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.