EU Fan Regulation: Publication of AMCA-Eurovent-EVIA position

Joint industry Position Paper, Draft Regulation – Revision of 327/2011

In the course of the Revision of EU Fan Regulation 327/2011, associations AMCA, Eurovent and EVIA decided to join forces in assembling a common position.

The associations appreciate the work done by the European Commission and hold that the proposed draft constitutes a much improved document from the current Regulation 327/2011, addressing many issues. In particular, we value the following points and strongly reinforce our support for: 

  • Clearer definition of a fan: Sound and clear definition of a ‘fan’ as a configuration of impeller, stator and drive system.
  • Removal of ‘not final assemblies’ / impellers from scope: Only complete assemblies (impeller, motor, stator) give meaningful and comparable test results.
  • 2020 implementation of the revised Regulation

However, the associations see further improvement potential concerning the following points: 

Axial fan minimum efficiencies / slopes: The industry has concerns regarding the proposed limits which are considered too high considering foreseeable technological advances.

Stator and additional part definition: The associations witness a need for a clear distinction between the essential parts of the stator and ‘non-fan components’ (additional parts).

Jet fans: The efficiency limit required for jet fans below 5kW is technically not achievable and removes the acknowledged car park ventilation solution from the EU market.

Replacement parts / proposed grace period of 5 years: The associations ask for a confirmation of our interpretation.

Exemption of fans for kitchen hoods: The associations see no technical or economic argument why fans used in kitchen hoods should be exempted from the 'EU Fan Regulation'.