Industry position on the VHK  Discussion  Document (Fans)

The industry associations CECED, EHI DIGITALEUROPE, EPEE and JBCE representing the downstream users of different fan types in a number of applications, appreciate the work done by the Commission to review Regulation 327/2011.

In reaction to the VHK discussion document reviewing the Fan Regulation and the 2nd stakeholders’ meeting we would like to express our concerns. These are in line with the previous joint industry position papers (see Annex).

• Centrifugal Forward Curved (FC) fans should not be merged with Centrifugal Backward Curved (BC) fans. This will effectively lead to the elimination of the FC fan. The FC fan is essential where small and quiet fans are required, such as servers and imaging equipment. For (typical industrial) applications where powers are above 5 kW, one efficiency for both fan types is acceptable (see figure 1).

• Spare parts should be exempted according to the ‘repair as produced principle’ (as applied in the RoHS and ELV Directives) instead of limiting the exemption to a fixed number of years. The availability of spare parts brings significant environmental benefits, as it guarantees longer product lifetimes and prevents waste generation, which is one of the core elements of the EU’s resource efficiency policy and the EU waste hierarchy. It is also crucial that spare parts are available for maintenance, repair, refurbishment and remanufacturing so that such activities remain costeffective, viable and overall sustainable.

• “Double” regulation, intended as ecodesign requirements addressing components of products covered by vertical ecodesign measures (such as fans, motors, lighting etc. – see figure 2), represents a non-justified burden for manufacturers and additional complexity for market surveillance authorities. A product that needs to comply with fans requirements incorporated into products already regulated may lead to an increase of the cost of a product without increasing its overall energy efficiency, therefore undermining the Least Life Cycle Cost (LLCC) principle. In addition, the misalignment of the tiers implementation, between product and components requirements, represents complications hardly manageable for both manufacturers and market surveillance authorities. We therefore call upon the Commission to exclude from the requirements fans integrated into products already regulated or soon to be regulated by other vertical regulation. Any proposal to integrate them should be justified by full impact assessment on the socio-economic impact of regulating fans integrated into products already regulated or soon to be regulated by other vertical or horizontal ecodesign regulations.

Also, the issue of double placing on the market that is of particular relevance to the fans regulation has not yet been solved. Different treatment of the parts integrated into appliances (put on the market separately or part of the final product) would create legal uncertainty and significant logistic problems.

Finally, downstream users, such as the IT/CE industry, incorporate fans into products that often take many years to design. CECED, DIGITALEUROPE, EHI, EPEE and JBCE call for regulation that allows freedom to innovate and design the most cost-effective products with the highest possible efficiency.