How should one deal with units combining a variety of functions that may be regulated by differing Ecodesign Regulations?

For NRVUs, a distinction is made between ventilation components and additional non-ventilation components. Additional non-ventilation components can include heating or cooling coils that are not part of the reference configuration, and are therefore corrected for in the calculation of SFPint. Ventilation components for a BVU include an HRS, among others. If this is combined with a heat pump for heat recovery, the BVU does not fall under Regulation (EU)1253/2014.

However, if an air-to-water heat pump uses exhaust air from the ventilation unit by using a coil (which can be considered an additional non-ventilation component not affecting heat recovery), the ventilation unit falls under Regulation (EU)1253/2014. The air-to-water heat pump must comply with the relevant Ecodesign Regulation.

With regard to RVUs, BVUs equipped with a heat pump for heat recovery only (the same as 'heat transfer being additional to heat recovery') do not fall under Regulation (EU)1253/2014.

RVU multifunctional products/systems, such as UVUs including exhaust air-to-water heat pumps, do not fall under Regulation (EU) 1253/2014 as long as the component(s) that constitute a ventilation unit are integrated into the rest of the system and are not commercialised/delivered separately. For example, if the ventilation unit is delivered separately (able to operate) and it is the responsibility of the end user to (potentially) integrate it with the heat pump, this ventilation unit will be compliant with Regulation (EU) 1253/2014. 17 The unit’s main function may be heating or cooling (or water heater function). If this is the case, the product must fulfil other relevant Ecodesign Regulations.

_{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.}