EU targets high frequency drives

EU Regulation 428/2009 and its subsequent amendments cover the export of "dual use” products - goods, software and technology normally used for civilian purposes but which may have military applications, or may contribute to the proliferation of weapons of mass destruction. Product types affected are listed in Annex I, No. 3A225. The latest amendments came into force in December 2014, while similar regulations are also in force in the United States. Similar regulations were introduced to China earlier this year.

For drives, this legislation lists as falling under the jurisdiction of the Regulation, drives having

• Multiphase output providing a power of 40 VA or greater;
• Operating at a frequency of 600 Hz or more; and
• Frequency control better (less) than 0.2%.

There is a subtle difference between the old version and the new (see Table (Teco)). But this apparently minor amendment brings into scope a much wider range of products.

While some interpretations of the new amendments may seem somewhat Draconian and over-stated - hefty penalties, including potential prison sentences, for machine builders and system integrators - it is at least worth bearing in mind the possible implications.

High frequency drives are used in a number of inoffensive applications, including certain types of medical diagnostic equipment. But they can also be used in uranium enrichment - hence the stricter export controls.

It is somewhat unclear whether the Regulation relates solely to drives on their own, or to products which contain them. Not everyone in the drives industry is at one on this, but the balance of opinion is that it does. Anyone requiring advice is encouraged to contact the UK Department for Business Innovation and Skills (BIS) for further advice.

Export controls of this nature are nothing new: during the Iran-Iraq war (September 1980 to August 1988), Saddam Hussein acquired metal tubes from firms in the United Kingdom, intended for the so-called Project Babylon supergun. All were intercepted by Customs and Excise and none ever reached Iraq. The suppliers were under the impression that their tubes would have been used in a pipeline project.

Project Babylon was a project commissioned by Saddam to build a series of 'superguns'. The design was based on 1960s research by the Canadian long-range artillery expert Gerald Bull. Bull wanted to launch a satellite using a huge artillery piece, and designed the Project Babylon "supergun" for the Iraqi government. Bull was assassinated outside his apartment in Brussels in March 1990.The project was halted and parts of these superguns were seized in transit. The components that remained were destroyed after the 1991 Gulf War.

More recently, aluminium tubes purchased by Iraq in 2001 were publicly cited by the White House as evidence that Iraq was actively pursuing an atomic weapon. After the 2003 invasion of Iraq, the Iraq Survey Group found no evidence of a programme to design or develop an 81-mm aluminium rotor uranium centrifuge.

The position of Emerson Industrial Automation, according to Control Techniques President Enrique Minarro Viseras, is that businesses which export to locations outside the EU controlled goods or machines that incorporate them must apply for the relevant export licences from their respective governments.

CT took the step of limiting the frequency of the majority of its drives in anticipation of the new legislation. The Control Techniques Unidrive M range was limited to 550Hz since its introduction in 2012, and older drive models were revised to be limited to 550 Hz.

Kollmorgen has updated its AKD and Servostar drive products to comply with amendments to EU Dual Use Regulation 428/2009 & US Dual-use regulation EAR Category 3 under ECCN3A225. Updates were incorporated in product shipped after 31 Dec 2014. To comply with new regulations, Kollmorgen changed the open-loop frequency limit on its products to 599Hz.