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General

Status quo concerning revision of the EU Fan Regulation 327/2011 (GEN – 804.00)

25 July 2017

3 min read
European Policy
General

Status quo concerning revision of the EU Fan Regulation 327/2011 (GEN – 804.00)

25 July 2017

3 min read

GEN – 804.00. With a new Policy Officer in charge since January 2017, a first informal meeting on reactivating the review of the EU Fan Regulation 327/2011 has taken place. Within the Commission’s tentative schedule, the aim is to have an Impact Assessment that will support the revised Regulation by the end of the year. The Eurovent Association is actively following the developments and participates in all relevant meetings at the Commission level.

Regulation review activities picking up again

The review study took place over a year between April 2014 and March 2015 when the final report by the Consultant VHK was uploaded on http://www.fanreview.eu/.

The Policy Officer Marcos Gonzalez Alvarez left DG Energy on 8 December 2015 for DG Competition where he oversees evaluating national support schemes designed to support renewables energies and energy efficiency.

In January 2017, Ronald Piers de Raveschoot, previously with JRC, joined DG Energy and was put in charge of the Lots 11, 30 and 31; Circulators, Compressors, Electric Motors and Fans. His priority lies with file related to the review of the Regulation on electric motors. The objective here is to have the Impact Assessment ready by early September, so that once approved by the hierarchy it can be submitted to the Regulatory Scrutiny Board at the end of September. The Regulatory Scrutiny Board replaces the Impact Assessment Board. It has wider responsibilities than its predecessor and requires a higher level of detail, precision and quality of the Impact Assessments.

The target within DG Energy has been to have the Impact Assessment for the Fan Review available by the end on this year (2017). As the work on the Impact Assessment for Electric Motors is slowed down by the new procedural requirements, the Commission has asked the Consultant VHK to initiate work on the review of the fan regulation, picking up where the study ended in 2015.

Differing views within different sectors

The views within different sectors have not really been changing since 2015. Some industry sectors oppose regulating products (components) integrated in regulated products. The wording in the discussions on this subject has transformed from ‘double regulations’ to ‘cascading regulations’. Other industries, for example the manufacturers of Cooling Towers, would like to beexcluded from the scope of the revised Fan Regulation.

Cooling Tower manufacturers call for exemption

VHK had EVIA and Eurovent to attend with a limited number of participants a meeting on 15 May 2017 in the Commission offices. Eurovent and EVIA members discussed the issues between fan and cooling tower manufacturers before this meeting.

During the meeting, technical aspects on various types were addressed (axial flow, cross flow, mixed flow jet fans were addressed first). The issue of fans working in different media (e.g. humid environment of cooling towers) or used for conveying/transporting material was discussed too.

A month after the meeting VHK made available a note on discussion items industrial fans.

There was a general agreement from industry that at least two years would be needed after the publication of the revised Fan Regulation to implement it. In practice and if the revised Regulation gets published in 2018, it would apply in 2021.

Weak market surveillance

It was pointed out that market surveillance is rather weak, even though the EU funded project INTAS is looking at this. For Market Surveillance Authorities, it is difficult to examine the formal requirements (technical documentation, conformity assessment documents…) of technical products where there is often a lack of access to independent laboratories and experts (as well as funding).  

Since the meeting on 15 May, the Eurovent Product Group Cooling Towers has prepared a Position Paper that it has shared with EVIA in view of a common meeting after the summer break.

Meanwhile, from contacts to the Policy Officer and the Consultant, it is very clear that they would like to have a common view from industry regarding both the scope of the revised Regulation and the requirements that should be set. It was hinted that a common view or common draft texts, by AMCA, EVIA and Eurovent would prove beneficial. 

Recommended Actions

Because different sectors have different views it will be necessary to find ways of converging these views. Within Eurovent, the involved Product Groups should meet and to progress towards common views and where necessary comment on the VHK discussion items.

It would be necessary to coordinate these views with other associations. For manufacturers, it will also be necessary to coordinate the views they express in the different associations where they are member.

The general aim of Eurovent is to aim for a wide industry acceptance both by fan manufacturers as well as fan users. This follows our overall approach of ensuring a European-wide level-playing field.

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