Position paper
EPEE Position Paper on ENER Lot 11 (fans) :
Position paper
EPEE Position Paper on ENER Lot 11 (fans) :

Executive Summary and Recommendations

The European Commission is reviewing Ecodesign Regulation (EU) No 327/2011 on fans (ENER Lot 11).
EPEE, the voice of the air conditioning, heat pump, and refrigeration industry in Europe, supports the
EU ecodesign and energy labelling policies, and agrees with the need to keep the legislation up-todate and in line with the latest technological developments.

This paper provides the EPEE position on the most recent proposals from the Commission on the
review of the requirements for fans. It offers our recommendations divided in seven different topics
as a reaction to the Consultation Forum of 1 April 2022.

  1. Avoid double regulation.
  2. Clarify the distinction between complete and incomplete products.
  3. Refine the requirements for custom fans as well.
  4. Maintain a three-year timeline for Tier 2.
  5. Avoid lowering the threshold for forward curved fans.
  6. Remove requirements to publish technical data on publicly accessible websites.
  7. Exclude material efficiency requirements on spare parts for fans integrated in other product specific ecodesign requirements.
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