U.S. Regulations for Air-Circulating Fans

Date: 2024-05-10 10:06:00

By: Christian Taber, BEMP, HBDP, CEM, Big Ass Fans

This article appeared in the 2023 edition of AMCA inmotion magazine.

The U.S. Department of Energy in 2022 and 2023 published final rules updating the federal test procedure for ceiling fans and establishing a new federal test procedure for air-circulating fans that are not ceiling fans. 

This article untangles the DOE and AMCA International test procedures, describes what is new in ANSI/AMCA Standard 230, and provides guidance on distinguishing compliant fans from noncompliant ones with respect to federal regulations.

What Is an Air-Circulating Fan?

According to ANSI/AMCA Standard 230, an air-circulating fan is “a fan that [1] has no provision for connection to ducting or separation of the fan inlet from its outlet using a pressure boundary, [2] operates against zero external static pressure loss and [3] is not a jet fan.”

Credit: Big Ass Fans

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Figure 1: shows the scope of the federal ceiling-fan regulations. A detailed definition of each product class can be found in Code of Federal Regulations (CFR) Title 10, Energy; Chapter II, Department of Energy; Subchapter D, Energy Conservation; Part 430, Energy Conservation Program for Consumer Products; Subpart B, Test Procedures; Appendix U, Uniform Test Method for Measuring the Energy Consumption of Ceiling Fans (10 CFR Part 430 Subpart B).⁵

For air-circulating fans that are not ceiling fans, the scope of coverage includes air-circulating axial panel fans, box fans, cylindrical air-circulating fans, housed air-circulating fan heads, and unhoused air-circulating fan heads (Figure 2). Only fans with input power equal to or greater than 125 W at maximum speed are included in the scope. A detailed definition of each product class can be found in CFR Title 10; Chapter II; Subchapter D; Part 431, Energy Efficiency Program for Certain Commercial and Industrial Equipment; Subpart J, Fans and Blowers (10 CFR Part 431 Subpart J).⁶

Federal Test Standards

There has been a mandatory test procedure for ceiling fans in the United States since January 2017. For small-diameter (7 ft [2.1 m] or less) ceiling fans, performance testing is based on a modified version of “ENERGY STAR^® Laboratory Guidance Manual: Building a Testing Facility and Performing the Solid State Test Method for ENERGY STAR Qualification of Ceiling Fans”⁷; for large-diameter (greater than 7 ft [2.1 m]) ceiling fans (LDCF), performance testing is based on ANSI/AMCA Standard 230-15. During the recent rulemaking, minor modifications were made to both. Most notably, for LDCF, measured electrical input power is converted to standard air density. This conversion generally causes a slight increase (roughly 3 percent) in published electrical input power. No changes were made to the efficiency metrics, while the minimum number of samples that must be tested remains two per basic model.

When it begins regulating a product, the DOE typically adopts an industry standard, which it may modify, for the test procedure. For air-circulating fans that are not ceiling fans, the DOE adopted ANSI/AMCA Standard 230-23. The DOE’s modifications to ANSI/AMCA Standard 230-23 include specification of test frequency, phase, voltages, and test-stability criteria. The efficiency metric for air-circulating fans is air-circulating-fan efficacy (Eff_circ) in cubic feet per minute (cfm) per watt (W) (cfm/W) at maximum speed. A minimum of two fans per basic model must be tested to determine product performance data.

Figure 1: Scope of the federal ceiling fan regulations.

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Figure 2: Various air circulating fans that are not ceiling fans.

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Once a DOE test procedure is in place, the DOE typically provides manufacturers 180 days to update published performance data to the latest test standard. The DOE requires manufacturers to make any representations of energy use or efficiency in accordance with the results of testing pursuant to the federal test procedure. Under certain circumstances, the DOE may provide an extension—typically, an additional 180 days—for manufacturers to meet this deadline.

Energy-Conservation Standards

The DOE test procedures provide a uniform method of rating the performance of ceiling and other air-circulating fans, including establishing an efficiency metric. For ceiling fans, rated performance must exceed the minimum efficiency level set forth in the energy-conservation standard. For example, ceiling-fan energy index (CFEI) is used for LDCF. CFEI is calculated at maximum speed (CFEI₁₀₀) and “40 percent or the nearest speed that is not less than 40 percent speed” (CFEI₄₀). A LDCF must meet or exceed the minimum efficiency levels in CFR Title 10; Chapter II; Subchapter D; Part 430; Subpart C, Energy and Water Conservation Standards; Section 430.32, Energy and Water Conservation Standards and Their Compliance Dates (10 CFR 430.32)⁸, to be legally offered for sale in the United States.

At the time of this writing, the DOE is revising the minimum efficiency levels for ceiling fans and has yet to propose minimum efficiency levels for air-circulating fans that are not ceiling fans. It is anticipated that, in late 2023 or early 2024, the DOE will publish a final rule for an energy-conservation standard for ceiling fans and a notice of proposed rulemaking (NOPR) for an energy-conservation standard for air-circulating fans that are not ceiling fans.

Identifying Compliant Products

According to CFR Title 10; Chapter II; Subchapter D; Part 429, Certification, Compliance, and Enforcement for Consumer Products and Commercial and Industrial Equipment; Subpart B, Certification; Section 429.12, General Requirements Applicable to Certification Reports (10 CFR 429.12)⁹, “Each manufacturer, before distributing in commerce any basic model of a covered product or covered equipment subject to an applicable energy conservation standard … shall submit a certification report to DOE certifying that each basic model meets the applicable energy conservation standard(s).” Manufacturers submit certification reports through the DOE’s Compliance Certification Management System (CCMS). The public can view data from certification reports using the DOE’s Compliance Certification Database (CCD). The CCMS and the CCD provide simple means of verifying published performance. For products also regulated by the state of California, the Modernized Appliance Efficiency Database System (MAEDbS) is another means of verification. Typically, there is a short delay between the submission of a certification report for a ceiling-fan model and posting on the CCMS or MAEDbS. Air-circulating fan heads will not appear in the CCMS until an energy-conservation standard is established.

Third-Party Certification

Purchasers and specifiers who are in unregulated markets, are purchasing products that are not fully regulated, or are unwilling to comb through thousands of products in a federal database have to rely on other means to evaluate published performance data. One quick and easy option is third-party certification. Programs such as AMCA International’s Certified Ratings Program (CRP) assure that air-circulating fans have been tested and rated in conformance with AMCA International test standards and rating requirements. In the United States, this includes testing and rating to the federal test procedure.

Identifying Non-Compliant Data

Tables 1 and 2 provide rule-of-thumb performance for LDCF and unhoused air-circulating fan heads, respectively. The two tables, along with the fan laws or equations from ANSI/AMCA Standard 230 and ANSI/AMCA Standard 214-21, Test Procedure for Calculating Fan Energy Index (FEI) for Commercial and Industrial Fans and Blowers, can be used to evaluate the likelihood of published performance data being realistic. 

With air-circulating fans, fan designers can reduce losses or increase output airflow for a given input power through more efficient variable-frequency drives, better gearboxes/belts or direct-drive motors, higher-efficiency motors, and increased blade efficiency. Of course, these increases in efficiency must be balanced with the added first cost to the consumer.

Though not to be considered absolutely accurate, the data in tables 1 and 2 can be used to intelligently evaluate published performance data. Take, for example, a cut sheet for a 24-ft (7.3 m) LDCF with a published maximum airflow of 365,000 cfm (10,336 cmm) and an input power of 1.75 kW. The rule of thumb in Table 1 is 243,000 cfm (6,881 cmm) for 1.75 kW for a fan of that size. The ratio of the published airflow to the rule of thumb is 1.5 times, and the published power is equal to the rule of thumb. Per the fan laws, increasing the rule-of-thumb airflow by 1.5 times would require an input power of approximately 6 kW, so the published input power is 30 percent of the calculated input power required. From the standpoint of wire-to-air efficiency, even if the drive, motor, and blades had efficiencies of 99 percent, a 24-ft (7.3 m) LDCF with 1.75 kW of input power could not provide the published airflow. Therefore, the published performance is highly unlikely to be accurate.

Table 1: Large diameter ceiling fan performance.

Table 2: ANSI/AMCA Standard 230 calculations.