If the product is not designed for replacing utilised air with outdoor air, it is not a ventilation unit, unless the same product is also designed to replace only utilised air. In this case, it must comply with all relevant requirements of the Ecodesign measure (bearing in mind any exclusion from the scope of the Regulation itself).
In the case that the product has an outdoor connection with a supply/exhaust air flowrate in regular operation of a minimum of 10% of the total declared recirculated air flowrate, the unit is considered a ventilation unit and falls under Regulation (EU)1253/2014.
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.