In a position paper published on 18 November 2014, Eurovent and its members were calling for an exemption of Cooling Towers from the revised Commission Regulation (EU) No 327/2011, which sets Ecodesign requirements for fans driven by motors with an electric input power between 125 W and 500 kW (hereinafter referred to as ‘EU Fan Regulation’). In the following, Eurovent would like to further elaborate on its key arguments. That said, further to the opinion that manufacturers could use test laboratory reports and guidelines from VDI and AMCA for scaling models and testing the models, we would like to provide additional clarifications on the difficulties cooling tower manufacturers would face in case of no exemption from the Regulation.