Short summary

Following the third Consultation Forum on industrial fans held on 9 June 2023, and the subsequent interservice consultations, the Commission has published the revised draft for feedback. Eurovent together with European AMCA submitted comments on draft elements in the working document presented at the Consultation Forum in June.

Feedback welcome via ‘Have your say’

Draft Regulation and its annexes are available on the ‘Have your say’ portal. Stakeholders can comment on the draft until 03 November 2023. Feedback will be taken into account for finalising the revised Regulation. The next step will be its adoption, which is expected in Q1 2024.

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Amended draft elements of the proposed new Fans Regulation

The policy officer, Mr Ronald Piers de Raveschoot presented updated draft elements in the working document of the revised Regulation and sought stakeholder’s opinions needed before launching the Interservice consultation. The amendments resulted from the analysis of stakeholders’ feedback after the second Consultation Forum in April 2022 and additional consultations. Compared to the document discussed in 2022, the main changes are outlined below.

Suspending the ‘incomplete fan’ concept following some legal issues

Mr de Raveschoot explained that the legal services of the European Commission considered the proposed approach for incomplete fans as being beyond the empowerment of Art 11 of the Ecodesign Directive. For this reason, the Commission put forward to abandon provisions for incomplete fans and retaining status quo of the current Regulation. 

Given the need to progress with the delayed review, this proposal was endorsed by stakeholders.

Including jet fans with impeller power > 750 W

Following requests from stakeholders, the Commission proposed to regulate jet fans > 750W but rated according to impeller power and not electric input power. Alternatively, equations for the minimum efficiency based on electric power input were also presented.

Stakeholders were asked to evaluate both proposal and provide feedback.

Correction factor for fans equipped with permanently fitted protective guards

To relax burden on manufacturers related with additional test needed, the Commission proposed a correction factor for efficiency of fans with permanent protective guards.

The proposal was supported by Eurovent and other fan industry associations.

Information requirements on partial load

The Commission detailed the specification of information requirements on partial load.

Stakeholders noted that the part-load information requirements should only apply to fans with adjustable speed and not all fans, (such as single-speed and custom-made fans).

Mr de Raveschoot stated that according to Commission’s information, each fan can be speed-controlled, and this information requirement would apply to all fans, apart from a few exceptions. Stakeholders were asked to provide feedback on the proposal.

Changes to the text including definitions and specific provisions

After discussing the major amendments, the policy officer went through draft elements of the working document and presented proposed changes to the text. These included:

• Detailing and aligning some definitions to existing standards,
• New equations for the minimum jet fan efficiency (both considered versions, based on impeller power and electric power input)
• Adjustments to resource efficiency requirements (availability of spare parts, access to repair and maintenance information) and material efficiency product information requirements.
• Verification tolerances for market surveillance purposes.

On the verification tolerances, which included part load operation, the fan manufacturers noted the requirements were increased compared to the previous working document version. It was stressed that the partial load tolerances should be thoroughly considered and assessed, which requires more time. Further, it was highlighted that for parameters like electric motor power input at partial load, the tolerance is highly dependent on factors which are not in fan manufacturers’ hands, e.g. VSD settings. Therefore, it was suggested to drop the requirements for part load tolerances. 

A call for a standardisation request for a new system efficiency standard was recently made by all major fan industry associations. New part load tolerances should be based on this future standard.    

The policy officer acknowledged these arguments and stated that the withdrawal of the part load tolerances could be considered.

On the other hand, representatives of Member States (NL, IT) noted that MSAs must be able to verify the performance of products, also at partial load.

The policy officer concluded that the Commission would reconsider these provisions.

Timeline for introduction of new requirements

The Commission proposed that new requirements would take effect 2 years after the publication and entry into force of the revised Regulation. An exception would be Art. 6 on software circumvention, that would apply immediately. For fans integrated into other products, an additional transition period of one year would apply. 

Anticipated adoption schedule

Mr de Raveschoot advised that the anticipated schedule of next steps for adoption is as follows:

• Short window for feedback.
• Inter Service Consultation during summer.
• Feedback and WTO notification: Q3 – Q4 2023
• Committee meeting end of the year
• Adoption Q1 2024
• Publication Q1 2024

Further steps on the review of the Fan Regulation

The Commission asked for feedback on the presented proposals within 4 weeks.

In order to provide meaningful feedback, Member States requested making available a draft of the entire reviewed regulation and not only its draft elements presented by the Commission. 

The Commission acknowledged this request and advised that the entire draft, taking into consideration issues raised at the meeting, would be made available in about a week after the Consultation Forum. Members States and stakeholders were asked to provide their feedback within the next three weeks after circulation of the complete draft.

Joint Eurovent and AMCA comments

The Eurovent Product Group ‘European Fan Technology’ (PG-FANS) and European AMCA will analyse the proposed draft and develop a joint position to be submitted to the European Commission during their meeting scheduled on 23 June 2023.   

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• Definition of a complete fan includes stator/rotor/motor to stator and motorised impeller
• MEPS based on complete fans only
• More on how the fan should be tested /evaluated in EN17166
• This option seems to be the only concrete solution with predictable timelines

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Fans

The draft minutes of the Consultation Forum meeting of 01 April 2022 on fans are available. Comments to these minutes should be sent to ENER-ENERGY-LABELLING@ec.europa.eu.

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Review Working Document

The Working Documents were presented, and the comments made during the Consultation Forum meeting have been integrated in the version released on 4 April.

Some of the elements from the discussion that are noteworthy.

Article 1

• The Commission does not intend to exempt of fans integrated in (final) products subject to Ecodesign regulations. This discussion has already taken place.
• The Commission indicated that commercial and professional refrigerators below 125 W are not and would not be covered by the fan regulation (request by Italy).
• The German delegation requested improved alignment with the Regulation on electric motors and variable speed drives EU 2019/1781.
• The spare part requirements under the new ESPI (see GEN – 1372.00) may limit the use of spare parts. CEMEP indicated this could lead to undesired effects. Under article 2, the definition for spare parts will be revised.

Article 2

• The Commission acknowledged the need to add an unambiguous definition of spare parts.

Article 4

• Italy asked to consider developing standard text on conformity assessment that could be applied across regulations.
• Italy also pointed out the need for clear rules on responsibilities between the supplier of an incomplete fan and the entity that assembles the incomplete fan and becomes a supplier of the complete fan.

Article 6

• Italy and the Netherlands asked for an omnibus amendment that would apply to all Ecodesign regulation on circumvention and software updates.

Article 8

• The prohibition of halogenated flame retardants (HFRs) has been deleted; the Commission indicated that it could be subject to a discussion on resource efficiency under the ESPI.

Annexes

• Several detailed technical comments were made.
• Following the position of the majority of stakeholders, the Commission endorsed the motion to skip Tier 1 and go straight to Tier 2 requirements.
• One association asked to exempt the information requirements for spare parts for custom made fans.
• Italy asked to re-introduce the notion of professional repairers.
• A request to align partial load requirement information for the Ecodesign lots 1 (space heaters) and 10 (air-to-air heat pumps, air conditioners, comfort fans) was formulated.

Recommended actions

The Product Groups that manufacture or use fans are asked to check the latest version of the draft working document and provide comments to Igor Sikonczyk (igor.sikonczyk@euroent.eu) by  22 April so that these can be compiled into the Eurovent comments to be provided to the Policy Officer by 29 April.

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Recap of the Fan Regulation review to date

The review study of Regulation (EU) No 327/2011 was carried out between April 2014 and March 2015, and the Consultation Forum meeting was held on 30 April 2015. Before the Consultation Forum, draft working documents of the revised Regulation and explanatory notes were made available. This was followed by an Impact Assessment, which revealed concerns regarding the approach to cascading and large fans. A revised Impact Assessment was approved by the Regulatory Scrutiny Board in November 2019. Inter-Service Consultations subsequently took place.

Consultation Forum on 1 April 2022

The Commission communicated in February that the next Consultation Forum regarding the review of the industrial fans Regulation would be held on 1 April 2022. It will aim to discuss on new aspects and validate the ideas that evolved since the last Consultation Forum in 2015.

A discussion document for consideration in the meeting was made available on 1 March. It includes changed elements of the working document from 30 April 2015, which are believed by the Commission to be minor and resulting from advancing insights.

The Eurovent Secretariat compiled a comparison document, which shows changes between the current and the 2015 draft.

Eurovent will participate in the Consultation Forum on 1 April to present the position of Eurovent members on the tabled working document, and to learn from the Commission about an expected timeline for the next review stages and developments regarding the related harmonised standardisation.

Update on prEN 17166 from CEN/TC 156/WG17 meeting on 23 February 2022

prEN 17166 ‘Fans – Procedures and methods to determine the energy efficiency for the electrical input power range of 125 W up to 500 kW’ was developed by CEN/TC 156/WG 17 (Fans) under the Commission standardisation mandate (M/500) as a candidate harmonized standard for Regulation (EU) 327/2011. In 2021 the project was cancelled due to exceeding the deadline and has been removed from the work programme. The main reasons for this were unresolved matters from the negative assessment of the EU Policy Officer. A solution in principle was agreed with the Commission and CEN/TC 156 WG17 intends to resubmit the standard as New Work Item Proposal (NWIP). If the NWIP is approved and re-included in the work programme, a new publication of a Draft Standard is foreseen. In case of a positive outcome of the Enquiry vote, it is intended to skip the step of voting on the Final Draft and to proceed directly to the publication of the standard.

Recommended actions

Fans are an essential element of ventilation and air-conditioning systems and are a key component of most HVAC devices covered in Eurovent. Members of the concerned Eurovent Product groups are recommended to study the amended working document and submit to the Eurovent Secretariat their comments which will be the basis for the Eurovent Position to present at the Consultation Forum on 1 April 2022. In addition, members who are interested to participate in the Consultation Forum as representatives of Eurovent are invited to contact the Eurovent secretariat for details.

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