From: Stefano Vit [ mailto:stefano.vit@delonghigroup.com ]

Sent: Tuesday, October 21, 2014 11:47 AM To: Sheppard, Margaret Cc: Hall-Jordan, Luke; Newberg, Cindy Subject: De Longhi: feedback meeting 26th September
Dear Ms. Scheppard, I thank again you and your department for the avail ability to meet on the 26th September for discussing about natural refrigerants. It has been a really interesting meeting for me. I write you for providing the additional informatio n request by you during the meeting. Please find hereafter these information. Recently a new proposal restricting the usage of fl ammable refrigerants for UL 484 has been circulated for comment. As you can image we are opp osing to this proposal. I hope you will find useful the additional informat ion reported hereafter in order to support the approach currently present in IEC, EN and UL standa rd for flammables. I'm at your disposal for any further information yo u may need on this issue.

Thanks in advance
Best regards

Stefano Vit

Complementary note to file “Dispersion_test_effect_ ventilation_and_leak_time.pdf”:
Some considerations are reported hereafter in order to underline that test assumptions are referring to a worst case scenario compared to the one considered into IEC 60335-2-40 Ed. 5. More in detail:

- according to IEC 60335-2-40 Ed.5 for propane max ch arge is 300 gr (linear formula for nonfixed hermetically sealed systems). In the test up to 325 gr where released (93% of total charge 345 gr) which is a more severe scenario that the on e allowed by the standard. This is even more true when considering that in cas e of leak (especially drastic) not all the charge is release to the room. The amount of re frigerant left within the system could be estimated to be close to 20% while in the test i s was considered to be just 7%.

- drastic release time in the test is 3 minutes while in the standard is 4 minutes.

- fan was stopping after 3 minutes while according to the standard it has to be continuously running. A continuous running fan provide a more homogenous mixture.
The previous considerations are provided with the p urpose of underlying the over-cautions taken in the approach taken into the IEC and EN standard when considering natural refrigerants.Propane Efficiency

Propane has the advantage to enhance efficiency (ar ound 10%) and provide a limited environmental impact. This can be duly represented when evaluating the TEWI impact of a product equipped with propane. It has to be noted t hat the charge with propane is around 60% of the charge with R410A.
In Europe F-gas regulation have been recently appro ved after a revision (No. 517/2014) requiring moveable air conditioning products to be equipped with refrigerant with GWP ≤ 150 from 1 January 2020

. This requirements is a consequence of an assessment on the benefit associated to the use of propane where both direct and indirect impact of a refrigerant circuit are minimized.
A TEWI analysis has been conducted during the devel opment of the Labelling and Ecodesign regulations in Europe. The results in relation to S ingle Duct air conditioners are proposed hereafter:
From Figure 6-25 it is possible to evince the effic iency and low environmental impact of propane compared to R410A.

De Longhi Dehumidifier with R290 for Japanese marke t.

With reference to the dehumidifier with R290 for Ja panese market please find attached the copy of the S-JET certificate and the test report which is in accordance with the METI Standard. The product was sold 5-6 years ago.
In the test report you will find same translations in English that are necessary because the whole report is written in Japanese.
The product was developed according to the IEC 6033 5-2-40 before to start the approval procedure in Japan which has not implied any change on the product.Attached files:

S-JET_Certificate_DE250ECO_Delonghi_R290_(S06-Y0557 ).pdf
Test_Report_DE250ECO_DeLonghi_R290 (2007-06-25).pdf