It is esti\u00admated that 21,5 Mt CO2 has been saved since 2012 as a result of this regu\u00adla\u00adtion.<\/p><\/blockquote>\n
What kind of prob\u00adlems did the regu\u00adla\u00adtion cause?<\/h3>\n
Until then, stan\u00addards defining energy effi\u00adciency limits were not in exis\u00adtence. The naivety and frag\u00admented voice of the fan industry resulted in regu\u00adla\u00adtions that are not clearly defined and have unnec\u00ades\u00adsary exclu\u00adsions. There is one excep\u00adtion in that the regu\u00adla\u00adtion retained an impor\u00adtant aspect discussed and heavily lobbied against during the study and drafting stage \u2013 that the scope includes fans \u2018inte\u00adgrated in other energy related prod\u00aducts\u2019.<\/p>\n
Why is this aspect so contro\u00adver\u00adsial?<\/h3>\n![](\"https:\/\/ebmpapst-7237.kxcdn.com\/en\/files\/2018\/08\/ebmpapst_erp_lockwood_DSC_2450-300x300.jpg\")
Geoff Lock\u00adwood is Tech\u00adnical Director at ebm-papst UK Ltd. and Chairman of the Fan Working Group of the Euro\u00adpean Venti\u00adlation Industry Asso\u00adci\u00ada\u00adtion (EVIA)<\/p><\/div><\/div>Inte\u00adgrated fans are compo\u00adnents that are incor\u00adpo\u00adrated inside other prod\u00aducts such as venti\u00adlation units, air-handling units, refrig\u00ader\u00ada\u00adtion and air-condi\u00adtioning units. The oppo\u00adsi\u00adtion claims that this cascading or double regu\u00adla\u00adtion of parts and prod\u00aducts causes unnec\u00ades\u00adsary burden to their devel\u00adop\u00adment without any bene\u00adfits. They claim that effi\u00adcient compo\u00adnents do not make effi\u00adcient prod\u00aducts.
\nNow they are suggesting that this could be clar\u00adi\u00adfied by regu\u00adlating fans shown in cata\u00adlogues and not regu\u00adlating fans that are \u2018bespoke\u2019. A bespoke fan is one that is different to a cata\u00adlogue fan. Just painting a fan pink will make it bespoke and a loop hole will exist to avoid regu\u00adla\u00adtion.\n
And what\u2019s the posi\u00adtion of the fan industry?<\/h3>\n
To exclude inte\u00adgrated fans from the regu\u00adla\u00adtion adds an oppor\u00adtu\u00adnity to avoid the require\u00adment to comply. It would add confu\u00adsion and multiple devel\u00adop\u00adments, e.g. for product lines to make effi\u00adcient designs where they are seen to be within the scope of the regu\u00adla\u00adtion and less effi\u00adcient ones where they are included within other energy-related prod\u00aducts.<\/p>\n
What would happen, if inte\u00adgrated fans would be excluded never\u00adthe\u00adless?<\/h3>\n
A large portion of the mentioned savings comes from fans inte\u00adgrated in other energy-related prod\u00aducts. In some industry sectors more than 90 percent of the fans placed on the market are inte\u00adgrated in other energy related prod\u00aducts. A change of the scope to exclude inte\u00adgrated fans will be a step back to 2012, an increase in energy consump\u00adtion, a loss of invest\u00adment and jobs and a return to using old inef\u00adfi\u00adcient machinery.<\/p>\n
A change will be a step back to 2012: with increased energy consump\u00adtion, a loss of invest\u00adment and jobs.<\/p><\/blockquote>\n
How does the process to discuss these topics on EU level look like?<\/h3>\n
There is a legal require\u00adment to review regu\u00adla\u00adtions. This occurred for 327\/2011 from April 2014 until the Consul\u00adta\u00adtion Forum of April 2015. There are some specific require\u00adments of the review including inves\u00adti\u00adga\u00adtion of raising the minimum energy effi\u00adciency limits. The forum is a meeting of member states, NGO\u2019s and other stake\u00adholders to see the proposed revi\u00adsion presented by the Policy Officer of Depart\u00adment General (DG) Energy. It had a posi\u00adtive effect with many changes in the revi\u00adsion coming from the fan industry.<\/p>\n
At the moment you are observing the next review \u2026<\/h3>\n
Yes, the review process has restarted. There is a new Policy Officer in DG Energy respon\u00adsible for regu\u00adla\u00adtion 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 posi\u00adtion with the EVIA fan WG to answer the ques\u00adtions and to balance the pres\u00adsure from the anti-cascading groups against the inclu\u00adsion of inte\u00adgrated fans.<\/p>\n
How did this work out?<\/h3>\n
In June 2018, the Regu\u00adla\u00adtory Scrutiny Board (RSB) rejected the impact assess\u00adment. It was rejected on two points: insuf\u00adfi\u00adcient evidence of the impact relating to large fans, with more than 100 kW, and of the impact on manu\u00adfac\u00adturers of prod\u00aducts where a fan is inte\u00adgrated.<\/p>\n
It is most worrying that most of the achieved reduc\u00adtion came from fans inte\u00adgrated in other prod\u00aducts!<\/p><\/blockquote>\n
This is most worrying: The objec\u00adtive of the eco-design regu\u00adla\u00adtion is to reduce our impact on our envi\u00adron\u00adment and most of the achieved reduc\u00adtion came from fans inte\u00adgrated in other prod\u00aducts! If the rejec\u00adtion remains, we would fall back to the level of 2012.<\/p>\n
And how will you continue?<\/h3>\n
The battle is not over, and the fan industry will be prag\u00admatic in its response via the Policy Officer. He plans to re-submit to the RSB in autumn with more evidence from stake\u00adholders. Hope\u00adfully people will see the true picture and retain the current scope and continue to reduce our impact on our envi\u00adron\u00adment.<\/p>\n","protected":false},"excerpt":{"rendered":"
How did you enter the ErP stage? In 2005 I became Chair of the Fan Manu\u00adfac\u00adtures Asso\u00adci\u00ada\u00adtion. One year later the Lot 11 study, that even\u00adtu\u00adally formed the Energy related Product Regu\u00adla\u00adtion for fans, was started. In February 2011 the Euro\u00adpean fan industry managed to organise itself into a Euro\u00adpean voice with the forma\u00adtion of [\u2026]<\/p>\n","protected":false},"author":6,"featured_media":0,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"wp_typography_post_enhancements_disabled":false,"footnotes":""},"categories":[91,4],"tags":[],"class_list":["post-12941","post","type-post","status-publish","format-standard","hentry","category-erp","category-insights"],"acf":[],"_links":{"self":[{"href":"https:\/\/mag.ebmpapst.com\/en\/wp-json\/wp\/v2\/posts\/12941","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/mag.ebmpapst.com\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/mag.ebmpapst.com\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/mag.ebmpapst.com\/en\/wp-json\/wp\/v2\/users\/6"}],"replies":[{"embeddable":true,"href":"https:\/\/mag.ebmpapst.com\/en\/wp-json\/wp\/v2\/comments?post=12941"}],"version-history":[{"count":1,"href":"https:\/\/mag.ebmpapst.com\/en\/wp-json\/wp\/v2\/posts\/12941\/revisions"}],"predecessor-version":[{"id":18604,"href":"https:\/\/mag.ebmpapst.com\/en\/wp-json\/wp\/v2\/posts\/12941\/revisions\/18604"}],"wp:attachment":[{"href":"https:\/\/mag.ebmpapst.com\/en\/wp-json\/wp\/v2\/media?parent=12941"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/mag.ebmpapst.com\/en\/wp-json\/wp\/v2\/categories?post=12941"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/mag.ebmpapst.com\/en\/wp-json\/wp\/v2\/tags?post=12941"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}
Geoff Lock\u00adwood is Tech\u00adnical Director at ebm-papst UK Ltd. and Chairman of the Fan Working Group of the Euro\u00adpean Venti\u00adlation Industry Asso\u00adci\u00ada\u00adtion (EVIA)<\/p><\/div><\/div>Inte\u00adgrated fans are compo\u00adnents that are incor\u00adpo\u00adrated inside other prod\u00aducts such as venti\u00adlation units, air-handling units, refrig\u00ader\u00ada\u00adtion and air-condi\u00adtioning units. The oppo\u00adsi\u00adtion claims that this cascading or double regu\u00adla\u00adtion of parts and prod\u00aducts causes unnec\u00ades\u00adsary burden to their devel\u00adop\u00adment without any bene\u00adfits. They claim that effi\u00adcient compo\u00adnents do not make effi\u00adcient prod\u00aducts.
\nNow they are suggesting that this could be clar\u00adi\u00adfied by regu\u00adlating fans shown in cata\u00adlogues and not regu\u00adlating fans that are \u2018bespoke\u2019. A bespoke fan is one that is different to a cata\u00adlogue fan. Just painting a fan pink will make it bespoke and a loop hole will exist to avoid regu\u00adla\u00adtion.\n
And what\u2019s the posi\u00adtion of the fan industry?<\/h3>\n
To exclude inte\u00adgrated fans from the regu\u00adla\u00adtion adds an oppor\u00adtu\u00adnity to avoid the require\u00adment to comply. It would add confu\u00adsion and multiple devel\u00adop\u00adments, e.g. for product lines to make effi\u00adcient designs where they are seen to be within the scope of the regu\u00adla\u00adtion and less effi\u00adcient ones where they are included within other energy-related prod\u00aducts.<\/p>\n
What would happen, if inte\u00adgrated fans would be excluded never\u00adthe\u00adless?<\/h3>\n
A large portion of the mentioned savings comes from fans inte\u00adgrated in other energy-related prod\u00aducts. In some industry sectors more than 90 percent of the fans placed on the market are inte\u00adgrated in other energy related prod\u00aducts. A change of the scope to exclude inte\u00adgrated fans will be a step back to 2012, an increase in energy consump\u00adtion, a loss of invest\u00adment and jobs and a return to using old inef\u00adfi\u00adcient machinery.<\/p>\n
A change will be a step back to 2012: with increased energy consump\u00adtion, a loss of invest\u00adment and jobs.<\/p><\/blockquote>\n
How does the process to discuss these topics on EU level look like?<\/h3>\n
There is a legal require\u00adment to review regu\u00adla\u00adtions. This occurred for 327\/2011 from April 2014 until the Consul\u00adta\u00adtion Forum of April 2015. There are some specific require\u00adments of the review including inves\u00adti\u00adga\u00adtion of raising the minimum energy effi\u00adciency limits. The forum is a meeting of member states, NGO\u2019s and other stake\u00adholders to see the proposed revi\u00adsion presented by the Policy Officer of Depart\u00adment General (DG) Energy. It had a posi\u00adtive effect with many changes in the revi\u00adsion coming from the fan industry.<\/p>\n
At the moment you are observing the next review \u2026<\/h3>\n
Yes, the review process has restarted. There is a new Policy Officer in DG Energy respon\u00adsible for regu\u00adla\u00adtion 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 posi\u00adtion with the EVIA fan WG to answer the ques\u00adtions and to balance the pres\u00adsure from the anti-cascading groups against the inclu\u00adsion of inte\u00adgrated fans.<\/p>\n
How did this work out?<\/h3>\n
In June 2018, the Regu\u00adla\u00adtory Scrutiny Board (RSB) rejected the impact assess\u00adment. It was rejected on two points: insuf\u00adfi\u00adcient evidence of the impact relating to large fans, with more than 100 kW, and of the impact on manu\u00adfac\u00adturers of prod\u00aducts where a fan is inte\u00adgrated.<\/p>\n
It is most worrying that most of the achieved reduc\u00adtion came from fans inte\u00adgrated in other prod\u00aducts!<\/p><\/blockquote>\n
This is most worrying: The objec\u00adtive of the eco-design regu\u00adla\u00adtion is to reduce our impact on our envi\u00adron\u00adment and most of the achieved reduc\u00adtion came from fans inte\u00adgrated in other prod\u00aducts! If the rejec\u00adtion remains, we would fall back to the level of 2012.<\/p>\n
And how will you continue?<\/h3>\n
The battle is not over, and the fan industry will be prag\u00admatic in its response via the Policy Officer. He plans to re-submit to the RSB in autumn with more evidence from stake\u00adholders. Hope\u00adfully people will see the true picture and retain the current scope and continue to reduce our impact on our envi\u00adron\u00adment.<\/p>\n","protected":false},"excerpt":{"rendered":"
How did you enter the ErP stage? In 2005 I became Chair of the Fan Manu\u00adfac\u00adtures Asso\u00adci\u00ada\u00adtion. One year later the Lot 11 study, that even\u00adtu\u00adally formed the Energy related Product Regu\u00adla\u00adtion for fans, was started. In February 2011 the Euro\u00adpean fan industry managed to organise itself into a Euro\u00adpean voice with the forma\u00adtion of [\u2026]<\/p>\n","protected":false},"author":6,"featured_media":0,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"wp_typography_post_enhancements_disabled":false,"footnotes":""},"categories":[91,4],"tags":[],"class_list":["post-12941","post","type-post","status-publish","format-standard","hentry","category-erp","category-insights"],"acf":[],"_links":{"self":[{"href":"https:\/\/mag.ebmpapst.com\/en\/wp-json\/wp\/v2\/posts\/12941","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/mag.ebmpapst.com\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/mag.ebmpapst.com\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/mag.ebmpapst.com\/en\/wp-json\/wp\/v2\/users\/6"}],"replies":[{"embeddable":true,"href":"https:\/\/mag.ebmpapst.com\/en\/wp-json\/wp\/v2\/comments?post=12941"}],"version-history":[{"count":1,"href":"https:\/\/mag.ebmpapst.com\/en\/wp-json\/wp\/v2\/posts\/12941\/revisions"}],"predecessor-version":[{"id":18604,"href":"https:\/\/mag.ebmpapst.com\/en\/wp-json\/wp\/v2\/posts\/12941\/revisions\/18604"}],"wp:attachment":[{"href":"https:\/\/mag.ebmpapst.com\/en\/wp-json\/wp\/v2\/media?parent=12941"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/mag.ebmpapst.com\/en\/wp-json\/wp\/v2\/categories?post=12941"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/mag.ebmpapst.com\/en\/wp-json\/wp\/v2\/tags?post=12941"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}