Joint industry paper on draft display regulation 20170703

AmCham EU, CECED, COCIR, DIGITALEUROPE, EGMF, EHI, EPEE, FEM and TIE wish to reiterate their strong reservations to the proposed Lot 5 draft Ecodesign regulation covering electronic displays and outline procedural as well as substantive concerns shared by many European industries.

1. Art.15.4(b) of the Ecodesign Directive, requires that an implementing measure can only include products that have been subject to prior assessment of the “impact on the environment, consumers and manufacturers, including SMEs, in terms of competitiveness — including in relation to markets outside the Community — innovation, market access and costs and benefits”. This has not been the case for the majority of products now included in the scope of the Lot 5 regulation, e.g. industrial equipment, machinery, medical equipment, smart meters, boilers, printers, laptop computers, heaters, air conditioning equipment, automation and control equipment, and household appliances. Without appropriate consultation and assessment of how the requirements would impact the functionality of products, the European Commission shortcut the process set forth in the Ecodesign Directive and cannot provide substantiation to verify the assumption that products with an integrated display can be subject to the same requirements as televisions and stand-alone computer displays. Stakeholders were only consulted on energy and resource efficiency requirements for TVs and computer displays.

2. Secondly, the industry is concerned that the nature of some requirements in the draft Lot 5 regulation is too prescriptive (e.g. restriction on gluing and welding), in that it imposes a specific design trait rather than setting performance requirements. This approach lacks consideration for future product concepts and production technologies, thereby unnecessarily restricting innovation in the IT industry and impeding manufacturers in their ability to design products with more functional capabilities, better connectivity and the rigidity to withstand everyday customer use. Prescriptive restrictions may therefore have an adverse effect on resource efficiency.

3. Thirdly, the scope of the proposed Lot 5 regulation is too broad and should exclude products with an integrated display also when larger than one square decimeter. In addition to the reasons also when already specified in the first point, the extended scope of the Lot 5 regulation would lead to multiple regulations impacting the same products, which generates unnecessary complications for the industry and may lead to inconsistencies and confusion. For example, a product may be in scope of the resource efficiency requirements of the proposed Lot 5 regulation and their energy efficiency in scope of another Ecodesign implementing measure. This horizontal approach will dramatically increase the number of companies and types of products affected by the proposed regulation, and is contradictory to the principle of Better Regulation promoted by first Vice President Timmermans.

In summary, industry recommends that all integrated displays are taken out of the scope of the regulation but rather managed through vertical regulations, if necessary. Furthermore, all requirements should be based on an impact assessment to ensure the proposed Ecodesign measures are helpful to achieve the overall objective of the regulation (decrease energy and resource consumption), do not unnecessarily burden the industry and hamper future innovation.