Position on EuP Lot26 Task 1-3 reports

19 April 2010

This paper represents DIGITALEUROPE’s position regarding the Task1-3 reports from the EuPs preparatory study on Networked standby (DG ENER Lot 26).

In these 3 reports, the contractors present a massive amount of information and a proposed definition framework. DIGITALEUROPE concludes from the Task 1 report that the products which have any kind of network standby function are for all covered by energy efficiency related regulations such as implementing measures under the Eco-design Directives or voluntary industry agreements. Further these products are seen to use a wide variety of network functions related to the specific product properties.

DIGITALEUROPE therefore proposes to strive for incorporation of eventual regulatory requirements in the existing product specific regulations and voluntary industry agreements.

Further DIGITALEUROPE proposes to revise the definitions framework of network standby in order to more precisely understand which functions are actually present in the network standby state: it is proposed to distinguish 3 different types of network standby.

Apart from these overarching proposals, DIGITALEUROPE listed a large number of detailed comments regarding numerous parts of the draft reports. These comments are focused on clarification and correct representation of the findings of the study.

DIGITALEUROPE proposes to discuss the positions and comments during a meeting with the contractors.