For years, the Ecode­sign Direc­tive has formed the over­ar­ching legal frame­work for energy-related prod­ucts in the EU. On this basis, the Euro­pean Union issues product-specific imple­menting regu­la­tions: For fans, this is the Fan Regu­la­tion. The revised version (EU) 2024/1834, published in 2024, is known in the industry as ErP 2026.

This new regu­la­tion replaces the previ­ously valid Fan Regu­la­tion (EU) No. 327/2011 (ErP 2015) and tightens the minimum require­ments for fan effi­ciency that have been in force for the last fifteen years (Figures 1 and 2). The regu­la­tion applies to fans with an elec­tric input power between 125 W and 500 kW and will be imple­mented in stages from 2026 and 2027. In addi­tion to stricter effi­ciency limits, the regu­la­tion focuses more on the fan as a func­tional overall system and supple­ments the require­ments with exten­sive infor­ma­tion, repair and docu­men­ta­tion oblig­a­tions.

The complete fan as the central refer­ence value

For the first time, the revised regu­la­tion clearly spec­i­fies when a fan is consid­ered complete in the regu­la­tory sense. The deci­sive factor for deter­mining complete­ness is the combi­na­tion of stator, impeller and motor—only their inter­ac­tion defines a fan within the meaning of the regu­la­tion (Figure 3).

Prod­ucts in which one or more of these compo­nents are missing or are placed on the market sepa­rately are referred to by the fan industry as “incom­plete fans.” This distinc­tion has far-reaching conse­quences: Any company that manu­fac­tures an incom­plete fan, inte­grates it into a device and places it on the market under their own name is consid­ered a manu­fac­turer for regu­la­tory purposes—with all the resulting oblig­a­tions regarding confor­mity assess­ment, CE marking and fulfill­ment of other ErP require­ments (Figures 4 and 5).

Stricter effi­ciency require­ments and new assess­ment approaches

ErP 2026 signif­i­cantly raises the minimum effi­ciency levels that have been in force since 2015. Effi­ciency will continue to be assessed using the Fan Effi­ciency Grade (FEG) but is now based on updated refer­ence points and measure­ment condi­tions. The aim is to provide a more real­istic repre­sen­ta­tion of the oper­ating behavior of modern fans, espe­cially under partial load condi­tions. While the minimum require­ments continue to be assessed at the best effi­ciency point, detailed infor­ma­tion on partial load behavior must also be docu­mented and provided.

The new regu­la­tion thus takes into account the fact that fans are not contin­u­ously oper­ated at their design point in many appli­ca­tions. Today, effi­ciency gains are achieved less through pure peak effi­cien­cies and more through a broad effi­ciency optimum over a wide char­ac­ter­istic curve range. Aero­dy­nam­i­cally opti­mized impellers, low-loss motor tech­nolo­gies and precise elec­tronic control are there­fore becoming more rele­vant.

Impact on designs and system inte­gra­tion

The stricter effi­ciency limits and modi­fied eval­u­a­tion methods have a direct impact on the design of fans and entire systems. Certain designs are becoming prob­lem­atic, while other concepts are gaining in viability. 

In partic­ular, the coor­di­na­tion between impeller geom­etry, motor and power elec­tronics is becoming a deci­sive factor. Flow-related losses during instal­la­tion, unfa­vor­able airflows or non-opti­mized hous­ings can prevent effi­ciency reserves from being fully exploited in real-world oper­a­tion. Consid­ering the fan as a whole there­fore forces manu­fac­turers and plant engi­neers to adopt a holistic approach to system design.

Docu­men­ta­tion, infor­ma­tion and repair oblig­a­tions

In addi­tion to effi­ciency require­ments, ErP 2026 expands oblig­a­tions relating to trans­parency, repairability and life cycle assess­ment. Manu­fac­turers will have to provide signif­i­cantly more product infor­ma­tion in the future. This includes effi­ciency values for defined oper­ating points, infor­ma­tion on partial load behavior and tech­nical data on disas­sembly and repair.

The regu­la­tion thus specif­i­cally strengthens the possi­bil­i­ties for repairing fans. It stip­u­lates that defined spare parts must be avail­able and imple­mented in such a way that they can be replaced profes­sion­ally and without causing perma­nent damage to the product. In addi­tion, profes­sional repair service providers receive access to these spare parts and the neces­sary repair infor­ma­tion. ebm-papst is imple­menting these require­ments, making all needed spare parts and the corre­sponding infor­ma­tion avail­able to qual­i­fied repair service providers.

Spare parts must also be avail­able for up to ten years after product discon­tin­u­a­tion, while product infor­ma­tion must be stored digi­tally for up to 20 years. These require­ments signif­i­cantly increase the orga­ni­za­tional effort and require robust docu­men­ta­tion and data manage­ment processes.

Conse­quences for OEMs, importers, plant manu­fac­turers and oper­a­tors

The new fan regu­la­tion affects far more than just tradi­tional fan manu­fac­turers. OEMs, importers, plant manu­fac­turers and oper­a­tors must also reassess their role in the regu­la­tory context. Dr. Julien Gril­liat, Director of Regu­la­tory Affairs at ebm-papst, observes a great deal of uncer­tainty in the market: “Many compa­nies under­es­ti­mate how quickly they can become fan manu­fac­turers in regu­la­tory terms through inte­gra­tion or comple­tion.” The conse­quences range from the oblig­a­tion to measure effi­ciency and prepare tech­nical docu­men­ta­tion to the CE decla­ra­tion of confor­mity.

For oper­a­tors, the choice of fan used is becoming increas­ingly impor­tant from a strategic perspec­tive. Effi­ciency, spare parts avail­ability and regu­la­tory compli­ance have a direct impact on oper­ating costs, system avail­ability and invest­ment secu­rity.

Tran­si­tional periods and schedule

The regu­la­tion will come into force on July 24, 2026. It distin­guishes between so-called “stand-alone” fans and fans that are inte­grated into other prod­ucts or appli­ca­tions, such as venti­lation units, heat pumps or refrig­er­a­tion systems. For these inte­grated fans, the ErP 2026 require­ments will only apply from July 24, 2027, provided that the first unit of the respec­tive product was placed on the market before July 24, 2026.

In prac­tice, replace­ment parts for fans will not be required until July 24, 2028. Fans that do not comply with ErP 2026 may then only be placed on the market as replace­ments under clearly defined conditions—and only if no suit­able compliant replace­ment is avail­able and the use is clearly marked as a replace­ment part. In this case, the regu­la­tion refers to replace­ment fans.

How ebm-papst supports customers in the tran­si­tion to ErP 2026

The require­ments of ErP 2026 neces­si­tate close inte­gra­tion of regu­la­tory exper­tise and tech­nical devel­op­ment. ebm-papst there­fore pursues a holistic approach: The company analyzes the regu­la­tion at an early stage, inter­prets it in consul­ta­tion with Euro­pean expert commit­tees and system­at­i­cally trans­lates the require­ments into product devel­op­ment, port­folio strategy and customer consulting.

A key compo­nent is the consis­tent design of the fan as a complete system. ebm-papst supplies fully assem­bled fans including motor, impeller, stator and elec­tronics from a single source. Effi­ciency assess­ment, measure­ment and docu­men­ta­tion are carried out at the system level. Customers receive ready-to-install solu­tions with clear regu­la­tory clas­si­fi­ca­tion, without addi­tional work to create their own effi­ciency certifi­cates or confor­mity assess­ments.

At the same time, ebm-papst is reviewing its entire port­folio for ErP 2026 compli­ance. The company is replacing prod­ucts that do not meet future require­ments with more effi­cient new devel­op­ments. However, today many current EC fans from ebm-papst already meet the stricter effi­ciency limits. Customers can use ebm-papst’s digital FanScout design tool to select the fans that meet their require­ments and thus iden­tify ErP 2026-compliant solu­tions at an early stage (Figure 6).

In addi­tion, ebm-papst supports its customers with specific services—from measure­ments in its own labo­ra­tory to assis­tance with tech­nical docu­men­ta­tion and training. “Our goal is to reduce regu­la­tory complexity for our customers as much as possible,” empha­sizes Dr. Julien Gril­liat: “This allows them to concen­trate on their appli­ca­tions while still main­taining complete plan­ning secu­rity.”

ErP 2026 as a tech­nical and strategic turning point

With the revised Ecode­sign Direc­tive and Fan Regu­la­tion, the EU is shifting the stan­dards for effi­ciency, trans­parency and system respon­si­bility in venti­lation tech­nology. ErP 2026 not only changes limit values but also defines the complete fan as a central refer­ence value and makes effi­ciency a holistic system prop­erty.

Compa­nies that address the tech­nical, orga­ni­za­tional and regu­la­tory require­ments at an early stage will secure deci­sive advan­tages. With system­i­cally designed fans, clear manu­fac­turer respon­si­bility and compre­hen­sive support, ebm-papst accom­pa­nies its customers on the path to compli­ance with ErP 2026 and the future-proof design of venti­lation systems.