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Market surveillance is expensive, cheating is easy and the environment is the loser. Environmental regulations do have a positive impact, but unfortunately there are organisations that want to by-pass the rules. The European fan industry understands the importance of regulations and the difficulty of enforcement authorities with limited resources. They have produced guidance and tools to assist in identifying possible infringements.
The European Commission regulation 327/2011 eco-design requirements for fans driven by motors with electric input power between 125 W and 500 kW has transformed the market with a European Ventilation Industry Association (EVIA) survey estimating 160 TWh of electrical energy saved, 75 Mt CO2, between 2012 and 2020. But every non-complying fan diminishes this impressive figure.
The scope of the survey was for fans within the scope of 327/2011 with an electrical input power of <22 kW. The survey identified that 80% of those are integrated in other product. Within Europe these integrated components are typically placed on the market before being used by other manufacturers in other products, such as ventilation Units. The Market Surveillance Authorities (MSA) has an opportunity to enforce prior to subsequent use. But many complete products are imported with fans already integrated, here is an opportunity to avoid the regulations and a more difficult challenge for MSA’s.
Physically testing fans to determine the performance and efficiency can cost thousands of Euros, and for some very large products it is not practical. The European Commission’s INTAS project, that included Industrial Fans, confirmed the difficulty of surveillance of such products and proposed some measures. One proposal is a check list to identify potential non-compliance.
EVIA has taken this proposal, expanded the idea to a tiered approach and published in a guidance document. The tiered approach starts from a simple check of the product rating plate up to full product testing, including a check-test tool to check published product data. It can be used for any fan, from the smallest, ones integrated in other product to the very large.
Non-compliance can occur from misunderstanding or deliberately avoiding the requirements. The guidance can be used by manufacturers to understand their obligations. MSA’s can use it to identify potential non-compliance and focus their limited resources.