Stringent Standby Requirements on the Way for Networked Electrical and Electronic Household Products
With Tier 3 networked standby ecodesign requirements commencing in 2019, industry actors are appealing for the adoption of tighter energy consumption requirements in the near future.
The EU Commission has been reiterating its commitment to developing a Circular Economy with increasing frequency, and has stressed that the circular model needs action on a number of regulatory fronts, including ecodesign.
In its Ecodesign Working Plan the Commission set out its ecodesign and energy labeling working priorities for 2016-2019, and emphasized that its intent was to contribute to the Circular Economy initiative, promoting a transition towards a more circular economy in the EU through a series of measures covering the whole life cycle of products and materials.
One particular ecodesign initiative, the energy consumption of electrical and electronic household and office equipment in low power modes, commonly known as the ‘standby regulation’, is gaining particular attention in recent times, a phenomenon which is undoubtedly linked to the new wave of household connected products and smart devices.
Whilst debates abound in particular on the efficiency and application of the product liability directive in this new digital context, legislative change is also being called for in view of eco risks associated with the increasing interconnectedness of household products and the growing use of networked household appliances in the place of traditional devices. Networked equipment, whilst yielding numerous benefits to the consumer, does contribute significantly to energy waste, and such equipment is a draw on energy even when not in use.
The Standby Regulation is a horizontal measure and as such impacts a vast number of products sold and used within the EU. The Regulation is currently under review, albeit a delayed one. The slow progress by the Commission is, according to some, regrettable. The Regulation was amended in 2013 to address concerns surrounding networked appliance energy use, and the 2019 deadline is approaching. There is however a view evolving that requirements need to be more stringent still, and, in line with Circular Economy principles, that material efficiency issues such as durability and recyclability also ought to be tackled. These changes are eagerly awaited. The threat of further delay will ultimately result in the cost being borne by the consumer and the environment.
As matters stand, energy consumption requirements are different for equipment in non-networked and networked standby, with the networked equipment subject to a more stringent requirement. Consumption requirements for off mode power is the same.
Networked standby mode
Under Point 4 of Annex II, at present the power consumption of HiNA equipment or equipment with HiNA functionality, in a condition providing networked standby into which the equipment is switched by the power management function, or a similar function, shall not exceed 8,00 W.
The power consumption of other networked equipment in a condition providing networked standby into which the equipment is switched by the power management function, or a similar function, shall not exceed 3,00 W.
Under Point 5, from 1 January 2019 the power consumption of networked equipment in a condition providing networked standby into which the equipment is switched by the power management function, or a similar function, shall not exceed 2,00 W.
The power consumption of equipment in any condition providing only a reactivation function, or providing only a reactivation function and a mere indication of enabled reactivation function, shall not exceed 0,50 W. The power consumption of equipment in any condition providing only information or status display, or providing only a combination of reactivation function and information or status display shall not exceed 1,00 W.
Power consumption of equipment in any off-mode condition shall not exceed 0,50 W.
The Commission consulted on its Inception Impact Assessment in January 2018, examining possible solutions to account for technological progress and to implement a further decrease in power losses in off mode. Critically, the Commission is now assessing the appropriateness and level of requirements for networked standby with regard to the third stage of implementation (which will start in 2019 under the existing regulation).
It is clear that the Commission unequivocally favours a full ecodesign regulation update and the provision of more stringent minimum efficiency requirements, as well as the inclusion of products not previously covered under the regulation.
An open consultation is ongoing, and later in 2018 draft measures will be subject to a 4-week feedback period.
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