09 Dec 2014

DIGITALEUROPE response to draft display regulations

DIGITALEUROPE response to draft display regulations

DIGITALEUROPE welcomes the opportunity to comment the draft display regulations. The paper is divided into a section highlighting industry’s major concerns and an annex with detailed comments and supporting argumentation on the Ecodesign and Energy label regulations for displays. This paper makes suggestions on how the objectives could be achieved differently. Our major concerns are:

1. Importance of maintaining the current Energy Label logic

2. Scope extension beyond the EU consumer display market

3. Unrealistic ambition levels for on-mode requirements

4. Micro-management through regulation

5. Inappropriate End-of-life requirements

6. Unrealistic transition period for computer display products

The draft regulation which endeavors to combine different technologies under one electronic display regulation succeeds in creating a number of technical challenges that restrict technology developments and places an unacceptable compliance burden on computer display manufactures for products currently on the market.

In particular manufactures would highlight the following technical requirements as unrealistic or inappropriate and recommends an alternative proposal in the Annex:

• Align definition for enhanced performance displays with ENERGY STAR 6.0 for Displays

• Remove Auto Power Down for computer displays to avoid poor customer experience

• Exempt Integrated Computer Desktops from ErP Lot 5 as they are already covered in ErP Lot 3.

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