Annex I, 2 if the Regulation list the 'Product Information Requirements'. The last two paragraphs of Annex 1, 2 refer to the manufacturer of circulators.
[…]
'Manufacturers shall provide information on how to install, use and maintain the circulator in order to minimise its impact on the environment.'
'The information listed above shall be visibly displayed on freely accessible websites of the circulator manufacturer.'
Who is responsible for this information in case of products with integrated circulators? Is it the manufacturer of the assembled product (e.g. boiler) or the manufacturer of circulators specifically designed to be integrated in products?
Article 1 of Regulation 641/2009 specifies that Ecodesign requirements are set for the placing on the market of the products in scope. According to the Ecodesign Directive, the entity placing the product on the market is responsible for compliance with all Ecodesign requirements, which it certifies through applying the CE-marking. One of the Ecodesign requirements is that the information as presented in Annex I.2.1 is provided; hence, the entity placing the product on the market and applying the CE-mark must ensure compliance with this provision.
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 differentiation can be found in the definitions in the regulations themselves:
Article 2(1) of Regulation 641/2009: ‘circulator’ means an impeller pump which has the rated hydraulic output power of between 1 W and 2 500 W and is designed for use in heating systems or in secondary circuits of cooling distribution systems;
Article 2(1) of Regulation 547/2012: ‘water pump’ is the hydraulic part of a device that moves clean water by physical or mechanical action and is of one of the following designs:
— End suction own bearing (ESOB),
— End suction close coupled (ESCC),
— End suction close coupled inline (ESCCi),
— Vertical multistage (MS-V),
— Submersible multistage (MSS);
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.