From January 1, 2015, fans must comply with the energy efficiency requirements of the Ecodesign standard on fans EU327/2011. This includes replacement fans supplied as spares for incorporation into existing products.
Groups representing the hvacr manufacturers have been joined by the electronics industry in arguing that replacing existing fans by functionally identical models complying with the Ecodesign requirements is disproportionate, technically difficult and detrimental to the environment.
EPEE, representing the European refrigeration, air conditioning and heat pump industry, has joined with the European Ventilation Industry Association (EVIA), the powerful Japanese air conditioning and refrigeration manufacturers’ association JRAIA, the Japan Business Council in Europe (JBCE) and DigitalEurope, representing the European digital technology industry, in calling for an exemption on spare parts.
Although supportive of the Ecodesign standards generally, the group argues that in this particular case it will be impossible to simply replace a fan without impacting the other components of a product. They further argue that it will imply technical modifications that can be far-reaching if the overall performance of the product is not to be negatively affected. For example, if an AC fan is to be replaced by an EC fan, it is necessary to change the controls. This requires new and additional electronic cards and can cause significant complications in the case of building management systems.
They also argue that inrush and leakage current require changes of the safety devices, documentation and declaration of conformity need to be adapted accordingly and the service personnel needs to be trained to handle the new fans. Failure to apply the required technical changes could be far-reaching, they maintain. This could include safety issues, loss of performance, and CE non-conformity. Applying all required changes, on the other hand, will generate disproportionate service cost for the consumer.
Besides a significant cost increase for users and manufacturers, the group insists it would lead to additional waste generation due to the reduction of the useful lifetime of equipment in case of a fan failure.
There are concerns that although manufacturers may stock existing fans, it will be difficult to foresee the quantity required, as failures typically do not happen in the first years of lifetime. Any spare parts which will not be used will be waste, they argue.
In addition, given the significant additional cost for repairing, consumers may opt for a new appliance rather than repairing their existing product. Again, significant cost and waste will be generated as the useful lifetime of the appliance will be considerably reduced.