One of Eurovent’s key tasks is to accompany the development of legislations and standards on a national, regional, European Union, and international level. As a globally recognised representative of the ‘HVACR’ industry, Eurovent is a frequently-consulted third party towards political institutions such as the European Commission.

While most of our advocacy takes place via personal meetings with decision-makers, we regularly publish Position Papers on issues of particular importance – either independently or in cooperation with partner associations such as REHVA, eurammon, or EPEE.

Types of Position Papers

Eurovent’s Position Papers commonly result from the work done by manufacturers within Eurovent’s Product and Issue Groups.

Manufacturers within Product and Issue Groups can independently issue Position Papers under the Group name (e.g. Position Paper of the Eurovent Product Group ‘Air Conditioning’). For a full-scale ‘Eurovent Position Paper’, the Eurovent Commission (our supervisory body) needs to approve the Position Paper within a maximum of ten working days.

The review by the Eurovent Commission ensures that a wide-ranging representativeness of Positions is being guaranteed, taking into account views of different industries and product categories. This is being done as a legislation on, for instance, air handling units, also has an impact on manufacturers of fans, energy recovery components, air filters, and coils as well.

When assessing position papers, are you aware whom you are dealing with?

Eurovent’s structure rests upon democratic decision-making procedures between its members and their representatives. The more than 1.000 organisations within the Eurovent network count on us to represent their needs in a fair and transparent manner. Accordingly, we can answer policy makers’ questions regarding our association representativeness and decisions-making processes as follows:

 

1. Who receives which amount of votes?

2. Who has the final decision-making power?

At Eurovent, the amount of votes is never related to organisation sizes, country sizes, or membership fee levels! No matter if SMEs or large organisations, each company receives one vote within our technical working groups. In our General Assembly or Eurovent Commission (supervisory body), our national member associations receive two votes per country.

 

The Eurovent Commission acts as the association’s supervisory body. It defines the overall association roadmap, makes decisions on horizontal topics, and mediates in case manufacturers cannot agree within technical working groups. The Commission consists of national association Members, receiving two votes per country independent from its size or economic weight.

3. How European is the association?

4. How representative is the organisation?

More than 90 per cent of manufacturers within Eurovent manufacture in and come from Europe. They employ around 150.000 people in Europe largely within the secondary sector. Our structure as an umbrella enables us to consolidate manufacturers' positions across the industry, ensuring a broad and credible representation.

 

Eurovent represents more than 1.000 companies of all sizes spread widely across 20+ European countries, which are treated equally. As each country receives the same amount of votes, there is no ‘leading’ country. Our national member associations ensure a wide-ranging national outreach also to remote locations.

 

Eurovent and transparency

You can check on us in the European Union Transparency Register under identification no. 89424237848-89. All Eurovent meeting documents are being made available on request for political decision-makers.

Recently published Position Papers

The following section provides a collection of our recently published Position Papers.


Eurovent input for the European Commission technical assistance study on ‘points system’ methodology

Since the advent of the 2012-2014 Ecodesign work plan, the analysis and investigations of complex energy-related products and systems for prospective Ecodesign and Energy Labelling implementing measures have significantly increased. These complex products and systems have degrees of heterogeneity that complicate their assessment against common metrics and measurement methods. The European Commission is working on a technical assistance study aiming to address the complex energy-relataed products within the Ecodesign Framework.

Document provides toolbox on how to deal with EU Regulations 1253/2014 and 1254/2014
Example of an air handling unit installation

Brussels, 12 April 2016. The Eurovent association and EVIA have published their joint Guidance Document on Ecodesign requirements for ventilation units. The document aims to provide answers to the many questions the market still has concerning EU Regulations 1253/2014 and 1254/2014, and following the release of the final draft FAQs by the European Commission on 21 December 2015. It provides for a more uniform and coherent implementation of these legislations across different sectors and product groups within the EU Common Market and in countries following EU legislation.

Eurovent comments on the November 2014 CLASP analysis of specific issues regarding EU policy proposals for DG ENER lot 12 Commercial Refrigeration

On 27 November 2014, CLASP, the European NGO focusing on the growing energy demand resulting from the use of appliances, lighting and equipment, published an analysis on the possible development of Ecodesign and Energy Labelling requirements for refrigerated commercial display cabinets. In reaction, manufacturers within the Eurovent network published a comment document on 12 December 2015.

Eurovent and EVIA argue why proposed energy efficiency requirements are too high

Eurovent and EVIA, the two main European associations representing European Ventilation manufacturers, decided to join forces in explaining the European Commission why it will not be feasible for manufacturers of High pressure/Low volume fans to meeting the newly set energy efficiency requirements.

Eurovent Position Paper co-signed by EPEE

On 2 October 2015, Eurovent and EPEE co-published this Position Paper related to the draft proposals for Ecodesign and Energy Labelling Regulations of refrigerated commercial display cabinets provided on 17 September 2015.

Clarifying questions from members of Eurovent Product Group 'Energy Recovery Components' concerning the Technical Assistance Study

Towards 1 January 2016, the date of entry into force of Commission Regulation 1253/2014 for Ventilation Units, the European Commission has outsourced a Technical Assistance Study to the Danish Technical Institute. In the course of this study, manufacturers of energy recovery components integrated into ventilation units came up with a number of questions aimed to clarify several Regulation articles.

Evaporative cooling equipment manufacturers elaborate on the possible exemption of their products from EU Fan Regulation 327/2011

During the Consultation Forum on the revision of the ‘EU Fan Regulation’ 327/2011 in Brussels on 30 April, Eurovent had reinforced its call for an exemption of evaporative cooling equipment from the future Regulation, which was supported by several Member State Representatives. Subsequently within the meeting, the Commission has asked VHK to further elaborate on this issue and on how an exemption can be implemented without creating loopholes.

Eurovent Product Group 'Air Handling Units' publishes guidelines for interpretation of Regulation 1253/2014

With this document, the Eurovent Product Group 'Air Handling Units' offers a guideline providing a common interpretation on the Commission Regulation (EU) No 1253/2014 of 7 July 2014 on non-residential ventilation units (bidirectional and unidirectional units).

Eurovent provides input complementing its Position Paper on evaporative cooling equipment from 14 April 2015

In its position paper from 14 April 2015, Eurovent proposed a new paragraph exempting fans exclusively transporting gases consisting of a mixture of liquid water and air having a relative humidity consistently larger than 90% from the revised EU Fan Regulation. This Position Paper elaborates on why the abovementioned paragraph is straightforward and necessary.

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

With this Position Paper, European AMCA, Eurovent and EVIA jointly position themselves concerning the Draft ‘EU Fan Regulation’ to be discussed at the Consultation Forum on 30 April 2015.

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