ERP 2026 Is Here. Am I the Fan Manufacturer Now?
Andrew Jones, Technical Director at Axair Fans, on the one question that actually matters with ERP 2026, and what to do once you've answered it.
If you've read anything about ERP 2026 and come away more confused than when you started, this one's for you. Most articles explain the legislation. This one explains the only question most people are actually asking and need answered: “Who is legally responsible for the fan? Am I the fan manufacturer now, and am I liable for the CE declaration before I place my fan on the market?”
Let’s make it simple to understand the context. When your fan arrived from your supplier, did it come as one complete, ready-built unit? Motor, impeller and casing all assembled and tested as a single product? Like a modular plug fan? Or did you buy some of the parts, a motor and impeller for example, and build the rest of it yourself before it went into the marketplace? Like the fan housing?
COMPLETE FANS
If it arrived complete and you installed it as it came, for example you buy a compliant modular EC plug fan (motor, impeller and stator) and install it into an AHU, you can stop worrying. The compliance responsibility under ERP 2026 sits with whoever built and tested the complete fan, your manufacturing partner, and nothing changes for you because the product data that was declared at the point of CE declaration matches the fan placed in the marketplace.
INCOMPLETE FANS
If you complete the fan assembly yourself after buying some of it from a supplier, say a motor and impeller without the housing, then in many cases you’ll be considered the manufacturer for the purposes of applying the regulation. Not Axair. Not Rosenberg. You. You created a product that will be placed on the market, so you’re responsible for the new product’s performance data and CE declaration. Think about it; the parameters that were tested initially have now changed.
I know that sounds alarming, so let me be clear about what it means, because it's less frightening than it sounds.
NEXT STEPS IF YOU ARE THE MANUFACTURER
If you’re the manufacturer, your responsibilities are straightforward: keep a technical file showing the fan meets the efficiency rules, and issue and sign a Declaration of Conformity, that part can't come from us or the manufacturer. It has to come from whoever finished the build. So, the honest, practical question to ask yourself today is simply, do I have a Declaration of Conformity for this fan, signed by me or my business? If yes, you're in good shape. If you're not sure, or the answer's no, that's not a crisis, it's just something worth sorting out before it becomes one.
And that's exactly where we come in. We've created a dedicated ERP resource online featuring a short set of questions that takes you through your setup quickly and gives you a straight answer on whether you're the manufacturer. But honestly, the fastest route for most people is just talking to us directly. We’ve built our reputation on technical support over the last 35 years, so we know what we’re doing.
If any of this applies to you, here's what I'd suggest. Call our technical team on 01782 349 430, or email [email protected], and ask for an ERP audit of your current fan set, even if it’s not from us. We'll either tell you straightaway that you're fine, or we'll book in a proper meeting and help you with as much as you need.
That's not us requesting a sales call and there's no charge for the conversation. It's the part of this job we're really good at, sitting down with a customer, working through the detail, and telling them straight where they stand.
ERP 2026 doesn't ask whether you've read the legislation. It asks whether you're the manufacturer. It's time to get that bit cleared up.