EcoDesign Directive for Energy related Products

9 July 2018

EUUN0001

This report covers key requirements of the ecodesign directives now transposed into UK Law through 'The Ecodesign for Energy-Related Products Regulations 2010' as amended by Statutory Instruments and specifically in relation to Commission Regulation (EU) No 1253/2014 and 1254/2014.

The European Commission has assessed the technical, environmental and economic aspects of ventilation units. The assessment showed that ventilation units are placed on the Union market in large quantities. The energy consumption in the use-phase is the most significant environmental aspect of ventilation units, presenting significant potential for cost-effective energy savings and greenhouse gas emission reduction.

Classification

Fans are an important part of ventilation units. Generic minimum energy efficiency requirements for fans have been established in Commission Regulation (EU) No 327/2011. The power consumption of the ventilation functions of fans which are part of ventilation units is covered by the minimum energy performance requirements of that Regulation, but many ventilation units use fans not covered by it. It was therefore necessary to introduce implementing measures for ventilation units.

Ventilation unit (VU) means an electricity driven appliance equipped with at least one impellor, one motor and a casing and intended to replace utilised air by outdoor air in a building or a part of a building designed for human occupancy. In this respect, the utilised air is the polluted air due to the presence of human beings and their use of the building including emissions from materials, equipment, internal and external heat gains. This Regulation should not apply to a product intended to be used in a building or part of a building not designed for human occupancy or to a product that is not intended, as its primary function, to replace utilised air, unless the same product is also designed to only replace utilised air and thus, should comply with all relevant requirements of the ecodesign measure.

An example of an application where the Regulation should not apply are Data centres.

A distinction has been made between measures applying to residential ventilation units (RVU) and those applying to non-residential ventilation units (NRVU) on the basis of their individual air flow rates because two different sets of measurement standards are used in practice. RVU defined as duty < 250 m3/HR and NRVU defined as duty > 250 m3/HR.

Air handling units supplied by ECE UK will fall under the category of NRVUs.

Unidirectional ventilation unit (UVU) means a ventilation unit producing an air flow in one direction only, either from indoors to outdoors (exhaust) or from outdoors to indoors (supply), where the mechanically produced air flow is balanced by natural air supply or exhaust.

Bidirectional ventilation unit (BVU) means a ventilation unit which produces an air flow between indoors and outdoors and is equipped with both exhaust and supply fans. 

These new Regulations apply to ventilation units and establishes ecodesign requirements for their placing on the market or putting into service. All air handling units placed on the market or putting into service from 1st January 2016 must conform to Commission Regulation (EU) 1253/2014 and 1254/2014.

Putting into service is included to cover products which are not put on the market for sale in a traditional manner but which are fabricated and installed directly e.g. bespoke and site fabricated items. It does not refer to setting to work after having been delivered. A ventilation unit sold / delivered before 1st January 2016 but commissioned in 2016 need not comply.

Products Designed for 100% Recirculation

If the product is not designed for replacing utilised air with outdoor air, it is not a ventilation unit, unless the same product is also designed to replace only utilised air, and thus it should comply with all relevant requirements of the ecodesign measure.

In case the product has a connection to the outdoor with a supply / exhaust air flowrate in regular operation of minimum 10% of the total declared recirculated air flowrate, the unit is considered a ventilation unit and falls under Regulation 1253/2014.

Although not explicitly stated in the directive, a mixing box does not constitute heat recovery.

This means that the unit falls under the regulation if the supply air (SUP) contains more than 10% outdoor air (ODA).

Exemptions

The Regulation shall not apply to ventilation units which:

(a) are unidirectional with an electric power input of less than 30W;

(b) are bidirectional, with a total electric power input for the fans of less than 30 W per air stream;

(c) are axial or centrifugal fans only equipped with a housing in terms of Regulation (EU) No 327/2011;

(d) ATEX as defined in Directive 94/9/EC;

(e) are exclusively specified for operating for emergency use, for short periods of time and that set out in Regulation (EU) No 305/2011;

(f) are exclusively specified as operating:

(i) where temperatures of the air being moved exceed 100 degrees;

(ii) where the operating ambient temperature for the motor, if located outside the air stream, driving the fan exceeds 65 degrees;

(iii) where the temperature of the air being moved or the operating ambient temperature for the motor, if located outside the air stream, are lower than - 40 degrees;

(iv) where the supply voltage exceeds 1 000 V AC or 1 500 V DC;

(v) in toxic, highly corrosive or flammable environments or in environments with abrasive substances;

(g) include a heat exchanger and a heat pump for heat recovery or allowing heat transfer or extraction being additional to that of the heat recovery system, except heat transfer for frost protection or defrosting;

(h) are classified as range hoods covered by Commission Regulation (EU) No 66/2014

Comment:

A heat exchanger shall be interpreted as a heat recovery system.

We hold that an NRVU which is equipped with a heat recovery device and combined with a complete heat pump (the main task is usually to be a cooler) shall apply to this regulation. An NRVU equipped with a heating or cooling coil, which are connected to a separate heat pump, shall also apply to this Regulation. The heat recovery device shall, in such a case, be included in all applicable requirements, but the heat pump shall have no impact and its parts shall be considered as additional non-ventilation components. An NRVU with just a complete heat pump shall not apply to this Regulation. 

Example:

An NRVU for a swimming pool with plate heat exchanger and additional cooling coil (condenser) in exhaust air for separate heat pump is included, but the cooling coil is a non-ventilation component. 

Toxic, Highly Corrosive or Flammable or in Environments with Abrasive Substances

'Toxic, highly flammable or flammable' refers to those industrial environments where the handling of toxic, highly corrosive or flammable gases or vapours, as defined in Regulation (EC) No 1272/2008 (CLP Regulation) and its adaptions, takes place. To this extent, and in line with the terminology of the CLP Regulation, the term "toxic" refers to a substance or mixture's classification as a health hazard (Part. 3 Annex I CLP Regulation), and "highly corrosive" refers to the hazard classification of a substance or a mixture as corrosive to metals (Section 2.16 Annex I CLP Regulation)

Abrasion is the process or wearing away a surface by friction.

An abrasive application requires special solutions for fans like special linings for reducing the abrasion of the impellor material.

The following are examples of applications where abrasive substances are present:

  • Cement industry
  • Asphalt industry
  • Ceramic industry
  • Cereal milling sector (pneumatic transport in mills)
  • Glass sector
  • Steel sector (air supply for burners and extraction of fumes)
  • Brick products sector (air supply for burners' circulation' of fumes)
  • Woodworking sector (filtration' dust removal)
  • Suction of material by leaf vacuums

Please note only ventilation units used exclusively within the production process are excluded, and not any other units (for example: a ventilation unit that also can be used for the office has to comply with the regulation).

Process Ventilation

The following applications (non-exhaustive list) are considered to be process ventilation and are therefore out of the scope of the Regulation:

  • Agricultural applications
  • Exhaust from professional kitchen hoods or cielings
  • Data centres, server rooms
  • Machine exhaust
  • Recirculation units (secondary air only)
  • Heat dissipation, e.g. compressor rooms, generator rooms, CHP-rooms, Televisions and other studios with high lighting heat load
  • Foundries, forging processes
  • Halls with industrial furnaces
  • Paper production

Professional Kitchen in the Scope of the Regulation

A unidirectional ventilation unit for a kitchen for supply air (UVU SUP) is in the scope of the regulation.

A unidirectional ventilation unit exclusively designed for operation with a kitchen process (like range hood etc.) for extract air (UVU ETA) is not in the scope of the regulation.

A unidirectional ventilation unit not exclusively designed for operation with a kitchen process (like range hood etc.) is in the scope of the regulation.

A bidirectional ventilation unit exclusively designed for operation with a kitchen process (like range hood etc.) is not in the scope of the regulation.

A bidirectional ventilation unit not exclusively designed for operation with a kitchen process (like range hood etc.) extract air (UVU ETA) is in the scope of the regulation.

Specific ecodesign requirements for NRVUs

From 1st January 2016:

  • All ventilation units, except dual use units, shall be equipped with multi speed drive or a variable speed drive.
  • Electronically Commutated (EC) fan equipped with EC motor is considered as equipped with VSD and thus fulfils the VSD requirement.
  • All BVUs shall have a heat recovery system (HRS).
  • The HRS shall have a thermal bypass facility. 'Thermal By-pass Facility' means any solution that circumvents the heat exchanger or controls automatically or manually its heat recovery performance, without necessarily requiring a physical air flow bypass. For instance summer bypass for plate recuperator and variable rotor speed control for thermal wheel.
  • Thermal efficiency of run around coils to be minimum 63%. This efficiency is based on equal balance of supply and extract air flow.
  • Brine in the run around coil system shall be a mixture with minimum 25% ethylene glycol and 75% water.
  • Thermal efficiency of plate recuperators and thermal wheels to be minimum 67%. This efficiency is based on equal balance of supply and extract air flow.
  • Efficiency bonus given to increase SFP permissible allowance if thermal efficiency is above 63% for run around coils and 67% plate recuperators and thermal wheels.
  • Fan efficiency for UVU to be minimum 62% * In(P) + 35% if P < 30 kW
  • Fan efficiency for UVU to be minimum 56.1% if P > 30 kW
  • To determine SFPint as the electric power supplied to a fan and related to the internal pressure of all ventilation components (filters, heat recovery and related casing including flow entrance and exit) divided by the air flow expressed in m3/s under design load conditions. SFPint value varies from run around coils to plate recuperators and thermal wheels. ECE UK will confirm compliance with SFPint within every quotation supplied.
  • Unidirectional ventilation unit intended to be used with a filter have a SFPint limit of 250 W/m3/s.

From 1 January 2018:

  • All ventilation units, except dual use units, shall be equipped with a multi-speed drive or a variable speed drive.
  • All BVUs shall have a HRS.
  • The HRS shall have a thermal by-pass facility.
  • The minimum thermal efficiency ηt_nrvu of all HRS except run-around HRS in BVUs shall be 73 % and the efficiency bonus E = (ηt_nrvu – 0,73) * 3 000 if the thermal efficiency ηt_nrvu is at least 73 %, otherwise E = 0.
  • The minimum thermal efficiency ηt_nrvu of run-around HRS in BVUs shall be 68 % and the efficiency bonus E = (ηt_nrvu – 0,68) * 3 000 if the thermal efficiency ηt_nrvu is at least 68 %, otherwise E = 0.
  • The minimum fan efficiency for UVUs (ηνu) is
    6,2 % * ln(P) + 42,0 % if P ≤ 30 kW and
    63,1 % if P > 30 kW.
  • The maximum internal specific fan power of ventilation components (SFPint_limit) in W/(m3/s) is
    for a BVU with run-around HRS
    1 600 + E – 300 * qnom/2 – F if qnom < 2 m3/s and
    1 300 + E – F if qnom ≥ 2 m3/s;
  • for a BVU with other HRS
    1 100 + E – 300 * qnom/2 – F if qnom < 2 m3/s and
    800 + E – F if qnom ≥ 2 m3/s;
    230 for an UVU intended to be used with a filter.
  • If a filter unit is part of the configuration the product shall be equipped with a visual signalling or an alarm in the control system which shall be activated if the filter pressure drop exceeds the maximum allowable final pressure drop.

ANNEX V

Information requirements for NRVUs as referred to in Article 4(2) 

1. From 1 January 2016, the following product information shall be provided: 

a) manufacturer's name or trade mark;
b) manufacturer's model identifier, i.e. the code, usually alphanumeric, used to distinguish a specific non-residential ventilation unit model from other models with the same trade mark or supplier's name;
c) declared typology in accordance with Article 2 (RVU or NRVU, UVU or BVU);
d) type of drive installed or intended to be installed (multi-speed drive or variable speed drive);
e) type of HRS (run-around, other, none);
f) thermal efficiency of heat recovery (in % or ‘not applicable’ if the product has no heat recovery system);
g) nominal NRVU flow rate in m3/s;
h) effective electric power input (kW);
i) SFPint in W/(m3/s);
j) face velocity in m/s at design flow rate;
k) nominal external pressure (Δps, ext) in Pa;
l) internal pressure drop of ventilation components (Δps,int) in Pa;
m) optional: internal pressure drop of non-ventilation components (Δps,add) in Pa;
n) static efficiency of fans used in accordance with Regulation (EU) No 327/2011;
o) declared maximum external leakage rate (%) of the casing of ventilation units; and declared maximum internal leakage rate (%) of bidirectional ventilation units or carry over (for regenerative heat exchangers only); both measured or calculated according to the pressurisation test method or tracer gas test method at declared system pressure;
p) energy performance, preferably energy classification, of the filters (declared information about the calculated annual energy consumption);
q) description of visual filter warning for NRVUs intended for use with filters, including text pointing out the importance of regular filter changes for performance and energy efficiency of the unit;
r) in the case of NRVUs specified for use indoors, the casing sound power level (LWA), rounded to the nearest integer;
s) internet address for disassembly instructions as referred to in point 3. 

2. The information listed in point 1(a) to (s) shall be available: 

a) in the technical documentation of NRVUs; and
b) on free access websites of manufacturers, their authorised representatives, and importers. 

3. The manufacturer's free access website shall make available detailed instructions, inter alia, identifying the required tools for the manual pre-/dis-assembly of permanent magnet motors, and of electronics parts (printed wiring boards/ printed circuit boards and displays > 10 g or > 10 cm2), batteries and larger plastic parts (> 100 g) for the purpose of efficient materials recycling, except for models of which less than 5 units per year are produced. 

Question:

Is it possible to install one UVU for supply and one UVU for exhaust in a building or part of a building? 

Answer: 

Yes. EU 1253/2014 is a product regulation. The product shall comply when placed on the market for the first time. In consequence no product and no manufacturer knows, how the products will be combined in buildings and how they interact, if there is no mechanical design aspect, which has to be considered in the product design. 

In NRVU no declaration on this topic is needed. This is necessary, because the airflow balance in these buildings depend very much on their use and operation.
If the whole ventilation unit is designed, manufactured and delivered under the approach that it is a BVU (in line with the relevant definitions given in the Regulations), it derives that it should be considered as a BVU. Therefore, the energy label and the compliance with the Ecodesign requirements should be evaluated accordingly. If several different components, among which various UVUs, are assembled on site (into a ventilation system), and each UVU is delivered separately, and capable to work independently from the others, in this case each UVU should be assessed separately. 

In consequence, the following combinations of units shall be considered as a BVU: 

  • Two or more units combined with a RAC heat recovery system
  • Two or more units directly (without building sided ductwork) connected with a mixing chamber. 

If two or more units in the meaning above are combined on site in the building by a third party (for example installer), a BVU (based on CE-marked UVU’s) will be “putted into service”. This means the third party has to declare the product conformity as a BVU and CE mark. 

Question: 

Repair and exchange of complete units, subassemblies and components.
What is meant by repair and changing the entire unit? 

Answer: 

Repair of a ventilation unit is always possible. This does not lead to a new assessment of conformity.
Repair of a ventilation unit does include a change of components and subassemblies if the performance is kept or better due to technical progress.
Example of components and subassemblies: 

  • Heat recovery units or sections
  • Motors and fans (please see EG 640/2009 and EU 327/2011 for minimum requirements of motor or a fan change).
  • Filters
  • Heat exchangers
  • Controls 

A change of the entire ventilation unit according EU 1253/2014 does always mean, that the entire ventilation unit has to comply with EU 1253/2014. 

Question:

What about ventilation equipment for 'cleanrooms'? Cleanrooms can be found in hospitals, research centres, pharmaceutical and certain other manufacturing plants. The ventilation units used for clean rooms treat large volumes of air, with limited replacement of the treated air with new air. One objective is to ensure overpressure in the cleanrooms so that the level of pollutants (dust, microbes....) is kept at minimal or controlled. Are they within the scope?

Answer:

As long as:

  1. These products can be defined as ventilation units, in line with definition 1 of article 2 of the Regulation 1253, i.e. "an electricity driven appliance, intended to replace air by outdoor air in a building".
  2. These products are not between the scope exclusions they fall in scope to Regulation 1253/2014. 

Question:

Which ventilation units are excluded?

Answer:

See following table for further explanations:

#  Unit Design Comments  EU 1253
1254 / 2014
1 Heat recovery only
1
  Included
2 Air to air Heat pump only
2
No performance data available for ventilation units with a heat pump for heat recovery only.
This system allows heat transfer being add. to heat recovery
This system shall be regulated in LOT 21. No double regulation
Predominantly heating or cooling
Excluded
3 Heat pump only 4 damper rooftop
3
No performance data available for ventilation units with a heat pump for heat recovery only.
This system allows heat transfer being add. to heat recovery
This system shall be regulated in LOT 21. No double regulation
Predominantly heating or cooling
Excluded
4 Heat recovery + 3 damper – heating
4
The additional heating and mixing does not affect the heat recovery SFP INT shall be calculated with SUP and ETA air volume flow as follows: Included
5 3 damper only
5
No longer allowed in NRV, because BVU shall have heat recovery, if the purpose of the unit is predominantly ventilation.

Included
6 Heat recovery + air to air heat pump
6
Clearly specified as an exclusion. Excluded
7 Heat recovery + Air/water heat pump
7
The Unit can be specified without impact of water heat pump
NRVU: The condenser/evaporator is considered as additional component and not included in SFP int.
RVU: The condenser/evaporator is not included in SFI.
Included
8 Heat recovery + add heating
8
The additional heating does not affect the heat recovery
NRVU: The heating coil is add. Component
RES. The impact of the re heater on the electrical power input should be corrected
Included
9 Run around coil
9
Heat recovery only Included
10 Run around Coil + add heating
10
The RAC can be measured without add. heating or cooling inside the water/brine circuit Included
11 Run around Coil + add heat pump in the water/brine circuit
11
The RAC can be measured without add. heat pump inside the water/brine circuit. Included
12 Heat recovery plus frost protection
12a
  Included
12 UVU plus Hot Water Heat Pump
12b
The evaporator/condenser in the air stream has no impact on ventilation function and shall be considered as an additional component. Included
13 Positive Input Ventilation with reheater
13
  Included
14 Secondary air fan-coil with outdoor air and 2 fans.
14
Is predominantly a fan coil
Using some outdoor air
LOT 21
SEK Excluded
ODA included
15 Secondary air fan-coil with outdoor air and 1 fan
15
Is predominantly a fan coil if outdoor air flow is minor (<10%)
Covered in LOT 21
ODA included if air volume flow is significant (>=10%)
SEK and RCA Excluded
ODA included if significant (>=10%)
16 Ventilation unit with add. secondary air
16
See above including cooling SEK Excluded
ODA and EHA included

Justification:

The core of the regulation is to specify the ventilation function of a unit. If the unit provides additional functions in combination with heat pumps or by using recirculation or secondary air the main function might not be ventilation.

Electric Motors for Fans

Commission Regulation (EU) No 640/2009 Ecodesign requirements for electric motors for ventilation units is already subject to the following legislative timetable:

1. From 1st January 2015:

(i) motors with a rated output of 7.5 - 375 kW shall not be less efficient than the IE3 efficiency level, or meet the IE2 efficiency level and be equipped with a variable speed drive.

2. From 1st January 2017:

(i) all motors with a rated output of 0.75 - 375 kW shall not be less efficient than the IE3 efficiency level, and be equipped with a variable speed drive.

References

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