) states that:

2.  This Regulation shall not apply to transformers specifically designed and used for the following applications:

-      transformers specially designed for emergency installations;

2.2       Definition of an emergency installation

According to the French order of August 26, 2013, relating to combustion plants with a capacity of at least 20 MW and subject to authorization under Section 2910 and Section 2931, an emergency installation may be defined as being intended only to supply power to safety systems or to provide emergency power when the main power supply fails.

We consider that this definition could be used in the EU countries.

Some examples of emergency installations: hospitals, retirement houses, generating sets used to ensure the safety of the national electricity grid with running time less than 400 hours per year.

For the avoidance of doubt all other installations where run hours exceed 400 hours per year should use the appropriate Eco-design compliant transformers.

2.3        Our position

As our emergency generators are primarily designed to supply power to safety systems or to provide power in the event the grid is lost, the transformers used in these installations may therefore be considered as being beyond the scope of the aforementioned regulation.

Disclaimer Notice.
This document is prepared with the views and findings of the Europgen Association and therefore do not constitute any legal or liability for the contents

Paul. E. Blything
General Secretary

13th January 2015


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It’s vital that the generating set industry understands the application of grid codes - including ENTSO-E Network Code for Requirements for Grid Connection Applicable to all Generators (March 2013) - and is positioned to advise and inform amendments and later legislation.

Europgen works in tandem with ENTSO-E, ACER and national authorities to ensure implementation is possible and to lobby on behalf of the manufacturers and suppliers to ensure reasonable criteria.

The named network code defines a common framework of grid connection requirements for Power Generating Facilities, including Synchronous Power Generating Modules, Power Park Modules and Offshore Generation Facilities. 

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European noise levels for outdoor generating sets are currently laid out in legislation document EU directive 2000/14/EC. If a generating set is sold for use within the EU it must be type-tested to achieve a EU declaration of conformity, be visibly CE certified (which means it is compliant with the directives) and contain an indication of the guaranteed sound level. The sound level for the purpose of the 2000/14/EC directive is calculated according to sound power, which is neither room dependent nor distance dependent but belongs only to the source. The Vehicle Certification Agency (VCA) carry out enforcement of the directives and upon inspection are likely to request verification documentation: if it is not forthcoming they have the power to suspend the use of the equipment and potentially ban products which they adjudge of failing to meet the correct standards.

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The RoHS directive originated in the European Union and restricts the use of specific hazardous materials found in electrical and electronic products. All applicable products in the EU market after July 1, 2006 must pass RoHS compliance.

The substances banned under RoHS are lead (Pb), mercury (Hg), cadmium (Cd), hexavalent chromium (CrVI), polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE).

Any business that sells applicable electronic products, sub-assemblies or components directly to EU countries, or sells to resellers, distributors or integrators that in turn sell products to EU countries, is impacted if they utilise any of the restricted materials.

Until recently generating sets had not been applicable and subject to the RoHS directive: as the primary energy is not electricity but fuel such as petrol, diesel or gas, all equipment powered by internal combustion engines did not fall under the scope of Directive 2002/95/EC.

The recast RoHS Directive 2011/65/EU was published in the OJ on 1st July 2011 and entered into force on 2nd January 2013.  Generating sets are defined as EEE within the Directive and therefore are within scope, except where subject to one of the exclusion clauses.  Transitional arrangements apply to products newly in scope that expire at various dates up to 22nd July 2019.

Of the restricted substances, lead is the only one likely to cause problems for generating set manufacturers and suppliers. The reason for the use of lead is the high temperature range and the vibration of the engine and the resulting high strength requirement for the solder joints.

Lead is also used in the starter batteries of internal combustion engines. In the End of Life Vehicles Directive, covering engines in automobile use, starter batteries containing lead are exempted as there currently is no suitable alternative for the specific application of use.

Europgen and our partners are working with the EU commission to research the availability of compliant components across the entire product range but full compliance is not likely by the end of the transitional stage. There is also concern that a rigid application of the RoSH 2 directive will severely limit the secondary market in generating sets.

Any business that sells applicable electronic products, sub-assemblies or components directly to EU countries, or sells to resellers, distributors or integrators that in turn sell products to EU countries, is impacted if they utilise any of the restricted materials.

How are RoHS and WEE related?

WEEE compliance aims to encourage the design of electronic products with environmentally-safe recycling and recovery in mind. RoHS compliance dovetails into WEEE by reducing the amount of hazardous chemicals used in electronic manufacture. RoHS regulates the hazardous substances used in electrical and electronic equipment, while WEEE regulates the disposal of this same equipment.

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In the US generating sets are now regulated for greenhouse gas emissions according to legislation RICE NESHAP (reciprocating internal combustion engines national emission standards for hazardous air pollutants). Though there are no concrete plans for a similar implementation in the EU Europgen is maintaining a watching brief in preparation for any announcement.

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