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Dual Use Changes

General Information

Kollmorgen is updating the AKD and Servostar drive products firmware in order to comply with the recently revised US & EU export regulations (EU Dual Use Regulation 428/2009 & U.S. Dual-use regulation EAR Category 3 under ECCN3A225). This revision  will reduce the open loop frequency limit to 599 Hz, without this change our products would become dual use goods in both the US and EU and may require Kollmorgen and/or you to obtain export licenses when exporting these products. While most customers will not be affected by the functional change or product compatibility changes caused by the update, the frequency limit may eliminate the need to obtain an export license however you should consult your export compliance administrator.

These product updates will occur in product shipped after Dec. 15th, 2014.

Please see Appendix A for references to the US and EU Amended Export Classifications for these Products.

Products affected:

Kollmorgen AKD servo drive – all models (model numbers starting with: AKD-B, AKD-P, AKD-T, AKD-N, AKD-M)

            Kollmorgen Servostar drive  - (part numbers starting with: S7xx, S3xx, S6xx, S4xx)

            *See product label schemes in Appendix B to identify affected product

Customers that are affected will have several options available to ensure compliance with export regulations and also to maintain product compatibility. See Appendices C and D for an explanation of possible actions.

Some Kollmorgen legacy products will also be affected by the dual-use laws, but will not be updated. Please check Appendix A, if older products you are using will fall under the export control.

If you do not use the above products, you are not affected in any way. For previously purchased products, the new export regulations do not require changes if products are integrated into higher level assemblies prior to export. If you have AKD or Servostar product in inventory, you may be required to comply with the new regulations, but only if you are exporting product without installing it into a top level assembly before export. This includes product sold as “spare parts” that may be shipped to customers. See Appendix E “Product Inventory Flow Chart” to understand your options and actions if you fall into this case. This letter is intended to generally inform you on the change in the export regulations and the steps that Kollmorgen has taken in response to the regulation change. Accordingly, you are encouraged to consult your export compliance professional with any questions and to determine how these regulations may impact your business in the future.

Appendix A - F.A.Q.

Q: What regulation(s) are changing?

A: The following regulations:

EU Dual-use Regulation 428/2009

U.S. Dual-use regulation EAR Category 3 under ECCN3A225

With the AKD and Servostar drives’ capability to potentially commutate an AC induction (open loop operation) over 600 Hz, we have chosen to limit the commutation frequency in all future product to 599Hz.  This change will exempt the products from the classification and allow them to remain non-controlled product.  Most industrial automation products fall under this general classification.

Q: Why do regulations apply to these products at > 600Hz commutation?

A: The regulations are intended to prevent certain individuals from obtaining technologies that can be used to build high speed centrifuges, which are an enabling technology for the enrichment of Uranium. Please consult your export office for certain countries that may require an export license.

Q: Is the model number of the product changing?

A: No.  The model number of the product is not changing.

Q: Is the firmware version changing?

A: Yes, in the AKD Product Family the new version of firmware shipping from Kollmorgen will be V01_13_xx_xxx (or later) and will be non-controlled items in the context of these regulations.

In the Servostar product family the firmware versions will be changed according to the following table:

Fw version State Comment
x.xx (e.g. 9.50) Export controlled (Dual use) Old Fw shipped before Dec. 15th
x.xx_ND0 (e.g. 9.50_ND0) Non controlled (non Dual use) Fw with limited output frequency in sensorless mode,
x.xx_ND1 (e.g. 9.50_ND1) Export controlled (Dual use) Fw with non limited output frequency, dedicated to customers which need this functionality

Q: How do I determine that I need a license if I decide that I want to export old product that I have in inventory?

U.S.: http://www.bis.doc.gov/index.php/regulations/export-administration-regulations-ear

In any other country: Other regulations and rules may exist.  Contact your export office for more information.

Q: Can I get product updated by Kollmorgen?

A: Yes, product can be returned to Kollmorgen for the updates free of charge. However, freight costs will not be covered by Kollmorgen. Follow the RMA process to return the product.  It will be upgraded and returned as uncontrolled product.

Q: Can I convert these products from “Controlled” to “Not Controlled” in the field (i.e. can I do it myself)?

A: No, the product must be returned to Kollmorgen if this update is necessary.  See “Product Inventory Flowchart” for guidance.  Follow the RMA process to return the product.  It will be upgraded and returned as uncontrolled product.

Q: Are any other products affected?

A: These Kollmorgen HF-Drives are affected.  These are legacy obsolete products, which are very rarely sold anymore.

ACO 5000, K 4000, VHF 1400

These will be listed 3A225.  We will not re-engineer changes to create a compliant dual-use product.

Appendix B - How do I know if I have controlled product or not?

Label from AKD Product Family

akd-label.PNG

Label from Servostar

servostar-label.PNG

EU Wiki page - http://wiki-kollmorgen.eu/wiki/tiki-index.php?page=Export+Classification

Appendix C - What is the functional compatibility of new and old products?

AKD Functional Compatibility  Matrix

Physical Product

Firmware Version

Compatibility

Notes

new product

new firmware

compatible

New product is compatible with the new firmware V01_13_xx_xxx  or later, or the "compliance updated" versions V01_11_00_011 & V01_12_00_003; which are being offered to help customers concerned with change control and want to use prior releases

new product

old firmware

not compatible

New product is not compatible with older firmware due to the new regulations.  Customers must upgrade to new firmware, which is V1_13_xx_xxx or one of the patch versions of older firmware which has been made compliant.

old product

new firmware

compatible

When the new firmware is downloaded, the produced is upgraded to the newly compliant state.  The product can no longer be used with older firmware.  It is now locked to compliant versions of firmware only.

old product

old firmware

compatible

Old Firmware will no longer be distributed by Kollmorgen, but customers can continue to use old firmware if they have it.

 

 

 

 

 

 

 

 

 

 

 

 

 

Servostar Functional Compatibility Matrix:

No

Physical Product

Export license needed

Old Firmware

Display

New Firmware

Display

1

Old  product

maybe

Compatible, No freq. Limit

5.80

Compatible, Freq limit

5.80_ND0

2

New product

No

Not compatible

-----

Compatible, Freq. limit

5.80_ND0

3

Old product

maybe

Compatible, No freq. Limit

5.80

Compatible,

No freq. limit

5.80_ND1

4

New product

maybe

Not compatible

-----

Compatible,
No freq. limit

5.80_ND1

  1. This refers to drives, which have been shipped before 12/15/2014.
  2. Refers to standard drives, shipped after 12/15/2014 with limited output frequency.
  3. Refers to new drives with export license, which can be used with old firmware. This version will only be available on request.
  4. Refers to new drives with export license.

Appendix D - Functionality Decision Flow Chart

functionality-decision-flow-chart.PNG

Appendix E - Product Inventory Flow Chart

product-inventory-flow-chart.PNG

Q: Will an export license be required to return product from outside to Kollmorgen?

A: No.