When it comes to the formulation of fan regulations, burying our heads in the sand is simply not an option, says Geoff Lockwood
At the bi-annual international motor summit in Zurich in December 2012, a European Commission policy officer pleaded with industry not to challenge draft regulation that is due to be ratified into law when all the issues could have been discussed and resolved during the previous two years.
What he failed to understand was the human nature of burying our head in the sand and hoping it all goes away. The situation is even more acute with the ecodesign fan regulations.
These went into law in March 2011 with the full effects of the requirements coming into force on 1 January 2013. There are many that still have their heads buried in the sand and others that are trying to argue the regulations are flawed. It is too late for that now. There are issues that the European fan industry is addressing through the European Ventilation Industry Association (EVIA).
Preventing a loophole
The most important point of regulation 327/2011 (the ecodesign requirement for fans driven by motors with electric input power between 125W and 500kW) is that the scope includes fans integrated into other energy related product. This was included by the Commission to prevent a loophole whereby non-compliant fans could be integrated into product manufactured outside of Europe, and then imported and placed on the market.
Without this, the full carbon savings would not be realised and it would give a significant disadvantage to European-based fan and equipment (other energy related product) manufacturers. What many have overlooked are the consequences of the scope; equipment manufacturers with integrated fans can be fan manufacturers with the full responsibility and consequences of the fan regulation.
As with all ecodesign regulations, the problem is defining and understanding the term 'placing on the market'. The Commission guide states: 'Placing on the market is the initial action of making a product available for the first time on the Community market, with a view to distribution or use within the Community'.
How can that be interpreted considering the fan regulation?
It is straightforward; it's when a fan manufacturer makes a complete product and places it on the market. However if the equipment manufacturer modifies the fan in any way, for example adjusting the housing resulting in an aerodynamic change, then a new fan has been created.
The equipment manufacturer is now a fan manufacturer and they are responsible to ensure it meets the minimum efficiency requirements and publish the relevant data.
The above takes an example of an integral fan, where the impeller, motor and housing are supplied pre-assembled by a fan manufacturer. There are other situations where equipment manufacturers purchase and assemble separate impellers, housings, belts and pulleys and motors.
In this case the first time the fan is placed on the market is the time when the equipment, with the fan integrated within, is placed on the market. Therefore that equipment manufacturer is also a fan manufacturer and is required to determine that the fan meets the required minimum efficiency and that relevant data is published on labels, catalogues and websites.
Placing on the market and who is the fan manufacture is one of many grey areas within the new regulation. The EVIA fan group has published a fan guidance document to help explain some of these points, see http://www.evia.eu/en
The EVIA fan group is also in discussion with the Commission trying to resolve even more pressing problems that will become serious in the next tier of the regulation in 2015; smoke control fans, a discrepancy in axial fan limits, default motor values and spare part availability.
// The author is chairman of the EVIA fan working group, past president of HEVAC and technical director of ebm-papst UK