Policy Recommendations Comfort Fans

Complete policy recommendations for download (pdf, August 2022), covering the entire proposed merged Energy Labelling for comfort fans, room heaters and room air conditioners.

Recommendations in short

The history of environmental dumping of comfort fans into Europe has recently been documented. As rightly proposed, comfort fans should be covered in the energy labelling and strict MEPS should be set in order to stop this practice and move the market towards more efficiency.

Topten welcomes the revision of the Regulations (EU) No 2011/626 regarding energy labelling of air conditioners and comfort fans and (EU) No 2015/1186 regarding energy labelling of local space heaters. Specifically, we support the merging of regulations for room appliances with the same function into one energy label - this offers comparability for the significant percentage of consumers who do have a choice between technologies.

Key policy recommendations

	1. Two separate scales for comfort fans. Differences in technology, use and efficiency between ceiling fans and all other types of comfort fans are of such significance that we recommend the use of two separate scales respectively, as already suggested in the Working Document.
	2. Strong energy class thresholds. For non-ceiling fans, multiple products are already by many factors more efficient than the proposed class A threshold. For ceiling fans, the models are so far out of range of the proposed scale for non-ceiling fans that most products would be in class A. The Energy Labelling Framework requires class A to be completely and class B to be mostly empty at the time of entry into force; lower classes should be set in a way that does not render them obsolete when taking into account the proposed MEPS for comfort fans.
	3. Align MEPS with 2022 Chinese MEPS. Before re-defining the lower energy class thresholds for comfort fans according to the proposed MEPS, we strongly suggest aligning the future EU MEPS with the Chinese MEPS entring into force on 1 November 2022. This simplifies matters for international manufacturers and dealers as well as ensuring a suitably extensive market supply.
	4. Base label classes and MEPS on service value. Class thresholds and MEPS for all comfort fans should be based on the service value (m³/min/W), excluding the correction factors for standby and control features that are included in the proposed seasonal service value. General requirements for standby modes are already covered in horizontal regulation. For the complex calculation with correction factors – especially with regards to the control features, not even required to be listed on the product information sheet (Annex V, Art. 19.7) – incorrect declarations are to be expected; in addition, consumers prefer values that are understandable and offer transparency. Keep it simple.
	5. Include air displacement (m3/min) and diameter on the label. As the air displacement (m3/min) is a deciding size parameter for consumers, it should be included on the label. Similarly, the diameter of the models is a vital parameter for the MEPS. In order to make sure dealers can easily comply with the MEPS, this value (if applicable) should be clearly visible.
	6. Display of power consumption (W). For consumers it would be very helpful to be informed about the power consumption (W) of the comfort fan. This value should be displayed prominently on the energy label.
	7. Ceiling fans: add label for lighting where applicable. An ABCDE label for lighting on the bottom could be added for ceiling fans much in the same way the noise level classes within the label design are set up. This is already in place for range hoods in regulation (EU) No 65/2014 and can easily be copied
	8. Complete information in product information sheets. The product information sheet should always contain the energy efficiency index of the products as well as all information necessary to calculate the energy efficiency index. This includes a field to list all applicable control features that are subject to correction factors (Fcorr) as listed in Table 30 of the Working Document.

Infoplus

Publications

Environmental Dumping of Comfort Fans in Europe. Hélène Rochat, EEDAL22 in Toulouse, 06.2022. Paper and presentation.

Standards and Labels

Commission Regulation No 206/2012 with regard to Ecodesign requirements for air conditioners and comfort fans