Ecodesign requirements for fans – the new regulation – what has changed and how may the regulation evolve in the future?

The revised ecodesign regulation for fans places new requirements on manufacturers, in addition to increased minimum energy efficiency limits and more product information requirements. What are those new requirements, the implications and how may the regulation evolve in future?
Regulation 327/2011 set ecodesign requirements for fans driven by motors with an electric input power between 125 W and 500 kW. Those requirements came into effect in 2013 and set minimum energy efficiency requirements and a necessity to publish specific data on the fan rating plate and in documentation.
The Commission initiated a study in 2014 to revise the regulation with some specific tasks. To assess -
• is a reduction of fan types possible?
• Is a reduction of exemptions possible?
• the adequacy of allowance for dual use fans
• requirements for jet fans (plus impacts)
• the adequacy of market surveillance
• other information relevant for review

After a short period of debate with stakeholders the Commission published a proposed revised draft at a consultation forum in March 2015. In summary the changes were 
• a slight change of the fan types
• an increase in exemptions
• a more pragmatic view of dual-use fans
• new requirements for jet fans
• an increase of minimum energy efficiency requirements
Unfortunately, the draft did not progress through to publication. Several years of debates and arguments followed, but no progress. The review process was re-started in 2022 with a second consultation forum in April 2022. 7 years later the draft had evolved as Europe started to consider the impact of products beyond just their energy consumption. Measures to stimulate better systems and a circular economy had been added.
After a few years of consultation, the revised regulation is now published and sets some very demanding efficiency requirements. There are significant additional activities for manufactures to provide information to improve fan systems and the first small step toward addressing their environmental impact.
The new ecodesign requirements for a Sustainable Product Regulation (ESPR) communicate how the fan ecodesign regulation will evolve in the future. What changes could be expected and how shall the fan industry address those expectations?