Ceced has recently expressed its position about the review of the fan regulation (327/2011) in a document realized in collaboration with DigitalEurope (representing the digital technology industry in Europe), Epee (European Partnership for Energy and the Environment), Jbce (Japan Business Council in Europe) and Jraia (Japan Refrigeration and Air Conditioning Industry Association). These organizations have called upon the European Commission and VHK (Netherlands-based private consultancy firm for research & development) to delete ecodesign requirements for fans incorporated into products, if these products already need to comply with ecodesign requirements (e.g. air-conditioners). In the worst case, such double regulation would increase the cost of products without increasing their energy efficiency, thereby possibly reducing the use of energy-efficient products by consumers. According to Ceced, a double regulation is counter-productive and can undermine the principle of Least Life Cycle Cost. Besides, the “Joint industry position paper” shows that applying ecodesign requirements to replacement fans will be detrimental to the environment. “We emphasise – the document explains – that replacing existing fans by functionally identical models complying with ecodesign requirements is disproportionate, technically impossible in some products, and detrimental to the environment. Besides a significant cost increase for users and manufacturers, it would lead to additional waste generation due to the reduction of the useful lifetime of equipment in case of a fan failure”. “We question – the position paper continues – the usefulness of individual information requirements for fans which are integrated into products that must already comply with information requirements. Such additional information requirements present an administrative burden for manufacturers of final products without adding value for consumers and users. In addition, the publication of information requirements on public websites would result in revealing commercially sensitive data”. Finally, the document tells about impellers for cooling electric motors, fans for tumble dryers and kitchen hoods. As regards to fan parts and Atex fans, the document says: “We agree that all configurations that occur before placing the fan on the market are considered to be fan parts. Therefore, they should not fall under the scope of this regulation. The final assembly will already be covered by requirements – there is no need to regulate individual parts, including impellers. Regarding fans covered by the ATEX Directive, we agree that they should be treated separately as they are not competing with standard fans”.
Click here to read the complete position paper.
