Ecodesign and Energy Labelling Consultation Forum on industrial fans (GEN – 1489.00)

19 June 2023

GEN – 1489.00. The Ecodesign and Energy Labelling consultation forum held on 9 June 2023, was to discuss with stakeholder draft elements of the revised Regulation (EU) 327/2011. The CRM act, the DPP standardisation request and repairability index for tumble dryers were also addressed.

Amended draft elements of the proposed new Fans Regulation

The Policy Officer, Mr Ronald Piers 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, main changes included.

Suspending the ‘incomplete fan’ concept following some legal issues

Mr Piers explained that 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 Piers 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 Piers 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.