The hidden ErP compliance issues associated with roof units

Recent changes to ErP legislation have put contractors and distributors at risk of falling foul of compliance. David Millward, Product Manager at Elta Group, explains the key considerations for those tasked with delivering ventilation solutions, and outlines the various options at their disposal.

Understanding the full range of legislation and regulations that apply to ventilation units can be a challenge, but in light of recent changes, which put contractors and distributors at the heart of compliance, it is more important than ever.

Who is responsible under the ErP directive?

The ‘manufacturer’ has a number of legal duties and responsibilities under ErP Directives to ensure products are compliant with energy efficiency targets. The levels that must be achieved are detailed in Ecodesign Regulation 1253/2014 (explored below), which dictates requirements based on whether the ventilation unit is residential (RVU) or non-residential (NRVU).

Crucially, the definition of ‘manufacturer’ has implications for contractors and distributors who may be unknowingly making themselves culpable. Under ErP Directives and the EU Blue Guide, anyone who takes multiple components and puts them together into a single product, such as a ventilation unit, could be deemed the ‘manufacturer’.

This is common in the installation of roof-top ventilation units, which frequently combines a roof cowl and a separate plate mounted axial fan. In this instance, the point at which these two products are combined – whether it is at the point of installation or distribution – is when the responsibilities and legal duties associated with being a ‘manufacturer’ come into force. Those who brand a product, with the intention of selling it on as their own, are also liable to be deemed ‘manufacturers’.

Ecodesign Regulation 1253/2014

The Ecodesign Regulation 1253/2014, which came into force in 2016, establishes minimum requirements for ventilation units. It sets benchmarks across RVUs and NRVUs such as maximum sound power level, availability of a variable speed drive, and minimum fan efficiency.

The full range of considerations are listed in EU documentation , and it is important to be aware that the stipulations apply to any ventilation units that are placed on the market or put into service. There are certain elements of the regulations that are absolutely pivotal, and by engaging with those, contractors and distributors can go a long way towards compliance.

The ErP Directive, and a significant proportion of the Building Regulations, obligates everyone involved in the supply chain to select and supply ventilation equipment with optimum energy efficiency, ensuring that no more energy is consumed than necessary. In reality, this means that the vast majority of commercial and industrial fans need to be provided with some form of control, enabling fan speed to be adjusted in response to demand.

Control options for fans with AC motors

There are a wide range of controls available to manufacturers, although care must be taken to ensure they are suitable for the latest changes to ErP legislation. For example, the Electronic Speed Controller, which is a low-cost solution for fans with AC motors, does not comply with the requirements of Regulation 1253/2014, and must not be used on a NRVU. There is also a reluctance on the part of many fan motor manufacturers to allow such controls to be used with their latest ranges as the lack of energy efficiency can actually lead to motor failure.

Transformer Speed Controllers represent a reliable alternative, but they are heavy, cumbersome and costly. They also suffer from significant energy losses, which manifests in the form of heat and contributes to increased electrical consumption. Combined with a tendency towards over-ventilation, this raises serious questions over their regulatory compliance.

The final option for fans with AC motors is a Variable Speed Drive, which provides accurate commissioning and suffers from negligible energy losses. However, they are also large and obtrusive, and require specialist knowledge to set up properly, leading to a higher total cost.

Control options for fans with EC motors

The demands placed on ventilation systems by the ErP Directive has led to an increase in fans fitted with EC motors to enable manufacturers to meet their legal obligations for compliance. Potentiometers, for example, are small, low cost, and provide accurate commissioning with negligible losses. Combining a low energy consuming EC fan motor with minimal control losses provides manufacturers with peace of mind that they aren’t in breach of Regulation 1253/2014.

Some manufacturers now equip EC motor fans with integral potentiometer commissioning devices as standard. It allows the fan to be switched on and off by the user via a simple separate switch, or can be speed controlled by setting a maximum fan speed through a separate potentiometer type speed control.

Final thoughts

Contractors and distributors of ventilation equipment should familiarise themselves with the latest changes to the ErP Directive. This brief outline is sufficient only as a starting point, but the main point of consideration is whether or not they are making themselves liable by acting as a ‘manufacturer’.

If there is any doubt, they should opt for products that guarantee compliance by ensuring optimum energy efficiency and integrated controls. It is also worth bearing in mind that abiding by the regulations will effectively deliver a higher quality of air, which is beneficial to all and likely to keep customers happy.