Stakeholder meeting review Ventilation Units Regulations, and updates on Ecodesign meetings (GEN - 1034.00)

GEN – 1034.00. About fifty persons attended the first stakeholder meeting to prepare the review of the Ventilation Units Regulations. The expectation is that the review process will be finalised in the last quarter of 2020. In the margin of the meeting, the Commission remarked that no one referred to the issue of circular economy.

Timing

The Ecodesign Regulation 1253/2014 required that the result of the review of this Regulation should be available by 1 January 2020. This deadline will not be met and tentatively the final review study should be available by the end of March 2020. If all goes well, the Impact Assessment should be adopted in July 2020 followed by a Regulatory Committee so that the revised regulations would still be adopted in 2020.

Contents of the study

The review shall include an assessment of the following items listed in Article 8 of 1253/2014:

Requirements on leakage rates
Possible extension of the scope to cover unidirectional units with an electric power input of less than 30W, and bidirectional units with a total electric power input for the fans of less than 30W per air stream
Verification tolerances set out in Annex VI
Appropriateness of considering the effects of low-energy consuming filters on the energy efficiency
Need to set a further tier with tightened Ecodesign requirements

Moreover, it will address the following items designated by the Commission in the Terms of Reference:

Consideration of the Climatic Zones influences
Specific provisions for landmarked buildings
Further clarification of ‘box fans’ and ‘roof fans’ and their compliance with the Regulation
Correction on ‘h_t’ for leakages in BVUs
Improvements and changes in definitions
Requirements regarding instructions for material recycling
Other requests coming from stakeholders

Energy Labelling

The review of the Regulation 1254/2014 shall assess the possible inclusion of non-residential units and units with a total electric power input smaller than 30W.

Stakeholder meeting

The consultant VHK structured its presentation based on input received from stakeholders respectively for Residential Ventilation Units (RVU) and Non-Residential Ventilation Units (NRVU). For each type of ventilation units, both horizontal (general) and specific topics were discussed.

Main RVU-related topics

Scope

The willingness to include multifunctional VUs (using a heat pump) into the scope of the VU Regulation was acknowledged. It was stressed that the definition of multifunctional units must be unambiguously set to avoid the risk of loopholes. Moreover, the market size must be identified to correctly assess the impact. Here the consultant awaits input from Evia and Eurovent.

Clarifications of the text

For the clarifications, reference would be made to the EVIA/Eurovent guidance document.

Filters

The reference to ISO 16890 would be integrated with specific requirements for supply and exhaust air. It is proposed to include filter information on the energy label. It is noted that not all manufacturers would support this.

Working point

The proposal to extend SEC information over the entire working range of the unit is considered. Another position addressed the need for adjusting the pressure parameter for units with free outlets and with ducted outlets to provide consistency with ISO 5801.

Better consideration of controls by including the ventilation performance into the assessment

The Energy Performance of Buildings Directive requirements for ventilation do not result in adequate ventilation performance. The consultant proposes to include the Ventilation Performance Assessment Method developed by VHK and the University of Gent for EVIA in the revised 1253/2014. This would also result in a revised SEC calculation method. The revision of the MEErP should consider the functionality of the product, not just energy consumption. This concept raised many questions from the participants’ side. EVIA informed the participants that final specification of the methodology would be available in a few weeks. Stakeholders are asked to comment on this proposal.

Indoor Air Quality (IAQ)

The proposal developed for EVIA to include a star-rating on the label was considered. As with the previous proposal, the authors were requested for further clarification.

Labelling for Unidirectional – UVU and Bidirectional – BVU

A proposal for setting a different label category for unidirectional units only.

SEC calculation

A proposal to integrate new factors into SEC calculations, like filters compensation factors (EN 13142) or CTRL factors for room-by-room Demand Control Ventilation.

Leakages consideration for BVU

A proposal for setting limits on internal leakages (as per EN 13142), defining a new testing method easily applicable for all HRS technologies, and introducing a correction of thermal efficiency due to leakages.

Climate Zone

Proposal to display on the energy label a rating for various climate zones.

Discussion

In the discussion, the possible exclusion of requirements for historical buildings was considered. Because there is no clear definition of historical buildings, no conclusions could be reached. Moreover, the regulation deals with the placement on the market and does not consider the type of buildings in which the VU ends up.

The Commission also indicated that it is aware of the problems around CTRL-factor declaration and the delivery and installation of the required sensors. Constructive comments and proposals for a solution are awaited on this issue. In the discussion surrounding controls and sensors, the concept of packages (as for space heaters) was mentioned as a possible solution.

For the multifunctional units, it is suggested to avoid overlap with other regulations, including the revision of the air conditioning regulation.

The issue of NRVUs used as RVUs was addressed, with NRVUs not being subject to labelling when used as an RVU and thus presenting an issue for market surveillance. Within the EEPliant 3 project this would be addressed under Work Package 10. A first meeting would take place on 19 June.

The integration or separate supply of sensors in the VU would be considered separately.

It was remarked that the proposal on filter requirements would hinder the downsizing of units. There was a support to improve the performance by specifying filters, however Rob van Holsteijn proposed to leave this issue as it is today. It was noted that testing according to EN 16890 is difficult. René Kemna suggested that filter manufacturers could make a cause for a separate Ecodesign Regulation. Martin Lenz indicated that filter requirements should consider the pressure drop due to dust build-up. For NRVUs there are already requirements and it may be possible to proceed with a similar approach for RVUs.

The testing of leakages was considered – using tracer gases, pressure differences, or other methods. The high cost of tracer gas test methods was brought up. CETIAT explained that the results of various methods are not comparable. The Commission requested that this issue be further considered and resolved.

NRVU-related topics

The proposals on horizontal topics, including definitions, text clarifications, and filters effects were in the same vein as those for RVUs.

Several other proposals on NRVUs were considered.

Internal and External leakages of BVU

A comprehensive proposal to set new definitions and requirements regarding leakages, including OACF and EATR factors.

Consideration of moisture recovery

A proposal for including enthalpy recovery in the heat exchanger efficiency.

A discussion took place on the need to distinguish between non-residential ventilation and process ventilation. The consultant René Kemna thought it would not be possible to make such a distinction. It was proposed to clarify that a unit declared as an RVU must be used in residential buildings.

Recommendation

The Product Groups ‘Air Handling Units’ (PG-AHU), ‘Residential Air Handling Units’ (PG-RAHU), and ‘Air Filters’ (PG-FIL) should consider the presentation. Several items have meanwhile been discussed in WebEx meetings. The important element is to ensure that enough written input is provided before the next stakeholder meeting scheduled for December 2019. The future revision of the MEErP will include aspects of the circular economy – relevant to ventilation units and other products subject to Ecodesign and Energy Labelling requirements.

Circular economy – future of MEErP

The previous day, 28 May, DG Grow hosted a workshop titled ‘The future of the MEErP (Methodology for the Ecodesign of Energy-related products) – reinforcement of circular economy aspects in the methodology’. The aim of the workshop was to gather views from stakeholders related to the review of the MEErP that is to be launched in early 2020.

Several presentations identified possible ways to include circular economy considerations into the future MEErP such as: Least Life Cycle Costs (LLCC) of material efficiency aspects, the use of environmental assessment tools (e.g. Eco-report, Product Environmental Footprint), Lifetime aspects including durability, energy consumption, water consumption, material consumption and life cycle cost. Investment in data acquisition for these aspects would be important to progress in these areas.

René Kemna stressed that the data used within the MEErP are the “politically agreed data”. This was confirmed by Han-Paul Siderius. It may prove worthwhile to comment on these data. As an example, it was indicated that the costs for the Global Warming Potential are likely to be an underestimation.

Amongst the comments formulated we note that there would be no link between the environmental performance of a product and the EPBD, nor with regards to chemicals REACH and F-Gases. The consumer associations put forward that consumers do want repairability and would be willing to pay around 30% of the price of product for repairs.

After the stakeholder meeting on ventilation units, the policy officer wondered that none of the stakeholders mentioned the circular economy aspects (recyclability, repairability and material efficiency). Even though the presentation on ventilation units did not consider these aspects, it is possible that some circular economy aspects may find their way into the ventilation units study.

Update Ecodesign and Energy Labelling Consultation Forum meetings

The Commission will host the following meetings

5 July on the reparability scoring
10 July meeting on third party certification/conformity assessment of local space heaters (this is different from the discussion within the review study for local space heaters)

The meetings announced previously for June/July will take place in autumn, including:

Energy labelling expert group meeting on communication strategy for the rescaling of energy labels
Review of the air conditioners Regulation
Review of the local space heaters Regulation

Stakeholder meeting review Ventilation Units Regulations, and updates on Ecodesign meetings (GEN – 1034.00)

17 June 2019