EU Stage 5 Entails Complex Transition Period

At present, manufacturers of engines and machinery have the possibility of gradually adapting their products to EU Stage 5. To this end, the legislator has provided different periods of time for the production and sale of engines and machinery.

Major changes in the legal framework for the production and approval of engines and machines continuously present manufacturers with challenges. The EU Stage 5 emission standard is no exception – in fact, quite the opposite. Significantly lower emissions from internal combustion engines requires major technical intervention. Some manufacturers have adapted their existing engine concepts as far as possible to meet the new EU standards. Others, such as Hatz, have taken this opportunity to redesign their engines in order to be optimally equipped for Stage 5 and the long term.

Both the newly designed engines and those that have been retrofitted with complex exhaust gas aftertreatment systems have an impact on machine manufacturers. Different mounting points, changed dimensions or the space-consuming components of the exhaust gas aftertreatment often require an adaptation to the machine – in some cases, even a completely new design. This particularly affects manufacturers of compact machines who have to cope with very limited space.

The bottom line is clear: EU Stage 5 requires a high level of commitment from the industry as a whole and a high level of investment. Regulators are aware of this problem and have already included a transition phase in the drafting of the EU Stage 5 regulation which allows manufacturers of engines and machinery a specific period of time for the changeover. However, this construct is complex and riddled with special regulations.

Differences between manufacturers

In the first step, EU Stage 5 distinguishes between engine types and application categories, which was discussed in the May, 2018 issue of Diesel Progress International. In the transition phase, additional differentiations are made between engine and machine manufacturers. The

The EU Stage 5 emissions regulations include 10 different categories to differentiate the engines by application. Special regulations for the various engine and machine categories are listed in the FAQ document of the CECE – Committee for European Construction Equipment.

primary goal of the legislator is to phase out the “old” non-EU Stage 5 engines. Not only is the production of engines considered, but also the production of machines. Firmly defined deadlines have been set for the production stop and sales stop of non-EU Stage 5 engines. Manufacturers of machines may install the engines in their machines beyond the engines’ production stop but must have sold them by the later sales deadline. Various individual regulations must be observed for EU Stage 5.

Time schedules for engines and machines

Since Jan. 1, 2017, manufacturers of engines and machinery have been in the transition phase of EU Stage 5 and must comply with different deadlines. During this phase, engine manufacturers may produce ‘transition engines’ which do not comply to Stage 5 emissions standards for a further two years. Production and placement on the market of these engines was permitted until the end of 2018.

In order to avoid grey areas regarding production and placement on the market, the legislation includes precise definitions. For example, the production of an engine is defined as the time at which the engine passes the final test after it has left the assembly line. Placement on the market of an engine or machine is equivalent to the first provision within the EU. An engine or machine is not placed on the market until the individual unit is available for distribution or use within the EU from the manufacturer or importer. This means that the engine or machine must be at least complete and ready to be transported from a factory within the EU or from customs to the EU, and there must also be an offer or agreement to transfer ownership or possession. The unit must then be sold or at least offered for sale.

The rule for transition engines states that manufacturers may designate certain engine types which are at least close to the Stage 5 emission standard – e.g. with emission stage 3b or 4, depending on the performance class – as transition engines. Although these engines could only be produced until the end of 2018, they may be put into circulation until the end of 2020. It remains to be seen how many engine manufacturers were able to produce and stock transition engines.

Machine builders also have a fixed time window for using transition engines. They may manufacture their machines with these engines until the middle of 2020 and must place them on the market by the end of that same year.

Decisive strategy

For manufacturers of engines and machines, problems can arise if their transition engine strategy is not well thought out. While some machine manufacturers are currently relying on transition engines that can be offered at attractive prices, in the medium-term, there is no way of getting around the somewhat more expensive EU Stage 5 engines which have also undergone significant technical development and are cleaner. Hatz, for example, combines the technology for transition and EU stage 5 engines with its new H series diesels. This combination, the company believes, allows machine manufacturers to take advantage of the transition phase and to be prepared for EU Stage 5 today. This approach can significantly mitigate a hastily-forced redesign of machines at the end of the transition phase and ensure continuous sales, even after the end of 2020.

Editor’s Note: This is Part 2 of a three-part series on EU Stage 5 issues written by Bernhard Richter-Schützeneder, head of Sales and Marketing at Motorenfabrik Hatz. The first in the series appeared in the May 2018 issue of Diesel Progress International.

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