According to the specific Ecodesign requirements of Regulation (EU) 1253/2014, Annexes II and II, ventilation units must be equipped with a multi-speed drive or a variable speed-drive (VSD).
EC (electronically commutated) motors are not mentioned specifically as VSDs, but they are drives consisting of a motor and an integrated motor control that are able to vary speed over a wide range, typically by means of an external control signal (0-10 V). The Regulation (EU) 1253/2014 does not specify requirements for external control signals or sensors for VSDs. In this respect, EC motors (including integrated motor control) can be considered VSDs. Please note that for RVUs, demand control requires a device (or devices) that measures a control parameter and uses the result to automatically regulate the flow rate(s).
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.