ABB’s two global Business Units, Business Unit Motors and Generators and Business Unit Drives welcome opportunity to take up aspects that are identified non-productive in otherwise well working directive.
These two Business Units produce electrical motors, generators and drives that are intended for industrial use.
While preferring option 1 in the Inception Impact Assessment, we would combine this option with digital documentation. Digital documentation is the default value in industrial environment. Paper copy requirement does not provide any addition-al value for customers safety but costs throughout entire value chain. Therefore we warmly welcome initiative to allow digital documentation in MD context.
Based on the experience BU Motors and Generators together with Business Unit Drives have gained, we would also ask clarifications in following:
1. Scope definitions
a. in some cases interpretation whether some motor or drive is under scope as such, as ”partly completed machinery” or not at all is difficult to make. Clear instructions / definitions in this are important to avoid confusions.
b. Together with increasing material efficiency requirements upgrading and repairing activities are becoming more frequent. Interpretation when a machinery is considered as a new machinery after upgrades / repairs should be instructed.
c. in some cases interpretation whether a motor or a drive is under MD scope as such, as ”partly completed machinery” or not at all is difficult to make.
2. Interaction with other Directives:
Electric products might be under the scope of many directives. While being partly overlapping, it is challenging to identify dominant directive.
One solution would be to let the manufacturers be responsible in evaluating which directive(s) are applicable regarding different features or aspects of the product.
3. Language requirements
MD requires translation into the official language of the member state where the product is sold to. This requirement is understandable for consumer goods. But its gains might be dubious in case of investment goods, especially where installation and use require experts. In these cases a reduced set of languages could be beneficial without jeopard-izing MDs ultimate goals.
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