An air-handling unit without recirculation with heating and cooling coils is not considered a fan coil unit.
An air-handling unit with 100% recirculation is considered a fan coil unit if it has no or minimal ductwork. In accordance with the guidelines accompanying Regulation (EU) 1254/2014 and 1253/2014, when the product has an outdoor connection with supply air/exhaust air flowrate at nominal operation point of at least 10%, it is not a fan coil unit but a ventilation unit.
These units are covered by Regulation (EU) 1253/2014; when the air flow rate is lower than 10% it is a fan coil unit covered by Regulation (EU) 2016/2281.
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.
No. If the minimum requirements for an application are not met, the chiller cannot be used for that application and the manufacturer cannot market the product as such.
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.
The main difference between an air heating product and a local space heater is the location of the heat generator.
Local space heaters fall under the scope of Regulation (EU)2015/1188. The heat generator of a local space heater is situated in the space that is heated, see Art.2(1) of Regulation (EU) 2015/1188.
Excluded from the scope of Regulation (EU)2015/1188 are air heating products. According to that regulation, an air heating product’s heat generator delivers its heat via an air based heating system. Here, it is the air based heating system that is at least partly situated in 12 the space that is heated, see Art.2(23) of Regulation (EU)2015/1188. As an example, when the air based heating system is a duct with a fan, this duct will supply the heated air from the heat generator (not situated in the space that is heated) to the space that is heated.
An additional specification is that to be excluded from the scope of Regulation (EU)2015/1188, air heating products need to be fastened or secured in a specific location or wall mounted.
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.
A single package means an assembly constituting a unique functional unit that is provided by one manufacturer with one single commercial reference. However, this assembly can be provided on one or two separate frames.
The following categories of roof-top units may exist:
- A unit mounted on a single frame that can be installed either outdoors (on the roof of the building or aside the building) or indoors. In the latter case, the unit is ducted on air side outdoors and/or indoors.
- A unit the components of which are mounted on two separate frames, and connected with refrigerant lines, constituting a single package installed as a unique product. The two parts are generally installed indoors at two different locations in the building, with or without air ducts.
The choice of configuration, i.e. one or frames, will depend on the constraints on the integration of the unit into the building for the required application.
The technical design and the individual components of the two types of units are identical and therefore both types are covered by the definition of rooftop air conditioner and/or rooftop heat pump.
A system only available in two or more structures (structures) such as a single split or a multi-split air conditioner or heat pump is not a rooftop air conditioner or heat pump.
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.
No. The definition of an air heating products and a cooling product does not exclude these products.
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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.
Depending on the intended use of the heat pump and on how it is marketed they are either in scope or they are out of scope.
When the intended use of the heat pump is space heating for the thermal comfort of human beings or when the heat pump is marketed as such, it is in scope of the regulation. Otherwise, it is not.
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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.
Yes. These products are in scope of the regulation and fall under the definition of a rooftop heat pump.
When sold as a single package, the efficiency value should reflect the product's efficiency, including the fossil fuel heater. In the absence of a calculation methodology for heat pumps integrating a fossil fuel supplementary heater, and in analogy with the manufacturer's guide for space and water heaters, suppliers can use the same methodology as laid down in EN 14825 for electrical supplementary heaters by replacing performances of electrical supplementary heater with the performances of fossil fuel supplementary heater.
The supplementary heater of a heat pump needs to be taken into account when measuring and calculating the rated heating capacity, seasonal space heating energy efficiency, sound power level and emissions of nitrogen oxides.
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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.
Yes. According to Art. 2(1), an air heating product can be equipped with one or more heat generators. Therefore, when warm air heaters are sold as a single package with the rooftop heat pump, they are in the scope and the reasoning in question 4 applies.
When warm air heaters are not sold as a single package and when the intended use of its air based heating system is space heating for the thermal comfort of human beings or when it is marketed as such, they are in scope of the regulation.
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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.
Yes. One of the intended uses of these appliances is space cooling and or space heating for the thermal comfort of human beings as such it is in scope of the regulation.
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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.
Yes. They have to comply with information and nitrogen oxide emissions requirements in case they are driven by combustion engines. The part load conditions for these heat pumps will be included in the EN14825:2017.
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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.
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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.
If the air-handling unit is marketed or intended to be used as a space heater for the comfort of human beings, it is an air heating product according to the regulation.
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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.
If the product is intended to be used/marketed solely to operate as a comfort chiller, it is in the scope of Regulation (EU) 2016/2281.
If the product is intended to be used/marketed solely to operate as a high temperature process chiller, it is not in scope of Regulation (EU) 2016/2281 (exempted by Art 1.2(l).
If the product is intended to be used/marketed for dual use i.e. either comfort chilling or high temperature process chilling, it is still a comfort chiller according to Regulation (EU) 2016/2281 and therefore in scope for the requirements related to comfort chillers.
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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.
It is recommended to declare the design capacity whenever the seasonal space heating efficiency for heating is declared. Only in this way, the end-user and the installer are informed about the design load used to calculate the seasonal space heating efficiency.
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.
Yes, the pump should be included in the SEPR value of process chillers even if the process chiller is placed on the market without a pump.
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