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24 March 2022


EUnited Cleaning comments on the review of the fans regulation and the proposal by the Commission to introduce a new formula for vacuum cleaners



The European Commission expert group “Ecodesign and Energy Labelling Consultation Forum (EELCF),” undertaken by DG ENER Unit B.3, will hold their next meetings on 31 March 2022 and on 1 April 2022 to review regulations on vacuum cleaners and industrial fans respectively.  Ahead of these meetings, EUnited Cleaning has published a draft position paper where we outline our concerns in relation to regulations on these specific products. EUnited Cleaning will represent the interests of our members during these meetings.

 

Ecodesign requirements on fans

Firstly, concerning the review of regulation 327/2011: Ecodesign requirements fans, the paper points out that the majority of cleaning machines are already state of the art and additional requirements would not necessarily result in more efficient machines. A requirement to change components may in fact result in downgraded machine performance. Using examples of previous consultation forums, the paper describes how it is difficult to cover high-pressure cleaners under the current regulation due to factors such as the size, weight, efficiency, and cost for the customer of these machines (all of which would increase significantly were high-pressure cleaners to fall under the scope of the current regulation).

 

The paper identifies a solution whereby these machines could be classified as out of the scope of the regulation in general as a consequence of their mobile characteristic and the unfavourable ratio of efficiency vs mobility and reduction of functionality. The paper also recommends reinstating in the regulation references to fans in hand-guided mobile equipment, particularly spare part fans which are designed for special purposes and to be integrated into end products. Furthermore, the paper stresses the importance of consistency regarding the regulation’s scope and exclusions concerning hand-held and hand-guided mobile equipment.

 

Proposal for a new formula for vacuum cleaners

EUnited Cleaning provides several comments from the cleaning industry on the Commission’s proposal to the new formula for vacuum cleaners. These comments can be summarized as follows:

 

The needs of the users of household and commercial vacuum cleaners are different. Therefore, we advocate taking these differences into account and developing a separate label for commercial vacuum cleaners. In this development, we should draw on the work of the international and European working groups that have dealt specifically with this issue.

 

An exclusive consideration of energy consumption falls short with regard to the needs of users. In addition to the energy consumption, for commercial users the introduction of a productivity/speed index (which is also included in the annual energy consumption calculation) adds considerable value for the customer and user. It creates comparability in the actual core competence of the vacuum cleaner in cleaning. The time to clean the area must be corrected with a cleaning efficiency factor as an effective vacuum cleaner conducts the task a lot faster and uses far less energy.

 

For questions and comments, please contact Dr. Frederik King (Frederik.king@eu-nited.net).

 


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