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29 May 2025
Gary James
Director
GEMS Product Review
Energy Security, Crisis Response & GEMS Branch
Energy Performance and Security Division
Email: GEMSProductReview@dcceew.gov.au
Consultation Regulation Impact Statement
Three Phase Cage Induction Motors
The Australian Industry Group (Ai Group®) is a peak national employer organisation representing traditional, innovative and emerging industry sectors. We have been acting on behalf of businesses across Australia for over 150 years. Ai Group and partner organisations represent the interests of more than 60,000 businesses employing more than 1 million staff.
Ai Group welcomes the opportunity to comment on the Consultation Regulation Impact
Statement – Three Phase Cage Induction Motors (CRIS). We support the move to IE3 and IE4 motor efficiency levels and the alignment with IEC60034-30-1, harmonizing to the EU best practice for 50Hz countries for regulation and scope of regulation.
From a policy perspective, it is crucial to recognize that improving motor efficiency directly contributes to reducing Australia’s greenhouse gas emissions. By adopting higher efficiency standards such as IE3 and IE4, we can significantly lower energy consumption, thereby decreasing the carbon footprint of industrial operations. This alignment with international standards not only promotes environmental sustainability but also ensures that our regulations are in sync with global efforts to combat climate change. Additionally, the Minimum Energy
Performance Standards (MEPS) regime is an important Government response to Australia's
2050 commitments, reinforcing the nation's dedication to achieving net-zero emissions.
Note that Ai Group’s submission draws on the SEW Eurodrive’s submission dated 1 May 2025 and member discussions.
A. SUMMARY
This submission is in response to the Consultation Regulation Impact Statement (CRIS) that has been prepared to consider policy options to improve the energy efficiency of three-phase cage induction motors supplied in Australia and New Zealand. These motors are commonly used in commercial and industrial applications such as pumps, compressors, and conveyor belts. They account for 38% and 34% of electricity use in Australia and New Zealand, respectively. Given their significant energy consumption, Ai Group acknowledges that even small efficiency gains can have a large impact. Bare three-phase electric motors and those embedded in or packaged with machines have been regulated in Australia and New Zealand since 2001 and 2002, respectively.
The CRIS considers a range of policy options, including expanding the scope of regulated products and increasing the Minimum Energy Performance Standards (MEPS). Less significant changes include registration modifications and new labelling requirements, such as displaying the registration number or disclosing information on technical datasheets. Additionally, technical changes are proposed to align with European Union eco-design requirements and improve international alignment.
A summary of Ai Group’s position is below:
• We support the CRIS regulations for "line operated motors" to align with IEC 60034-30-1
and EU Commission Regulation 2019/1781.
• Motors designed for Variable Speed Drives (VSD) should be excluded unless they can
operate on standard mains. IE4 motors are larger and have higher inertia, affecting starting
current and efficiency.
• We emphasize improving driven system efficiencies alongside motor efficiency.
• We disagree with the proposal for unique model identifiers for motor labelling, as it is
impractical and costly. Instead, we suggest no changes or using a single company
registration number.
• Motor suppliers must adhere to IEC standards for nameplates. Labelling on machines with
embedded motors is the responsibility of the machine builder.
• Electric motors require engineering into equipment and cannot be treated as consumer
products. Detailed technical information is available through manuals, specifications, CAD
drawings, and supplier websites.
• Motors should meet the IE level at either 75% or 100% load point.
• The "family of models" definition should focus on efficiency and align with IEC 60034-30-1.
Future regulations should follow international terminology for efficiency levels: IE1 =
Standard, IE2 = High, IE3 = Premium, IE4 = Super Premium
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B. Key Points
1. Regulations to apply to” Line Operated Motors”
The proposed future regulations should only apply to “line operated motors” to align with the
IEC 60034-30-1 standard and international best practices, including the EU Commission
Regulation 2019/1781. Motors designed specifically for operation with Variable Speed Drives
(VSD) are covered by IEC 60034-30-2 and should be excluded from the proposed regulation on
“Line Operated Motors” unless they can also operate on standard 50 or 60Hz mains.
2. IE4 Motors Considerations
IE4 motors are physically larger than IE3 motors, resulting in higher inertia rotors. This increases starting current and time, affecting peak starting KVA demand. IE4 motors are best for continuous duty applications with few starts and stops. Frequent starting and stopping can reduce overall efficiency. The efficiency difference between IE3 and IE4 4 pole motors in the 75 to 200kW range is less than 1%. Improving driven system efficiencies, such as mechanical transmission and VFD drives, can yield far greater efficiency gains.
While we support the introduction of IE4 motors, we emphasize the importance of other efficiency improvement methods.
3. Labelling and Nameplates
The proposal for unique model identifiers for motor labelling aims to enhance traceability and compliance with regulatory standards. However, we disagree with this proposal as it is impractical and would require extensive changes to supplier documentation, catalogues, and nameplates. Most motor suppliers already have clear model identifiers. The registration number changes with each renewal, making it costly to label motors specifically for AU/NZ.
To reduce the burden on suppliers, we suggest no changes to labelling/name plating or using a single company registration number instead of individual motor registration numbers, similar to
C-Tick registration for electronics. Motor suppliers must adhere to IEC standards, ensuring that nameplates include essential data such as supplier/manufacturer name, motor model, and technical specifications, including the IE rating.
Note that labelling on machines where electric motors are embedded is out of control of the motor supplier and up to the machine builder.
4. Three Phase Electric motors are not a consumer product:
Electric motors are technical products that require engineering into equipment. They need to be coupled and mounted to the machinery they are driving (the driven load). Unlike consumer products, electric motors cannot be treated as domestic products. A motor purchased on its own is useless until it is engineered into and coupled with the driven equipment.
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Highly detailed technical information about three-phase electric motors is available to engineers and designers through detailed online and paper manuals, technical specifications,
CAD drawings, and supplier websites and support portals.
5. Efficiency Load Point
In previous determination motors were accepted as achieving the IE level if they met the minimum efficiency at either 75% or 100% load point. We recommend that this would continue any new regulation or determination.
6. Family of models
The definition of the "family of models" should focus on product efficiency rather than factors like insulation class and rated voltage/current, which do not affect efficiency. For example, motors with different temperature rise classes can have the same winding, stator, and rotor, making insulation class irrelevant. Similarly, the connection type (star or delta) does not impact the motor's physical frame, power, or efficiency.
The definition should align with the IEC 60034-30-1 standard and include characteristics like frame size, number of poles, efficiency level, duty type, rated output, and reliance on a single test report.
7. Aligning of naming conventions
IE2 motor is named in AUS/NZ as standard efficiency, and our IE3 is only called high efficiency.
This unfortunately does not align with international terminology which states:
• IE1 = Standard Efficiency.
• IE2 = High Efficiency.
• IE3 = Premium Efficiency.
• IE4 = Super Premium Efficiency.
We recommend that all future regulations or determinations follow the internationally recognized terminology.
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C. Detailed responses to questions
1. Do you support the proposal to increase the MEPS and/or expand the scope of MEPS for three phase electric motors and why?
We support the alignment and harmonizing AU/NZ MEPS to the minimum values as well as scope of regulation to best practice of the 50Hz countries (e.g. EU27 + UK). This would improve handling by motor manufacturers' customers, Standardization (since already known scope) and improves the cost situation due to positive scaling effects in terms of quantity.
2. What is your preferred option(s) and why?
In the interest of standardization and harmonization with international best practice we support option “Level 2”.
Cost benefit and modelling assumptions
3. Do you agree with the assumptions and parameters used in the cost benefit modelling
(listed in Appendix 1: Cost benefit approach and parameters)? If not, can you please provide information on what you consider the assumptions/parameters should be.
These parameters are comparable to the EU for each stage (1-9).
• average power
• annual service life
New parameters are per stage (1-9)
• half-life of the service life
• proportional use in industry
• storage factors in trade.
The deviation of the load factor (=0.6) and efficiency of the utilization (at 75% PN) is known, and was ultimately evaluated as insignificant, which may be considered permitted.
4. Do you agree with the assumptions on the proportion of motors sold as bare motors compared to those embedded or packaged with machines?
Disagree - only the heat dissipation concept (TEFC, TEAO or TENV) plays a key role in the size/power assignment when embedded or packaged within machines
5. What do you think will be the impact on competition in the market and three phase electric motor availability if the proposed new MEPS levels are adopted, namely:
▪ IE4 MEPS (75kW <= x <= 200kW, poles 2, 4, and 6)
▪ IE3 MEPS (0.75kW <= x <= 375kW)
▪ IE2 MEPS for small three phase electric motors (0.12kW <= x < 0.75kW)
The electric motor market in AUS/NZ is heavily influenced by imported goods. There is no local manufacturing of 3 phase induction motors. Since IE2/IE3/IE4 are already available in the EU and 50Hz countries, this gives the local industry the advantage of readily available electric
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motors.
6. The CBA is based on the supply of bare three phase electric motors. Do you think that the supply of three phase electric motors contained within other equipment, such as pumps, fans and compressors, differ significantly in their size, efficiency and other characteristics from the market for bare motors?
Not necessarily, only the heat dissipation concept (TEFC, TEAO or TENV) plays a key role in the size/power assignment.
7. Do you have any comments on how the market for IE3 motors is changing, compared with the market for IE2 motors, and what factors are driving this change?
End customers see drive technology only as an indirect operating cost and do not understand much of the reduction effect when less energy is required. It must be recognized that the share of energy costs in the final product of the end customer is unknown or so low that an analysis is often not carried out.
Legal requirements, MEPS regulation and government incentives help to force the use and use of higher-quality energy-saving motors in new machines and systems.
8. Figure 12 shows in Australia the overall stock of three phase motors is increasing until
2012 and then declining until 2030 with a slight increase over the next decade. This is largely due to the rapid increase in the period 2000 to 2012 of motors under 4kW. Do you have any insight into why this is the case?
A classic effect is the replacement of a large drive whose power has been mechanically distributed by a number of smaller drives (not mechanically linked) that are installed where the power demand is.
We would expect the overall decline to be due to the increase in controlled drive technology, as newer technologies are used in driven machines The switch to Permanent Magnet, Integrated
Permanent Magnet, Line Start Permanent Magner or Synchronous Reluctance synchronous motors while currently in infancy, we expect will rapidly grow in future.
Minor technical changes
9. Do you support lowering the voltage threshold to 1,000 V?
Yes, to promote alignment and harmonization with IEC global standards.
10. Are you supportive of adopting EU duty cycles under regulation?
Yes, to promote alignment and harmonization with IEC global standards. Other duty types are a very minuscule proportion of electric motor application.
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11. What are your opinions on regulating the following types of motors:
• motors with integral variable speed drive;
• motors incorporating integral brakes; and
• motors specifically designed for the traction of electric vehicles?
Only mechanically inseparable units consisting of motor and VSD or motor and brake should be allowed. If a separation of the motor and the Integral VSD, Integral Brake can be performed and the efficiency of the remaining motor can then be measured, then there is no reason for exemption, provided that the remaining motor is then an asynchronous motor with squirrel-cage rotor and can be line operated on 50 or 60z mains.
All motors in mobile traction of electric vehicle applications should be exempt. These are not
“Line Operated” and would have specific variable speed controllers.
12. Do you support allowing IEC 60034-2-1 (Edition 3):2024 (Method 2-1-1B) as a test
Standard for compliance purposes? This is in addition to IEC 60034-2-1 Ed 2.0 (2014)
(Method 2-1-1B), IEEE 112:2004 and IEEE 112:2017 which are allowed in the current
GEMS determination.
Yes – the efficiency determination by summation of losses is equivalent between these standards.
13. Should three phase electric motors designed to be used with VSDs be regulated separately to non-VFD motors, and what should MEPS level be (IE2, IE3, etc.)?
A distinction between VSD-only motors and DOL (Direct On- Line – Line Operated) motors has proven itself internationally. Introducing a MEPS for VSD-only motors requires a clear definition of the scope of power or torque, the design principles of the motor, and the measuring method to be used to determine efficiency.
The spread of these motors, which are often tailored to the application, E.g. from a thermally highly utilized motor and only used for a short time or a highly dynamic motor with multiple torque or a motor that can be loaded far into the field weakening with multiple nominal speed is extreme and cannot currently be understood in terms of standards to determine minimum efficiencies, Which, in turn, should only be the basis of legal requirements.
Minimum Energy Performance Standards and scope
14. Do you support regulating small three phase electric motors (0.12kW <= x < 0.75kW) at IE2 levels?
Yes we support IE3 for motor below 0.75kW.
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15. Do you support regulating medium (0.75kW <= x <185kW) and large three phase electric motors (185kW <= x 375kW) at IE3 levels?
Yes we support.
16. Do you support adopting IE4 efficiency levels for the three-phase electric motor in 2,
4, and 6 poles configuration in the range 75kW <= x <= 200kW levels?
Yes, to obtain as little country-specific specifications as possible as stated in reply to 1.
Implementation
17. How much lead time would you consider is necessary to comply with an increasing of
MEPS to IE3 levels for the current scope 0.75 kW to 185 kW? Note the proposed timeframe is 2027.
At least 12 months from the introduction of regulations or determination.
18. How much lead time would you consider is necessary to comply with introducing
MEPS at IE2 levels for small three phase electric motors 0.12 kW (inclusive) to 0.75kW?
Note the proposed timeframe is 2027.
For lead time we support at least 12 months from the introduction of regulations or determination.
19. How much lead time would you consider is necessary to comply with introducing
MEPS at IE4 levels for three phase electric motor in 2, 4, and 6 pole configurations in the range 75kW <= x <= 200kW levels? Note the proposed timeframe is 2029.
For lead time we recommend at least 12 months from the introduction of regulations or determination. We support 2029 for the IE4 levels for three phase electric motor in 2, 4, and 6 poles configuration in the range 75kW <= x <= 200kW.
Registration
20. Do you support the proposal to change the family of model’s definition for three phase electric motors? Do you have any feedback on the proposed definition e.g. should it include: shaft diameters and length requirements?
Please see detailed discussion on Family of Models above.
21. Do you support a new requirement to provide an image of a motor’s nameplate at point of registration and why?
We do not support, as nameplates are subject to further national, international and normative change requirements and this would then result in a high effort to make the changed layouts
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known in the registration.
Furthermore, no reference date method can be implemented, as it can take several months between the introduction of a new nameplate layout, the delivery of an OEM and then the onward delivery to Australia / New Zealand.
Labelling
22. Do you support the introduction of product information requirements in line with EU eco-design 2019/1781 requirements Annex 1 point 2?
The product information in Annex 1 (2) contains 13 elements and leads to a multi-page document for the EU. If the same document can be used in AUS/NZ without changes or adjustments, there are no objections. Separate and new documents mean outlay and costs that are assigned to the product and therefore the introduction of such product information is not supported.
23. Do you support the introduction of the requirement to display the current registration number of the three-phase electric motor when offered for supply? Note this includes when a machine that contains a three-phase electric motor is offered for supply.
Please see comments re: Labelling and Nameplates above
Needs clarification – as to whether the reg.-no. would also be attached or displayed on the nameplate or only in quotations and orders.
24. Do you think the existing nameplate requirements on three phase electric motor should be expanded to require a nameplate to be placed on a machine with the motor information, where the motor is not visible externally?
Please see comments re: Labelling and Nameplates above.
Requirements for manufacturers of the machine and systems to attach a 2nd nameplate of the motor visibly should be carefully considered regarding misuse of nameplates. UL and other certifiers generally prohibit the delivery of loose nameplates with their logo so that no other product is mislabelled.
Compliance
25. Is regulation of three phase electric motors and some products they are embedded into e.g. air conditioners and chillers an issue? If so, can you please explain in detail the issue you see.
If a product such as an Air-Conditioner or Chiller is already MEPS regulated, then it would be irrelevant to consider the individual component efficiency of the internally embedded equipment.
The higher the degree of integration of the motor and/or parts of a motor into the application, the more it will be an individual solution. Proof of compliance and market supervision is difficult to demonstrate or only with a high effort that would make little economic sense.
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If they are genuine stand-alone motors, they could be separated from a machine for verification and testing. However, it only makes sense if it costs, effort and results in a real application are willing to be met by compliance and supervision teams.
26. Do you have any suggestions on how compliance of three phase electric motors
(including those embedded in or packaged with machinery) could be improved?
There are basically two ways to consider compliance with laws:
In Europe, manufacturers are subject to the obligation of self-declaration of conformity with all
European directives and regulations. In many other countries, third-party agency approval with certificates and proof exists. However, like in Europe, there are no third-party test labs for power ratings higher than a few kilowatts, and they are not capable of testing all motors within the scope of regulations such as 2019/1781. If all countries required third-party testing with different voltage and frequency combinations, possibly including periodical testing, manufacturers might find this an overwhelming burden.
Both systems have advantages and disadvantages. The European system is based on the original trust of the honest merchant, and proof of abuse must be provided by the state. Market supervisory authorities are consulted to see if customs have a suspected case, and imports can be stopped for this purpose. Most often, test reports are available and required to verify manufacturers' designs, and customers can attend tests.
The Australian/New Zealand system provides registration as proof of conformity before the first delivery. This can be seen as a supported process. It would be advantageous if AU/NZ customs authorities could carry out random checks at national borders. This might be possible for small motors, considering the costs of test equipment, manpower with expertise, and the need for the lab to carry accreditation by Australian NAS.
If you have any questions on this submission, please contact the undersigned.
Sincerely yours,
James Thomson
Lead – Standards and Product Regulation
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