AFEC publishes briefing note on eco-design requirements for stand-alone and rooftop equipment

AFEC Publishes an Informative Note on Ecodesign Requirements for Autonomous and Rooftop Units

 

AFEC (Association of Air Conditioning Equipment Manufacturers) recently published an informative note on compliance with Regulation (EU) 2016/2281, concerning ecodesign requirements for Air Heating Products, Cooling Products, High-Temperature Process Chillers, and Fan Coil Units.

The purpose of this note is to remind that air conditioning units covered by the Regulation must comply with established requirements, including:

• Minimum Seasonal Energy Efficiency values for Space Heating of Air Heating Products and Space Cooling of Cooling Products.
• Product Information Requirements, with various tables outlining parameters that manufacturers must provide.

KEY POINTS ABOUT AUTONOMOUS AND ROOFTOP UNITS HIGHLIGHTED BY AFEC

• Autonomous and Rooftop units for thermal comfort fall under the scope of the 2016/2281 Ecodesign Regulation, regardless of any optional features included (mixing boxes, outdoor air intakes, free cooling, heat recovery systems, etc.). Therefore, units providing comfort heating and/or cooling, even with added functions like free cooling or heat recovery, must meet the Regulation’s requirements. This means there are no exceptions for these units, even with added features.

 

• Autonomous and Rooftop units have specific characteristics that define them, clearly differentiating them from split, VRF units, etc., meaning the latter cannot be equated to the former, except where split system parts are identical to those in compact versions.

 

• Instruction manuals for installers and end-users, as well as publicly accessible web pages of manufacturers, authorized representatives, and importers, must contain all information about the respective units as outlined in the Ecodesign Regulation.

 

• Regarding CE marking, Article 5 of the Directive 2009/125 on establishing ecodesign requirements for energy-related products states that the CE Declaration of Conformity should refer to appropriate implementation measures. Therefore, it is not sufficient to declare compliance with the Directive; relevant implementation measures must also be mentioned. In other words, the Declaration of Conformity for Autonomous and Rooftop units must state compliance with Regulation 2016/2281.

 

• Autonomous and Rooftop units intended for industrial applications are outside the scope of Regulation 2016/2281 and thus do not need to meet its requirements. Consequently, units not meeting these requirements cannot be installed for human thermal comfort. For this reason, documentation for industrial application units should clearly state that their intended use is solely for industrial applications, and not permitted for human thermal comfort. This information prevents installation in spaces intended for human comfort due to lack of awareness.

 

• All units within the scope of this Ecodesign Regulation or any other regulation derived from the aforementioned Directive 2009/125 must comply with applicable requirements, regardless of their intended sale, rental, leasing, or gifting. This is based on the following definition from the Directive:
  • Market placement: the first commercialization of a product within the EU market for distribution or use within the Community, whether for payment or free of charge, and regardless of the sales technique used.
  • The “Blue Guide” on the application of EU product rules also states:
    • A product is marketed when provided for distribution, consumption, or use within the EU market during a commercial activity, whether paid or free.
    • Transfer may occur for payment or free and can be based on any legal instrument. Therefore, transfer includes sales, loans, rentals, leasing, or gifting.
    • Market surveillance can be exercised in various locations, such as importers, wholesale or retail distributors, rental companies, users, etc.

• Rental units within the scope of this Regulation remain subject to it regardless of installation location, such as air conditioning tents or similar installations.
  • NOTE: Repeated leasing of the same product does not constitute a new market placement. The product must meet the applicable EU harmonization legislation requirements at the time of its first rental.

AFEC emphasizes the need for all manufacturers to strictly comply with regulatory obligations to ensure a fair and balanced market.

Access the full Informative Note by clicking here.