DIGITALEUROPE comments on the Draft Ecodesign Regulation on Electronic Displays
DIGITALEUROPE has strong reservations with the WTO notified draft display regulation, which we have also raised through the better regulation consultation process. Despite providing significant amount of data to the process, our comments have been largely disregarded, and, furthermore, new scope and requirements have been included in the proposal which were not subject to proper consultation or impact assessment. As a consequence, more than half of displays currently available cannot comply with the proposed technical requirements, a matter which will impact consumers significantly and be of high public concern. In this paper we will detail our concerns about scope, definitions, on-mode/standby requirements, resource efficiency and information requirements.
This paper presents a detailed overview of DIGITALEUROPE’s concerns with the draft display regulation. The first section of the paper considers the significant extension in scope compared with the previous regulation. Displays integrated into other products now also fall in scope of resource efficiency requirements and this extends the regulation to cover all kinds of other products including tablet computers, specialized displays, printers, medical equipment and home appliances. One of DIGITALEUROPE’s key concerns is that an impact assessment on this extended scope has not been carried out. The requirements do not make sense for all of the products and there is an assumption that an integrated display can be treated the same as a stand-alone display, which is not always the case. DIGITALEUROPE proposes that all integrated displays are taken out of the scope of the regulation and managed through vertical regulations where required.
The paper then discusses the energy requirements. DIGITALEUROPE is concerned with the on-mode requirements as they can limit industry’s ability to innovate and prevent state-of-the art technologies from being placed on the market. The requirements are also not aligned with global developments, as they will prevent some Energy Star certified models from accessing the European market. The Commission’s analysis is based upon a CLASP (Collaborative Labeling and Appliance Standards Program) paper which in itself is based on incorrect assumptions. The CLASP paper is discussed in Annex 4 of this paper. The impact of the energy requirements is most significant for smaller sized monitors and very large televisions. There is also a concern with timelines which are not aligned with manufacturer design cycles. DIGITALEUROPE proposes a timeline and on-mode requirements in order to deal with some of the issues and proposes exemptions where significant technological advances are not expected or where market share is very small. In addition, the standby limits are considered unrealistic for the considerably larger and broader range of displays which now would suddenly fall into scope of the regulation. Over half of the models placed on the market in 2016 would not meet the proposed standby limit and consequently an adjustment is suggested.
DIGITALEUROPE has also made some comments on power management requirements; allowances/adjustments and software/firmware updates.
The fourth and fifth sections of this paper are concerned with the resource efficiency and information requirements proposed. The requirements also apply to integrated displays which may be complex to manage since it is not always clear what the boundaries of an ‘integrated display’ are and this impacts how requirements may apply (e.g. labelling). The regulation proposes to prohibit gluing and welding. DIGITALEUROPE is keen to ensure that innovation is not hampered and instead proposes that components are removable without the European Commission prescribing how manufacturers do this. Further, it is noted that standards currently under development would help to steer the setting of resource efficiency requirements and ensure that requirements are measurable and enforceable. The regulation also proposes significant information requirements on flame retardants, repair, dismantling and substances. Detailed substance information can be very difficult to source from suppliers and this would present a huge burden without analysis of benefits. It is suggested that certain information requirements are deleted since the environmental benefits are not clear.