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General

Revision of the Fan Regulation 327/2011 (GEN – 924.00)

02 July 2018

4 min read
European Policy
General

Revision of the Fan Regulation 327/2011 (GEN – 924.00)

02 July 2018

4 min read

GEN – 924.00. The Commission has just been informed that the Impact Assessment for the proposed draft regulation did not pass the Regulatory Scrutiny Board.  The Commission will now try to improve on the Impact Assessment by mid-August so that it could be submitted to the RSB in September. The Commission is looking for input by 18 July to redraft the Impact Assessment.

Process overview

Comments/objections by the RSB on the Impact Assessment

The RSB believes the Impact Assessment did not adequately address two issues:

  • Large fans
  • Cascading

Large fans

The RSB questioned if there is a need to regulate large fans. 

In the opinion of the RSB the customers of large fans are professionals that select the fans based on rational behaviour. In the opinion of the RSB there would be no market failure indicating that non-performing large fans would be bought. The RSB would also have expressed doubt regarding the capacity of Market Surveillance Authorities to deal with large fans.

Cascading

The RSB considers that the Impact Assessment did not adequately analyse the financial impact (costs) related to integrating fans into other products.

To be clear, one must note that the RSB did not express an opinion in favour or against cascading.  

Follow-up

After an exchange of views with the Policy Officer, Ronald Piers de Raveschoot. Eurovent provided him with the latest document that had been published within the INTAS project (GEN – 917.00, GEN – 918.00) and the information that could be gathered from California (GEN – 922.00).

It is evident that reworking the Impact Assessment will be time-consuming and doing so within a six-week period challenging.

The Policy Officer will look for associations to help him in contacting manufacturers and users of large fans (including manufacturers of blades and impellers). In the current approach large fans are defined as having an electric input power above 100 kW.

A questionnaire has been received focusing on large fans. It is enclosed as GEN – 924.01 and can be replied to until 18 July 2018.

In the discussion, Eurovent hinted that possibly it may be useful to include a definition of large fans into the Impact Assessment and that some inspiration could be gathered from the INTAS study.

The consideration of costs aspects related to fans integrated into other products (not only into products subject to ecodesign requirements, but also into other products) will present the biggest challenge.

In the discussion Eurovent highlighted the opposing views that exist on the issue of cascading. Manufacturers of final products look at the optimisation of their final product. Being obliged to make use of regulated components presents different types of challenges for them regarding the final energy and non-energy performance of their products. Manufacturers of fans but also of other regulated products that can be considered components have been obliged to invest into developing their products to comply with ecodesign requirements. Such investments cannot be rendered null overnight. It would be necessary to look at both concerns in a manner that could lead to a balanced approach. A possible solution, but this would require investigation, could be to include specific component performances in the regulations for final products. In addition, the surveillance aspects would need to be looked at.

Next steps

The Commission, DG Energy, hopes to have an improved Impact Assessment ready by mid-August so that it can be submitted to for evaluation by the RSB in September. 

Once the evaluation by the RSB has been positive, DG-Energy will send out the proposals for Inter Services Consultation (ISC) that is expected to take 4 (maybe 6) weeks.

It is possible that the draft of the revised fan regulation would be shared at the start of ISC. If not, it will be available at the start of the WTO Consultation (60 days) and stakeholders will have the opportunity to comment during the 4-week feedback period on the Commission Better Regulation website. 

Once the comments of the WTO notification and the 4-week feedback period have been analysed and integrated into the final draft of the revised fan regulation, the Regulatory Committee will meet to discuss and vote this regulation.

Recommended Actions

Manufacturers (of large fans, impellers, blades, etc.) that are impacted by the fan regulation are recommended to respond to the questionnaire by 18 July. Please do feel free to provide all relevant comments (role of the fan in the final product, comments on threshold is 100 kW a useful limit, suggestions, etc.).

The Commission will look for arguments and input from the INTAS report, so it makes sense to consider the contents of these documents as they may help in formulating your reply.

Because little information is available on the cost impact of cascading, this aspect would benefit from separate analysis within the affected industry.

It may be appropriate for the products groups “Fans”, Air Handling Units”, “Cooling Towers” to draft jointly or separately a reply. Even though it would be difficult, a first approach regarding the calculation of the costs relating to cascading, its advantages and disadvantages could possibly be developed.

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