BCAS 2018

20 www.bcas.org.uk Working to keep legislation real BCAS reports on the on-going work from one of the organisations it works closely with, Pneurop. P neurop members are national associations representing more than 200 manufacturers in 8 EU Member States, in Switzerland and in Turkey. Speaking on behalf of its members in European and international forums regarding the harmonisation of technical, normative and legislative developments. This relationship will have continued importance as we work through the Brexit debate – seeking to ensure the many years of globally harmonised standards are well understood and maintained has to be an important focus for us all. Machinery Directive (MD) The European Commission and its consultant in charge of the study on the review of the Machinery Directive are currently consolidating the responses of stakeholders to the public consultation. The study’s final report was expected to be published by mid-2017. However, the Commission’s impact assessment process will not start before the end of 2017. The surveillance problem is common to most countries, enforcing the directive and removing non-compliant equipment from the market. Outdoor Noise Directive (OND) The review of the Outdoor Noise Directive has been on hold for a few months. The European Commission recently launched the impact assessment study w. It aims to assess possible changes in the OND such as stricter noise limits and removal of third party certification, noise labelling and data collection. The Commission legislative proposal to review the OND is foreseen in 2019 at the earliest. RoHS2 Directive The European Commission tabled its legislative proposal to revise the scope of the RoHS2 Directive on 26 January 2017. This review tackles a series of problems that cannot be solved by exemptions and guidance. The proposed amendments are in line with the previous draft and are very positive for the industry: they remove obstacles to the repair of EEE and withdraw the ban on secondary market operations. As a next step, this RoHS review proposal will be discussed in the European Parliament and the Council. Energy Efficiency Energy Labelling Directive Negotiations between the European Parliament and the Council on the proposed new EU Energy Label Regulation are still ongoing. Although negotiators agreed on the rescaling mechanism and timeframe, there are still a few sticking points. Ecodesign Directive The European Commission started implementing the new principles set in the Ecodesign Working Plan 2016-2019: they notably tabled Ecodesign requirements to implement the circular economy policy in the draft Ecodesign measure on electronic displays. Although this is specific to a product group, it can be seen as a precedent for upcoming implementing measures. For example, the draft measure requires a specific technique to facilitating dismantling, re-use, recycling and recovery. It also sets information requirements for repair purposes and relevant information for dismantling, re-use, recycling and recovery at the equipment’s end-of-life. Ecodesign Directive - Update on Lots / implementing measures Compressors, ENER Lot 31: The draft final report on low pressure and oil-free compressor packages has been published on the dedicated study website. The report concluded that energy savings due to Ecodesign requirements are very low, applying heat recovery offers a bigger saving potential. Pneurop produced a paper 30 march 2017 showing calculations for heat recovery and summarised the potential limitations of the energy savings achievable. ● Risk of condensation ● Losses in heat recovery - heat exchangers etc create additional pressure losses that increase the energy consumption of the compressor package. ● In sensitive applications (e.g. food, medical) each additional component increases the risk of contamination. ● Transforming low grade heat into useful heat w=not in the immediate proximity requires additional equipment which makes the return smaller and the investment larger. ● Compressors are sometimes placed near the process they supply with compressed air. Recovering heat from many small machines distributed in the system or in remote locations entails complicated setups for minimal returns. Revision of the Regulation on fluorinated gases (F-gas Regulation) As regards national codes & standards relevant to alternative refrigerants, the Commission intends to request that the European standardisation organisations support updating relevant standards, ensuring a technology-neutral and consistent approach. It will also ask for a technical report to be delivered on the issue of ensuring a wider but safe use of flammable refrigerants. The European Environment Agency has published a report showing that the production, import and export of fluorinated gases fell in the European Union in 2015. Larger reductions are expected in the coming years as a result of the phase-down scheme. Pneurop