Grundfos believes that clearly excluding the discontinued IEC frame sizes from EISA is the right decision.
Grundfos utilizes IEC 100 frame size and imports the motors from Hungary. We would like to have sufficient grace period (12 weeks from Feb 4th) to minimize the financial impact on manufactuers who imports the motors.
From the day the decision is made for these motors in our offices to the time the motors arrive to customs is about 16 weeks. A 12 weeks grace period will mnimize the impact by allowing the products in production or on a boat at the time of ruling.
I believe no grace period or short grace period will penalize only foreign manufacturers.
Regards,
2011-01-10 Submitter Information
This is comment on Proposed Rule
2011-01-05 Energy Conservation Program: Test Procedures for Electric Motors and Small Electric Motors
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