Here is a summary of regulatory and standards activities specifically within the EU from Neil Jones.

NOTE: Not a great deal has changed since the end of June. Various authorities, organizations, policy officers and their consultants, etc., have been busy (hopefully) preparing, drafting, editing behind mainly closed doors. October and November should see the release of information and draft documents with some meetings called at relatively short notice. I have updated the Summer Report where new information has become available.

Regulation 327/2011 “Industrial” Fans

The Review of the Regulation is nearing completion.  European AMCA and many of our members are registered as stakeholders. A joint European AMCA-Eurovent-EVIA position paper was sent to the Commission Policy Officer on 14th April. Further copies were sent to Member States representatives with a covering letter on 15th April.

At the European Commission Consultation Forum meeting on 30th April, the Commission reviewed the text of their working document line by line and made the necessary notes to fine-tune the final draft. The commenting was largely done on the basis of our joint position paper, much of which seemed to have been taken into account. We have subsequently followed up on the Consultation Forum by providing the European Commission with some further information that they needed on Industrial and Dust Conveying Fans and Car Park Jet Fans, as well as reinforcing our previously submitted paper with a follow-up statement. From now on, the progress of the revision will follow a set sequence of procedures that are largely outside of the public domain. It is unlikely that we will know exactly what the future efficiency targets to be implemented in Jan 2020 (together with possible dispensations and exemptions) will be until the Regulation is published.

The Consultants (VHK) are expected to provide the Commission with their final Impact Assessment in November.

At the very earliest we could see publication shortly before Christmas 2015, but the Policy Officer has suggested that it is more likely to be April/May 2016.

CEN TC 156/WG17 is nearing completion of its work on a Harmonised Standard, under a mandate from the European Commission, to provide instruction and guidance on compliance with Regulation 327.  It will reference other standards including EN ISO 5801 (laboratory testing of fans) and EN ISO 12759 (fan efficiency).  A productive meeting was held in Madrid at the beginning of June 2015 and the draft is almost ready for release for comment, subject to the completion of the mandatory ZA Annex.

At the next meeting to be held towards the end of October, work will resume on finalizing the draft of the former prEN 14461, Fans – Safety requirements. This will be a “product-specific” standard that may be applied to demonstrate compliance with the “Machinery Safety Directive”. The original working draft was compiled by Bill Cory, Myself and Henrik Witt.

Ventilation Units

Following the publication of the Ecodesign Regulation on residential and non-residential ventilation units, a study for the Ventilation Units Product Group has been launched to provide the European Commission with technical assistance on draft transitional methods, frequently asked questions and other technical issues. Two stakeholder meetings were foreseen according to the project plan.

At the first stakeholder meeting on 15 June 2015, the European Commission and their consultants made it clear that their main purpose in holding the meeting was to receive questions and comments for further consideration and not necessarily to provide answers on the day. It was also made clear that the purpose of the study was not to consider any revision of the Regulation, but to provide clarity and guidance with regard to its implementation.

At the outset, and in response to a question from the floor, it was stated that the European commission is still committed to the principle of “Double Regulation” and that while a Ventilation Unit (includes Box fans, Roof fans and AHUs) must comply with Regulation 1253/2014, the fans inside them must comply with Regulation 327.

Regulation 1253 defines a ‘housing’ as a casing around the impeller which guides the gas stream towards, through and from the impeller. The study has proposed a systematic approach for identifying a product as a Unidirectional Ventilation Unit based on the following considerations:

  • A ‘fan’ can be with or without a ‘housing’;
  • The housing can be considered the first layer enveloping the air stream;
  • A ‘ventilation unit’ is always configured with a casing; and
  • The ‘casing’ can be considered the second layer enveloping the air stream.

This implies that any first layer enveloping the fan air stream will be a ‘housing’ and that a Ventilation Unit will always have both a first layer (‘housing’) and a second layer (‘casing’). So a fan with just a ‘housing’ must comply with Regulation 327, whereas a fan with a ‘housing’ and a ‘casing’ is a Ventilation Unit and must comply with Regulation 1253 and the fan inside (with its housing) must comply with Regulation 327. This seems a reasonable approach to add clarity but concern was expressed at the meeting with regard to some potential problems or loopholes. The comments were noted by the Consultants and matter will be considered further.

Comments and questions about internal SFP were received from Air handling, heating and cooling manufacturers.

(Note:  requirements for SFPint do not apply to Unidirectional VUs that are not intended for use with filters.)

Further information has been requested on a correct way to specify fan efficiency for a range of operating points for a “catalogue” ventilation unit, as opposed to efficiency at the “nominal” operating point of a bespoke/contract ventilation unit.

The Draft agenda, Discussion documents and Explanatory notes are available on the study website at http://ventilationunits.eu. The ‘Questions and answers’-document planned is not due until October 2015. The main topic of the second stakeholder meeting will be this ‘Questions and answers’- document.

Material Efficiency under Ecodesign

The European Commission has issued a draft standardization request with regard to ecodesign requirements on material efficiency aspects under the Eco-design Directive. This document is a revised version of M/529 on material efficiency aspects, which had been rejected at the end of 2014. The Commission services intend to have this request and its accompanying Implementing Decision adopted in the autumn, once all the necessary consultations have been completed.

This standardization request will mandate CEN and CENELEC to develop Harmonized Standards to assess the following material efficiency aspects: Extending product lifetime; Ability to re-use components or recycle materials from products at end-of-life; Ability to recover energy from products at end-of-life; Use of re-used components and/or recycled materials in products. It also covers other aspects such as upgrade-ability, ability to extract key components for reuse, repair, recycling and treatment; calculation of recycled and re-used content in products; methods to identify components by e.g. their MTF (mean-time to failure) or environmental impact; reporting formats; reusability, recyclability and recoverability indices.

Market Surveillance (Ecopliant)

The final publishable report from the Ecopliant Market Surveillance Project is now available. The objective of Ecopliant was to help deliver the intended economic and environmental benefits of the Ecodesign Directive and provide a level playing field for businesses. It expects to achieve this by strengthening Market Surveillance and so increasing compliance with the Ecodesign Directive and the relevant implementing measures.

As part of the project, sixteen document inspections of fans driven by motors were carried out by the Market Surveillance Authority in Hungary. A “significant problem” was identified in that some products did not fulfil the product information requirements on free access websites because of the great number of product variants. Only two products complied with the requirements because of deficiencies in the technical documentation, the Declaration of Conformity and in providing information on free websites. I spoke to the head of the Hungarian MSA and was told that their expectation was to be able to look at a manufacturer’s website to find all the information as is required in Fan Efficiency Regulation 327 for every fan available by reference to model identification codes. I explained that this is not always practical because of the great number of potential product variants that have to be available to meet customers’ performance specification requirements, and that are often configured via fan selection software. However, once a selection is confirmed, the relevant efficiency data, etc., is available. His opinion was that this was a failure to comply with what is stated in the Regulation! However, he did concede that he had no reason to believe that the fans themselves were non-compliant and appropriate energy efficiency data had been made available in documents from manufacturers.

The European Commission has now attempted to clarify the legal situation at the as follows:

“If it is necessary to subscribe and then use a password, even if anyone can subscribe to the website, this is NOT considered to be a free access website. A Free Access Website is to be understood as one that can be accessed without having to pay or to provide personal information. If a regulation, however, refers to a part for professionals of free access websites, that part for professionals can require subscription through password.”

Jet Fan Standard

The revision of (EN) ISO 13350 has received approval. ISO have indicated their intention to publish any time now. Meanwhile, the thrust-based method for calculation of efficiency that is the main focus of the revision has been included in the draft revision of Regulation 327.

ATEX (Hazardous Area) Fan Standard

The revision of EN 14986 is all but complete. A meeting of the Working Group was held in Braunschweig, Germany on 17th September 2015. We are waiting to hear if the final draft standard has been approved for submittal to CEN for issue to Member States for vote.

Emergency Smoke and Heat Control Fan Standard

The revision of harmonized standard EN 12101-3 has been published and released (in English) by at least one member state. It will become the official version to be used by Notified bodies in the EU for the Certification of Smoke Control Fans once it’s publication has been announced in the Official Journal of the EU (Note: this does not normally take place until it has been published in at least three of the main languages of the EU).

The ‘Circular Economy’ Package

In July 2014, the Commission published its so-called Circular Economy Package that was composed of a Communication on Circular economy and a proposal for the review of waste legislation. In December 2014, the Commission announced the withdrawal of the Package and subsequently declared its new objective to propose a more ambitious package by the end of 2015. It will focus on concrete measures that will cover the whole value chain from the extraction of raw materials to recycling and will contribute to EU objectives such as the Energy Union, the climate objectives and resource efficiency.

The European Commission has now launched a public consultation on the “Circular Economy”. The consultation will run until 20 August and on 25 June the Commission held a conference in Brussels that will feed into the consultation process.

 

Neil Jones

28th September 2015

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About amcainternational

The Air Movement and Control Association International Inc. is a not-for-profit international association of the world’s manufacturers of related air system equipment, primarily but not limited to fans, louvers, dampers, air curtains, airflow measurement stations, acoustic attenuators and other air system components for the industrial, commercial and residential markets.

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