On 21 November 2014, Dutch consulting agency VHK, which is in charge of advising the European Commission on the current Fan Regulation revision, published a discussion document outlining the proposed changes to Fan Regulation 327/2011. Manufacturers from the Eurovent network herewith provide a detailed response.
In a position paper published on 18 November 2014, Eurovent and its members were calling for an exemption of Cooling Towers from the revised Commission Regulation (EU) No 327/2011, which sets Ecodesign requirements for fans driven by motors with an electric input power between 125 W and 500 kW. In addition, Eurovent now provides additional clarifications on the difficulties cooling tower manufacturers would face in case of no exemption from the Regulation.
In the light of the Revision of Fan Regulation 327/2011, Dutch consultancy firm VHK published a 'discussion document' as starting point for the European Commission. Welcoming the major part of the document's contents, manufacturers from the Eurovent Product Group 'European Fan Technology' advise VHK to slightly modify parts of the proposed Regulation.
In the light of the current revision of Fan Regulation 327/2011, manufacturers of evaporative cooling equipment in the Eurovent network ask for an exemption of Cooling Towers from the revised Regulation.
In the light of the revision of Fan Regulation 327/2011, the Eurovent Product Group 'European Fan Technology' published a Position Paper stressing the importance of effective Market Surveillance of fan products.
According to the proposed revised version of Fan Regulation 327/2011, fan suppliers and appliers would be obliged to use ErP 2015 (Tier II) compliant fans also when replacing fans. With this Position Paper, Eurovent Members aimed to explain why such a measure would not be feasible.
Eurovent collected a number of case studies demonstrating why fans sold before 2015 that are not in conformity with ErP 2015 requirements defined in Regulation 327/2011 should be excluded from the revised Fan Regulation.
With this Paper, Eurovent elaborates on its request to VHK and the European Commission to ‘provide clear definitions and clarify what exactly is in the scope of the measure’ as well as exclude impellers from the Regulation.
Towards the start of the revision period of Fan Regulation 327/2011, Eurovent published a paper outlining its most important issues to be addressed in finalising the revised Regulation. Eurovent's Product Group 'European Fan Technology' underlined, amongst others the importance of a clear and measurable scope, alignment with EN and ISO standards as well as relevant EU legislation such as the Ecodesign Directive, and the prevention of loopholes.