Let’s Talk Transformer Ecodesign!

A lot has been happening for the past few months as DG Grow hired a consultancy to review the current Ecodesign Directives (Tier 1 & Tier 2 for transformer losses). ICF, the company performing the review, published the first draft in November 2023 with the second draft coming in April. DG Grow will be presented with the final report in July and it’s on them then to take it and decide what’s coming next for the world of transformers

As part of Transmission & Distribution Europe and BEAMA, we have discussed the regulation and potential changes over what feels like an infinite number of meetings, and more is still to come. Now we’re talking Europe but the UK adopted these regulations after Brexit and will most likely keep doing so or go more strict, no one knows yet if they have anything planned for us.

Nothing is finalised yet (different stakeholders have different opinions naturally) but to keep you in the loop, below are the main debate areas in the simplest language for non-transformer experts.

?Introducing stricter Tier 3 requirements

Ultimately, this is the core of the regulation, mixed views:

• Compared to other regions, Tier 2 is ahead of other countries requirements but major economies are looking at stricter losses
• Supply chain: Given the exacerbated stress Tier 2 has caused the supply chain (mainly e-steel core manufacturers), some think it will create more headaches and distract us from other more prominent areas of energy savings such as grid agility or even other grid equipment that are less efficient
• Additional costs & dimensional barriers, change between Tier 1 & Tier 2 resulted in an average of 15-25% price increase, 15-20% bigger volume and 30% more mass
• Alternative core materials to CRGO: The review looked at more efficient core materials used worldwide. There is resistance from European manufacturers due to the lack of those core manufacturers within Europe but it must not be dismissed as a viable alternative elsewhere
• Making transformers more compact is a suggestion that assumes manufacturers haven’t already gone for the most effective and economically feasible design
• Moving from TCO to LCA is necessary to inform the final decision of both manufacturing new transformers and replacing ageing assets. This allows us to consider other areas than cost such as carbon, end of life, transport, etc. But more realistically practical and easy-to-use methodology needs to be unified across all manufacturers.

?Peak Efficiency Index calculation for medium power transformers (distribution transformers)

The majority of manufacturers strongly advise against it. PEI looks at every project separately considering the load factor when designing the losses. Not desirable because it throws standardisation out of the window and opens the door for manipulation. Absolute load and no-load loss values are the best way to maintain industry standards.

?End of life

Transformer materials are highly recyclable or down-cyclable apart from epoxy resin, paper & wood. Regulating this is a good idea but there are already markets set up to utilise key components such as Cu, Alu, steel, dielectric fluid, etc. but making this the responsibility of the manufacturer will cause market disruptions and complications.

?Technology neutral approach

Mainly to force Dry Type to become as efficient as Liquid Immersed. Many people think it’s not possible without massively inflating the cost. Both types can be used interchangeably (at design stage) in a lot of private applications but limitations persist especially with power rating limitations. There should be a better naming convention to clearly state that Tier 3 Dry is not the same as Tier 3 Liquid. Moreover, the majority advise against using technology-biased terminology mentioned in the draft such as fire-safe transformers.

?Functional categorisation of transformers

For example, conventional transformers, over-load transformers, etc. shouldn’t be the focus of this regulation, IEC 60076 covers this and can expand on it.

?Reverse Power Flow

The introduction of design features aimed to increase the lifetime & efficiency of transformers when working with reverse power flow is recommended but the regulation needs to focus on the original scope or redefine the scope before going into specifics.

?Refurbishing and repairing transformers

Whether there is a need to make them comply with Ecodesign (Tier 1, 2 or 3). LCA is needed first.

?Appropriateness of concessions and exemptions

• Exemptions for offshore transformers – all reasons for the initial exemption still stand with platform costs, wind turbine nacelle and tower global design limitations, etc.
• Concessions for pole-mount transformers – should be maintained for pole-mount for weight reasons but DNOs would know better
• Concession for special combinations of winding voltages – removing the concession is technically possible (everything is technically possible) but it’ll massively affect the price & physical dimensions and not make a good use of material utilisation
• Environmental impacts – noise and material efficiency are mostly covered by other standards or local authorities
• Concession for 1-2-1 replacement with size constraints and disproportionate costs of installing more efficient transformers – this was never defined by the regulation and has been left to interpretation
• Better policing – countries haven't set a process in place to police concessions apart from the UK with the Regulatory Relief Tool

Worth mentioning that the opinions above do not all reflect my or WPS’ views. I am open to hearing people’s thoughts on the key discussion points.

Regulations in question: Regulation on ecodesign requirements for power transformers (EU) No 548/2014 & the amendment Regulation (EU) 2019/1783.