IP rating is a separate matter.The current downlights haven't the correct IP rating and the fan is not 12v, (the fan and 2 lights are very definitely in zone 1) the plan is to swap out for ones that are ... I was advised that this constituted added "new work"
Fans do not have to be 12V - 230V is fine as long as suitable for the location.
Replacement of appliances is not new work.