A QUICK GUIDE TO NON-ROAD MOBILE MACHINERY (NRMM) LEGISLATION

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A QUICK GUIDE TO NON-ROAD MOBILE MACHINERY (NRMM) LEGISLATION

WHAT IS THE NON-ROAD MOBILE MACHINERY LEGISLATION?

In the legislation Non-Road Mobile Machinery (NRMM) is defined as any mobile machine, item of transportable industrial equipment or vehicle that is not intended for carrying passengers or goods on
the road and is installed with a combustion engine. This covers a wide spectrum of different machinery including:

  • Small gardening equipmen
  • Agricultural and farming machiner
  • Railway locomotives
  • Inland waterway vessels
  • Construction machinery
  • Generators used in non-fixed/ mobile installations (typically hire applications)

Engines are split into two categories: spark ignition (SI) and compression ignition (CI). These are then further separated by engine power rating. These different categories are given limits for the engine’s ‘stage’, or its specified gaseous output. SI engines of up to 19kW net power are covered by NRMM, while variable-speed and fixed-speed CI engines (as used in generators) are covered where their rated power is above 18kW.

 

WHAT’S CLASSED AS NON-ROAD MOBILE MACHINERY?

The pathway to reducing diesel engine emissions (NRMM) started back in 1997 and have been amended eight times since then. These directives have allowed individual EU members to modify laws to achieve the intended outcomes, resulting in 28 national (UK) laws currently in effect. The EU has adopted a series of seven directives over the past two decades, with the latest Stage V
standards being adopted in 2016 and coming into effect in January 2019 and 2020.

 

WHEN DID THIS COME INTO EFFECT?

The pathway to reducing diesel engine emissions (NRMM) started back in 1997 and have been amended eight times since then. These directives have allowed individual EU members to modify laws to achieve the intended outcomes, resulting in 28 national (UK) laws currently in effect. The EU has adopted a series of seven directives over the past two decades, with the latest Stage V
standards being adopted in 2016 and coming into effect in January 2019 and 2020.

WHAT WILL THE NRMM LEGISLATION MEAN FOR YOU?

The Stage V emissions standards have tightened restrictions and set stricter limits on emissions. The introduction of these requirements has led engine manufacturers to adapt the design of older engines or design new engines in the effected power range. Most have found it necessary to add additional filtering to the exhaust system utilising technologies which includes: Diesel Oxidation Catalysts (DOC), Diesel Particulate Filters (DPF), Exhaust Gas Recirculation (EGR) and Common-rail (CR) fuel injection.

  • DOC – Most commonly used catalyst converter, containing palladium, platinum and aluminium oxide, which catalytically oxidise hydrocarbons and CO with oxygen to form CO2 and water.
  • DPF – Designed to remove diesel particulate matter from the exhaust gas of a diesel engine.
  • EGR – Recirculates a portion of an engine’s exhaust gas back to the engine cylinders, diluting the O2 in the incoming air stream to reduce peak in-cylinder temperatures and reduce NOx emissions.
  • CR – is a high-pressure direct fuel injection system, resulting in a more complete and cleaner combustion.
    Engines with power outputs above 56kW will also require the addition of Selective Catalytic Reduction (SCR) modules to reduce the level of Nitrous Oxides (NOx) emissions. The SCR is a special catalyst which is built into the exhaust system. When the engine reaches its optimum operating temperature a liquid reductant (usually ammonia) is injected into the exhaust stream, this sets off a chemical reaction that turns NOx into nitrogen, water and a small amount of CO2.

When choosing the generating set for non-fixed installation the chart below shows the transition from EU Stage III to EU Stage V. Non-transition engines MUST have been manufactured and in the in use by the deadline of the 31st December 2018. Machines with transition engines, in general, may be produced for 18 months from the respective Stage V “placing on the market dates” and may be placed on the market for a further 6 months. This rather “opaque” ending of the transition machine production leaves scope for ambiguity but the onus is placed on the used to ensure they comply with these statutory requirements.

From this chart it is easy to determine that the transition from Stage IIIa to Stage V engines came to an end on the 31st December 2020. Engines built by that date had to be built into a “completed generator” and ready to be “placed on the market” prior to the end of June 2021. In order to be in full compliance, all completed generating sets MUST have reached and been “placed on the market” by the 31st December 2021. Placing on the market is defined as ‘Placing on the market’ occurs when the genset is transferred from the manufacturer or importer to the next step in the supply chain, within GB. It does not have to be with the end user; it could be with a distributor (so long as they are not the importer) or dealer. (1)

As a company hiring and or using a Non Road Mobile Machine you are responsible to ensure that you comply with the law. Things to look for and check:

  • Manufacturers of Stage V product are keen for you to know that it is a compliant piece of equipment and as such is likely to be clearly mark / visible on the size of the packaged generating set (as above illustration)
  • The generating set will, as part of its maintenance regime, require to be topped up with “AdBlue”
  • The date of production on the engine serial plate will be 2019 or later (except for powers between 26-130kW which will be 2020 onwards)
  • Look for the year of production of the generating set itself – the generator must have completed production and been tested by the 30th June 2019 (except for powers between 26-130kW where the generating set must have completed production and been tested by 31st December 2020) https://www.euromot.eu/wp-content/uploads/2021/02/StageV_marketsurveillance_ guidance_January-2021_V2.pdf

To protect your legal position:

  • Check with your supplier for their compliance (seek documentary confirmation) such as:
  • Generating set factory test documents
  • Date of supplier purchase – such as purchase invoice (confirmation of market placement)
  • Date of first hire if the company hiring the set is also the manufacturer
  • Check the engine serial plate for the year of production
  • Check the generating set production date
  • That the set is fitted with an SCR and that AdBlue is required
  • Make the provision of a “stage V” generating set a contractual obligation of the hire agreement etc

The additional emissions filtering equipment has added significantly to the cost of producing the Stage V machines, this combined with some additional maintenance costs have had the impacted significantly to the cost of hiring Stage V equipment. WB has invested heavily in Kohler Stage V product so please talk with us about your requirements etc

 

LOW EMISSION ZONES

London has led the way with the introduction of low emission zones with other such as Birmingham and Manchester in hot pursuit. London’s ‘Low Emission Zone’ for Non-Road Mobile Machinery Non-Road Mobile Machinery (NRMM) | London City Hall is now in place and its requirements adhered too. For further information of this requirement please follow the link.

https://www.london.gov.uk/programmes-and-strategies/environment-and-climate-change/pollution-and-air-quality/nrmm

 

CLARIFICATIONS

(1) As per guidance issued by The Association of Manufacturers of Power generating Systems (AMPS) March 2023

AUTHOR
G R Halliday

Business Consultant

WB Power Services Ltd

Geoff Halliday started his career as an apprentice working for Square D (later part of Schneider) before moving into the critical power sector where he has now worked for over 40 years, splitting that time equally between both the UPS and standby diesel generation sectors.

During this period Geoff has held several roles ranging from Customer Service Engineer, Project Manager, Technical Director, Sales Director through to Managing Director.

The Critical Power market exposes the individual to a wide and diverse range of market sectors ranging Health Care, Life Science, Water Treatment, Banking and Finance, Military, Manufacturing, Process Control through to Data Centres of all sizes. Drawing on his management skills, product knowledge and vast application experience amassed throughout his career Geoff now enjoys sharing his knowledge with others.

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