Executive Summary Sheet

Impact assessment for a Regulation on ecodesign requirements for off mode, standby mode and networked standby energy consumption of electrical and electronic household and office equipment pursuant to Directive 2009/125/EC of the European Parliament and Council and repealing Regulation (EC) No 1275/2008 1  and Commission Regulation (EC) No 107/2009 2

A. Need for action

Why? What is the problem being addressed?

A vast number of electric and electronic products used in households and offices spend the majority of their time in low power modes while plugged in electric sockets. This includes off mode, standby, and networked standby. These functioning modes consume small amounts of electricity for the following reasons. Products in standby and networked standby can be reactivated immediately, e.g. by using a remote control (for standby) or via a signal sent from a smartphone through a wifi network (for networked standby). In off mode products may provide an indication that they are turned off, e.g. via a LED indicator. We need to ensure that the energy consumed in these modes is very small; otherwise, it would have a big impact on overall household and office energy consumption due to the high number of appliances currently in use (around 800 million products sold yearly, with an estimated 5 billion units in use across EU). In addition, there is a need to protect the users’ interests, as they might not be fully aware of, or pay attention to, the energy consumption of their products while they are in low power modes.

Regulation 1275/2008 currently in force (amended six times, notably by Regulation (EU) No 801/2013 that introduced networked standby) has proven to be highly effective in reducing the energy consumption in low power modes. The estimated electricity savings are around 33 TWh/year by 2020. However, the effectiveness of this Regulation may now by hindered by: (i) outdated scope, (ii) outdated exemptions, which are creating an uneven playing field, (iii) outdated requirements on maximum consumption in low power modes, and (iv) lack of readily available information.

What is this initiative expected to achieve?

A revised Regulation will:

˗expand the scope of the Regulation to include new product types coming to the market in increasing numbers, and to close potential loopholes ensuring a level playing field for all manufacturers;

˗update the requirements for low power modes in line with technological developments;

˗raise user’s awareness about how much energy is consumed in low power modes;

˗make the Regulation more consistent with other ecodesign regulations. 

What is the value added of action at the EU level? 

There is clear added value in requiring minimum energy efficiency levels at EU level. Without harmonised requirements across the EU, Member States would be incentivised to lay down their own product-specific energy efficiency requirements as part of their national energy and environmental policies. This would undermine the free movement of products. Before the ecodesign and energy label measures were implemented, this was in fact the case for many products.

B. Solutions

What legislative and non-legislative policy options have been considered? Is there a preferred choice or not? Why? 

Five policy options have been examined:

˗option 1 - Business-as-Usual (BAU). Baseline scenario, where the current Regulation remains unchanged;

˗option 2 - lenient measure. Would expand the scope and include stationary products equipped with low voltage external power supplies (LV EPS) by partially removing an exemption present in the current Regulation (which refers to all products with LV EPS). Portable (battery-operated) products with LV EPS would remain exempt;

˗option 3 - balanced EU measure, reducing the standby power consumption requirement for products with status displays to maximum 0.8 W. The scope could be extended to include either only stationary products with LV EPS, or all products with LV EPS. The latter (all products with LV EPS) is preferable because it would generate most of the benefits (in terms of energy and financial savings for end-users) in the most cost effective way ( results in the lowest life-cycle costs for the vast majority of products in scope);

˗option 4 - alternative balanced EU measure is similar to option 3 (including the two possible extensions for the scope), but would also reduce the power consumption in off mode to maximum 0.3 W;

˗option 5 - stringent EU measure  would include all products equipped with LV EPS by completely removing the current exemption. It would also cap the power consumption at 0.8 W for standby mode in products with status display, at 0.3 W for standby mode in all other products and at 0.3 W for off mode;

Apart from the differences outline above, all options except option 1 include a number of standard requirements, such as: (i) extending the scope to include adjustable furniture and motor-operated building elements; (ii) providing information on networked standby, standby and off mode on publicly accessible websites and in user manuals; (iii) including a new definition and further clarifying some of the concepts and terms used.

Preferred option 

Option 3, covering all products with LV EPS (most benefits in the most cost-effective way).

Who supports which option? 

˗The standard requirements are supported by Member States (MS) and NGOs and, to a large extend, by the industry representatives;

˗option 2 is mainly supported by industry stakeholders;

˗options 3 and 4 are proposals based on discussions with stakeholders in the Consultation Forum in December 2017, and feedback from stakeholders throughout the preparatory process (including the views of MS);

˗option 5 is mainly supported by the environmental and consumer NGOs.

C. Impacts of the preferred option

What are the benefits of the preferred option (if any, otherwise main ones)?

By 2030, the preferred option is estimated to bring the following results:

˗achieve the least life cycle costs for typical households and bringing savings on annual end-user expenditure of € 0.53 billion ;

˗energy savings of 4 TWh/year (amounting to cumulative savings of 23 TWh) and related GHG emission reductions of 1.36 Mt CO2eq./year;

˗additional business turnover for manufacturers of around € 180 million/year;

˗adequate update of ecodesign requirements to keep up with technological progress;

˗limited impact on small and medium enterprises (SMEs) manufacturing products covered by the Regulation. 

What are the costs of the preferred option (if any, otherwise main ones)? 

Compliance and administrative costs are direct costs estimated as follows for 2030:

˗Manufacturers (large companies): compliance cost of €52 million/year and administrative costs (for testing and documentation) of €20 million/year

˗Consumers: Increased product purchase costs of around €320 million/year. These costs will be recovered in full via reduced electricity bills over the product life cycle, and financial savings will be made over that timeframe.

How will SMEs and micro-enterprises be affected?

The proposed regulation is fully applicable to micro-enterprises and SMEs associated with manufacturing products covered by the Regulation. The SME share of the market is assumed to be around 30%. The key costs for these firms will be related to product compliance/redesign and testing (a total of around €30 million /year in 2030). However, these costs will be marginal; for instance testing costs of about €1300 per model will result in an average increase of €0.028 in the price of each unit sold. Therefore, they are assumed to be fully transferred to customers.

Will there be significant impacts on national budgets and administrations? 

There are no additional estimated impacts on national budgets and administrations. Member States would instead benefit from more cost-effective market surveillance (through better access to information on the performance of the products in standby and off mode).

Will there be other significant impacts? 

No other significant or negative impacts are expected.

D. Follow up

When will the policy be reviewed?

A review clause will propose the review of the regulation within five years after its adoption.