eceee views: Comments on the proposed eco-design regulation for fans 125W-500kW

(25 Mar 10) eceee welcomes the proposal for eco-design requirements for fans. However, we cannot support the proposed requirements, which are too weak to achieve the potential savings of 2 TWh linked to this measure.

eceee welcomes the proposal for eco-design requirements for fans. However, we cannot support the proposed requirements, which are too weak to achieve the potential savings of 2 TWh linked to this measure.

We welcome that fans integrated into other products are covered by the proposal. The generally low ambition in setting requirements means, however, that the proposed regulation will fail to maximise energy savings in a cost efficient manner. Furthermore, the weak requirements are also likely to penalise the most innovative and quality-oriented part of the European fan industry, and instead stimulate imports of low-cost inefficient products. This regulation should carefully avoid repeating the mistake of the motor requirements, which were far too lax.

In general, we believe that there are too many categories of fans in the proposal, but realise that this cannot be fixed now. It should be considered when this measure is up for review.
eceee proposes that:

• By 2012, the requirements should be those proposed for 2015.
• By 2015, the requirements should be those of the benchmark levels presented in Annex IV.
• Motors intended to operate above 40°C or below -15°C, should not be excluded
• Fans integrated in box-fans and roof-fans should also be required to fulfil the ecodesign requirements for the respective fan type (this is a similar approach that motors integrated into other products also need to fulfil the motor requirements);
• For box-fans and roof-fans, the minimum efficiency requirement should be made independent of the type of fan integrated, and that the level of the requirement should be the one for backward curved fans.
• For fans above 500 W, the minimum requirements for forward and backward curved fans should be the same, and be set at the level of the requirements for backward curved fans (the more stringent level).
  

After informal contacts with several fan manufacturers, the more stringent requirements proposed by us appear to be realistic and also desired by manufacturers focusing on quality and energy efficiency.

See eceee's full comments (pdf)
See eceee’s eco-design products pages

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