In its first Position on the Revision of the ‘EU Fan Regulation’ 327/2011 (find attached to this PDF file), Eurovent asked VHK and the European Commission to ‘provide clear definitions and clarify what exactly is in the scope of the measure’. It was stated: ‘Products within the scope shall be measurable and it should be possible to survey these products. Today, this is not possible for impellers alone. The interpretation made in the FAQ document to Regulation 327/2011 is not substantiated by any kind of arguments. Eurovent strongly advices legislators to exclude impellers from the legislation.‘ In the following, Eurovent provides for an extended version of this position in the hope that regulators are going to acknowledge the loopholes that would maintain from non-action on this issue.