© ebm-papst

“We stand by our customers to face this new chal­lenge.”

Dr. Julien Gril­liat is Director of Regu­la­tory Affairs at ebm-papst. In this inter­view, he talks about the new Ecode­sign Direc­tive and the asso­ci­ated fan regu­la­tion (ErP 2026), what it means for manu­fac­turers and oper­a­tors, and how ebm-papst is supporting its customers through this tran­si­tion.


Dr. Gril­liat, everyone is talking about the new Ecode­sign Direc­tive. How do you perceive the mood in the industry?

Customers are uncer­tain and don’t yet know what to expect. Many compa­nies don’t have suffi­cient capacity to delve deeply into such a regu­la­tion. The basic ques­tion is quite simple: “Will our company be a fan manu­fac­turer in the future—yes or no?” Those busi­nesses who address this ques­tion in time and seek our support will not run the risk of being caught off guard by the regu­la­tion.

What exactly is ErP 2026—and why is it now being tight­ened?

ErP 2026 is the collo­quial term for the new EU Regu­la­tion (EU) 2024/1834. It spec­i­fies the Ecode­sign Direc­tive for fans with an elec­trical input power between 125 watts and 500 kilo­watts and replaces the previous Fan Regu­la­tion 327/2011—often referred to as ErP 2015. The idea behind it is not new, but it is more rele­vant than ever: the aim is to increase energy effi­ciency, conserve resources and thus contribute to the EU’s climate targets. Instead of focusing solely on the motor, the stricter regu­la­tion considers the fan as a complete system and supple­ments the effi­ciency require­ments with topics such as docu­men­ta­tion require­ments, repara­bility, and circular economy. 

Every­thing you need to know at a glance

CE conformity/CE marking

The CE marking indi­cates that a product complies with all EU direc­tives and regu­la­tions and may be placed on the market in the EU. This requires a proper confor­mity assess­ment by the manu­fac­turer.

Tech­nical docu­men­ta­tion

Tech­nical docu­men­ta­tion includes all docu­ments that prove that a product meets legal require­ments, such as measure­ment reports, calcu­la­tions, tech­nical data and descrip­tions. It must be created by the manu­fac­turer and archived for many years.

Complete vs. incom­plete fan

According to the ErP Regu­la­tion, a complete fan consists of at least a stator, rotor and motor. If one of these compo­nents is missing or if they are deliv­ered sepa­rately, the product is consid­ered an incom­plete fan—with impli­ca­tions for the manufacturer’s role and respon­si­bility.

Manu­fac­turers within the meaning of the regu­la­tion

A manu­fac­turer is not only someone who manu­fac­tures a product, but also someone who completes it, inte­grates it into a device, or places it on the market under their own name. OEMs, importers, system construc­tion compa­nies and oper­a­tors can thus become manu­fac­turers in legal terms.

Placing on the market

Placing on the market refers to the first time a product is made avail­able on the EU market—regardless of whether it is sold, installed or passed on. This point in time is deci­sive for the appli­ca­tion of the ErP require­ments.

Mile­stones of ErP 2026

The new ErP Regu­la­tion will apply starting on July 24, 2026. Tran­si­tion periods until 2027 apply to embedded fans, and addi­tional regu­la­tions for spare parts will take effect in 2028.

Embedded fans

Embedded fans are fans that are perma­nently inte­grated into devices such as venti­lation units, heat pumps or refrig­er­a­tion systems. In some cases, longer tran­si­tion periods apply to these fans before the new ErP require­ments take effect.

Replace­ment fan

A replace­ment fan is a fan that is used exclu­sively to replace a defec­tive existing product. Under certain condi­tions, it may be sold even if it no longer meets the current ErP require­ments.

Spare part avail­ability and repara­bility

The ErP Regu­la­tion requires manu­fac­turers to keep certain spare parts avail­able for many years and to enable repairs. The aim is to extend the service life of prod­ucts and conserve resources.

To what extent will fans be consid­ered a complete system in the future?

According to the new regu­la­tion, a fan consists of at least a stator, rotor, and motor—i.e., the air-conducting elements, the impeller, and the elec­tric drive. Only when these three compo­nents come together can they legally be referred to as fans. In the future, the industry will there­fore have to distin­guish between “complete” and “incom­plete” fans.

In addi­tion, there are stricter minimum effi­ciency require­ments, addi­tional infor­ma­tion require­ments— for example, on partial load behavior—and exten­sive require­ments relating to spare parts and repara­bility. Manu­fac­turers must provide certain spare parts for up to ten years and publish product infor­ma­tion online for up to 20 years.

What do these changes mean in concrete terms for OEMs, importers, plant manu­fac­turers and oper­a­tors?

The regu­la­tion will apply from July 24, 2026 onwards to anyone who places fans in the spec­i­fied perfor­mance range on the EU market for the first time, regard­less of whether they manu­fac­ture, import or install them. Anyone who inte­grates a fan that is incom­plete by defi­n­i­tion into a device, completes that fan and is then legally consid­ered a fan manu­fac­turer. This person is then respon­sible for CE confor­mity (Confor­mité Européene), including compli­ance with ErP require­ments. This means that you need to know exactly what you are buying and how you are installing it. 

Our customers gain plan­ning secu­rity and can concen­trate on their appli­ca­tions

Dr.-Ing. Julien Gril­liat, Head of Regu­la­tory Affairs ebm-papst

What are the advan­tages for customers when ebm-papst takes on the role of fan manu­fac­turer?

Our customers receive fully assem­bled fans that can be inte­grated into their systems without any addi­tional testing, docu­men­ta­tion, or coor­di­na­tion. The regu­la­tory respon­si­bility lies entirely with ebm-papst, which means that our customers gain plan­ning secu­rity and can concen­trate on their appli­ca­tions.

Can you explain the time­line for the new regu­la­tion? What are the most impor­tant mile­stones?

The key date is July 24, 2026: From then on, the new ErP 2026 will formally apply. The stricter effi­ciency require­ments and docu­men­ta­tion oblig­a­tions apply directly to new, stand-alone fans. The EU is granting a tran­si­tion period until July 24, 2027 for fans built into venti­lation units, heat pumps or refrig­er­a­tion systems. By then at the latest, these “embedded fans” must also meet the new require­ments.

Starting in 2028, the rules for replace­ment fans will also apply: From then on, manu­fac­turers will only be allowed to sell ErP 2026-compliant fans as replace­ment parts—and only if no suit­able compliant replace­ment is avail­able and the use is clearly marked as a replace­ment part. Depending on the product, replace­ment parts and infor­ma­tion may be avail­able until 2037. 

Ques­tions about ErP 2026?

Dr.-Ing. Julien Gril­liat, Head of Regu­la­tory Affairs ebm-papst

What specific steps is ebm-papst taking to support its customers on their path to ErP compli­ance?

Firstly, we have been closely involved in the legis­la­tion process. I repre­sent ebm-papst in Euro­pean asso­ci­a­tions, including Eurovent, and am chairman of the fan working group. Together with EVIA and AMCA, we have collab­o­rated on a Europe-wide FAQ docu­ment on the inter­pre­ta­tion of the regu­la­tion. This enables us to provide our customers with targeted support in designing their prod­ucts and systems to be safe and future-proof.

That is why we are running a major internal project: we are inter­preting the regu­la­tion, reviewing our entire port­folio, iden­ti­fying poten­tial non-confor­mi­ties and deciding where to replace prod­ucts or develop new solu­tions. At the same time, we are defining spare parts, preparing regis­tra­tion and ordering processes for repair compa­nies, and adapting our CE decla­ra­tions, type plates, and general terms and condi­tions.

And very impor­tantly, we offer our customers tech­nical support—from labo­ra­tory measure­ments and assis­tance with product docu­men­ta­tion to training courses. This saves them as much admin­is­tra­tive effort as possible.

To what extent can customers rely on ebm-papst solu­tions being future-proof?

Many of our current EC fans already meet the stricter effi­ciency require­ments. We will replace other prod­ucts that do not meet the new limits with more effi­cient alter­na­tives. The big advan­tage for our customers is that we deliver complete, ready-to-install fans including motor, impeller, stator, and elec­tronics from a single source. We measure and docu­ment the effi­ciency of the entire system and provide the required CE decla­ra­tion of confor­mity free of charge. Those who opt for this complete solu­tion are on the safe side with regard to ErP 2026.

Ready for 2026?

More back­ground infor­ma­tion, sched­ules and services related to the new ErP Regu­la­tion can be found on the offi­cial ebm-papst infor­ma­tion page.

Finally, what advice would you give your customers?

I would say: don’t wait, take action now. The new ErP 2026 is not a tire­some formality, but an impor­tant lever for energy and resource efficiency—and thus also a compet­i­tive factor. Those who address the issue in good time can not only make their prod­ucts compliant, but also more attrac­tive and effi­cient.

Addi­tion­ally, we stand by our customers to face this new chal­lenge. At ebm-papst, we see ourselves as venti­lation experts at our customers’ side. If you involve us in your product devel­op­ment at an early stage, we can tailor our fans perfectly to your appli­ca­tion, while at the same time ensuring that you are in compli­ance with regu­la­tions. 

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