“The regu­la­tion of fans works!”

How did you enter the ErP stage?

In 2005 I became Chair of the Fan Manu­fac­tures Asso­ci­a­tion. One year later the Lot 11 study, that even­tu­ally formed the Energy related Product Regu­la­tion for fans, was started. In February 2011 the Euro­pean fan industry managed to organise itself into a Euro­pean voice with the forma­tion of the Fan Working Group of the Euro­pean Venti­lation Industry Asso­ci­a­tion (EVIA fan WG)—with me as chairman—just before the publi­ca­tion in March 2011 of regu­la­tion 327/2011.

What’s ErP all about?

The “Regu­la­tion 327/2011 eco-design require­ments for fans driven by motors with an elec­tric input power between 125 W and 500 kW” was published in the Offi­cial Journal of the Euro­pean Union on 6th April 2011 and since then it has had a big impact. It has caused prob­lems but found to actu­ally work: It is esti­mated that 46,800 GWh of energy or 21,5 Mt CO2 has been saved since 2012 as a result.

It is esti­mated that 21,5 Mt CO2 has been saved since 2012 as a result of this regu­la­tion.

What kind of prob­lems did the regu­la­tion cause?

Until then, stan­dards defining energy effi­ciency limits were not in exis­tence. The naivety and frag­mented voice of the fan industry resulted in regu­la­tions that are not clearly defined and have unnec­es­sary exclu­sions. There is one excep­tion in that the regu­la­tion retained an impor­tant aspect discussed and heavily lobbied against during the study and drafting stage – that the scope includes fans ‘inte­grated in other energy related prod­ucts’.

Why is this aspect so contro­ver­sial?

Inte­grated fans are compo­nents that are incor­po­rated inside other prod­ucts such as venti­lation units, air-handling units, refrig­er­a­tion and air-condi­tioning units. The oppo­si­tion claims that this cascading or double regu­la­tion of parts and prod­ucts causes unnec­es­sary burden to their devel­op­ment without any bene­fits. They claim that effi­cient compo­nents do not make effi­cient prod­ucts.
Now they are suggesting that this could be clar­i­fied by regu­lating fans shown in cata­logues and not regu­lating fans that are ‘bespoke’. A bespoke fan is one that is different to a cata­logue fan. Just painting a fan pink will make it bespoke and a loop hole will exist to avoid regu­la­tion.

And what’s the posi­tion of the fan industry?

To exclude inte­grated fans from the regu­la­tion adds an oppor­tu­nity to avoid the require­ment to comply. It would add confu­sion and multiple devel­op­ments, e.g. for product lines to make effi­cient designs where they are seen to be within the scope of the regu­la­tion and less effi­cient ones where they are included within other energy-related prod­ucts.

What would happen, if inte­grated fans would be excluded never­the­less?

A large portion of the mentioned savings comes from fans inte­grated in other energy-related prod­ucts. In some industry sectors more than 90 percent of the fans placed on the market are inte­grated in other energy related prod­ucts. A change of the scope to exclude inte­grated fans will be a step back to 2012, an increase in energy consump­tion, a loss of invest­ment and jobs and a return to using old inef­fi­cient machinery.

A change will be a step back to 2012: with increased energy consump­tion, a loss of invest­ment and jobs.

How does the process to discuss these topics on EU level look like?

There is a legal require­ment to review regu­la­tions. This occurred for 327/2011 from April 2014 until the Consul­ta­tion Forum of April 2015. There are some specific require­ments of the review including inves­ti­ga­tion of raising the minimum energy effi­ciency limits. The forum is a meeting of member states, NGO’s and other stake­holders to see the proposed revi­sion presented by the Policy Officer of Depart­ment General (DG) Energy. It had a posi­tive effect with many changes in the revi­sion coming from the fan industry.

At the moment you are observing the next review …

Yes, the review process has restarted. There is a new Policy Officer in DG Energy respon­sible for regu­la­tion 327/2011 and its review. This has meant going over old ground as the Policy Officer has reviewed the old files. However the fan industry was in a good posi­tion with the EVIA fan WG to answer the ques­tions and to balance the pres­sure from the anti-cascading groups against the inclu­sion of inte­grated fans.

How did this work out?

In June 2018, the Regu­la­tory Scrutiny Board (RSB) rejected the impact assess­ment. It was rejected on two points: insuf­fi­cient evidence of the impact relating to large fans, with more than 100 kW, and of the impact on manu­fac­turers of prod­ucts where a fan is inte­grated.

It is most worrying that most of the achieved reduc­tion came from fans inte­grated in other prod­ucts!

This is most worrying: The objec­tive of the eco-design regu­la­tion is to reduce our impact on our envi­ron­ment and most of the achieved reduc­tion came from fans inte­grated in other prod­ucts! If the rejec­tion remains, we would fall back to the level of 2012.

And how will you continue?

The battle is not over, and the fan industry will be prag­matic in its response via the Policy Officer. He plans to re-submit to the RSB in autumn with more evidence from stake­holders. Hope­fully people will see the true picture and retain the current scope and continue to reduce our impact on our envi­ron­ment.