EUROVENT versus ECODESIGN

Transcription

1 White Paper EUROVENT versus ECODESIGN

2 2 I Eurovent versus Ecodesign Introduction This white paper describes the relationship between the Eurovent certification with its new energy labels and the European ecodesign legislation for ventilation units. ErP 2018 The specific characteristics relating to energy efficiency that result from these two procedures are compared as well as the aspects relating to the machine directive (CE marking). We will also look at the differences between them. Eurovent is a quality agreement between the affiliated product group members and has no legal obligation for any manufacturer, while ecodesign is part of European legislation. A ventilation product that does not comply with the ecodesign requirements will not be granted CE marking. Figure 1 - Systemair logo; energy-related products

3 Eurovent versus Ecodesign I 3 Ecodesign legislation From 1 January 2016 the new European ecodesign legislation for ventilation units has effect (regulation 1253/2014). This legislation makes heat recovery with minimum efficiency compulsory for most balanced ventilation systems and limits the SFP int1. For air handling equipment above 250 m 3 /h in nonresidential applications regulation 1253/2014 describes the values that have been set from 1 January 2016 and how these will be tightened on 1 January By 2020 the complete set of measures that form part of the coordinating ecodesign law 2009/125 2 will be evaluated. This means that there is a real possibility of further tightening by 1 January For products in hybrid ventilation systems (mechanically combined with natural ventilation) only the requirements for fan performance or SFP int apply, if the unit also includes a filter. The requirements set out in 1253/2014 (for non-residential products) are based on the moderate climate zone within the European Union (the -10 zone). This also includes the Netherlands. The requirements set out for this zone naturally achieve higher energy savings in the colder North European countries than in the warmer South European countries. For the residential construction market ecodesign legislation takes account of the climate zone where the product will operate. Ecodesign legislation tries to simplify the underlying calculations as much as possible. This however makes it quite difficult to explain to a customer in e.g. Greece or Spain that heat recovery really is a legal obligation for his air handling units in a balanced ventilation system. Apart from the official legal text of 1253/ the most recent interpretation available from the European Commission and formally applicable is the Final draft version faq_vu 4 of 21 December Within the Dutch association of suppliers of air handling equipment (VLA) there have also been agreements about the way in which we as affiliated suppliers deal with specific questions from the market about 1; (Internal Specific Fan Power is the absorbed fan power per m 3 /s as a result of pressure drops across the openings, clean filters, heat recovery as well as installation losses of the fans). 2; DIRECTIVE 2009/125/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 21 October 2009 establishing a framework for the setting of ecodesign requirements for energy-related products. 3; COMMISSION REGULATION (EU) No 1253/2014 of 7 July 2014 implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for ventilation units. 4; FINAL DRAFT 21 DECEMBER 2015, FREQUENTLY ASKED QUESTIONS TO COMMISSION REGULATION (EU) No 1253/2014 of 7 July 2014.

4 4 I Eurovent versus Ecodesign certain situations that are unclear in the legal texts. With this additional explanation of the FAQs we try to act as carefully as possible and in mutual coordination. Eurovent certification Eurovent is the European association of product suppliers relating to indoor climate, process cooling and the chilled-food chains. Over 1,000 companies from all over Europe, the Middle East and Africa have joined this organisation. Eurovent is a quality label - since 1994 Eurovent - affiliated manufacturers decide how their products in various product groups can be compared in a reliable way. They are also committed to the complete certification procedure that is monitored by an independent organisation (Eurovent Certita Certification in Paris). The Eurovent product group for manufacturers of air handling equipment has agreed to: Each year compare the selection software of a certain product range with the actual manufactured product; Every three years a unit that is in production in the factory at that moment is selected to be tested and measured. The manufacturer then makes an exact copy of the selected unit and sends it to the TÜV laboratory; Every six years the model box that is representative for the product range is checked in detail against the EN1886 values given by the manufacturer. All tests are of course carried out in an independent TÜV laboratory in line with measurement tolerances, and negative deviations compared to the specifications are not permitted. Internationally agreed standards such as EN1886 for casing characteristics and EN13053 for characteristics that determine the energy efficiency of air handling units are used as control measurements. Thanks to the control measurements in accordance with EN1886 the casing characteristics below are well comparable:

5 Eurovent versus Ecodesign I 5 Mechanical strength (D); Air leakage (L); Filter bypass factor (F); Thermal transmittance (T); Thermal bridging factor (TB); Acoustical insulation in db. EN13053 measures the factors that influence the energy efficiency of the air handling units such as: The air flow that results in an average air velocity class (V); The available external static pressure; The absorbed electric power (P); The thermal heat recovery performance (H) with associated pressure drop; The capacity of the heat exchangers and their water-side pressure drop; The acoustical casing insulation. The offers of certain Euroventcertified product ranges can carry the Eurovent logo. This HHFlex logo includes a unique Eurovent diploma number that only Software version: E4.50 ( )(R168)/A Eurovent identification number: applies to this product range. The number in Figure 2 is the unique diploma number of the HHFlex air handling unit product range with the Holland Heating brand, a brand that is manufactured by Systemair. This number is, just as all other Eurovent-certified products, registered and listed on the Eurovent website This means the manufacturer himself is not certified, but his specific product range is. It is possible that manufacturers have several product ranges, some being Eurovent-certified and others not. Receiving and maintaining the Eurovent certification for a product range costs the manufacturer over 30,000.- in external costs per product range annually. The Eurovent certificate is definitely not free-of-charge and optional, and therefore provides the customer with a significant risk limitation contribution. For the end user this is a guarantee that the specifications published by the manufacturers for Figure 2 - Eurovent logo with identification code

6 6 I Eurovent versus Ecodesign certified products are correct. It therefore eliminates the risk of negative differences with regard to the specifications. It is also possible to have even more assurance, if the manufacturers also carry out a factory acceptance test (FAT) on their supplied products. This is not standard for all products, but some manufacturers carry it out at a limited additional cost. The certified Eurovent software is used to carry out calculations that lead to an energy label for an air handling unit. The Dutch government uses these energy labels example to grant subsidies for lowenergy products. With the introduction of the ecodesign legislation the Eurovent energy labels have also changed. Ecodesign update with additional explanations At the last stakeholders meeting on 17 December 2015 in Brussels the details of regulation 1253/2014 were again carefully examined. Davide Polverini, representative of the European Commission, was the chairman of the meeting. Point by point he dealt with the draft version commission communication of 14 December 2015 and then with the draft version faq_vu of 11 December The approximately 60 stakeholders from various European countries present could react to what was said and their remarks were then discussed. Both documents mentioned were published on 21 December in a (barely) revised version 5, and the older versions were cancelled. Together with the original legal text of 7 July 2014 these documents form the legal review framework used by the enforcement agencies in the various member states to judge the products with the associated mandatory product information. More can be found on the website The original legal text of regulation 1253/2014 describes general minimum requirements for air handling equipment in a balanced ventilation system, the so-called bidirectional ventilation unit (BVU). These minimum requirements 5; DRAFT COMMUNICATION FROM THE COMMISSION in the framework of the implementation of Commission Regulation (EU) No 1253/2014 of 7 July 2014 implementing Directive 2009/125/E, version 21 December 2015.

7 Eurovent versus Ecodesign I 7 apply to new products that, as mentioned earlier, were placed on the market on 1 January 2016 and will be tightened on 1 January 2018, notably in the areas of heat recovery performance and SFPint. Therefore the following conditions apply from 1 January 2018 onwards: All fans must include speed control; Controllable heat recovery must be included with a dry performance of at least 73% for heat recovery wheels or heat exchangers and at least 68% for a twin-coil system; The required fan power (SFP int ) to overcome internal resistance of clean filters, dry heat recovery, fan installation and suction and discharge openings may not be more than 800 [W/(m 3 /s)]. Added up for supply and exhaust air fans for air flows above 2 m 3 /s. The maximum allowed SFP int increases as the air flow is reduced and/or as a higher heat recovery performance is applied. The maximum allowed SFP int decreases if the return air filter quality is not at least M5 and/or the supply air filter quality is not at least F7; Filters must include a clearly audible and visible filter dirty signal. For unidirectional ventilation units (UVUs) that are generally part of a hybrid ventilation system the following ecodesign requirements apply from 1 January 2018: All fans must include speed control; The static fan performance at the operating point must be at least 63.1% for a fan power of more than 30 kw and changes in line with the natural logarithm to 42% for a fan power of 1 kw; If the supply air unit includes a filter this must be at least an F7 filter, and the maximum allowed fan power SFP int as a result of the pressure drops across the openings, the clean filter and the fan installation becomes 230 W/(m 3 /s)]; Here too the filters must include a clearly audible and visible filter dirty signal. The above ecodesign requirements indirectly imply that in 2018 the average air velocity in air handling units decreases to approximately 2.2 m/s for heat recovery wheels and plate heat exchangers and to approximately 1.8 m/s for twin-coil systems. As a result of the ecodesign legislation these

8 8 I Eurovent versus Ecodesign low-energy air handling units become larger, require more space (important point for replacement) and are also somewhat more expensive to buy. Exemptions generally apply in cases where the return air is so contaminated that dangerous situations could develop for maintenance or operation. Also if it is difficult to acquire materials that are able to withstand the conditions/ compositions of the exhaust air, as in potentially explosive atmospheres or systems for removal of toxic, highly corrosive or highly abrasive substances. In addition to the legal text below further relevant interpretations to the FAQs of 21 December where necessary with an additional explanation agreed by the technical commission of the VLA: When a manufacturer or distributor supplies a product to a distributor or end user for the first time, in legal terms this action is always called placing to the market. For this a (verbal or written) agreement between two or more natural legal persons is required Figure 3 - VLA logo for the transfer of ownership of the product. In this case the product need not have been physically supplied (article 2.3 of The Blue Guide forms the legal framework for all harmonization laws within the European Union 6 ); It is the intention of the ecodesign regulations that professional extractor kitchen hoods are not covered by regulation 1253/2014, except if they are also (partly) used for kitchen ventilation. According to the TCVLA a ventilation unit that only removes air via an extractor hood is a UVU. The associated one-to-one supply unit is then also seen as a UVU. If part of the kitchen air is removed in a different mechanical way, this part together with the supply unit is seen as a BVU; Regulation 1253/2014 does not mention process air. The detailed description in the relevant FAQ mentions applications for ventilation units for residential buildings. The reverse TCVLA interpretation is that air handling equipment for a (part of a) building where no people are present, except for example in emergencies, does not 6; The Blue Guide on the implementation of EU product rules 2014, European Commission.

9 Eurovent versus Ecodesign I 9 have to comply with 1253/2014; Ventilation units for (parts of) buildings that are not heated (for example a car park) or that are only used to remove the internal heat produced (for example a data centre) are outside the scope of regulation 1253/2014; Nominal air flows used in regulation 1253/2014 and for example as a basis for fixing heat recovery are the maximum design air flows with, if applicable, closed recirculation dampers (full of outside air). In this case there is no difference for summer and/or winter operation; Ventilation units with less than 10% outside air share are seen as recirculation units and must not comply with 1253/2014; If components in an existing balanced ventilation system must be replaced in part, the components to be replaced are seen as new products and must therefore comply with regulation 1253/2014. The regulation regards the components to be replaced as new products on the European market. The interpretation of a new product is given in The Blue Guide 7 (article 2.1; a product that has been significantly modified or updated ). In this case we can refer to the main base points of the ecodesign legislation (point 1 of 1253/2014). The idea of the Commission is that introduction does not lead to excessive cost. Article 4 of the coordinating ErP legislation 2009/125 also mentions introduction must save energy with a better design and this must also result in economical savings for companies and end users. Vice versa, if replacement of components results in excessive (extra) cost to ensure that the complete system complies with 1253/2014, this is not in the spirit of the ecodesign legislation and can therefore not be seen as reasonable. In these cases one-for-one replacement is seen as a real option. This can be based on a standard Life Cycle Cost (LCC) calculation that is linked to the environmental legislation and states that simple repayment times of five years maximum are seen as reasonable and can therefore require compliance (personal view of the author). 7; The Blue Guide on the implementation of EU product rules 2014, European Commission.

10 10 I Eurovent versus Ecodesign It is notable that in the FAQ all low-energy requirements become invalid, if an air handling unit is not listed as a BVU (with heat recovery) in the sense of regulation 1253/2014. Recirculation units for data centres, for example, are still covered by requirements for SFP int. Eurovent energy labels Since 2009 Eurovent has awarded energy labels to air handling units. The energy class is calculated using quite complex but generally accepted formulas. This energy class is based on the average air velocity in the unit (v class ), the heat recovery performance versus the absorbed electrical energy (η t-class ) and the pressure drops across the heat recovery section in the AHU (Δp class ). In addition to the ecodesign method the calculation includes a weighting factor that is related to the outside wither design temperature. The thought behind this is that heat recovery results in more energy gains in colder countries and therefore may also have increased pressure drops. The objective is to ensure that a good and controlled comparison between various certified air handling unit selections is possible. Table 1 gives an overview of the various Eurovent energy labels. Contrary to ecodesign requirements Eurovent energy labels also take the outside climate into consideration. In European countries with winter design temperatures of +9 C (e.g. Greece) heat recovery is not included in the energy label. As the winter design temperature decreases further below +9 C heat recovery may lead to increased pressure drops. Label Reference value Label calculations Finale label check Velocity Heat recovery Absorbed power factor V label ŋ t-label ΔP label f label-pref m/s % Pa - A 1, ,9 B 2, ,95 C 2, ,0 D 2, ,06 E No calculations required No requirements Table 1 - Old Eurovent energy labels

11 Eurovent versus Ecodesign I 11 From Table 2 we can deduce that the ecodesign requirements for 2018 are more or less the same as the old Eurovent energy label A. This then in fact became the legally set minimum in Europe, and therefore Eurovent had to re-name special, i.e. extra low-energy air handling units. Therefore from 1 January 2016 other Eurovent energy labels apply. Table 2 gives an overview of the label classification. The legally set minimum for 2018 will be a B-label. To be able to get an A-label the air handling unit must therefore use even less energy than the legally set minimum. Label Reference Value Label calculations Finale label check Velocity Heat recovery Absorbed power factor V label ŋ t-label ΔP label NGref-label m/s % Pa - A+ 1, A 1, B 1, C 2, D 2, E No calculations required No requirements Table 2 - New Eurovent energy labels The label requirements are such that it can be expected that approximately 1% of all air handling units supplied in Europe will be awarded an A+ label. In the meantime the rules for receiving EIA subsidies have also been adjusted. The energy list refers in article (W) to the new A-label as the minimum for eligibility for energy investment deductions when purchasing new low-energy air handling units. Figure 4 shows the new Eurovent logo that affiliated members will include from this year in their quotations to indicate which energy label applies. 001 ENERGY EFFICIENCY 2016 Report to performance data Figure 4 - New Eurovent energy label 8; Energie Investeringsaftrek (EIA) Energielijst 2016, Rijksdienst voor ondernemend Nederland in opdracht van het ministerie van Economische Zaken.

12 12 I Eurovent versus Ecodesign CE marking IIA or IIB With the introduction of the ecodesign legislation that is linked to the European machine directive (CE marking) Eurovent must also clarify which CE marking applies to air handling units: IIA or IIB? Fully in line with the intention of the machine directive Eurovent now 9 states that an air handling unit even without controller, and taking into account the manufacturer s technical construction file is a machine that can in itself perform its specific application but which only lacks the necessary protective means or safety components. According to Eurovent an air handling unit manufacturer must mark a product that is introduced to the European market with an IIA CE marking and also supply the required technical construction files. The ecodesign legislation prescribes that an air handling unit that does not comply with the ecodesign requirements, cannot be placed on the European market with a full CE declaration, IIA. A composite CE declaration for a complete installation therefore consists of a combination of the IIA declarations for the various components that make up this installation, possibly complemented by a risk assessment of the components that do not have a IIA declaration. This risk assessment must then be ordered by the end user to be carried out by the installer. Ecodesign enforcement Enforcement of the ecodesign legislation is in principle market controlled. The European Commission is however entitled to issue laws that are legally valid throughout the Union, but must leave enforcement of the laws to the separate member states. In the Netherlands the Inspector for Aviation and Transport (Inspectie Luchtvaart en Transport = ILT) is responsible for the control of compliance with the European ecodesign legislation. The ILT may carry out spot checks at the manufacturers on the execution of the finished product and the required information that accompanies it. But market controlled enforcement starts with the manufacturers. 9; Eurovent 6/2-2015, Recommended code of good practise for the interpretation of the Directive 2006/42/EC on machinery concerning air handling units, second edition, published 19 October 2015.

13 Eurovent versus Ecodesign I 13 They must check with their customers to find out in which type of system their products will be installed. Based on this information the manufacturer labels his air handling unit, for non-residential applications, as an UVU or a BVU. Exemptions from regulation 1253/2014 are also labelled as such. If an installation is assembled from components that separately comply with regulation 1253/2014, based on the information available from the manufacturer, but where the typology changes (UVU becomes BVU) because of the final ventilation system type (balanced instead of hybrid), CE marking for these products becomes invalid. The installer then builds an installation that no longer complies with current legislation and may be made responsible for this. In this case compensation for consequential damage/loss may well be possible. The questions manufacturers ask when a quotation for ventilation units is requested must take this into consideration. Using the correct information and well-researched quotations ensures that the manufacturer s customers will not have any problems later. If there are significant differences of opinion relating to the exact and correct interpretation of regulation 1253/2014 between market parties and enforcement authorities, these can be checked by the European Court of Justice. As for all European laws the European Court is the only authority to give a final ruling on the legality and the interpretation of European laws.

14 White Paper EUROVENT versus ECODESIGN Do you have any questions after reading this white paper? Or do you want to know more about Eurovent and ecodesign and what this can mean for you? For more information visit or register for our newsletter via with the subject Register for newsletter, or to receive white papers with the subject Register for white papers. We also keep you informed via our own customer magazine Informair about all developments regarding ecodesign. Here you can also read more about interesting and unique projects and will be kept informed about product and company information. Please register by sending an to with the subject Register for Informair and you will receive our customer magazine twice a year free-of-charge. Systemair B.V. Van Leeuwenhoekstraat 2 Zanddonkweg 7a 3846 CB Harderwijk 5144 NX Waalwijk Tel: 0031 (0) Tel: 0031 (0) The Netherlands The Netherlands