The European Association of the Electricity Transmission
and Distribution Equipment and Services Industry
Implementation Guide 2/3/2020
T&D Europe Implementation Guide for Commission
Regulation 2019/1783, amending Commission Regulation
N°548/2014
Scope of the paper
This Implementation Guide describes the main changes to Commission Regulation (EU) No
548/2014 of 21 May 2014 on implementing Directive 2009/125/EC of the European Parliament
and of the Council with regard to small, medium and large power transformers1, following the
adoption of Commission Regulation 2019/17832. differences between the original
implementing Eco-design regulation voted in 2014 and the changes introduced by the
amendment voted on January 15th, 2019 and published in official journal L272 on 25/10/2019.
Disclaimer: This T&D Europe Imlementation Guide reflects the best knowledge of industry
experts from all over Europe and the state of the art at the moment of its publication. This
document aims at providing a descriptive overview of the relevant legal provisions,
interpretation notes and reference documents that technology manufacturers need to be
aware of when identifying the precise compliance measures to be taken for their specific
products. A binding interpretation of EU legislation is of the exclusive competence of the
European Court of Justice. Subject to new information, this document may be modified to
accommodate new developments. Such information will be made available on T&D Europe’s
website.
1
https://op.europa.eu/en/publication-detail/-/publication/9124a197-e17f-11e3-8cd4-01aa75ed71a1/language-
en
2
https://eur-lex.europa.eu/legal-content/GA/TXT/?uri=CELEX:32019R1783
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Introduction
In 2007, the European Commission started working on the performance of power transformers
to help the EU to reach by 2020 the 20/20/20 targets agreed by Member States.
The 20/20/20 targets are:
• 20 % cut in greenhouse gas emissions (from 1990 levels);
• 20 % of EU energy should come from renewables;
• 20 % improvement in energy efficiency;
In 2007 the Commission agreed to begin developing the transformer regulations. Following
extensive studies by VITO (a consultant contracted by the Commission) with stakeholders,
including transformer manufacturers and utilities, the European Commission adopted
Regulation No 548/2014 in 2014. This Regulation fixed the minimum energy performance of
transformers from 1st July 2015. The Regulation contained a provision that required that it
should be evaluated and, if necessary, modified after 3 years. In compliance with this
requirement, the current revision was conducted in 2019, resulting in the development and
publication of an amending regulation. This paper sets out the changes that are immediately
applicable (after 14/11/2019) as well as the new and improved minimum energy performance
requirements, effective from 1st July 2021. The implementation of the new provisions are
estimated to result in energy savings of 16 TWh per year from 2020 onwards, which corresponds
to 3.7 Mt of avoided CO₂ emissions. This is equivalent to saving half of the annual electricity
consumption of Denmark (32 TWh) per year3.
The main conclusion of the evaluation was that transformer technology can reach TIER1 [I4]
4
efficiency levels in 2015 without difficulty. In all case where there are no other constraints
for the transformers' specification, there are no technical barriers foreseen by manufacturers
in producing TIER2 transformers[I6].
3
Press release European Commission : https://europa.eu/rapid/press-release_IP-14-591_en.htm
4
References in square brackets refer to the page of the relevant text of the amended regulation and annex
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The amendments to the Regulations comprise two parts, the first contains revisions to the
scope, definitions, global requirements of eco-design, conformity, benchmark, market
surveillance aspects and the content of the review. The second part concerns the annex which
contains detailed eco-design requirements with tables and values.
The content of the amendment
As explained above, the amendment deals with more general administrative requirements and
not the specific data for an individual transformer.
Most transformers are produced in large quantities for common applications, making the
definition of energy performance relatively easy, but in a few cases with special transformers
and those intended for special applications and meeting specific constraints, it is not so easy
to define the performance because this depends on several parameters that are not always
known. For this reason, the Commission has decided to exclude some types of transformers
from the energy efficiency requirements of the Regulations [A1.2]. In the previous Regulation
some of the definitions for the excluded transformers were not clear and this has been
reviewed. In the case of transformers for onshore wind turbine and solar applications [A1.2b],
it is now made clear that these are not excluded from the regulation and must apply the energy
performance criteria. Special transformers for railway applications [A1.2f, A.1.2h], and
starting transformers [A.1.2i] have clearer definitions. Transformers for offshore platform
[A.1.2d] (wind turbine) have been excluded along with some nuclear power plant[2o]
applications and all transformers rated less than 5kVA [A.1.2p]. Nevertheless, the obligation
to fulfil the official technical documentation for all transformers was highlighted even when
the transformers are excluded [Annex4d] from the energy performance requirements of the
regulation.
The definition of transformers for emergency conditions [A.1.2d] is now more clearly defined
and corresponds to transformers especially designed to replace normal power supply for a
limited period due to unplanned events or maintenance operation. These kinds of transformers
are excluded from the energy performance related requirements of the Regulation.
The amendment now clarifies the performance requirements of the transformers that are
subject to after sales operations [A1.3] considering the kind of operations to be done. If all or
a part of the magnetic core is replaced and also one or more windings replaced (IEC60076-1
Chapter 3.3), then the transformers must meet the new efficiency requirements in force when
it is made available again.
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Note:
The regulation is applied only in the case of a change of 3 medium voltage or 3 low voltage
phase coils along with the partial (e. g. upper yoke) or complete change of core
The definition of Large power transformers and Medium power transformers has changed [A2.3,
A2.4], and it has been decided that all non-standard transformers will be set peak index
efficiency (PEI) requirements which are immediately applicable. This changes the limits of
Maximum Rated Power for standard transformers (called MPT) which is now 3150kVA instead
of 40MVA. MPT are referred to as standard transformers because they are manufactured in
large quantities with common components.
To meet the needs of some Member States, the rating of pole mounted transformers has been
increased from 315kVA up to 400 kVA. [A2.7]
The definition of declared values [A2.17] has been clarified to be the values measured on the
transformer during routine factory tests [A2.20] that shall be included in the technical
documentation before compliance checks by Market Surveillance Authorities (MSA). The
declared value of losses or PEI have to meet the requirement of the Regulation without
applying any tolerances [Annex III].
Definitions for dual voltage [A2.18], equivalent model [A2.21], model identifier [A2.22],
witness testing [A2.19] and factory acceptance test [A2.20] have now been given.
A concession has now been given for electricity distribution networks in the Czech Republic
where the insulation level led to uncertainties in the definition of losses[A3].
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It is important to note that manufacturers, importers or authorized representatives are
responsible for the conformity of the product with the Regulation[A8].
The Regulations will be reviewed to see if technological progress creates the need for further
amendment, any such changes will be presented to the Consultation Forum by 1st July
2023.[A7] The review will address several points, most notably whether the TIER 2 has been
cost effective and if some other measures might be appropriate. Among these measures the
European Commission can:
• introduce a definition of TIER 3 performance levels
• set minimum performance requirements for small transformers
• evaluate
o some exemptions such as offshore applications
o concessions related to pole-mounted transformers
o special combinations of windings
o new concession on MPT and LPT brought in by the 2019 amendments
• consider introducing environmental impacts other than energy in the use phase, such
as noise and material efficiency
• consider the possibility of applying PEI calculations for losses instead of absolute loss
values for MPT
• whether or not to adopt a technology neutral approach for liquid immersed, dry-type
and electronic transformers.
Modification of the Annex
The Amendment Annex deals with more specific data for dedicated transformers and presents
most of the value for the design of the transformers.
In the original Regulation No 548/2014 there were no energy performance requirements for
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• All transformers with voltage >36kV and rated power less than 3150 kVA
• Dry type transformers above 40MVA.
In the 2019 Amendment Annex, PEI has been established for these cases where the limit is now
≥200MVA and has been changed above 100MVA for liquid immersed [Annex I Table I.7] and
≥63MVA for dry type transformers [Annex I Table I.9].
The table of losses has also been reviewed for three-phase liquid-immersed medium power
transformers with one winding with Um ≤ 24kV and the other with minimum voltage Um ≤ 3,6kV
rather than 1,1kV [Annex I Table I.1, Annex I Table I.2]. This has been done to avoid
manufacturers over sizing the insulation of their transformers to take benefit of correction
factors for losses.
For Um ≤ 24kV the correction factor has been eliminated and these transformers now have to
fulfil the same energy performance requirements as basic transformers [Annex I Table I.3a]
independently of the secondary highest voltage. However, for Um =36kV the correction factor
remains valid with a small change for no-load losses for liquid immersed which changes from
20% to 15% [Annex I Table I.3a]. The table covering dual voltages has been fully reviewed as
this table was liable to misunderstanding in the original Regulation [Annex I Table I.3b].
To ensure that pole mounted transformers were not too heavy for the existing poles in certain
countries, pole mounted transformers have been allowed to have higher levels of losses. To
avoid having to replace existing poles to withstand the higher weight of more efficient
transformers, the Commission allows for ‘one to one’ replacement of pole mounted
transformers, in which case a special table of higher losses applies [Annex I 1.4]. In this case
the manufacturers, importers or the authorized representatives must specify that this is a ‘one
to one’ replacement in the technical documentation along with all other mandatory
information, such as the address, either the local destination or the specific installation type.
This means that for other cases new pole mounted transformer installations must comply with
the standard table of MPT.
Experience with implementing the Regulations has shown some difficulties in some cases in
installing compliant transformers, for example, the weight or size could create issues for
transportation to the location where the transformers were installed. For this reason, it has
been decided to give some concessions. The following concessions may be applied but shall be
notified to the competent national market surveillance authority and justified in the Technical
documentation (to be done by the manufacturer, importer or authorized representative).
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When disproportionate costs appear with TIER 2(Installation, surface, ….) that are not
compensated by electricity losses saved for the expected service life the following rules can
be applied:
• For Medium Power transformers ≤3150kVA ≤36kV, the replacement of one to one can
be done with TIER 1 transformers. It is the responsibility of the manufacturer to obtain
evidence that the customer is buying the transformer for one to one operation; [Annex
I 1]. There is no concession in the case of a new installation.
• For Large Power transformers, the replacement of one to one can be done with
transformers TIER 1 or no minimal requirements. It is also allowed for new installations
to implement TIER 1 transformers [Annex I 2].
The text of the Regulation has been improved by clarifying what information must to be given
on the rating plate [Annex I 3] and also when the transformer has been exempted from the
regulation [Annex I 4]. This exemption must now be written in the technical documentation
with the specific reasons leading to this exemption [Annex I 4].
When calculating efficiency, the electrical power required for the cooling system is now well
defined and includes all the losses caused by the operation of the transformer [Annex II].
Market surveillance, which was a weak point in the Regulation, has been improved by making
it possible for the market surveillance authorities to attend the FATs to verify compliance with
the Regulations [Annex III 1].
Rules of application for the amendment 2019/1783
The amended Regulations was published on the 25 October 2019 and the modifications
described in paragraph 2 and 3 of this document must be applied as of 14th November 2019.
All new contracts signed after 14th November 2019 shall be fully compliant with the regulation
2014/548 and 2019/1783.
The rules regarding the manufacturing and delivery of TIER 2 are subject to guidance set out
in the Blue Guide5 which covers European Union product regulation from 2016.
5
The 'Blue Guide' on the implementation of EU product rules 2016,
http://ec.europa.eu/DocsRoom/documents/18027/
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In the Blue Guide, two stages are defined:
1) Placing on the market
A product is placed on the market when it is made available for the first time on the union
market.
This phase is only relevant to for manufacturers or importers.
❑ In normal situation (when there is no concession), this means that after 1st July 2021
manufacturers and importers will not have the right to transfer of ownership of
transformers TIER 1. Then only Transformers TIER 2 can be supplied, even if contract has
been signed before 1st July 2021. The meaning of transfer of ownership depends of
Incoterms applied with the contract.
2) Making available
Products made available on the market must comply with the applicable Union harmonisation
legislation at the moment of placing on the market.
In the case of a distributor that had received transformers from a manufacturer or importer,
then the transformers have been placed on the market and made available.
• The Blue Guide demands "to place on the market" or to "put in service" transformers
compliant with TIER 2 after the 1st July 2021 but not necessarily both of these steps.
❑ That means that from 1st July 2021, a distributor can transfer to the user or another
distributor and put in service transformers TIER 1 if these transformers have been placed
on the market before 1st July 2021. Stockpiling of Tier-1-only compliant transformers by
distributors is certainly in conflict with the aim and spirit of the regulation.
Impact on the CENELEC standards
It is normal for the Commission to list Harmonized Standards which, if manufacturers comply
with them, provide an assumption of conformity with the Regulations. This link was
established when EN50588 and EN50629 were listed in the Official Journal (2016/C 416/04)
published in 11.11.2016 for the original Regulations adopted in 2014. With the amendment of
the regulation adopted on October 1st, 2019, the previous ENs are now obsolete.
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The two standards (EN50588 MPT ≤3150KVA and ≤36KV and EN50629LPT >3150KVA and > 36KV)
will be superseded by the new series of prEN50708 which it is expected to be adopted following
the amendment.
CENELEC has decided to review all transformer standards related to the Directive to improve
their visibility by adopting an appropriate numbering EN50708.
The new standard EN50708 will be split in 3 mains parts and subparts:
1. EN50708-1-1 Power transformers - Additional European requirements: Part 1-1 Common part
• EN50708-1-2 Power transformers - Additional European requirements: Part 1-2
Assessment of power transformer energy performance
• EN50708-2-1 Power transformers - Additional European requirements: Part 2-1
Medium power transformer
• EN50708-2-2 Power transformers - Additional European requirements - Medium
power transformer: Part 2-2 Accessories
• EN50708-2-3 Power transformers - Additional European requirements - Medium
power transformer: Part 2-3 Special tests
• EN50708-2-4 Power transformers - Additional European requirements - Medium
power transformer: Part 2-4 Single phase transformers
• EN50708-2-5 Power transformers - Additional European requirements - Medium
power transformer: Part 2-5 Non-conventional technology power transformers
2. EN50708-3-1 Power transformers - Additional European requirements: Part 3-1 Large power
transformer
3. EN50708-3-2 Power transformers - Additional European requirements - Large power
transformer: Part 3-2 Special tests for corrugated tank and radiators
These standards will be published starting in early 2020 for the main part and up to 2022 for
the sub parts 1.2, 2.2 and further parts.
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Conclusions
The revision of the regulation is a step forward in energy efficiency and sustainability.
This revision has clarified:
• the scope of excluded transformers
• set out the rules for the repair
• clearly defined the declared values
• improved by around 10% the efficiency of the transformers by the implementation
of the TIER2.
To help the users in case of highly constrained situations, concessions have been defined for
MPT, LPT, pole mounted with compulsory declarations in the technical documentation and to
the market surveillance authorities.
CENELEC standards will soon be ready to support this amendment.
The target of the next revision of the regulation that will start in 2023 is also defined.
ABOUT T&D EUROPE
T&D Europe is the European Association of the Electricity Transmission & Distribution Equipment and Services
Industry, which members are the European National Associations representing the interests of the electricity
transmission and distribution equipment manufacturing and derived solutions. The companies represented by T&D
Europe account for a production worth over € 25 billion EUR, and employ over 200,000 people in Europe. Further
information on T&D Europe can be found here: http://www.tdeurope.org
CONTACTS
Diederik Peereboom Laure Dulière
Secretary General, T&D Europe Policy Adviser
[email protected] [email protected]
+32 2 206 6888 +32 2 206 6863
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