Eco-design proposals for computers and monitors could be more ambitious

(08 Oct 09) eceee welcomes the proposed eco-design requirements for computers as well as the proposal for computer displays. Both lack ambition, however, and risk to have very little practical effect on the market. The proposed requirements for computer displays also have an insufficient scope. eceee further suggests that computer displays should be included in the European energy labelling scheme.

eceee’s comments on computer requirements in summary

• eceee supports Energy Star Alignment in general. By applying the regulation early, EU creates room for influencing upcoming Energy Star specifications in the near future.
• The mandatory requirements are thus introduced far too late: Tier II requirements should take effect 31 July 2011 instead of January 2013. projected market penetration rates in the Working Document show that 89 % of the products are expected to meet Tier I requirements when it comes into force in January 2011 and 95 % of the products to meet Tier II requirements when it comes into force in January 2013. This is not cost effective from either a consumer or environmental perspective and will not deliver enough energy savings.
• The Commission may also wish to consider skipping Tier I requirements completely, which would also make the regulation easier to apply since the definition of efficiency differs between Tier I and Tier II.
• The requirements should be revised after three years instead of five years in view of the rapidly improving nature of this industry.
• Chapter 4 proposes to exclude computers from the list of energy-using products in the Regulation (EC) No. 1275/2008 (stand by). The Wake up on Lan (WOL) function belongs to a networked standby requirement. Until implementing measure for networked standby has been prepared, WOL requirement could be included in the eco-design requirements for computers.
• There is a particularly strong energy efficiency benefit by removing computers from the mercury exemption list of the RoHS Directive. Laptops that use light-emitting diodes (LEDs) as backlight instead of cold-cathode fluorescent lamps (CCFL) use no mercury and are more energy efficient. The Commission should work towards removing computers from the list of exemptions before the end of 2011 and require clear information on mercury to consumers.
  
  

Comments on computer requirements in summary

• We support that the proposal is aligned with Energy Star.
• We support the coverage of digital photo frames.
• The proposal to limit the scope to screens of maximum 30 inches is not justified. We propose that the display screen size is aligned with the Energy Star definition to include displays with a viewable diagonal screen size of less than or equal to 60 inches. Requirements for TVs also cover larger screen sizes and displays and TVs should be harmonised in this respect.
• Tier II should be moved forward from October 2012 to January 2012.
• The revision period time is changed from four to three years.
• We propose that the Commission presents a proposal for energy labelling of electronic displays; the proposal should be based on a “progressive efficiency” approach where the energy efficiency index (power/surface area) becomes relatively stricter with larger screen size.
• The Tier I sleep mode shall not exceed 1 W and that the Tier II sleep mode shall not exceed 0,5 W. It has been shown that all displays can easily fulfil the standby and off mode regulation (1275/2008) and it should thus apply.
• Information requirement on mercury content should be clearly available when marketing the product. The information required is the total amount of mercury in the product in mg.
• The Commission should inform the working group revising the RoHS Directive that it is possible technically and economically to remove CCFL (cold cathode fluorescent light sources screens) used in LCD screens from the RoHS exception list, from January 2012, with substantial energy efficiency benefits.

Download eceee’s comments on eco-design requirements for computers. [pdf]
Download eceee’s comments on eco-design requirements for displays. [pdf]
See also eceee’s eco-design pages

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