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Document 52019SC0354

COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document COMMISSION REGULATION (EU) .../...laying down ecodesign requirements for electronic displays pursuant to Directive 2009/125/EC of the European Parliament and of the Council, amending Commission Regulation (EC) No 1275/2008, and repealing Commission Regulation (EC) 642/2009 and COMMISSION DELEGATED REGULATION (EU) …/... supplementing Regulation (EU) 2017/1369 of the European Parliament and of the Council with regard to energy labelling of electronic displays and repealing Commission Delegated Regulation (EU) No 1062/2010

SWD/2019/0354 final

Table of Contents

1.    Introduction: Political and legal context……………………….

1.1.Benefits of Ecodesign and Energy Labelling

1.2.Legal framework

1.3.Legal context of the reviews

1.4.Political Context

1.5.Need to act

2.Problem definition

2.1.Problem 1: Outdated energy efficiency requirements

2.2.Problem 2: Outdated scope

2.3.Problem 3: Poor ‘Circular Economy’ performance

2.4.General market failures

2.5.Who is affected?

2.5.1.Manufacturers and retailers

2.5.2.Repair-reuse sector

2.5.3.Recyclers and waste disposal industry

2.5.4.Consumers

2.5.5.Society as a whole

3.Why should the EU act?

3.1.Legal basis

3.2.Subsidiarity: necessity of EU action

3.3.Subsidiarity: Added value of EU action

4.Policy Objectives: what is to be achieved?

4.1.General objectives

4.2.Specific Objectives

5.What are the available Policy Options?

5.1.What is the baseline from which options are assessed?

5.2.Description of the policy options

5.2.1.Option 1 – Baseline

5.2.2.Option 2 – ECO

5.2.3.Option 3 - Ambitious

5.2.4.Option 4 - Lenient

5.3.Option discarded at an early stage: Voluntary agreement by the industry

6.What are the impacts of the policy options?

6.1.Methodology and key assumptions

6.2.Environmental Impact

6.2.1.Electricity savings

6.2.2.Greenhouse Gas Emissions

6.2.3.Circular Economy perspective

6.3.Business impacts

6.3.1.Business revenue

6.3.2.Innovation, Research and Development, Competitiveness and Trade

6.3.3.Compliance costs

6.3.4.Intellectual property rights

6.3.5.Stranded investments

6.4.Consumer expenditure

6.4.1.Sensitivity analysis

6.5.Administrative burden

6.6.Social Impact

6.6.1.Affordability

6.6.2.Health, Safety and Functionality Aspects

6.6.3.Employment

6.6.4.SMEs

7.How do the options compare?

7.1.Summary of the impacts

7.2.Market Surveillance

7.3.Assessment in view of Article 15(5)

7.4.Assessment in view of the objectives

8.Preferred option

8.1.Preferred option – Why?

8.2.REFIT (simplification and improved efficiency)

9.How will actual impacts be monitored and evaluated?

Table of Content of the ANNEXES

Annex 1Procedural informationA 1

Annex 2:Stakeholder consultationA 9

Annex 3:Who is affected and howA 18

Annex 4:Analytical model usedA 20

Annex 5:Minutes of the Ecodesign Consultation ForumsA 28

Annex 6:The market of electronic displaysA 58

Annex 7:The Ecodesign and Energy Labelling FrameworkA 75

Annex 8:Existing Policies, Legislation and Standards on electronic displaysA 79

Annex 9:Evaluation of current regulations (REFIT)A 90

Annex 10:IAB opinion of 4 September 2013 & adjustments madeA 94

Annex 11:Administrative burdenA 96

Annex 12:Consumer understanding of the energy label (displays)A 100

Annex 13:Background: Energy databases and testingA 102

Annex 14:Background: Energy Flows, Luminance, HDRA 113

Annex 15:Background: Circular economy and other non-energy impacts.0A 130

Annex 16:Acronyms & conversion tableA 140

Annex 17:ReferencesA 143



This report commits only the Commission’s services involved in its preparation and does not prejudge the final form of any decision to be taken by the Commission.

1.Introduction: Political and legal context

This impact assessment relates to the review of Commission Regulation (EC) No 642/2009 1 (Ecodesign) and Commission Delegated Regulation (EU) No 1062/2010 (Energy Label) 2 on televisions and television monitors.

1.1.Benefits of Ecodesign and Energy Labelling

Ecodesign and energy labelling are recognised globally as one of the most effective policy tools in the area of energy efficiency. It is central to making Europe more energy efficient, contributing in particular to the ‘Energy Union Framework Strategy 3 , and to the priority of a ‘Deeper and fairer internal market with a strengthened industrial base’ 4 . Firstly, this legislative framework pushes industry to improve the energy efficiency of products and removes the worst-performing ones from the market. Secondly, it helps consumers and companies to reduce their energy bills. In the industrial and services sectors, this results in support to competitiveness and innovation. Thirdly, it ensures that manufacturers and importers responsible for placing products on the European Union (EU) market only have to comply with a single set of rules.

It is estimated that by 2020, ecodesign and energy labelling regulations will deliver around 175 Mtoe (i.e. about 2035 TWh) of energy savings per year in primary energy, roughly equivalent to Italy's energy consumption in 2010, close to half the EU 20 % energy efficiency target by 2020 and about 11 % of the expected EU primary energy consumption in 2020 5 .

Moreover, the average household saves about € 500 annually on its energy bills by 2020, whilst for industry, service and wholesale and retail sectors it will result in € 55 billion per year of extra revenue.

This legislative framework benefits from a broad support from innovative European industries, consumers, environmental non-governmental organisations (NGOs) and Member States (MSs), because of its positive effects on innovation, increased information for consumers and lower costs, as well as environmental benefits.

Televisions have been subject to EU minimum energy efficiency requirements since 2009 and to energy labelling measures since 2010. Even before 2009, the energy consumption and carbon emissions per unit of viewing area reduced by more than 60 % compared to business as usual (BAU) due to technological developments, and likely also in anticipation of the Regulations.

However, at the same time the size of televisions screens increased, as did the number of sales with a peak in 2010. These trends were not fully foreseen in the preparatory study and impact assessment in 2007, because the available sales and stock data was poor and information from industry was not forthcoming at that time 6 .

As a result, in 2017 the energy consumption of the installed television stock was around 10 TWh (around 13% of the total energy consumption of TVs) lower than what was expected in 2007, as can be seen in Figure 1. This was driven by both technological progress and regulatory pressure around the world.

The increase of the energy consumption estimated to start around 2024 is partly because the current regulations (which in the BAU scenario would not be revised) would lose their effect on the market. Moreover, efficiency improvement is expected to slow down because the technologies that thus far have caused the large efficiency improvements are nearing their limits and further improvements would require major investments (see also section 5.2.1). More details about the past and future market trends can be found in Annexes 4, 6 and 14.

Figure 1: Electricity consumption of televisions 1990-2025, according to 2007 impact assessment (based on best data 2007) and real 2017 data as assessed in this study.

It has to be noted that it is very difficult to estimate to which extent the improvements are driven by autonomous technology progress, by competition or by regulatory pressure. However, we consistently see that product sectors regulated under ecodesign and energy labelling anticipate upcoming regulations. This was most obvious with televisions after the introduction of the first regulations in 2011: only after a few months of the rules starting to apply, many manufacturers came forward with models in the higher classes of the label. This is to be expected as companies need to plan their product development investment well in advance, in particular if new technologies are needed to meet requirements or move to the higher energy classes 7 . If companies wait with such investment decisions until the requirements enter into force, they run the risk of being ‘behind the curve’ of sector-wide improvements and will lose market share 8 .

The BAU assumes that without continued regulatory pressure further major efficiency gains will not materialise autonomously, and that with the increasing volume of displays and the introduction of new features that tend to be more energy consuming, total energy consumption will go up.

1.2.Legal framework

Lowering the demand for energy by ‘putting energy efficiency first’ is one of the five main objectives of the Energy Union strategy. In 2015, Member States in the Council confirmed the imperative need to reach the 20% energy efficiency target for 2020. In November 2016, the Commission proposed to further strengthen this beyond 2020 with a 30% EU energy efficiency target for 2030 9 . In the EU, the Ecodesign framework Directive 10 sets a framework requiring manufacturers of energy-related products to improve the environmental performance of their products by meeting minimum energy efficiency requirements, as well as other environmental criteria such as water consumption, emission levels or minimum durability of certain components before they can place their products on the market.

The Energy Labelling framework Regulation 11 complements Ecodesign by enabling end-consumers to identify the better-performing energy-related products, via the well-known A-G/green-to-red scale. The Regulation sets out the general rules for rescaling the existing A+ to A+++ labels:

·Class A shall be empty at the moment of introduction of the label, and the estimated time within which a majority of the models falls into that class is at least 10 years;

·Where technology is expected to develop more rapidly, as in electronic equipment sectors such as displays, classes A and B shall be empty when introducing the label;

·Moreover, the A to G steps of the classification shall correspond to significant energy and cost savings and appropriate product differentiation from the customer’s perspective.

In general, the boundaries of the label scale are defined by the performance of products on the market incorporating ‘Best Available Technology’ (BAT) and the minimum requirement under ecodesign for those products. Subsequently, the bandwidth of the classes is determined to keep the same effort to move from one class to the next one. For specific product groups this may however be different to take into account appropriate product differentiation.

The BAT is determined following the MEErP methodology, and is based on purely technical grounds, i.e. the product on the market with the lowest environmental impact, while ensuring that other functional requirements (e.g. performance, quality, durability) are equivalent to the base case.

The energy label is recognised and used by 85% of Europeans 12 .

The legislative framework builds upon the combined effect of the two aforementioned pieces of legislation. See figure 2 for a visualisation of this effect.

The Ecodesign framework Directive and the Energy Labelling framework Regulation are implemented through implementing and delegated Regulations that cover specific energy-related products representing a significant volume of sales (more than 200 000 units a year), having a significant environmental impact within the EU and representing a significant energy improvement potential without increasing the cost excessively.

Figure 2: Effect of Ecodesign alone and when combined with Energy Labelling

As an alternative to the mandatory ecodesign requirements, voluntary agreements or other self-regulation measures can be presented by the industry, see also Article 17 of the Ecodesign Framework Directive. If certain criteria are met the Commission formally recognises these voluntary agreements 13 . The benefits are intended to be a quicker and more cost-effective implementation, which can be more flexible and easier to adapt to technological developments and market sensitivities.

Under this framework, televisions and television monitors 14 are regulated by Commission Ecodesign Regulation (EC) No 642/2009 and Commission Delegated Energy Labelling Regulation (EU) No 1062/2010.

The EU Ecolabelling Regulation (Regulation (EC) 66/2010 15 ) complements ecodesign and energy labelling. It is a voluntary scheme that awards products with the best environmental performance throughout their lifecycle. Products that fulfil the criteria can bear the EU ecolabel. Televisions and television monitors are covered by the EU Ecolabel under Commission Decision 2009/300/EC and follow-up acts 16 . The Ecolabel has some stricter energy efficiency requirements and addresses other environmental issues 17 .

Displays, including computer monitors and signage displays, were included in Annex C of the EU-US Energy Star agreement, which expired on 20 February 2018 18 . The agreement did not allow the inclusion of products in its Annex C if such products would be covered by energy labelling. Hence, televisions were never included in the Agreement.

As regards waste management, article 4 of the Waste of Electric and Electronic Equipment (WEEE) framework Directive (which covers televisions and displays) explicitly states that Ecodesign requirements should be laid down to facilitate the re-use, dismantling and recovery of WEEE, its components and materials, by addressing such issues during the design phase.

Finally, under article 6 of the Energy Efficiency Directive, Member States shall ensure that central governments purchase only products, services and buildings with high energy-efficiency performance 19 . In this context, computer monitors and signage displays are also part of the Commission’s Green Public Procurement (GPP) guidelines 20 , 21 , which are developed to facilitate the inclusion of green requirements in public tender documents.

A more detailed overview of existing policies, legislation and standards covering televisions and computer monitors is given in Annex 8.

1.3.Legal context of the reviews

Article 6 of Commission Regulation (EC) No. 642/2009 requires the Regulation to be reviewed within 3 years after entry into force (i.e. by September 2012) in light of technological progress. Article 7 of Commission Delegated Regulation (EU) No. 1062/2010 requires a review within 5 years (i.e. by December 2015).

The Ecodesign working plan 2016-2019 22 also includes the review of both regulations, requiring in particular to examine how aspects relevant to the circular economy can be assessed and taken on board. This is in line with the Circular Economy Initiative 23 , which concluded that product design is a key in achieving the goals, as it can have significant impacts across the product life cycle (e.g. in making a product more durable, easier to repair, reuse or recycle).

Finally, in August 2017, the new Energy Labelling framework Regulation (EU) 2017/1369 entered into force, repealing Directive 2010/30/EU 24 . Under the repealed Directive, energy labels were allowed to include A+ to A+++ classes to address the overpopulation of the top classes. Over time, due to technological development, also the A+ to A+++ class became overpopulated, thereby reducing the effectiveness of the labels significantly. To resolve this, the new framework regulation requires a rescaling of existing energy labels, back to the original A to G scale. Article 11 of the Energy Labelling framework Regulation lists 5 priority product groups for which new delegated acts with rescaled energy labels must be adopted 15 months after the entry onto force of the Regulation. Televisions are one of the priority product groups.

1.4.Political Context

Several new policy initiatives indicate the need for a broader scope for the revision than required by Article 7 of the current Ecodesign and Energy Labelling Regulation. The main ones are:

·the Energy Union Framework Strategy which calls for a sustainable, low-carbon and climate-friendly economy;

·the Paris Agreement 25 , which calls for a renewed effort in carbon emission abatement;

·the Circular Economy Initiative 26 , which amongst others stresses the need to include reparability, durability and recyclability in ecodesign;

·the Emissions Trading Scheme (ETS) 27 , which aims at cost-effective greenhouse gas (GHG) emissions reductions and indirectly affected by the energy consumption of the electricity-using products in the scope of ecodesign and energy labelling policies; and

·the Energy Security Strategy, which sets out a strategy to ensure a stable and abundant supply of energy.

1.5.Need to act 

The need to act is driven by the following main considerations:

Cost effective energy savings:

Manufacturers and consumers stand to benefit from the fact that there are still cost effective energy savings to be achieved in this product sector. By way of illustration, Figure 3 shows the past and expected future increase of total viewing surface area in 1990 (21 km2), 2010 (125 km2) and 2030 (496 km2). It also shows what would have happened in 2010 and 2030 if television energy efficiency had stayed at the 1990 level, and the effect of the Business-as-Usual (BAU) scenario. The figure anticipates the potential savings in 2030 with updated measures (ECO-scenario) for televisions only (i.e. not including other displays that are currently not covered by the Regulations in force).

 

Figure 3: EU television screen area and energy use 1990-2010-2030 (source: VHK for the EC, 2017)

Other policies/political imperatives:

Several other policies and political priorities require the revisions to look beyond the technical revisions mentioned in the review article of the existing regulations, e.g.:

·renewed effort in carbon emission abatement through the Paris climate agreement;

·the Commission’s Circular Economy policy;

·the Better Regulation policy aiming at more efficient and effective legislation;

·the need to address possible circumvention of testing standards;

·renewed energy efficiency targets.

Rescaling of energy labels

The new Energy Labelling framework Regulation requires the Commission to rescale the existing labels for five priority product groups, including televisions, 15 months after the entry into force of the Regulation, to remove the A+ to A+++ classes.

More generally, the filling up of the top classes means that the label is no longer effective. If there is still a significant difference in energy efficiency of products remaining on the market, a label will still bring added value in terms of guiding consumers to more efficient products.

In particular for televisions, over the past 5 years, the energy label has been successful in driving the market, by pulling consumer choice towards the highest classes and incentivising manufactures to compete by having a large offer of products in the top classes. As a result, in 2017 almost no televisions in classes below B were sold in the EU ( Figure 4 ) and the top 3 energy efficiency classes are now overpopulated in terms of sales

Figure 4: EU television unit sales by EU Energy Label classes 2013-2017 (source VHK based on data from GfK).

This means the use of the label to help consumers to differentiate between the products on the market is lost. Moreover, the "A+", "A++" and "A+++" classes introduced by the Energy Labelling Framework Directive (Directive 2010/30/EU) have been shown to be less effective in persuading consumers to buy more efficient products than the A to G scale 28 . The television energy label was therefore included in the list of product groups to be rescaled as a priority under the Energy Labelling framework Regulation.

1.Problem definition

Televisions and other electronic displays constitute almost 3% of the European Union’s electricity consumption: in 2016, the electricity consumption of televisions was almost 80 TWh/yr 29 , up from 25 TWh/yr in 2005, close to the total electricity consumption of EU household refrigeration appliances (86 TWh/yr). This consumption is slowly decreasing due to progress in energy-saving technology but still has the largest share amongst all electronic household products and, without policy action, is expected to reach 50 TWh/yr in 2030. However, revised Ecodesign and Energy Label measures could reduce this to around 30 TWh/yr by 2030 (i.e. back to pre-1990 levels) without significant negative impacts, both on life-cycle costs and product functionality.

In addition, although their energy efficiency has been improving, this is not fast enough to compensate for the increase in energy use due to a growing number of displays per household 30 . New image compression techniques and increasing Internet bandwidth availability are also driving the shift from traditional broadcasting to video streaming "on demand" that, in turn, encourages individual watching thereby increasing the number of hours each display is in use. See Annex 6 for market details and projections.

2.1.Problem 1: Outdated energy efficiency requirements

The problem: The current ecodesign requirements for televisions and television monitors no longer capture cost-effective energy savings. Moreover, the current energy label no longer allows consumers to differentiate effectively between the appliances on the market and no longer provides information reflecting real-use patterns as shown by the review. Although the 2012 Ecodesign limit (3 W) was ambitious at the time, nowadays for LED LCD televisions and monitors a level of 1 W/dm² is typical.

Without an update of the eco-design and energy label measures, they will lose their effectiveness and the incentives for industry to design more efficient products will be lower.

Drivers of the problem

Problem driver 1: technological progress, outdated testing methods and circumvention

As outlined in the review, a number of quickly-developing technology and market changes occurred since the entry into force of the existing regulations on televisions, such as ever-larger screens, new backlighting technology 31 , increases in picture definition and contrast/colour gamut, in particular High Dynamic Range (HDR).

At the same time, the testing methodology used for setting minimum energy efficiency requirements under ecodesign and defining the efficiency classes on the energy label is based on the energy use of a television with "traditional" contrast/colour gamut control (known as Standard Dynamic Range or SDR) 32 . With the introduction of HDR, energy consumption can more than double. Premium televisions on the market from 2017 started offering this new feature 33 that is progressively offered on less expensive models.

Figure 5 shows, for two television models on the EU market since 2017, how the energy consumption can differ when operating in HDR mode: the left graph shows for a specific model an energy use in HDR of 456 W versus 199 W in SDR (which is the only indication reflected in the label). The right graph shows how for another model with a more energy-efficient implementation of HDR, the energy use has a negligible increase (129 W in HDR versus 128 W in SDR).

Figure 5: Second-by-second power use of two display models (source STEP project, personal communication).

The current testing method was not designed to deal with this feature and, as a result, the actual energy use of some televisions is possibly considerably higher than what is indicated on the energy label. Hence, in situations where HDR images are displayed on a HDR-capable display, the label does not always correctly represent the energy efficiency and energy use, also leading to an impaired comparability of different models (see annex 14 for more details).

Moreover, independent testing has shown that some displays from some manufacturers abnormally decrease their power consumption in certain situations, such as during the energy consumption test 34 , raising suspicion of the use of so-called "defeat devices" 35 . Given the confidential nature of compliance control activities by market surveillance there is however no precise information on the size of the problem. Market surveillance authorities, and consumer and environmental NGOs have argued for improved test modalities and legislation provisions to better support enforcement and discourage circumvention.

The testing method also needs to be updated to include Auto Brightness Control, a new feature for adapting screen luminance to the ambient conditions, which can reduce power use up to 75% in specific circumstances whilst improving visual comfort.

Without an update of the measures, consumers' confidence in the energy label will decrease, as it will become less and less representative of the energy consumption and efficiency in real life conditions.

In addition, international standards are being developed for televisions, based on an update of the current testing loop 36 . Not including this new test in the ecodesign and energy labelling measures would result in double testing of televisions (i.e. according to the EU standard and other markets).

Problem Driver 2: Increasing display size, outdated calculation method

Manufacturers’ marketing pushes consumers towards bigger and bigger screens, with retailers encouraged to show only the biggest models, which have higher profit margins per unit sold. Figure 6 provides an overview of the market developments between 2015 and 2016 per display size, clearly showing the trend towards larger displays. Since 2005, the energy efficiency per unit of display surface area (i.e. Watts/dm²) started to go down, but by no means enough to compensate for the additional energy consumption due to the increased display size and higher number of displays.

Figure 6: TV display unit sales Europe by diagonal size, in inch, 2015-2016 (source: VHK on GfK POS, April 2017).

At the time the current Regulations were established, the average display size was slightly above 30 inches of diagonal, and the contribution of the different electronic components (which is fixed) and that of the screen (which is relative to size) to the energy consumption of the display was more balanced. Because of the commercial trend to ever-increasing screen sizes, the relative contribution of the screen to energy consumption is increasing.

The current energy label for televisions provides a certain advantage to the biggest displays. Indeed, the calculation method (based on power consumption linearly increasing with screen area) does not correctly capture the influence of the display size with respect to other electronic components (the power consumption of which is independent from the screen area). This results in an indication of efficiency that can mislead consumers. More details can be found in Annex 6.

2.2.Problem 2: Outdated scope

The problem: The outcome of the review shows that the current scope of both Ecodesign and Energy Labelling regulations is unclear, technology-prescriptive and creates uncertainty as to whether some products are in or out of the scope. This causes an unlevelled playing field for industry, and Market Surveillance Authorities (MSAs) have difficulties to evaluate the scope and perform proper market surveillance. In addition, the current scope of both regulations does not cover an increasingly important share of devices on the market.

The current Regulations cover:

·Televisions; defined as products designed primarily for the display and reception of audio-visual signals; and

·television monitors; defined as products designed to display on an integrated screen a video signal from a variety of sources, including television broadcast signals.

Technological progress and convergence of different products increasingly blurred the line between television monitors and other display products such as computer monitors or even signage displays 37 . A functional overlap is now evident, with, e.g. the classic television no longer the only way for watching video content 38 and, because of enhanced resolution levels now available, televisions are sometimes used as monitors for game consoles, although specific wide and curved monitors now exist for that. Already in 2012, most stakeholders agreed that the review of the television measures should be used to cover computer monitors and signage displays (see Annex 2 for details on the rationale of including these products in a revised television measure and Annex 5 for the position of stakeholders in the Consultation Forum of October 2012).

Moreover, new modular signage displays can be used to create video walls, and this market is moving from public spaces to premium domestic home theatre screens replacing projectors for domestic use (or even in public cinemas 39 , replacing projectors). Most of the features and components of signage displays are the same as for domestic televisions and monitors and these products are replacing older signage boards because of their flexibility. Technology progress in one sector drives other related ones 40 .

Figure 7: Share of electronic display surface per product group (EU 2020, source VHK)

Figure 7 shows the estimated area of electronic displays per ‘product group’. In combination with the energy consumption data ( Figure 10 ) it becomes evident that the currently limited market of signage displays will become relatively more important in terms of energy use in the coming years.

If computer monitors and signage displays currently not covered by the ecodesign and energy labelling regulations remain unregulated, significant energy savings would not be realised. Consequently, consumers would not benefit from reduced energy consumption (and therefore reduced electricity bills) of those products. Since these two product categories fall within the scope of the WEEE Directive, recycling targets of 80 % as of 2018 would be more difficult to reach 41 .

Moreover, signage displays are listed in the Commission’s 2016-2019 Ecodesign Working Plan to be taken up in the revision of the existing regulations for televisions.

Drivers of the problem:

Driver 1: Outdated product definitions/unclear scope

Both regulations in force include in scope "televisions and television monitors". However, their definitions of "television monitor" based on the availability of certain input interfaces has become obsolete and inaccurate because of technology development, outdated terminology and because use patterns have changed significantly. This has resulted in legal uncertainty and there are recurring interpretation questions from market surveillance authorities and even court cases and litigation 42 (See Annex 11 for more information).

Driver 2: New product types

The outcome of the review has shown that the increasing availability of relatively cheap electronic displays is driving the replacement of traditional signage media (e.g. paper billboards, split-flap boards, etc.) and provides new opportunities for displaying video content, typically for advertisements (see Figure 8 ). From an energy perspective, many of these signage displays are on all the time, using up to 2.5 times more power than a normal TV of the same size 43 . Moreover, they tend to be much larger.

At the same time, ‘professional’ signage displays are migrating into the consumer market (driven amongst others by miniaturisation of LED technology, commonly known as Crystal LED or MicroLED), for example by bringing "video wall" technology used in commercial settings to homes, with new premium products such as 150-inch home theatres. This new “domestic” use of these products broadens their traditional customer base from commercial entities to include households. Annex 6 includes some examples of new signage display markets and of technologies now emerging.

Figure 8: an electronic signage display in a hospital mimicking (sound included) a mechanical split-flap board.

2.3.Problem 3: Poor ‘Circular Economy’ performance

The problem: The existing ecodesign and energy labelling requirements for televisions focus on energy efficiency improvements as the most significant environmental impact during the life-cycle of electronic displays. However, since the introduction of these regulations, new policies on circular economy and other environmental aspects have been introduced and there is a need to address these issues increasingly through Ecodesign and, potentially, Energy Label measures. This was confirmed with the adoption of the current EU Circular Economy Action Plan in 2015, followed by the Ecodesign Working Plan 2016-2019 in November 2016.

The traditional Cathode Ray Tube (CRT) TVs and computer monitors had many environmental and health concerns, e.g. regarding phosphors, lead, large glass tubes, large high-voltage capacitors, heavy mass of casing materials, and in particular flame retardants in plastics. With the advent of the flat screen TV, although there were initially some issues with mercury in backlights and cadmium in nanomaterials, the total material input in producing displays has decreased by 80-90 %: new LED/LCD displays weigh only a fraction of the old CRT TV.

According to the latest Eurostat statistics for 2014, collected waste displays made up 83% of the weight of the consumer electronic products placed on the market and 79 % of that collected waste was recycled, with 2 % being recovered or re-used in another way.

 

Figure 9: Estimated mass flow (in kt) of televisions sold and discarded (excluded packaging) over the 1990-2012 period with baseline projections for 2013-2030. (source: VHK. See Annex X)

As regards durability, a recent study for the German Environmental Protection Agency 44 , found that planned technical obsolescence is not common for electronic displays. Most people discard the old TV, in perfect working order, to buy a better/bigger model.

One issue that has been raised by stakeholders, is the use of standardised external power supplies (EPSs), which convert 230 Volt AC current into low voltage DC current. This would address the following concerns in terms of reparability, durability and recyclability:

·Repairing a broken, internal power supply requires a technician and frequently is not cost-effective, e.g. because it is integrated on the main electronic board and the replacement cost is comparable to a new display. A broken standardised external EPS can be replaced by any user at moderate/low cost;

·An standard EPS can have a lifetime longer than the main load product (e.g. a television) and can thus be used after the main load product is at its end of life;

·Flame retardants hinder recycling of plastics and can be toxic and ecotoxic (in particular halogenated flame retardants). The power supply is the only component where AC current is supplied. By removing the power source from the interior of an electronic display the need for using flame retardants in plastics is reduced 45 .

Finally, the WEEE Directive regulates the recycling of electronic displays. Article 8(2) of this Directive includes a list of materials that need to be collected separately during the recycling process, including LCD screens above 100 cm2 and plastics with brominated flame retardants, and ecodesign requirements can facilitate this by requiring those components to be easily removable. Moreover, Article 4 of the WEEE directive refers to the role of ecodesign to address upstream issues related to re-use, dismantling and recovery. Recycling and material recovery are important for this product group because of the presence of critical or precious raw materials (such as Au, Ag, Pd, In) 46 and big plastic parts. Plastics recycling, mainly of the back-cover and the stand, is rendered more difficult because of the presence of halogenated flame retardants (HFRs) in some of the plastic parts. .

Although circular economy aspects were not specifically evaluated in quantitative terms, the need to examine options for better supporting circular economy objectives was articulated by stakeholders as early as 2012 47 .

Drivers of the problem:

Driver 1: Glued and welded components

Typically, televisions and displays are not well designed for recycling. The WEEE Directive requires the removal, for separate treatment and before further processing such as shredding, of several electronic components usually contained in electronic displays 48 . Televisions and displays have many components, which cannot be easily detached because they are welded or glued, and trying to remove them can be dangerous or ineffective. The European Electronic and Electric Recyclers Association (EERA) reports 49 almost every day a fire in recycling plants of one of its members, because e.g. lithium-ion batteries explode during extraction attempts or in shredding machinery.

Driver 2: Use of flame retardants

Electronic displays contain flame retardants (FR) as additives to plastic polymers, as well as synergists such as Antimony Tri-Oxide (ATO). FRs were introduced in old CRT displays, where high voltages were involved 50 . Safety standards required flame retardancy in the case a candle on top of those old TVs was reversed. It is estimated that currently around 20 kt of HFRs and ATOs is used in the production of electronic displays sold in the EU 51 .

EFRA (2014) estimated that only 12% of the plastics in a display is recycled 52 . It should be noted that most of these plastics are currently either incinerated or landfilled, as it is not possible with most recycling technologies to separate out these plastics with sufficient quality. However, recent research has demonstrated that it is technically possible to sort these plastics after manual disassembly e.g. by means of spectroscopic analysis. It has also been demonstrated that these plastics can be recycled to produce products with the same properties 53 .

Halogenated flame retardants (HFR), used in plastics of electronic displays, are a low-cost solution to obtain the high flame retardancy required by certain standards (i.e. UL94 class V1 or higher) but appear to hinder recycling 54 . The necessity to use HFRs is expected to diminish, because modern displays do not involve high voltages, with some using only low voltage DC current (when the power supply is external). As a result, the so-called ‘candle test’ (which entails an open flame being applied to the back cover of the television over a prolonged period without the back cover actually catching fire) is no longer required. It was prescribed in EN 60065:2002/A11:2008, a harmonised standard under the Low Voltage Directive (LVD). However, this standard was superseded by EN 60065:2014, which will in turn be superseded by the harmonised standard EN 62386-1:2014 that no longer requires this ‘candle test’. 55  

Plastics with HFR additives, particularly bromine-based compounds (BFR), constitute a main bottleneck in reaching the required WEEE recycling rates as they pollute otherwise recyclable polymers that therefore have to be incinerated, thereby lowering recycling yields. In fact, the RoHS Directive 56 restricts the use of specific HFR 57 , but a number of other HFR compounds are still allowed and more could be created.

For electronic and electric products, RoHS legislation has clearly defined limit values for the presence of any restricted substance such as BFRs and under the WEEE Directive plastics need to be treated in specialised plants, capable of separating e.g. BFR containing plastics 58 , with consequent additional costs 59 .

Mechanical separation of polymers containing HFRs from non-HFR polymers is feasible 60 , however with state-of-the-art technologies it is currently not economically sustainable to separate plastics containing still allowed substances from those restricted by the RoHS Directive. Hence, recyclers opt for incineration of any plastic with HFRs 61 . Moreover, restricted HFR additives have serious toxicity and ecotoxicity 62 issues, constituting a major threat to the health of workers in recycling plants during end-of-life processing 63 (see Annex 15 for more details).

Banning of all flame retardants, particularly HFRs, is consistently requested by environmental NGOs 64 that have been also fighting the candle test for several years, claiming that the fire safety measures are disproportionate, based on outdated fire statistics and related to old TV technologies (CRT). The recycling industry is also in favour of completely banning 65 the use of at least halogenated flame retardants 66 .

Alternative solutions exist 67 , at least for the enclosure, that have been already in use for years by major manufacturers 68 , such as:

·using polycarbonate PC/ABS 69 blends and HIPS/PPE blends that can be flame-retarded using phosphorus solutions 70 ;

·providing design solutions avoiding any FR such as shields between circuit boards and the enclosure, or increasing the separating space; or

·using non-flammable materials.

The Ecolabel for televisions 71 requires that plastic parts shall not contain a number of flame retardant substances.

 

As some safety standards still require a certain level of flame retardancy also for the enclosure, a complete elimination of all flame retardants, as recyclers crave, appears still difficult at this stage 72 . More details are given in Annex 15.

Driver 3: Spare parts availability

Currently no measures exist which regulate the availability of spare parts, or software and firmware updates, which has a direct impact on the durability of products.

The review showed that the replacement rate (a proxy for service life) of TVs reduced from 9-11 years in the 1990s to 5-6 years between 2003 and 2010, mostly due to the replacement of analogue, bulky CRT displays but is now again rising to 8-9 years (see Annex 6). Replacement is mostly driven by natural product obsolescence; i.e. people buy a new display because of functional requirements (i.e. size, resolution), but rarely because the display is broken. In the case of signage displays, which are often always on, replacement is driven by the degraded picture quality, often within 5 years.

Reparability of TVs is under investigation in a new study by JRC 73 and preliminary findings indicate that remote controls, external power supplies (EPS) and internal power boards are the components most likely to fail or break.

2.4.General market failures

In addition to the product specific problem drivers described in the previous sections, some general market failures have been identified:

Myopic behaviour - Without up to date energy efficiency requirements and energy labels, economic actors (both business and private) will not choose the product that is the most cost-effective over the product's life-time. This is because economic actors are limited by the information they have, their knowledge about products, and the finite amount of time they have to make a decision.

Split incentives – Without up to date energy efficiency requirements, the guarantee that the products will be cost-effective over their life-time is lost. This is especially important for a certain groups of consumers, in particular those in a landlord-tenant situations, where the landlord buys the appliance and the tenant pays the energy bill, which for this product group is particularly relevant for signage displays.

Price reflection – The price of the products does not reflect the real environmental costs to society in terms of circular economy. Hence, without setting requirements that will improve circular economy aspects of the product, the different actors in the life cycle of the appliance will not be incentivised to improve the circular economy aspects of the appliance.

2.5.Who is affected? 

All market actors, consumers and society in general are affected by the problems.

2.5.1.Manufacturers and retailers

For manufacturers and retailers, the energy label is one of the main market drivers and an important quality feature. The energy label allows industry to distinguish itself based on quality and innovation rather than solely on price.

Outdated energy efficiency requirements mean that new, innovative features are no longer properly reflected on the label, and manufacturers are thereby less able to distinguish their products based on quality and innovation rather than solely on price.

The overall energy use (and efficiency) of a display is mostly dependent on the panels (the "screen"). The electronic displays sold in the EU all use panels made in Asia. Jobs in this sector in the EU are mainly in assembly and distribution centres and in utilities supplying casings, non-video components and subassemblies 74 .

It is estimated that a few thousand jobs (2000-4000) in the EU are involved. SMEs in this sector, i.e. companies with less than 250 employees, could not be found. Most companies involved in electronic display manufacturing/assembly/design are represented by DigitalEurope 75 .

2.5.2.Repair-reuse sector 

Statistics on repair shops are not detailed enough to give an exact estimate of the number of enterprises involved in TV and monitor repair. Based on their relative turnover it is estimated that there are between 5,000 and 10,000 repair jobs for TVs and monitors in the EU. More than 80-90 % of these jobs are in SME enterprises, most of them probably also in retail 76 . Lack of repair information hinders the development of the repair-reuse sector.

2.5.3.Recyclers and waste disposal industry

For recyclers, design requirements that facilitate the separate collection of the materials listed in Article 8(2) of the WEEE Directive 77 would reduce the time needed to disassemble and process an electronic display. Workers in the recycling industry would also benefit from reduced presence of HFRs. The absence of requirements in this area would also delay investments by the recycling industry to improve WEEE treatment techniques and improve yields.

The recycling industry is represented by the European Recycling Industries’ Confederation (EURIC) and by the European Electronic and Electric Recyclers Association (EERA). For more information on the end-of-life materials please see Annex 12.

2.5.4.Consumers 

For consumers, the energy label offers a unique opportunity to make an informed choice as to which products offer the best environmental and energy performance allowing them to save money in the long run. Ecodesign requirements safeguard consumers from the worst performing products. Without up to date ecodesign and energy labelling requirements, consumers may miss out on savings of EUR 2.8 billion annually by 2030 (BAU compared to the ECO option, see Section 6).

Consumers are represented by the Bureau Européen des Unions de Consommateurs (BEUC) and the European Association for the Co-ordination of Consumer Representation in Standardisation (ANEC).

2.5.5.Society as a whole

For society as a whole, ambitious policies in the area of energy efficiency are important tools to mitigate climate change. Effective and efficient energy labelling and ecodesign regulations contribute to achieving goals set in the Paris Agreement; they help achieve the 2030 EU climate and energy objectives. In total, all these measures will generate 0.29 % of the total EU GHG-emissions savings target for 2030 and 0.66 % of the total EU final energy consumption savings target for 2030.

Environmental organisations are represented by the European Environmental Citizens Organisation for Standardisation (ECOS), the European Environment Bureau (EEB), TopTen, the Collaborative Labelling and Appliance Standards Program (CLASP).

2.Why should the EU act?

3.1.Legal basis

The legal basis for acting at EU level through the Ecodesign framework Directive and the Energy Labelling framework Regulation is Article 114 and Article 194 of the Treaty on European Union and the Treaty on the Functioning of the European Union (TFEU) 78 respectively. Article 114 relates to the "the establishment and functioning of the internal market", while Article 194 gives, amongst others, the EU the objective "in the context of the establishment and functioning of the internal market and with regard for the need to preserve and improve the environment" to "ensure security of energy supply in the Union" and "promote energy efficiency and energy saving and the development of new and renewable forms of energy".

The Ecodesign Framework Directive and Energy Labelling Framework Regulation include a built-in proportionality and significance test. For the Ecodesign Framework Directive, Articles 15(1) and 15(2) state that a product should be covered by an ecodesign or a self-regulating measure if the following conditions are met:

·The product should represents a significant volume of sales;

·The product should have a significant environmental impact within the EU;

·The product should present a significant potential for improvement without entailing excessive costs, while taking into account:

o an absence of other relevant Community legislation or failure of market forces to address the issue properly;

oa wide disparity in environmental performance of products with equivalent functionality.

The procedure for preparing such measures is described in Article 15(3). In addition, the criteria of Article 15(5) should be met:

·No significant negative impacts on user functionality of the product;

·No significant negative impacts on Health, safety and environment;

·No significant negative impacts on affordability and life cycle costs;

·No significant negative impacts on industry’s competitiveness (including SMEs see Section 6.6.3).

The Energy Labelling Framework Regulation includes similar criteria for products covered by an energy label:

·The product group should have significant potential for saving energy and where relevant, other resources;

·Models with equivalent functionality should differ significantly in the relevant performance levels within the product group;

·There should be no significant negative impact as regards the affordability and the life cycle cost of the product group;

·The introduction of energy labelling requirements for a product group should not have a significant negative impact on the functionality of the product during use.

Following the procedure as defined in Article 15(3) of the Ecodesign Directive, it was established that electronic displays fulfil the above eligibility criteria.

3.2.Subsidiarity: necessity of EU action

Action at EU level gives end-users the guarantee that they buy an energy efficient product and provides end-users with harmonised information no matter in which MS they purchase their product. This is becoming all the more relevant as the online trade increases. With ecodesign and energy labelling at EU level, energy efficient products are promoted in all MSs, creating a larger market and hence greater incentives for the industry to develop them.

It is essential to ensure a level playing field for manufactures and dealers in terms requirements to be met before placing an appliance on the market and in terms of the information supplied to customers for sale across the EU internal market. For this reason, EU-wide legally binding rules are necessary.

Market surveillance is carried out by the MSAs appointed by MSs. In order to be effective, the market surveillance effort must be uniform across the EU to support the internal market and incentivise businesses to invest resources in designing, making and selling energy efficient products.

Manufacturers of electronic displays are worldwide companies placing the same or equivalent product models in different regions of Europe. Consequently, the ecodesign and energy labelling requirements in Europe can only be effectively implemented at EU level.

Finally, Regulation (EU) 2017/1369 requires the Commission to update the current energy labelling regulation for televisions, in particular as regards rescaling the label to remove the A+ to A+++ classes. Under the repealed Directive, energy labels were allowed to include A+ to A+++ classes to address the overpopulation of the top classes. Over time, due to technological development, also the A+ to A+++ class became overpopulated, thereby reducing the effectiveness of the labels significantly.

3.3.Subsidiarity: Added value of EU action

There is clear added value in requiring minimum energy efficiency levels and energy label class limits at EU-level.

Without harmonised requirements at EU level, MSs would be incentivised to lay down national product-specific minimum energy efficiency requirements in the framework of their environmental and energy policies. This would undermine the free movement of products and increase design, manufacturing and distribution costs. Before the ecodesign and energy label measures were implemented, this was in fact the case for many products.

The added value of EU action in the area of the circular economy has already been enshrined in the Circular Economy Action plan and the Ecodesign Working Plan 2016-2019.

3.Policy Objectives: what is to be achieved?

4.1.General objectives

Following the legal basis in the TFEU, the general objectives are to:

1.Facilitate free circulation of efficient electronic displays within the internal market;

0.Promote the energy efficiency of electronic displays as a contribution to the EU's objective to reduce energy consumption by at least 30 % and domestic greenhouse gas (GHG) emissions by 40 % by 2030; implement the energy efficiency first principle established in the Commission Communication on Energy Union Framework Strategy; and

1.Increase energy security in the EU and reduce energy dependency through a decrease in energy consumption of electronic displays.

There are several synergies between these objectives. Reducing electricity consumption (by increasing the energy efficiency) leads to lower carbon, acidifying and other emissions to air. Tackling the problem at EU internal market level enhances efficiency and effectiveness of the measure.

4.2.Specific Objectives

The specific objectives of the policy options considered in this impact assessment are to correct the problems identified in the problem definition:

1.Update the energy efficiency requirements and the energy label in line with international and technological developments, and the revised Energy Labelling framework Regulation, to achieve cost-efficient energy savings;

0.Redefine the scope to close loopholes, remove ambiguities, facilitate execution of the Regulation, align it with market developments and better capture the potential for energy savings;

1.Contribute towards a circular economy by facilitating dismantling and recyclability.

These objectives will drive investments and innovations in a sustainable manner, increase monetary savings for the consumer, contribute to the Energy Union Framework Strategy and the Paris Agreement, contribute to the Circular Economy Initiative and strengthen the competitiveness of EU industry.

4.What are the available Policy Options?

The procedure for identifying policy options follows from the Better Regulation Toolbox 79 . Specific measures in the policy options are the result of a combination of initiatives including three discussions in the Ecodesign Consultation Forum, input from a public consultation and from WTO on a previous proposal on Ecodesign only and inspiration taken from the Ecodesign framework Directive, the Energy Labelling framework Regulation and the Circular Economy Initiative. They aim to address the issues identified in Section 3 and achieving the policy objectives defined in Section 4.

Some measures presented in this impact assessment were extensively discussed with stakeholders during three Consultation Forums (8 October 2012, 10 December 2014 and 6 July 2017) and represent the consensus achieved. They apply to all policy options and are further detailed under option 2 - ECO. The main elements that need to be further assessed are the inclusion of signage displays (see policy option 3), restricting the use of HFRs (see policy option 3) and more lenient requirements for newer display technologies (see policy option 4).

Subsequently, the policy options considered for this impact assessment are listed in Table 1 (detailed description in the next sections):

Table 1: Policy options

Option

Name

Short name

Description

Option 1

Baseline

BAU

No further action, the current regulations regarding televisions stay in place unchanged, no scope extension to other displays.

Option 2

ECO

ECO

Set the Ecodesign limits at a maximum Energy Efficiency Index (EEI) level of 0.9, reducing it to 0.75 after 3 years and 0.6 after 5 years.

Rescaling the label, leaving the top two classes empty.

Extending scope for on-mode energy use to computer monitors and improve definitions.

Introduce circular economy requirements for a number of displays.

Option 3

Ambitious

Ambi

As ECO but with inclusion of signage displays in the energy label nd.

Option 4

Lenient

Leni

As ECO but with a lower ambition level through a “50% allowance” for UHD/HDR displays (which allows them to satisfy ecodesign requirements more easily).

5.1.What is the baseline from which options are assessed?

In the baseline, the current Ecodesign and Energy Labelling Regulations and all other relevant EU-level policies and measures are assumed to continue.

The requirement in the ETS to reduce emissions (from amongst other electricity production) will impact electronic displays in a baseline scenario. Indeed, if the energy consumption of electronic displays is not reduced, the indirect emissions (i.e. from electricity consumption) of electronic displays relative to the allowed emissions will increase. This either leads to higher ETS prices (which could in turn increase electricity prices) or to the need for additional emission reductions in ETS sectors (higher renewable energy targets or more reductions in industry).

Sections 2.1, 2.2 and 2.3 have described how the situation will evolve in a baseline scenario in terms of energy savings, circular economy and scope.

Table 2: Intervention logic

  

5.2.Description of the policy options

5.2.1.Option 1 – Baseline

This option implies that the current regulations and all other relevant EU-level policies and measures will continue, without any changes.

Figure 10 gives an estimate of annual energy use in on-mode of the EU stock of televisions, monitors and signage displays until 2030. It has to be noted that only televisions (and television monitors) (blue area) are in the scope of the current Regulations.

Figure 10: Yearly energy use in on-mode of the three most relevant types of electronic displays, in TWh, 1990-2030 (source VHK, 2018).

This shows that without further measures, the energy consumption of electronic displays will start to go up after around 2025 because of diminishing efficiency improvements and continued increase of the number of signage displays on the market.

This is largely because the sector is nearing some hard technological limits (see also Annex 4, section 6): getting beyond 5 nanometres in semiconductor manufacturing is not possible to date for electric signal processing and the development of light-chips or similar technology will take more time. Moreover, LEDs with an efficacy higher than the current market-best of 200 lm/W will be technically challenging and expensive. Although the development of so-called microLEDs (i.e. looking straight into millions of flawlessly operating LED-subpixels to create the picture without Liquid Crystals (polaroid and filters)) is advancing, and might bring the next step-change in energy efficiency, it has to be noted that the development and commercial mass production of microLEDs in conventional television sizes is considered as a major investment. This would probably mean at least a doubling of the ‘normal’ investment, which for a modern but still conventional display factory is over 10 billion Euros 80 .

In this context, the question is whether the sector would make such investments if there is no commercial incentive through an up-to-date energy label and no regulatory pressure of ecodesign requirements phasing out the worst performing products from the market. While EU regulations are not the only driver in this sector, evidence shows that countries worldwide are regulating television efficiency and are looking at the EU to take the lead.

In conclusion, regulating electronic displays under Energy Labelling and Ecodesign is an important driver for energy efficiency and climate change abatement where the EU can tip the global balance in moving to the next stage of innovation. Without such regulatory pressure, the BAU assumes that further major efficiency gains will not materialise, and that with the increasing volume of displays, total energy consumption will go up.

To properly assess the impact of the different policy options, the BAU scenario includes signage displays. In this way, it has been possible to take into account the increasing market share of signage displays and their impact on the energy consumption of the products in the scope of the impact assessment.

5.2.2.Option 2 – ECO

The ECO scenario includes the following measures for the Ecodesign and Energy Label scope, test standard and metrics, energy efficiency limits and circular economy.

Table 3: Proposed measures under Option 2-ECO

Identified problems

Proposed measures

Problem 1: Outdated energy efficiency requirements

1.Update Ecodesign energy efficiency limits

2.Rescale Energy Label

3.Update test standard and calculation method

Problem 2: Outdated scope

4.Extend scope and improve definitions

Problem 3: Poor 'circular economy' performance

5.Set requirements for dismantling, plastic marking, halogenated flame retardants, EPS

Measures related to Problem 1

Measure 1: Update Ecodesign energy efficiency limits 

According to the Ecodesign framework Directive, minimum energy efficiency requirements should be set at the Least Life Cycle Cost (LLCC) level, provided there are no significant negative impacts. In principle, the LLCC can be calculated from purchase price (PP), lifetime of the unit (N in year), operating expense (OE), end-of-life costs (EoL), discount rate (d) and escalation rate (e). This assumes that the cost for improving the energy efficiency of a product is related to the price of that product: the price increases due to the cost for changing the product to improve the efficiency (this is the case for household appliances and lighting).

However, research 81 and market data (Annex 6) have shown that for consumer electronics and ICT products (including televisions), their price does not relate to the efficiency of the product. In fact, for displays, over the last 10-15 years, usually around one year after a new development, the average price of displays dropped, e.g. from EUR 800 in 2005 to EUR 450 in 2017, while at the same time the energy efficiency increased (up to 7-8 % per year).

Product price is largely driven by the size of the display, processor power, operating system characteristics, "smart" features (such as gaming, browsing or streaming), number of external interfaces, audio capabilities, screen curving, contrast ratio and luminance and capabilities newly introduced in the market. High prices are asked for new products with high performance features. Once on the market, the price of these products will decrease (exponentially) until they are superseded by new products with improved functionality or new features.

This means that a specific LLCC-point cannot be determined but rather an economically reasonable pace of improvement needs to be determined in the light of the iterative impact analysis on display databases compiled since 2012 to determine cut-off and trends over the years. The latest database with energy efficiency information used for the calculations was created in January 2018 82 and covers over 600 models offered on-line until December 2017. Database analysis can be found in Annex 13.

Moreover, an analysis of requirements in other jurisdictions was undertaken to verify whether that was some level of alignment given the global nature of the display market. Figure 11 shows the minimum energy efficiency limits around the globe in comparison to the proposed EU values. More details on efficiency schemes, inside and outside the EU, are provided in Annex 8.

Figure 11: Proposed EU Ecodesign limits for 2020, 2022, 2024 in comparison to 2012 EU limit and non-EU limits for on-mode power in Watt per viewable surface area in dm².

The proposed EU Ecodesign limits follow maximum Energy Efficiency Index values of EEImax=0.9 EEI (tier 1, one year after entry into force), EEImax= 0.75 EEI (tier 2, three years after entry into force) and EEImax=0.6 EEI (tier 3, five years after entry into force).

Apart from this new on-mode requirement, stricter requirements for other modes are also proposed, i.e. 0,3 W on off-mode, 0,5 W in standby and 2 W/6 W in network standby. Allowances are proposed for the features of Auto Brightness Control (ABC) and for presence sensors (switching off the display would the room be empty or the user fallen asleep). For signage displays, no minimum efficiency requirements for on-mode are proposed, as available data is not sufficient to set meaningful limits.

Based on the analysis of the available energy consumption data, for UHD/HDR displays an allowance of 20 % on the EEI is proposed to take into account their intrinsically higher energy consumption (which is on average 20 % higher than HD displays).

Figure 12: Proposed Labelling top class compared with non EU energy efficient top class displays

Stakeholder views: Some television manufacturers and some monitor suppliers consider the requirements too ambitious for some niche displays, although laboratory tests have not identified any reason for setting specific allowances (see Annex 13, Intertek tests). An exemption, limited in time, for OLED displays is proposed to take into account the relative youth of this technology and its low environmental impact at end of life. No major objection was raised by European manufacturer organisations on power limits in other modes than on-mode.

The Open Public Consultation (OPC) resulted in 64% of respondents considering the explicit indication on the label of power use in HDR influencing their purchase choice (with 16 % preferring to include this parameter in a single indicator) and 60.5 % asking to have the parameter clearly indicated.

Measure 2: Rescale the Energy Label

As per the new Energy Labelling framework Regulation, the updated energy label for displays would leave the ‘A’ and ‘B’ energy classes empty when the label is introduced, i.e. by April 2020. The estimate of Best Available Technology (BAT) and Best Not yet Available Technology (BNAT) are as follows:

BAT: UHD/HDR is 0.76 W/dm2 for a 55” TV display and 0.72 W/dm2 for a 60” TV display. HD 0.53 W/dm2 for a 49” TV. The computer monitor 83 that the US Energy Star rates as ‘best in class’ consumes 0.85 W/dm2. All in all, BAT is close to the current A+++ class limit.

BNAT: micro-LEDs promise a factor 2.5 to 3 improved energy efficiency over OLED with better picture quality. This would mean a value of 0.4 to 0.5 W/dm2. Indium Gallium Zinc Oxide (IGZO) panels are a promising efficient technology for high-end portable computers/tablets, but identifying the specific power for a commercial IGZO screen that is optimised for efficiency was not possible so far.

The proposed energy classes provided in table 4 below are not directly comparable with the current classes 84 . However, Figure 13 illustrates how the new A-G class limits relate to the existing A+/A++/A+++ class limits.

Table 4: ECO energy efficiency classes

Energy efficiency class

New EEI

A

EEI ≤0.30

B

0.30 <EEI ≤0.40

C

0.40 <EEI ≤0.50

D

0.50 <EEI ≤0.60

E

0.60 <EEI ≤0.75

F

0.75 <EEI ≤0.90

G

0.90 <EEI ≤1.10

Figure 13: Approximate comparison between new and old energy labelling classes.

The proposed Ecodesign requirements will be synchronised with the Energy Label: Tier 1 in 2020 will eliminate high definition (HD) displays falling in the new ‘G’ class (but G-class will still apply to UHD products), which is similar to the current A+ and lower. Tier 2 in 2022 will eliminate HD displays in the new ‘F’ class and UHD ones in the ‘G’ class. Tier 3 in 2024 will eliminate HD displays 85 in the new ‘E’ class and UHD in the ‘F’ class.

Figure 14 shows the proposed energy classes in comparison with two other non-EU labelling schemes with multiple energy classes (the numbers inside the coloured bars are Watts of energy use in on-mode, as the y-axis indicates 86 ).

Figure 14: Proposed label classes compared with non-EU labelling schemes for a 40" (44dm2) HD display.

Stakeholder views: Industry stakeholders consider the proposed label classes after rescaling rather ambitious, while NGOs would prefer even more ambitious levels. Stakeholders also commented on a provisional draft of the label, generally suggesting not to overload it with indications considered not crucial for a fair comparison of different displays models. No consensus was identified on specific aspects such as printing the label on the display packaging, indicating on a separate scale the power use for SDR and HDR (manufacturers in favour, some MS hesitant) or indication of annual energy use (details in Annex 5). 75 % of respondents to the OPC considered it important to indicate the resolution level of displays, a parameter not present on the current label.

Measure 3: Update test standard and calculation method

The test standard will be adapted through a mandate to ESOs (European Standardisation Organisations) 87 , in accordance with the global International Electrotechnical Committee (IEC) 62087 standard, adjusted to fit the EU’s needs (but still largely comparable to the rest of the world, except for China see Figure 15 and Annex 8). This will inter alia include an update of the testing modalities to cope with higher resolutions (UHD-4K), larger colour gamut, and contrast ratios (‘HDR’), and to mitigate the risk of defeat devices 88 .

Figure 15: Use of the IEC 62087 standard worldwide (source: Catriona McCalister, Jeremy Tait for SEAD; www.superefficient.org)

At the same time, the calculation method will be adapted to address the relative advantage that bigger displays have in meeting the energy efficiency requirements for the different classes on the label.

Stakeholder views: All stakeholders supported the update of the test standard as it would better reflect real life conditions and help avoid circumvention. A testing method for ABC has been repeatedly discussed with manufacturers’ representatives. Since the first Consultation Forum meeting (see Minutes in Annex 5.3), the majority of stakeholders were also in favour of a calculation method that was based on a logarithmic regression line 89 , as this would be more stringent for the largest TVs.

Measures related to problem 2

Measure 4: Update scope, improve definitions

The scope of both Ecodesign and Energy Labelling would be extended from televisions to monitors and signage displays. For Ecodesign only, standby and non-energy requirements are extended to professional and commercial monitors as well. No requirements for on-mode energy efficiency are proposed as this professional market is very specialised.

These products are currently already covered by the horizontal standby Regulation 90 . However, standby requirements will be included in this revised Regulation to reduce administrative burden (all requirements for these products will be in one single regulation).

The energy savings that can be achieved from very small displays are not considered significant. Moreover, minimum efficiency requirements could interfere with the functional specifications for certain special purpose displays. Therefore, full or partial 91 exemptions for small displays 92 , special purpose displays (medical, broadcast, security displays, etc.), digital photo frames, projectors, displays in means of transport are proposed to ensure an appropriate balance between energy savings to be realised and estimated administrative burden.

Finally, this option does not include energy efficiency requirements for signage displays. While this is a growing market, little data is available on their energy efficiency (other than that it is typically higher than that for ‘normal’ displays) and they comprise a wide range of different products (see Annex 6.3 for further details). They are however covered by material efficiency and information requirements.

Stakeholder views: Since the first Consultation Forum a majority of Member States and NGOs agreed on extending the requirements to electronic displays other than televisions, including computer monitors and signage displays (see minutes in Annex 5). Industry representatives on the contrary considered that signage displays are a very specific market about which too little is known to justify setting minimum efficiency requirements and for which specific test standards would have to be developed. Moreover, manufacturers requested exceptions for specialised displays with distinct characteristics, and temporary extensions for new, emerging technologies, such as OLED. Manufacturers are also in favour of moving standby requirements for all displays into the "vertical" regulation on displays, as this would mitigate the administrative burden.

Measures related to problem 3

Measure 5: Set circular economy requirements

A number of requirements were discussed extensively with stakeholders throughout the revision process, and include:

Requiring components subject to the WEEE Directive to be safely and easily removable 93 ;

Marking of plastics components >50g;

Requiring repair information relevant for replacement of defective components;

Requiring detailed documentation on the presence and chemical composition of flame retardants in components 94 ;

Requiring stickers/marking on the back cover and internally on the panel, indicating whether the product contains mercury (‘Hg’ icon) and/or cadmium (‘Cd’ icon), which are substances considered particularly toxic and needing specific manipulation by staff at recycling centres;

-Encouraging the use of standardised “universal” external power supplies (EPS), 95 by including a logo on the energy label indicating whether a standardised EPS is provided with the product.

As regards reparability and durability, replacement of the entire display panel is technically feasible. However, the replacement costs are too high compared to the cost of a new display, to justify requirements on availability of spare panels.

While the requirement to provide information on the presence and chemical composition of flame retardants would in itself not reduce their presence in plastic parts, it would allow recyclers to identify them easier and avoid health risks during the recycling process.

Stakeholder views: Manufacturers and other industry sectors, particularly FEICA 96 , as well as some third countries 97 , strongly objected to a dismantling requirement that, in their view, would overly restrict the use of gluing techniques as was proposed in a draft discussed at the Consultation Forum in December 2014. An alternative requirement, proposed to the Consultation Forum in July 2017 satisfied manufacturers, but recycling and repair industry associations, and NGOs were critical (see Annex 2 and Annex 5.1).

Recyclers would also like to see a requirement for a minimum amount of recycled plastics in new products, although this would complicate compliance control by Member States. The Open Public Consultation (OPC) showed that 67% of respondents preferring a display with a standardised EPS and 63% considering it important to have it indicated on the energy label (as an indicator of durability/reparability).

The latest draft working document presented to the Ecodesign Consultation Forum in 2017 contained a proposal for marking and detailed information requirements regarding type and quantity of the flame retardants. This proposal met with criticism regarding the administrative burden for industry and market surveillance authorities. It was also questioned whether recyclers would really act on the availability of this type of information. On the other hand, recyclers and NGOs were in favour of a total ban of at least halogenated flame retardants, as any plastic containing any type of halogenated substance (mostly bromine compounds) is currently incinerated because separation of allowed additives from non-allowed ones is economically unsustainable.

5.2.3.Option 3 - Ambitious 

Option 3 includes the same measures as option 2 but with an extension of the scope of Energy Labelling to include signage displays, and restricting the use of halogenated flame retardants in the enclosure and stand.

Inclusion of signage displays in the energy label

Most signage displays consume on average 2.5 times more energy than a television of the same size 98 and it is a rapidly growing market. While setting minimum efficiency requirements under ecodesign would be premature, their inclusion in the energy label would allow customers of these displays to be informed about their efficiency and be able to compare their performance. Labelling of signage displays, moreover, would be a useful, reliable and efficient tool in public procurement, in view of Directive 2012/27/EU, Annex III.(a) which requires Member State governments to procure only products in the highest efficiency classes of the energy label.

The energy label for signage displays would be similar to the one for televisions and computer monitors. The EEI is adapted to take into account the higher luminance of signage displays, through a correction factor for peak luminance applied to the EEI formula.

Phasing out halogenated flame retardants

This option involves restricting the use of any HFRs in the display-casings and stands by April 2020, while maintaining the requirement to document the presence of any type of flame retardant as per the ECO option.

This has become feasible since, by June 2019 (i.e. almost one year before the proposed application date), a new safety standard EN 62386-1:2014 will supersede the old standards in the EU, thereby removing the ‘candle’ test. As a result, restricting the use of at least halogenated flame retardants in the casings and stands should be feasible for manufacturers. In fact, several display manufacturers are already making the switch to non-HFR such as phosphorous, inorganic and nitrogen-based flame retardants. Some display manufacturers claim that all brominated flame retardants were eliminated already a long time ago, not only from the enclosure and stand, but even from connectors, circuit boards and other internal components 99 .

Stakeholder views: Throughout the consultation process, several Member States and NGOs advocated for the inclusion of signage displays in the scope of the Regulations (see Annex 5). Manufacturers never expressed "a priori" opposition but argued for specific tests and requirements, possibly adapted from televisions and monitors.

Many stakeholders in the Consultation Forum in 2012 (Annex 5.3) already solicited the Commission to introduce "non-energy" requirements and signalled in particular that the use of certain flame retardants was hindering recycling. However, some product manufactures and the representatives of producers of halogenated flame retardants (FRE) consider that RoHS or REACH legislation may be more appropriate for restricting the use of certain substances 100 .

In the Consultation Forum of 2014 (Annex 5.2), the proposed resource efficiency requirements were supported by an overwhelming majority of stakeholders. However, some specific requirements, such as time limits as an indicator for compliance of dismantle-ability, were criticised by industry representatives as being overly prescriptive.

5.2.4.Option 4 - Lenient 

Option 4 includes the same measures as option 2 but with a more lenient minimum energy efficiency requirement under ecodesign for UHD/HDR displays by allowing for a 50% higher on-mode consumption. In the Eco and in the Ambi options only 20% is foreseen 101 and no limit is set for HDR displays.

Stakeholder views: Several major manufacturers strongly requested a 50% allowance since the consultation forum meeting in 2014, to avoid stifling innovation and depriving consumers from the latest technology. On the contrary, NGOs and some Member States have supported an ambition level comparable or even higher than the ECO option.

Throughout the consultation process, most of the Asian manufacturers have requested generous energy allowances for every new feature that came on the market, such as a 50% bonus for 3D-TVs and a bonus of 50% for UHD-4K resolution compared to HD. Data analysis on the displays of 2016 and of end 2017, however, shows a clear trend to a power use for UHD resolution closer and closer to HD.

5.3.Option discarded at an early stage: Voluntary agreement by the industry

A voluntary agreement has to be given priority according to the Ecodesign Framework Directive, provided it meets the objectives in a quicker and more cost-effective manner. Today minimum mandatory requirements are already in force. Since no proposal has been put forward by industry, there is no voluntary agreement that meet the conditions of the Ecodesign Directive. As a consequence, this option is discarded from further analysis. When substituting mandatory requirements by a voluntary agreement there would be a risk of free riders 102 , in case not all actors present on the market would sign such an agreement and comply with it.

Stakeholder views: None of the stakeholders is in favour of voluntary agreements for the reasons set out above.

5.What are the impacts of the policy options?

The options for further analysis include BAU, ECO, Ambitious (Ambi) and Lenient (Leni) scenarios as described above.

6.1.Methodology and key assumptions 

The latest draft working document presented to the Ecodesign sources. Digital Europe delivered in 2012, 2014 and in 2016 datasets of televisions, computer monitors and some signage display models (600 or more models). Other databases, including 2017 models, established by CLASP, VHK and Intertek were used as well. For more information, please see Annex 13, which also contains the outcome of an Intertek measurement test for the Commission on computer displays.

Employment impacts are derived from revenue per employee, checked against reported revenue totals for the sector and information from annual reports of individual manufacturers.

In this Impact Assessment, in line with the MEErP 103 , energy prices were assessed from Eurostat data and for future projections an escalation rate of 4% was used, together with a sensitivity analysis based on the most recent PRIMES rates (0.95% escalation rate from 2020). All prices and costs are expressed in Euro 2010, calculated with historical inflation. For investment-type considerations, a discount rate of 4% is used, in line with the Commission's recommended values (see guidelines in the Better Regulation Toolbox).

For primary energy conversion rates for electricity generation and distribution, a Primary Energy Factor (PEF) of 2.5 is used, implying, by convention, a 40% efficiency over the full projection period. For GHG emissions, the emission rate (in kg CO2 eq./kWh) varies over the projection period in line with overall EU projections as indicated in the MEErP. More details of the modelling can be found in Annex 4.

Figure 16 illustrates the expected trend in energy labelling under the ECO-scenario (only TVs and monitors in the scope). Under the Lenient scenario (with a credit of 1.5 instead of 1.2 for UHD/HDR) the lower classes will include more products (as more products are allowed on the market under Ecodesign). In the Ambitious scenario, where inefficient signage displays are in the scope, it is also expected that the lower energy label classes will be more populated.

This projection assumes a progression of 7.5% per annum improvement in energy efficiency – thus, each model in the 2018 database is improved by 7.5 % for 2019, and a further 7.5 % for 2020 and so-on. This rate of technology progression matches the levels observed in the market from 2011 through 2017 and also takes into account some new technology being introduced to televisions including quantum dots and logical pixels. Moreover, it assumes that half the models in the database adopt Automatic Brightness Control, which offers a power allowance of 15 %.

Figure 16: Energy label class distribution of standard electronic display models available in the EU over the period 2010-2030 (actual 2013-2016 and projections 2017-2030) with proposed Ecodesign and Energy Labelling measures.

It has to be noted that there are considerable uncertainties in future projections for this highly ‘volatile’ product group and consumption and savings estimates should be conceived as ranges within a certain bandwidth.

No direct relation appears to exist between retail prices and the level of energy efficiency. Topten analysed this specific aspect on television models, using sales data from GfK 104 : Figure 17 shows that, whilst there is a clear correlation between screen size and cost, there is no clear relation between energy class and cost (e.g. the A++ class has an average cost lower than A+ and A and close to B). Moreover, as explained further, the formulas for calculating the energy class in the current regulation are advantageous for the biggest displays, thus the highest classes tend to be more populated with bigger displays.

Figure 17: TV average retail price according to display size and to energy classe for 40-50 inch television displays (source: Topten on GfK data for 2012).

6.2.Environmental Impact 

6.2.1.Electricity savings

Figure 18 shows the development of EU energy consumption of electronic displays under the different scenarios. The graph indicates that:

In 2020, the BAU-scenario predicts 94 TWh/yr electricity consumption, equivalent to the 2016 final electricity consumption of Belgium.

In 2030, the BAU scenario is estimated to result in 4 TWh/yr additional electricity consumption due to the lack of updated energy efficiency requirements, while the size and number of televisions keeps rising.

The ECO scenario gives 24 TWh/yr additional savings in 2030 with respect to the BAU (equivalent to Irish final electricity consumption in 2013), while the Lenient scenario (‘Leni’, green line) saves 16 TWh/yr in 2030.

The ‘Ambi’ scenario combines the ECO scenario with labelling for signage displays 105 , which will save an additional 15 TWh/yr in 2030. In total, the saving of the ‘Ambi’ scenario is estimated to be 39 TWh/yr in 2030.

Figure 18: Energy consumption scenarios 1990-2030 electronic displays

The significant savings in all scenarios are driven by technology improvements, underpinned by the proposed measures, which counteract the increase in energy consumption in the BAU scenario. In the BAU scenario, the energy consumption of electronic displays will start to go up after around 2024 because of diminishing efficiency improvements and continued increase of the number of signage displays on the market.

Stakeholder views: Already since the second of the four Ecodesign Consultation forums (2012), there was a consensus among all stakeholders on the need of reviewing the Ecodesign Regulation, because the technology progress had been quicker than expected and some further adaptations would be cost effective, such as scope extension to computer monitors and signage displays.

In 2014, stakeholders requested to delay the review of the Labelling measure until after the revision of the framework Directive. The third Consultation forum in 2017 further confirmed the need to come forward quickly with revised Ecodesign and Labelling regulations, and confirmed the need to address signage displays.

Manufacturers always advocated for less strict requirements for UHD and for the exclusion of new technologies from Ecodesign, such as OLED and HDR. They also requested a different energy efficiency index and other specific requirements for signage displays, such as the removal of the "auto power down" requirement.

6.2.2.Greenhouse Gas Emissions

The trends in scenarios for greenhouse gas (GHG) emissions are similar to the energy consumption trends. The main difference is that the absolute savings over time are higher, as the energy scenarios use, by convention, a fixed power generation and distribution efficiency of 40 %, whereas for the projections of the GHG-emissions the changes in carbon-intensity of electric power generation are taken into account. As a result, figure 19 shows that by 2030 (compared to 2015):

the BAU scenario gives a saving of 7 Mt CO2 eq.;

the ECO scenario saves an additional 7 Mt compared to BAU;

the Ambitious scenario saves 13 Mt more than BAU; and

the Lenient scenario gives an extra 5 Mt savings with respect to BAU.

Stakeholder views: Stakeholders never raised specific views on GHG emissions as they are closely linked to the energy requirements (see above). However, manufacturers have sometimes voiced the concern that, as improvements in the use-phase are increasing the relative importance of energy consumption and emissions during the manufacturing stage, where certain greenhouse gases are used 106 .

Figure 19: EU greenhouse gas over the period 2005-2030, in Mt CO2 equivalent, for various scenarios

6.2.3.Circular Economy perspective

The environmental life-cycle assessments in the technical review studies show that energy consumption and the related emissions, especially GHG emissions, are dominant environmental impacts for this product category.

Televisions and monitors are subject to the WEEE-directive. From August 2018, the recovery rate for these products must be 85 % with at least 80 % recycled. To facilitate recycling, the removability of key components as per Article 8(2) of the WEEE Directive is important.

Presence of (in particular halogenated) flame retardants in plastics is the main barrier to plastics recycling. Through the measures proposed in all scenarios it is estimated that an additional 76 kt plastics could be recycled instead of being incinerated. These measures would also prevent the introduction of 20 kt/year of halogenated flame retardants on the market.

Halogenated compounds degrade into dioxin derivatives, particularly when heated, such as during production, recycling or even exposure to sun. Electronic waste is often melted to recycle the metal components and such heating can generate toxic dioxins and furans. Poor-quality incineration, similarly, releases high quantities of toxic degradation products. Consequently, recycling can contaminate workers and communities near recycling plants. In humans, HFRs have been shown to cause reproductive abnormalities, diabetes, thyroid dysregulation, cognitive changes and undescended testicles in new-born boys (see also Annex 15).

There is no administrative burden for industry and distributors and a limited burden (laboratory spot-checks but no paper trails to check) for surveillance authorities.

Stakeholder views: Already since the Consultation Forum of 2012 (Annex 5.3), Member States and NGOs required the inclusion of circular economy requirements. The recycling industry argued that gluing and welding pose problems for the recycling process for the safety of workers, the environment and the increased contamination of the waste stream, particularly PMMA 107 boards (see e.g. EURIC position, Annex 5.1). At the same time, the chemical industry claimed that research is ongoing for more compatible glue compositions making depollution and de-bonding possible.

Recyclers and NGOs also systematically requested a ban of flame retardants, or at least of halogenated ones (Annex 5.1 and 5.2), while manufacturers claimed that this may involve the redesign of some products.

6.3.Business impacts

6.3.1.Business revenue

As mentioned before there is no demonstrated correlation between energy efficiency and the price of the displays 108 . In other words, there is no rational basis for establishing whether the prices and thereby business revenues and jobs will be different from Business-as-Usual (BAU) in the various policy scenarios. For the BAU we will assume the price (EUR 448/unit for a TV) and sales established in Annex 6.

‘Business impacts’ is a part of the Impact Assessment report that should give the impact of policy options on the European industry. As mentioned, there are no longer any European TV-panel manufacturers 109 . There is a ‘business impact’ of the measures from lower energy costs of operating signage displays for companies and institutions (shops, schools, public transport). This is taken into account in the consumer expenditure section hereafter.

As mentioned in section 2.5, another ‘business impact’ comes from recyclers who are a party most interested in the phasing out of halogenated flame retardants, better disassembly, etc. In addition, the 5000-10,000 persons estimated to be involved in display repair will benefit from better disassembly and repair information.

6.3.2.Innovation, Research and Development, Competitiveness and Trade

There is no EU industry for display panels nor, given the huge investment needed to set up a manufacturing plant and the current market situation 110 , is it likely that it will develop in the near future. Hence, although an EU university or research institute might get an occasional assignment from an Asian industry to work in a related field, there is no relevant Research and Development in the field of display-technology in the EU. In short, most innovation in this sector will come from Asia. The EU is still an attractive market of 500 million relatively wealthy consumers. Setting ambitious mandatory minimum Ecodesign requirements, combined with a stimulating Energy Label scheme, will positively influence innovation.

Improving the potential yields of usable recycled material will encourage the development of technologies to treat properly waste from electronic displays, possibly in larger scale plants.

Trade data lack accuracy because the Asian display panels enter and leave the EU through various routes and in various forms (as an entire product, or just the display panel). All display panels and 80% of other components are imported.

6.3.3.Compliance costs

Ecodesign and energy label requirements for televisions and displays in the scope have had a strong influence on the market and have been in existence for almost 10 years.

Research and development as well as production investments are common practice in this innovative and dynamic sector. Redesign would happen with or without new measures. Any potential extra cost is expected to be absorbed by the industry. With or without the measures, manufacturers will be obliged to test their products according to the new test method, to compete on the global market. Therefore, costs from testing according to the new standard will be the same for all options.

6.3.4.Intellectual property rights

The technologies considered in all scenarios are commonly available to all major manufacturers and, as confirmed by stakeholders, the measures do not impose proprietary technologies.

6.3.5.Stranded investments

In the case of electronic displays, stranded investments may arise in Asia but not in the EU since there is no production. Stakeholders did not raise the issue.

6.4.Consumer expenditure

Consumer expenditure consists of acquisition costs, maintenance/repairs and running costs. In this case, where repair costs are modest (estimated in the order of EUR 0.5 bn/year), they are assumed to be included in the acquisition costs. The running costs consist thus only of energy costs.

As explained before, it is not possible to differentiate between acquisition costs per unit in the various scenarios. The only acquisition cost differentiation is between a scenario including signage displays and a scenario excluding signage displays and in the difference in unit sales for these two scenarios. The average price of a signage display is set at twice the price of a normal television, because it is twice the average surface area and generally used in a more demanding environment (e.g. high ambient lighting, outdoors).

In 2020, the acquisition costs excluding signage displays in the EU are calculated at EUR 25.8 bn, of which standard TVs make up EUR 5.9 bn, smart TVs EUR 17.6 bn and monitors EUR 2.4 bn (all incl. VAT). Including signage displays, at acquisition costs of EUR 3.6 bn (excl. VAT 111 ), the total acquisition costs are EUR 29.4 bn.

In the same year, the total energy costs are EUR 17.7bn excluding signage displays and EUR 23.5 bn including signage displays. For signage displays the nominal energy costs and acquisition costs add up to EUR 9.4 bn. For TVs and monitors, the sum of energy and acquisition costs is EUR 43.5 bn, of which the energy costs are around 35 %. Including also signage displays, the total becomes EUR 52.8 bn in 2020 as shown in

Table 5 : Estimated costs of electronic displays in 2020

In EUR billion

Acquisition costs

Energy costs

Acquisition and Energy costs

TVs and monitors

25,8

17,7

43,5

Signage displays

3,6

5,8

9,4

Total

29,4

23,5

52,8

.

Table 5: Estimated costs of electronic displays in 2020

In EUR billion

Acquisition costs

Energy costs

Acquisition and Energy costs

TVs and monitors

25,8

17,7

43,5

Signage displays

3,6

5,8

9,4

Total

29,4

23,5

52,8

In accordance with the MEErP methodology, the escalation rate for the electricity price is 4 %. Inflation – to arrive at euros 2010 – follows historical tariffs as available and 2 %/yr thereafter. Figure 20 shows that the ECO scenario will save the consumer EUR 8 bn/yr in 2030 compared to BAU. The Lenient scenario will save EUR 6 bn/yr. When including signage displays, it is assumed that the ‘Ambi’ scenario would add another EUR 10 bn/yr savings to the ECO scenario and thus result in a total saving of EUR 18 bn.

Figure 20: Consumer expenditure scenarios 1990-2030 (in fixed euros 2010).

6.4.1.Sensitivity analysis

The consumer expenditure above has been calculated according to the MEErP with an escalation rate, i.e. a price increase above inflation, of 4 %. This means for instance for 2030 a household electricity tariff of EUR 0.36/kWh (in Euro 2010). Recent PRIMES scenarios use a considerably lower tariff, which on average results in an escalation rate of 1.5 %. This means a tariff of EUR 0.24/kWh (in Euro 2010) for 2030.

The sensitivity analysis presented in the table below gives the consumer expenditure and energy costs at this lower tariff, in order to validate whether this would make the scenarios uneconomical for consumers. The costs are given per year (2015-2040) and accumulative over the periods 2021-2030 and 2021-2040.

Table 6. Scenario results with electricity tariff escalation rate 1.5%(from 2015) instead of 4%

Consumer expenditure (in bn Euros 2010)

per year

accumulative

 

2015

2020

2025

2030

2040

'21-30

'21-40

BAU

43

50

53

61

65

542

1176

ECO

43

50

52

57

58

527

1097

Lenient

43

49

51

55

58

515

1078

Ambi

43

47

47

51

52

478

988

Energy costs (in bn Euros 2010)

 

2015

2020

2025

2030

2040

'21-30

'21-40

BAU

19

20

20

24

28

212

475

ECO

19

20

19

20

21

197

397

Lenient

19

19

18

19

21

185

377

Ambi

19

17

15

14

15

148

288

The most important outcome is, although monetary savings are of course lower than at an escalation rate of 4 %, the energy costs are still a substantial part of life cycle costs and savings are worthwhile in all scenarios.

6.5.Administrative burden

In the impact assessment prepared in view of the revision of the Energy Labelling framework Regulation 112 the administrative burden of the new measures under that regulation was calculated. Table 7 summarizes those costs for the product group of electronic displays.

For Ecodesign measures, the above-mentioned impact assessment study considers that there is no additional administrative burden for industry, because there is a vested commercial interest 113 . More details can be found in Annex 12.

Table 7: Administrative burden in '000 euros 

Administrative burden

one-off

annual

BAU

For the first 6 months provide a second label and supply extra labels on request to dealers

3300

-

Dealers re-labelling around 2.5% of products on stock/display or on the internet.

600

-

Database, supplier costs

90

-

Database, EU budget

90

9

-

Joint support actions, EU budget (e.g. EEPLIANT)

33

x

Support joint surveillance actions (Horizon2020)

60

x

External laboratory costs (SMEs)

66

x

Market surveillance, Member State costs

 

330

x

Total business-as-usual (BAU)

-

489

Total new costs of measures

3990

99

of which

- Supplier budget

3300

90

- Dealer budget

600

-

- EU budget

90

9

Stakeholder views: No issue was raised regarding affordability.

6.6.Social Impact

6.6.1.Affordability

As mentioned before, there is no direct relation between the energy efficiency level of electronic displays and their retail price. Moreover, the new technologies generally bring – after the first introduction period – both an energy efficiency increase and a price decrease. In that sense, no negative impact on affordability is expected.

Stakeholder views: No issue was raised regarding affordability.

6.6.2.Health, Safety and Functionality Aspects

There are no known negative impacts from using more efficient appliances as prescribed by the policy options. Reduced/no use of flame retardants, some of which are toxic, would be beneficial for workers in WEEE plants (for further details see section 6.2.3).

6.6.3.Employment

No significant impact of the proposed measures on EU employment is expected. No product price increase is expected due to higher efficiency. The measures to improve resources efficiency have mostly neutral or positive business impacts.

Stakeholder views: No issue was raised regarding employment.

6.6.4.SMEs

As mentioned in section 2.5, no independent SMEs working in the production chain of electronic displays could be identified 114 . SME retailers do exist, but it is not expected that the specific measures proposed here will have a significant impact on them. The 5,000 to 10,000 SME repair shops will benefit from better repair information and easier disassembly. Likewise, SME recyclers will benefit, in the long term, from the elimination of HFR for non-electric components and from measures for easier disassembly.

6.How do the options compare?

7.1.Summary of the impacts

Tables 8 and 9 summarise the impacts described in Section 6. Option 1 – baseline – does not contribute to any of the objectives. Option 2 – ECO – contributes to all objectives but does not achieve as many cost effective energy savings as option 3. Option 4 – lenient – only contributes to two out of three specific objectives (does not achieve cost effective energy savings) and it is therefore not seen as an appropriate policy option. Option 3 – Ambitious – contributes to all three objectives and achieves most cost-effective energy savings. Therefore, Option 3 is the preferred option.

Table 8. Overview main annual impacts of the policy options

Impact (unit)

2020

2030

2040

absolute

absolute

increment

absolute

increment

BAU

BAU

Leni

ECO

Ambi

BAU

Leni

ECO

Ambi

On-mode specific power stock (W/dm²)

1,82

1,20

-0,31

-0,50

-0,58

0,83

-0,28

-0,40

-0,45

Electricity consumption (in TWh/yr)

94

98

-16

-22

-40

98

-22

-25

-45

GHG emissions (in Mt CO2 eq./a)

33

28

-6

-7

-14

29

-7

-7

-13

Material resources inputs (in kt) [1]

770

1185

0

0

0

1438

0

0

0

Waste collected (in kt, 10yr post-input) [2]

700

700

0

0

0

1066

0

0

0

Waste recycled/reuse/recovered [3]

595

595

76

76

84

906

126

126

140

Acquisition costs (in €bn)

29

36

0

0

0

37

0

0

0

Energy costs (in €bn)

23

36

-6

-8

-15

53

-12

-13

-24

Consumer expenditure (in €bn)

50

73

-6

-8

-15

90

-12

-13

-24

EU Industry revenue (in €bn)

1

1

0

0

0

1

0

0

0

Importers revenue (in €bn)

14

17

0

0

0

18

0

0

0

Retail revenue (in €bn)

10

12

0

0

0

12

0

0

0

Total business revenue (in €bn)

25

31

0

0

0

31

0

0

0

Employment (in '000' jobs, mainly retail)

224

272

0

0

0

275

0

0

0

[1] Sales x weight. TV sales in 2020/'30/'40 was 52/69/70 m units at weight of 12/15/18kg per unit. Monitor weight in those years was 5/6/7 kg, always at 10 m unit sales. Signage display sales was 4/3/3 m units at product weight 24/30/36 kg.

[2] 90% of materials input 10 years before (trend in WEEE statistics)

[3] In BAU, recovery rate is 85% of collected waste (80% recycled) ; in policy scenarios without halogenated flame retardants and optimal disassembly some 76 kt plastics could be recycled extra (theoretical maximum at 100% and c.p.).

Table 9. Overview main accumulative impacts of the policy options

Impact (unit)

2021-2030

2021-2040

 

absolute

increment

absolute

increment

 

BAU

Leni

ECO

Ambi

BAU

Leni

ECO

Ambi

EU electricity consumption (in TWh/yr)

927

-64

-115

-277

1922

-303

-385

-744

EU GHG emissions (in Mt CO2 eq./a)

332

-22

-40

-98

648

-98

-126

-247

Consumer expenditure (in €bn)

619

-22

-38

-89

1448

-132

-162

-304

Energy costs (in €bn)

289

-22

-38

-89

615

-132

-162

-304

Acquisition costs (in €bn, incl. VAT)

325

0

0

0

691

0

0

0

Industry revenue (in €bn)

10

0

0

0

20

0

0

0

Wholesale revenue (in €bn)

158

0

0

0

166

0

0

0

Retail revenue (in €bn)

112

0

0

0

124

0

0

0

Total revenue (in €bn)

280

0

0

0

310

0

0

0

7.2.Market Surveillance

All proposed policy options would be subject to Article 15(8) of the Ecodesign Framework Directive, as well as Article 8(1) and (3) of Energy Labelling Framework Regulation, which requires that market surveillance authorities can verify the conformity of a product with all regulatory requirements.

The ComplianTV project 115 has shown that current compliance level for this product group is good and would be further improved under the Ambi scenario.

The cost for market surveillance is lowest for the baseline because in this case there would not be a new energy label. The cost for surveillance of the other options would be the same, i.e. as indicated in section 6.4. The extension of the Energy Label scope in the Ambi scenario will add to surveillance costs, but the new Energy Label database will contribute in lowering surveillance costs.

Stakeholder views: DigitalEurope have emphasised the importance of securing a sufficient level of market surveillance to ensure that only compliant products are placed on the market. In this respect, they call for increased enforcement by MSAs.

7.3.Assessment in view of Article 15(5)

According to Article 15 of the Ecodesign Directive, each policy option should not have a significant negative impact. Qualitative aspects discussed across Section 6 are summarised in Table 10 below.

Table 9: Evaluation of policy option impacts compared to the baseline

Significant impacts as stipulated in Article 15 of the Ecodesign Directive

BAU

ECO

Ambi

Leni

No significant negative impacts on the functionality of the product from the perspective of the user (section 6.4.1)

Health, safety and the environment shall not be adversely affected (section 6.6.2)

No significant negative impact on consumers in particular as regards affordability and life-cycle costs (section 6.6.1)

No significant negative impacts on industry's competitiveness (section 6.3)

Setting of an ecodesign requirement shall not have the consequence of imposing proprietary technology on manufacturers (section 6.3.4)

Impose no excessive administrative burden on manufacturers (section 6.5)

All options fulfil the criteria of Article 15(5).

Pursuant to Article 16(2) of the Energy labelling Framework Regulation, future implementing measures should fulfil a number of criteria (see Section 3.1). The criteria are fulfilled, namely:

·The product group has significant potential for saving energy;

·The proposed bands of the energy label will differentiate among displays (see section 6.1), which are today all concentrated in the top classes;

·There is no negative impact on affordability, as shown in Section 6.6.1 and Table 9 ;

All options with the new energy label fulfil the criteria of Article 16(2).

7.4.Assessment in view of the objectives

The qualitative evaluation according to the objectives presented in Section 4, on the basis of Tables 8 and 9, is shown in Table 10 .

Table 10: Score of impacts against objectives (see section 4).

General Objectives

BAU

ECO

Ambi

Leni

1. Ensure free circulation of efficient products within the internal market;

0

+

+

+

2. Promote competitiveness of the electronic display industry through the creation or expansion of the EU internal market for sustainable products;

0

0

0

0

3. Promote the energy efficiency of electronic displays as contribution to the EU's objective to reduce energy consumption by 30 % and domestic GHG emissions by 40 % by 2030;

0

+

++

0/+

4. Increase the security of energy supply in the Union through a reduction in energy consumption of electronic displays

0

+

++

0/+

Specific Objectives

1. Update the energy efficiency requirements and the energy label in line with international and technical developments;

0

+

++

0/+

2. Redefine the scope to close loopholes, remove ambiguities

0

++

++

++

3. Contribute towards a circular economy

0

+

++

+

No Change (0), slight improvement (0/+), limited improvement (+), significant improvement (++).

Option 1 – BAU does not contribute to any of the specific objectives.

Option 2 – ECO is a balanced option for televisions and computer monitors that also takes into account circular economy aspects. However, it does not take into account the rapidly growing market of signage displays and there is thus a risk that the energy savings from televisions and computer monitors will be overshadowed by an uncontrolled increase of energy consumption of signage displays.

Option 3 – Ambi builds on the ECO scenario, but the scope is extended to include signage displays, which are estimated to become a major energy consumer in the near future and could constitute a major loophole for television and computer monitors if not regulated. In addition, it contributes most to circular economy objectives through the restriction on the use of halogenated flame retardants in relevant parts of displays.

Option 4 - Leni has the least savings and thus contributes the least to the energy efficiency-related objectives.

7.Preferred option

8.1. Preferred option – Why?

Option 3 - Ambitious fulfils the criteria in Article 15(5) of the Ecodesign Regulation and Article 16(2) of the Energy Labelling Regulation (see Section 3.1) and will achieve the objectives as set out in Section 3 in the best way.

Building on option 2, option 3 brings the most savings and, in terms of avoiding loopholes, is the most robust. Therefore, it is considered the preferred option and results in the following overall net savings and impacts versus the BAU option in 2030:

·Electricity savings of 39 TWh/yr and GHG emission abatement of 13 MtCO2eq/yr, i.e. 2.66 % of the Commission’s 2030 target for final energy consumption savings (30%) and 1.22 % of the Commission’s 2030 target for GHG-emissions savings (40%);

·Savings on annual end-user expenditure of EUR 15 bn;

·Additional 84 kt of plastics could be recycled instead of being incinerated. 20 kt/year of halogenated flame retardants would not enter the EU market.

·Scope and ambition level aligned with technological progress and global minimum energy efficiency requirements in other economies.

With respect to signage displays, the fact that this option does not include minimum on-mode efficiency requirements means that there will only be limited impact on compliance cost (i.e. only for product testing but not for redesign or production).

8.2.REFIT (simplification and improved efficiency)

This section describes how the preferred option is expected to improve the efficiency of the existing measures.

Given that there is no relation between increased efficiency and product price (see section 5.2.2), it is assumed that industry, wholesale and retail revenue will not be effected by the measure. While there will be cost for industry to comply with the revised ecodesign and energy labelling requirements, the absence of a link between price and increased energy efficiency implies that those costs are absorbed as part of the normal competition pressure in this market. This also means that acquisition cost for consumers are assumed to remain the same, and that the energy cost is the only cost driving consumer expenditure as compared to the baseline. Table 11 gives an overview of the increment in cost and as compared to the baseline.

Table 11: Increment in costs, revenue and administrative burden

 

Implementation date

2030

2040

Comment

Acquisition costs (EUR million)

0

0

No correlation between acquisition cost and efficiency could be identified. Energy costs decrease.

Energy costs (EUR million)

6 000

10 000

Consumer expenditure (EUR million)

6 000

10 000

Industry revenue (EUR million)

0

0

There is no increase in revenue for industry, wholesale and retail related to the proposed measure

Wholesale revenue (EUR million))

0

0

Retail revenue (EUR million)

0

0

Administrative burden dealers (EUR million)

0.6

The increase in administrative cost is due to the introduction of the rescaled energy label and the database requirements

Administrative burden suppliers (EUR million)

3.9

0.09

0.09

Administrative burden EU (EUR million)

0.09

0.009

0.009

The administrative burden for dealers and suppliers is related to the introduction of the rescaled energy label imposed by the new Energy Labelling framework Regulation.

8.How will actual impacts be monitored and evaluated?

The main monitoring element will be the tests carried out to verify compliance with the ecodesign and energy labelling requirements. This monitoring should be done by MS market surveillance authorities to ensure that requirements are met.

The main indicator for evaluating the impact of potential ecodesign and energy labelling regulations is the achievement of a market improvement towards electronic displays with a smaller environmental impact.

For products subject to energy labelling, the main tool to monitor this indicator is the product registration database 116 that will show the progress of products placed on the market towards the highest classes.

An analysis of the products on the market (sales figures, performance, etc.) will determine if the shift towards more resource efficient products has happened as estimated, in particular based on the following sub-indicators, which reflect the general and specific objectives:

·Percentage of sales for products in the top energy efficiency classes on the label;

·Speed with which products move towards the higher efficiency classes on the label;

·Reduction of the electricity consumption and related GHG emissions of electronic displays;

·Increasing the economic savings for European consumers;

·Improving the regulatory effectiveness and efficiency of the regulation;

·Compliance with the energy efficiency requirements, i.e. maximum EEI for the different product categories;

·Compliance with the circular economy requirements, in particular:

-Restricting the use of halogenated flame retardant in the plastic parts most relevant (in size/weight/volume);

-dismantling of components relevant for the WEEE Directive;

-information requirements to facilitate reparability.

The evaluation should assess these indicators in line with the originally anticipated impacts of the policy option.

A review will be necessary in such a quickly evolving market sector within three years after entry into force. Such a review should focus in particular on the following aspects:

1.the need to update the scope and the definitions of the Regulation;

2.the need to adapt requirements as result of new available technologies, such as HDR, 3D mode, and resolution levels above UHD-8K (33,177,600 pixels), or new standards.

3.the appropriateness of setting specific on-mode energy efficiency requirements for signage displays or other displays not covered in this respect;

4.different or additional requirements to enhance durability and to facilitate repair and reuse;

5.different or additional requirements to improve dismantling at end of life and recyclability including on material efficiency aspects, such as targeting other possibly problematic flame retardants that may hinder the recyclability of plastics;

6.resource efficiency requirements for displays integrated into products covered by other Ecodesign regulations implementing Directive 2009/125/EC and in any other products in scope of Directive 2012/19/EU.

As per the Energy Labelling framework Regulation, the energy labelling delegated regulation shall be reviewed if the Commission estimates that 30% of the units of models placed on the Union market fall into class A, or if 50% of those units fall in classes A and B. The availability of data from the registration database should inform such an assessment, where necessary augmented with additional market data.

(1)       Commission Regulation (EC) No 642/2009 of 22 July 2009 implementing Directive 2005/32/EC of the European Parliament and of the Council with regard to ecodesign requirements for televisions . OJ L 191, 23.7.2009, p. 42–52
(2)       Commission Delegated Regulation (EU) No 1062/2010 of 28 September 2010 supplementing Directive 2010/30/EU of the European Parliament and of the Council with regard to energy labelling of televisions . OJ L 314, 30.11.2010, p. 64–80
(3)       Communication from The Commission To The European Parliament, The Council, The European Economic And Social Committee, The Committee Of The Regions And The European Investment Bank - A Framework Strategy for a Resilient Energy Union with a Forward-Looking Climate Change Policy. COM/2015/080 final. (Energy Union Framework Strategy)
(4)       Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions - Upgrading the Single Market: more opportunities for people and business COM/2015/550 final. 28 October 2015 . (Deeper and fairer internal market)
(5)       Ecodesign impact accounting – Overview report for the European Commission DG Energy, VHK December 2016
(6)      More reliable sales and stock data is now available and industry has collaborated.
(7)      This is exemplified by the statement of CECED (industry trade association) in the Consultation Forum from 2012: “CECED disagreed with a view that the development of TVs has not been influenced by the existing EU Regulations. It explained that industry had been working on new energy efficient technologies already during the consultation phase preceding the adoption of the Regulations.”
(8)      As an example, Japanese companies lost the TV market because they were too late with investing in LCD/LED technology. The more fast-moving a sector is, the higher the risk of being ‘left behind’.
(9)      This target is currently under examination in the ordinary legislative procedure: there is no sign that final agreement will be on a level of ambition lower than that proposed by the Commission.
(10)       Directive 2009/125/EC of the European Parliament and of the Council of 21 October 2009 establishing a framework for the setting of ecodesign requirements for energy-related products . OJ L 285, 31.10.2009, p. 10 (Ecodesign Framework Directive)
(11)       Regulation (EU) 2017/1369 of the European Parliament and of the council of 4 July 2017 setting a framework for energy labelling and repealing Directive 2010/30/EU.  OJ L 198, 28.7.2017, p. 1 (Energy Labelling Framework Regulation)
(12)       Study on the impact of the energy label – and potential changes to it – on consumer understanding and on purchase decisions - London Economics and IPSOS, October 2014
(13)      Commission Recommendation (EU) 2016/2125 of 30 November 2016 on guidelines for self-regulation measures concluded by industry under Directive 2009/125/EC of the European Parliament and of the Council; OJ L 329, 3.12.2016, p.109
(14)      Television monitors are, in short, televisions without a tuner for receiving/decoding broadcast signals. The definition in the current regulation is however far more specific and has become a source of legal uncertainty as it could also apply to computer monitors.
(15)       Regulation (EC) No 66/2010 of the European Parliament and of the Council of 25 November 2009 on the EU Ecolabel . OJ L 27, 30.1.2010, p. 1 (EU Ecolabel Regulations)
(16)      Commission Decision 2009/300/EC of 12 March 2009 establishing the revised ecological criteria for the award of the Community Eco-label to televisions (notified under document number C (2009) 1830) (Text with EEA relevance). OJ L 80, 28.3.2009, p. 3; [validity prolonged until 31.12.2019 by Commission Decision (EU) 2018/59 of 11 January 2018 ]
(17)      About a hundred television models have been certified with an Ecolabel. Requirements include e.g. absence of the most toxic flame retardant (FR) additives, design facilitating repair and dismantling at end of life.
(18)      Council Decision 2013/107/of 13 November 2012 on the signing and conclusion of the Agreement between the Government of the United States of America and the European Union on the coordination of energy-efficiency labelling programmes for office equipment. OJ L 63, 6.3.2013, p. 5–80
(19)      Directive 2012/27/EU of the European Parliament and the Council on energy efficiency, OJ L315 of 14.11.2012, p.1
(20)      GPP criteria can be found at http://ec.europa.eu/environment/gpp/eu_gpp_criteria_en.htm  
(21)      Technical background study GPP: JRC, Revision of the EU Green Public Procurement (GPP) Criteria for Computers and Monitors, JRC-IPTS and Öko-Institut e.V, November 2016.
(22)       2016-2019
(23)      Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions: Closing The Loop - An EU Action Plan For The Circular Economy (Circular Economy Initiative)
(24)       Directive 2010/30/EU of the European Parliament and of the Council of 19 May 2010 on the indication by labelling and standard product information of the consumption of energy and other resources by energy-related products.  OJ L 153, 18.6.2010, p. 1.
(25)       http://ec.europa.eu/clima/policies/international/negotiations/future/index_en.htm ( Paris Agreement )
(26)       Communication from The Commission To The European Parliament, The Council, The European Economic And Social Committee And The Committee Of The Regions Closing The Loop - An EU Action Plan For The Circular Economy (Circular Economy Initiative)
(27)       https://ec.europa.eu/clima/policies/ets_en (ETS)
(28)

     Commission Staff Working Document Impact Assessment Accompanying the document Proposal for a Regulation of the European Parliament and of the Council setting a framework for energy efficiency labelling and repealing Directive 2010/30/EU. SWD/2015/0139 final - 2015/0149. (Impact Assessment Energy Labelling Regulation)

(29)      Equivalent to more than the primary energy consumption of a country like Slovenia in 2012.
(30)      In 1990, only 23% of EU households had more than one TV; in 2010, 80% of households had two TVs, with video content usually watched also on other displays types, such as computer monitors.
(31)    From Cold Cathode Fluorescent Lamp (CCFL) to Light Emitting Diodes (LED) to self-emissive panels
(32)      To calculate the average on-mode power consumption for the current energy label (indicated in Watts), a testing methodology is in use (according to standard IEC/EN 62087-3:2015) that measures the average power consumption when playing a specific test video, with conventional broadcast images in Full HD, from material produced in SDR.
(33)      Competing industry standards were consolidated only from 2016.
(34)      Articles appearing in the press in 2015, particularly in the USA, revealed the results of tests performed by NRDC that resulted in a few models inappropriately activating "low power modes", thus providing misleading power use information https://www.theguardian.com/environment/2015/oct/01/samsung-tvs-appear-more-energy-efficient-in-tests-than-in-real-life . The same test loop is used for compliance control in the EU.
(35)      Action to combat the circumvention as possible "in principle" (e.g. by a smart display capable of recognising the typical pattern of the current test video) was discussed in the consultation Forum in 2014.
(36)      EN 62087:2016 is being updated, specifically with provisions to avoid circumvention and take into account new features such as HDR (High Dynamic Range) and higher resolution (UHD, 8K).
(37)      Electronic signage displays (signage displays in the rest of the document) are displays, generally "resembling" a television but possibly far bigger and with a different size ratio (proportion of horizontal versus vertical size); common in train stations and airports to display timetables, they are nowadays uses far more widely. See also Annex 8.
(38)      Laptops, tablets or even smartphones can be used to watch video content, although the displays integrated in these products would be better tackled within the review of the Regulation on computers.
(39)      The Arena cinema in the Sihlcity shopping centre in Zurich is probably the first in Europe where the projection screen is replaced by a video wall of signage modules, using microLED technology. The manufacturer claims 10 times the peak brightness of projectors using 96 modules with UHD 4k HDR and 3D image capability.
(40) Tecnology progress not necessarily has energy efficiency as goal, as energy use is on the customer mostly with little transparency in the lack of appropriate labelling or information requirements.
(41)      Correct management of these displays at their end of life as WEEE is desirable, as once disposed of, it is virtually impossible to distinguish a television from a monitor of from some types of signage displays. Lack of the same ecodesign requirements for such displays leads to improper and/or inefficient treatment.
(42)      In February 2014 a German court judged that products marketed as computer monitors, if advertised showing video images, fall under EU Energy Labelling Regulation 1062/2010
(and, consequently, also under 642/2009).
(43)      As a consequence of the higher luminance, e.g. between 500 to 700 cd/m² for indoor versions compared to 300-350 cd/m² of a domestic TV.
(44)    Siddharth Prakash et al., Einfluss der Nutzungsdauer von Produkten auf ihre Umweltwirkung: Schaffung einer Informationsgrundlage und Entwicklung von Strategien gegen „Obsoleszenz“, study for Umwelt Bundesamt (UBA) Texte/11/2016, Feb. 2016.
(45) Pilot projects have demonstrated the possibility of avoiding use of flame retardants by removing the power supply from inside the TV (e.g. https://corporate.bestbuy.com/fewer-chemicals-same-fire-safety-for-insignia-tvs/)
(46)    The efficient use and recycling of critical raw materials is a priority of the EU circular economy action plan.
(47)    Consultation Forum 8 October 2012, see Annex 5.3
(48)      Obligations in the directive include LCD panels, plastics containing Brominated Flame Retardants (BFR), batteries, electrolyte capacitors, printed circuit boards greater than 10 cm2, and other components containing substances hazardous for the operations, the workers’ health or the environment.
(49)      Private communication from the European recyclers association: https://www.eera-recyclers.com/
(50)      Early TVs were using thermionic valves, that could heat up and even explode.
(51)

     Assuming 56 million TVs sold in the EU-2015 with a plastic back-cover weighing 2 kg (EERA 2013 mentions 1.6 kg for a 33" display), half of displays using back-cover with HFR/ATO with a HFR concentration of 25 wt.% (EFRA-2014 mentions 20-30%) with a 5 wt. % ATO (EFRA 2014 mentions 3-5%). Thus the HFR/ATO use is 56x2x0.5x0.3= 16.8 million kg= 16.8 kt. Including also PC-monitors the total is estimated at a rounded 20 kt annually.

(52) EFRA European Flame Retardants Association was, until 2017, a sector group of the European Chemical Industry association CEFIC. The new CEFIC sector group for flame retardants is PINFA (Phosphorous, Inorganic and Nitrogen Flame Retardants Association), representing 32 producers of non-halogenated flame retardants ( https://www.pinfa.eu/about-pinfa/members/ ).  
(53)    See e.g. Peeters et al (2013), Wagner et al (2017) on recycling of PC/ABS from LCD TV back covers
(54)      Some compounds of this group are restricted by RoHS legislation because of their demonstrated toxicity and hazardousness.
(55)      Commission communication in the framework of the implementation of Directive 2014/35/EU of the European Parliament and of the Council on the harmonisation of the laws of the Member States relating to the making available on the market of electrical equipment designed for use within certain voltage limits (2017/C 298/02), OJ, C298, p. 14, d.d.8.9.2017
(56)  Directive 2011/65/EU of the European Parliament and of the Council of 8 June 2011 on the restriction of the use of certain hazardous substances in electrical and electronic equipment. OJ L 174, 1.7.2011, p. 88
(57) Polybrominated biphenyls (PBB) and Polybrominated diphenyl ethers (PBDE), tolerating maximum concentration values of 0,1 % by weight in homogeneous materials.
(58) Plastics are checked as described in the EN 50625-1 "General treatment and depollution standard" to verify that the plastics contain less than 2.000 ppm of Bromine restricted substances.
(59) According to EERA, about 10% of annual production of EEE plastics are delivered to specialized recycling facilities in Europe to be recycled as Post-Consumer Recycled (PCR) plastics. 3/4 of the WEEE plastics have been exported outside Europe and no data is available about the final amount recycled as PCR plastics.
(60) Polymers containing brominated flame retardants, for example, increase the specific weight, so separation techniques based on weight can be used.
(61) Presence of the now restricted PBB and PBDE is possible e.g. in electronic displays produced before their ban, but less than 0,1 % in weight is allowed in the recycled yield.
(62)      Toxicity refers to the degree to which a toxic substance may harm a (human) cell or organism, while ecotoxicity refers to the potential for biological, chemical or physical stress, affecting the entire ecosystem.
(63)      This issue had been already highlighted in the previous Impact Assessment (Sec(2009) 1011 final) but at that time alternative solutions appeared insufficient and possible action to limit them had been judged not yet feasible.
(64)      See. e.g. http://ecostandard.org/category/flame-retardants/ http://greensciencepolicy.org/topics/flame-retardants/
(65)      See positions expressed by EERA, EURIC and ECOS in particular in Annex 5.
(66)      Non-halogenated FRs are e.g. aluminium hydroxide and phosphorus-based (PFR) and recent tests show that, for example, PFR PC/ABS compounds can be (closed loop) recycled.
(67)      Two EU-funded projects are currently investigating these areas: CloseWEEE (http://closeweee.eu) and PolyCE ( https://www.polyce-project.eu )
(68)  Apple has completely eliminated BFRs since 2008, Sony from selected products since 2013, https://www.scientificamerican.com/article/do-we-need-flame-retardants-in-electronics/
(69)      PolyCarbonate Acrylonitrile Butadiene Styrene. 
(70)      UL94 V0
(71)      Commission Decision 2009/300/EC of 12 March 2009 establishing the revised ecological criteria for the award of the Community Eco-label to televisions, OJ L 82, 28.3.2009, p. 3
(72)      Nevertheless, some manufacturers have already eliminated all HFRs, even from circuitry and use metal for the housing and stand.
(73)

     The Joint Research Centre Directorate B, Circular Economy & Industrial Leadership unit, has compiled a multi-level approach for assessing the reparability and upgradability of products, which will be tested on televisions and is expected to be completed by the end of 2018.

(74)      EU brands integrating display panels of Asian production into premium "home entertainment" products are Bang&Olufsen (DK), Loewe and Metz (DE). EU-based assemblers of mass-market televisions and monitors are wholly or partially owned by Chinese display manufacturers. Some have ‘strategic partnerships’ with South-Korean companies such as Barco (BE) or Solari (IT) that also use Asian panels.
(75)       www.digitaleurope.org  
(76)      In Eurostat's SBS (Structural Business Statistics), NACE Rev. 1.1, there is a category 'Repair of electrical household goods' (G5272) that mentions for 2007 that there are over 50,000 businesses and an added value of 5.4bn Euro. The share of TVs and other displays will be at the most 20%, i.e. 10,000 repair shops with 1 bn euro turnover. It can be assumed that most of these enterprises combine repair with retail. So at the most we can assume one employee per enterprise dedicated to repairs, probably less. All in all, EU employment in TV repair is estimated at 5000 to 10,000 jobs. http://ec.europa.eu/eurostat/statisticsexplained/index.php/Computer_and_personal_and_household_goods_repair_statistics_-_NACE_Rev._2 gives data at a higher aggregation level (NACE Rev. 2, Division 95) and confirm the order of magnitude of the above estimate. Average personnel costs are between €23k and €33k per employee, which indicates a business revenue of at the most €50k per employee, i.e. overall EU repair revenue €0.25bn to €0.5bn per year (less than 2% of sales value).
(77)       Directive 2012/19/EU of the European Parliament and of the Council of 4 July 2012 on Waste Electrical and Electronic Equipment . OJ L 197 of 27-07-2012, p 38 (WEEE Directive)
(78)       Consolidated version of the Treaty on the Functioning of the European Union.  OJ C 326, 26.10.2012, p. 47 (TFEU)
(79) https://ec.europa.eu/info/sites/info/files/file_import/better-regulation-toolbox-17_en_0.pdf ( Better Regulation Toolbox )
(80)  Cmparable to the cost of a nuclear power plant.
(81)      Hans-Paul Siderius. Setting MEPS for electronic products. Energy Policy 70: 1-13
(82)      The data was taken from the product information sheets that the current Labelling regulation requires supplier to make available to dealers. Such a burden (of keeping data available by suppliers and of collecting the spread data for review purposes) will be eliminated once a product registration database as from Regulation 2017/1369, art. 12 will provide all data centrally.
(83)      A portable USB-Type-C ready 15.6” LCD/LED model.
(84)      The EEI is calculated with a "linear" curve in the current regulations, whilst a tangent hyperbolic is proposed, that cannot be superposed.
(85)      It is likely that only very little HD displays may be produced by that time.
(86)      For instance and for 40”HD, in the new EU proposal an A is <15.7W. For a B you add 5.6W (so <21.3W), etc.  For India, the best is a 5-star and that is for energy on-mode<39.1W; a 4-star is 39.1+6.2 = <45.3W etc.  In South Korea the labelling has a very large range, from the best class called “Energy Frontier” at <23.2W down to the 5th grade 291.8W.
(87)      Namely CEN, CENELEC and ETSI
(88)      Personal Communication from. Robert Harrison, member of the IEC standardisation committee and https://www.nrdc.org/resources/secret-costs-manufacturers-exploiting-loopholes-governments-tv-energy-test  
(89)      Requirements laid down in the current Regulation 642/2009 are based on a "linear" regression line
(90)      Commission Regulation (EC) No 1275/2008, with regard to ecodesign requirements for standby and off mode, and networked standby, electric power consumption of electrical and electronic household and office equipment.
(91)      For instance, no requirements on on-mode power are foreseen for the special purpose displays mentioned but they will be subject to requirements on maximum (networked) standby and off-mode power use as well as product information and circular-economy aspects.
(92)      100 cm2, or about 6-7 inches of diagonal
(93)      The WEEE Directive lists a number of components, some of which are present in electronic displays, to be removed before further treatment, such as shredding.
(94)      Back covers and stands are generally the biggest and most cost-effective plastic parts to recycle and the presence of FR, particularly HFR, limits recycling opportunities.
(95)      USB PD specification extends the power and voltage specifications up to 100 W and 3 voltages. "Universal" EPSs are coming to the market with multi-USB-ports being able to charge different devices, even at a time and at different voltage levels and using a unified reversible connector (USB Type-C): http://www.usb.org/developers/powerdelivery/
(96)      Association of the European adhesive and sealant industry, http://www.feica.eu
(97)      An earlier version of the ecodesign proposal was notified to the WTO with comments from South Korea, the USA and Japan.
(98)      As a consequence of the high luminance such as 500 to 700 cd/m² for indoor versions, compared to 300-350 cd/m² of a domestic TV
(99)      E.g. https://www.apple.com/lae/environment/safer-materials/
(100) It should be noted that Directive 2011/65/EU (the RoHS directive) mentions that the Ecodesign Directive should enable “specific ecodesign requirements to be set for energy-related products which may also be covered by this Directive. Directive 2009/125/EC and the implementing measures adopted pursuant to it are without prejudice to Union waste management legislation” (recital 13).
(101)      For many models the difference between equivalent UHD and HD is up to 20% (see VHK database)
(102)      A free-rider problem occurs when those who benefit from resources, goods, or services do not pay for them, which results in an under provision of those goods or services. (Baumol, William (1952). Welfare Economics and the Theory of the State. Cambridge, MA: Harvard University Press.)
(103)      See annex 7 for detailed explanations on the model used.
(104)      European TV market 2007 – 2012 Energy efficiency before and during the implementation of the Ecodesign and Energy Labelling regulation. TopTen, October 2013. The study can be found at: http://www.topten.eu/uploads/File/European_TV_market_2007%E2%80%932013_July14.pdf
(105)      No eco-design requirements for on-mode would be set, as minimum standards may possibly block new products coming to market over the coming years.
(106)      During manufacturing certain cleaning agents are used, such as Nitrogen Trifluoride and Sulfur Hexafluoride with a global warming potential (GWP) of over respectively 17200 and 24000 the GWP of CO2. Mitigation of the use of compounds with high GWP or regulating the energy use in the production phase cannot be tackled for display panels as production is not in Europe and compliance control is not feasible.
(107)      PolyMethylMethAcrylate
(108)      The production cost of displays is largely determined by a few components like screen panels, backlight units (BLUs) and electronics (e.g. video boards). Screen panels are produced by only a dozen manufacturing plants, mostly in mainland China. The screen cost increases with the area. Backlight units are also an area of strong global competition. Video boards are electronics and thus ‘governed’ by Moore’s Law (every 2 years the number of ‘transistors’ is doubled, at the same price, same size and half the energy consumption). Furthermore, the production costs determine only a part of the market price as marketing strategies play the major role and determine large price differences for similar products between the US, China, India and Europe.
(109)      Philips was the last one but gave up its share in a joint venture with the Taiwanese TPV
(110)      Building a display-panel manufacturing plant requires an investment of ca. €10bn. This is comparable to the investment in a nuclear power plant. Unless the EU wants to follow the US example and give a €3bn subsidy to one Taiwanese company to build a €10bn plant on its soil, it is unlike to have that manufacturing again in the EU. Further, the unit sales for electronic displays are declining, so there is also no commercial incentive for such an investment.
(111)      Signage displays are a B2B market, meaning the consumers can recuperate VAT; VAT is thus not included.
(112)      SWD(2015)/319 final, European Commission, 15.7.2015, Brussels.
(113)      Industry associations recently issued a Joint Position Paper on implementation aspects of the database http://www.ceced.eu/dam/site-ceced/PUBLIC-WEBSITE-ASSETS/MEDIA-RESOURCES/Position-Papers/2017/2017---11---Joint-Industry-Position-Paper-on-EPREL/2017%20-%2011%20-%20Joint%20Industry%20Position%20Paper%20on%20EPREL.pdf
(114)      Metz GmbH, Bang&Olufsen and Loewe, EU display manufacturers, do not qualify as SMEs.
(115)      A joint market surveillance project funded by the European Commission that checked compliance of televisions on the EU market. For more information see: www.compliantv.eu
(116)      According to the Energy Labelling framework Regulation, products have to be registered in a product registration database from 1 January 2019 onwards, for all products belonging to models placed on the market after 1 January 2019; and by 30 June 2019 for products belonging to models placed on the market between 1 August 2017 and 1 January 2019
Top

Table of Contents of the Annexes (1/2)

Annex 1    Procedural information …………………………………………………….1

Annex 2:    Stakeholder consultation …………………………………………………....9

Annex 3:    Who is affected and how? …………………………………………………18

Annex 4:    Analytical model used ……………………………………………………..20

Annex 5:    Minutes of the Ecodesign Consultation Forums ………………………...28

Annex 6:    The market of electronic displays ………………………………………..58

Annex 7:    The Ecodesign and Energy Labelling Framework ……………………...75

Annex 8:    Existing Policies, Legislation and Standards on electronic displays …...79

Annex 9:    Evaluation of current regulations (REFIT) ……………………………...90



ANNEXES

Annex 1    Procedural information

1.Lead Directorates General (DG), Decide Planning/CWP references

DG GROW and DG ENER are Co-Chef de File for Ecodesign. DG ENER is the lead DG for this product group. DG ENER is Chef de File for energy labelling.

The Decide number of the underlying initiative for the review of ecodesign requirements for electronic displays is 2014/ENER/011 (no inception impact assessment because this is initiative predates the requirement).

The Decide number of the underlying initiative for the review of energy labelling for electronic displays is 2013/ENER/066 see above for the IIA & OPC.

The following DGs (Directorates General) were invited to contribute to this impact assessment: ENER (Energy), SG (Secretariat-General), GROW (Internal Market, Industry, Entrepreneurship and SMEs), ENV (Environment), CNECT (Communications Networks, Content and Technology), JUST (Justice and Consumers), ECFIN (Economic and Financial Affairs), REGIO (Regional policy), RTD (Research and Innovation), CLIMA (Climate Action), COMP (Competition), TAXUD (Taxation and Customs Union) EMPL (Employment), MOVE (Mobility and Transport), TRADE (Trade) and the JRC (Joint Research Centre) were consulted on the draft IA in May 2018.

2.Organisation and timing

The review of the ecodesign and energy labelling for televisions and television monitors started in 2012 and a review study was conducted for this purpose. This evaluated the impact of the current legislation, as reported in Annex 9, also looked at the technological and economic evolution of the sector and at stakeholders' views. Results from the study have been used directly as input to the analysis model of Annex 4.

The review process ran far longer than usual, with four Ecodesign Consultation Forums (in October 2009, October 2012, December 2014 and in July 2017; see Annex 5), while usually only one is needed. This happened largely because of political scrutiny at College level which led to long delays and the subsequent need to take into account technology evolution, market changes and new features introduced for TVs and displays.

The last Ecodesign Working Plan 2016-2019, adopted in November 2016, confirmed that televisions and electronic displays continue to be a priority product group. Furthermore, the recent Energy Labelling Regulation (EU) 2017/1369 stipulated that televisions are one of the five priority subjects for which the Commission should adopt a new energy label regulation in accordance with the said overall regulation by 2 November 2018.

Article 19 of the Ecodesign Directive foresees a regulatory procedure with scrutiny for the adoption of implementing measures. Article 17 of the Energy Labelling Regulation foresees consultation of the energy labelling expert group before the adoption of a delegated act. Subject to qualified majority support in the Regulatory Committee and after scrutiny of the European Parliament and of the Council, the adoption of the measures by the Commission is planned for the end of 2018.

3.Consultation of the RSB

The Regulatory Scrutiny Board (RSB) delivered a negative opinion on a draft of the Impact Assessment on 18 June 2018 after the meeting on 13 June. The draft report was subsequently improved, based on the Board’s Opinion and the “Horizontal issues for discussion” sent to DG ENER on 8 June 2018, and was resubmitted to the Board. A positive 2nd opinion with reservations was issued on 4 July 2018, containing further recommendations for improving the report The table below shows how those two sets of recommendations are addressed in this revised Impact Assessment report.

RSB Opinion

Where and how the comments have been taken into account

(B) Main considerations

(1) The report does not clearly draw conclusions from the evaluation(s) to support the problem definition.

It is unclear about the success of the previous measures and the discontinuity in projections. 

Information has been added to section 1.1 and to the problem definition which gives more information on how the evaluation process fed into the problem definition. Information has also been added to section 6.

In Annex 2 a description of the full review process, started in 2012, with even preliminary discussion in 2009, is now presented. The results of the preparatory study/evaluation are summarised as well as the evolution of the need to act

Information on the savings achieved has been added to the introduction, see pages 3-4, as well as at the end of the new section 1.5 on need to act and in Annex 9.

Sections 1 and 2 in particular have been enriched and content partially reorganised to better describe the success of the current Regulations in reducing energy consumption and the need to act to capture the relevant future potential savings that, otherwise, would be missed in a BAU scenario.

(2) The report is not precise enough on the content of the options and does not sufficiently explain future developments in prices and energy savings. 

It contains factual and numerical errors, which do not provide the necessary guarantees for the choice of the preferred option.

Section 6.1 illustrates the methodology and key assumptions in respect to prices.

A graph in this same section (Figure 18) illustrates the expected progress in terms of populating the highest energy classes.

In the specific market sector of electronic displays, the evolution of prices has no demonstrated correlation with energy efficiency improvements. Moreover, for the same efficiency class, the cost of new products tends to decrease. This is clarified in sections 6.4, 6.6.1 and in Annex 6.

The values in the tables related to the Ambi scenario have been corrected (see Annex 4, tables 4.4 and 4.5), however no change in future projections resulted for inputs.

(3) The report does not integrate circular economy aspects comprehensively and in a way which is consistent across ecodesign products. It does not impact assess them either.

See new information added to sections 2.3, 6.2.3 and Annex 15. It is also explained that while circular economy aspects were not specifically impact assessed, they were discussed at the Consultation Forums (2012 – 2017).

(C) Further considerations and adjustment requirements

(1) The report should clarify whether horizontal and/or product specific evaluations were conducted to prepare this initiative.

In addition, it should clarify what the expectations were of the original legislation, to what extent the results deviate from them, and what are the lessons to draw for this.

Key conclusions should directly feed the scope and problem definition. In particular, the report should explain very clearly why the predicted savings on energy consumption in 2025 are now 27% lower than what was predicted in previous impact assessment from 2007.

The 2012 Review study was specifically on TVs and also covered monitors and signage.

Additional details evaluations and discussion with stakeholders along a process lasting over 6 years (including 4 Consultation Forums, a previous impact assessment approved by the IAB, a public consultation and WTO notification–Ecodesign only on a previous draft proposal) have been added to Annex 2.1.

Clarifications have been introduced in section 1.1 with a graph extended beyond 2025, better showing that the predicted and now achieved savings exceed predictions by about 7%)). It has been clarified how the lack of accuracy in the previous preparatory work was due to an unprecedented evolution of the sector during the preparatory work and in the lack of sales/stock data (now available and reliable).

Section 1.1 now better illustrates the situation and explains that real savings calculated on more reliable 2017 data show that projections to 2020 are in fact 7% better than predicted.

(2) The report should better explain the scope of the initiative and why it adds (only) signage displays.

The description of the options should become more precise.

The report should be clearer about what elements that have already been agreed upon and how stakeholder views shaped the options and influenced the choice of the preferred option.

Any divisive issues between stakeholders should be better explained.

Information has been added to section 2.2 “problem of outdated scope” to better explain the current scope and the proposed future scope, which covers computer monitors and signage displays as well as TVS.

Text has been added to section 5.2 to give more details on the options.

Annex 5 gives information on what aspects were discussed, and possibly agreed upon, by stakeholders in the Consultation Forum meetings (also summarised in Annex 2).

Stakeholder views have been added throughout section 5, see also Annex 2 section 4.

(3) The report should provide a more thorough analysis of the circular economy dimension of the initiative.

The limits to the approach need to be more transparent. The report should in particular expand on the impacts on the health and safety of the use of flame-retardants. The report should present the views of the different stakeholders and explain how it addressed them.

See answer B 3 above. A new section on “Effects on health” has been added to Annex 15, also summarised in section 6.2.3.

Stakeholder views are set out in 5, measure 5.

(4) The report should explain the evolution of the baseline in more detail. In particular, it is currently not clear why the ongoing trend of increasing energy efficiency seems to stop in 2024.

Errors in the impact analysis need to be corrected. In particular, inconsistencies across tables on the energy efficiency of the ambitious scenario need to be resolved. Assumptions around this scenario should be better substantiated.

The international comparison of ecodesign limits gives the impression that the proposed EU ecodesign limits are less ambitious than those of US, India and Korea. This issue should be better explained and the figure, if necessary, revised

See new text in section 5.2.1.

Figure 1 (previously in Annex 8) shows a comparison between the projections in the preparatory study of 2007 (up to 2025) and current projections (up to 2030). The trend to increasing energy use continues beyond 2025 but no prediction is available which is why the graph appears to stop.

The tables have been corrected to avoid any incorrect data interpretation. The two values spotted in table 4.4 were the result of the retroactive application of the modelling, with no consequence on the forecast for 2020

The previous graph for comparison of eco-design limits has been replaced by 3, more relevant graphs: see figures 11 (Proposed EU Ecodesign limits for 2020, 2022, 2024 compared to best performance grades in the US, India and Korea), 12 (Proposed Labelling top class compared with non EU energy efficient top class displays) and 14 (Proposed label classes compared with non-EU labelling schemes for a 40" (44dm2) HD display). These show that the proposed ecodesign limits are not less ambitious than those of US, India and Korea

(6) The monitoring and evaluation section should be strengthened to reflect how progress in this specific product group will be assessed.

The section has been integrated, particularly answering the question on "main indicators" to proof the success of the measure.

(7) This report should be streamlined as far as possible with the impact assessments accompanying the other proposals in this package of proposals for implementing legislation regarding ecodesign and energy labelling. It requires in particular that the specific characteristics of the product come out more clearly in the different sections of the impact assessment.

The structure of the report and the annexes has been harmonised as far as possible with the other impact assessments and further explanations of the specificities of TVs and monitors have been added to Annexes 6 and 14.

Horizontal Issues

1)    Evaluation of how product regulations have worked is not systematic.

See answer to B1

2)    The need to act is not always clear.

A new section 1.5 has been added.

3)    The approach to defining energy labelling bands for specific products does not seem consistent.

Information has been added to section 1.2.

4)    The reports are not transparent about what elements have already been agreed upon (and on what basis), and what is left open for political decision, i.e. what is to be assessed in an impact assessment.

See information added to section 5.1.

5)    The addition of circular economy requirements appears artificial

See answer B.3 above.

6)    There is no critical discussion whether the applied methodological approach (MEErP) is consistent with the extension of the framework

See new information in section 6.1 on the methodology used.

7)    The approach to a range of issues going beyond energy efficiency as such – new testing methods, scope, exceptions – is not explained for all product groups

See for example problem definition 2

8)    The assessment of some impacts is unclear, e.g. as regards the employment effects, potential cash-flow problems and business revenues

See section 6 on assessment of options

9) The choice of the preferred option is not always sufficiently well justified with the presented analysis.

See section 8.1

10) As the ecodesign and energy labelling proposals are to be adopted in a package, information about contributions from particular product groups need to be presented systematically and in ways that allow for comparisons.

See section 8.1

RSB Overall (second) Opinion 04.07.2018 – Positive with reservations

Where and how the comments have been taken into account

(B) Main considerations

The Board acknowledges the improved coverage of circular economy aspects and a better description of the consultation process. However, the report still contains significant shortcomings that need to be addressed. As a result, the Board expresses reservations and gives a positive opinion only on the understanding that the report shall be adjusted in order to integrate the Board's recommendations on the following key aspects.

(1) The report does not sufficiently distinguish between energy savings from technological changes that were the result of the current regulation and those that would likely have happened without it. Because of a similar issue in the analysed future scenarios, the effects of the proposed measures is likely to be overestimated.

(2) There are inconsistencies and errors in data in the report and annexes. Although this does not undermine the choice of preferred option, it puts into doubt the evidence supporting the intervention.

Additional text has been included in section 1.1.

The modelling has been checked and modified, and the revised data has been added to the report and the annexes where appropriate, in particular in Sections 6 and 7 of the main report and Annex 4.

(C) Further consideration and recommendations for improvement

(1) The report should present more evidence or analysis to distinguish the effects of autonomous technological progress from those of the current regulation. This is also of importance to establish an appropriate baseline. The current baseline assumes that energy savings for monitors will stop in 2018 and for televisions in 2027. The report should justify this assumption in a sector with strong technological progress (which is the argument to leave classes A and B of the proposed energy label empty).

Additional text has been added to Sections 1.1 and 5.2.1 on the baseline option.

(2) Numerical errors persist. The energy saving potential and greenhouse gas reductions presented in the graphs in the report are not consistent with the data in annex 4. Moreover, the corrected figures in the annex are not internally coherent. This should be fixed with adequate explanation for the non-expert reader to understand. Solid justification for the initiative depends on robust energy savings estimates.

The modelling has been checked and modified, and the revised data has been added to the report and the annexes where appropriate, in particular in Sections 6 and 7 of the main report and Annex 4.

(3) The report presents the options in more detail. However the report should be clearer on the rationale between the ecological option ('Eco') and the ambitious option ('Ambi'). The report should be more transparent on the implications on health and safety of maintaining flame retardants in the 'Eco' option, despite their serious toxicity, ecotoxicity and threat to the health of workers in the recycling industry. The report should explain the necessity of an option excluding signage displays from the scope of Energy labelling given the large consensus among stakeholders on the need to address signage displays.

Additional justifications have been added to section 5.2.2, page 33 on signage displays and section 5.2.2, page 34 on halogenated flame retardants.

(4) More specific indicators have been identified regarding monitoring. The report should provide information on how often progress will be assessed and it should also refer to the next review or evaluation planned or required by the parent legislation.

Text of Section 9 in the main IA report has been updated.

(5) The attached quantification tables of the various costs and benefits associated to the preferred option of this initiative need to be adjusted to reflect changed estimations of costs and benefits.

The relevant tables have been adjusted where appropriate as per the updated modelling results. See Annex 3.

4.Evidence, sources and quality

This impact assessment builds on the previous version that had been approved by the Impact Assessment Board on 4/9/2013. For this deep review and update, the main supporting studies were as follows:

·Review study 2012 1

·Study assessing consumer understanding of a draft energy label for electronic displays 2 (2017)

·Evaluation of the Energy Labelling and Ecodesign Directives SWD(2015) 143 final 3

JRC studies were also relevant I particular on "circular economy" aspects such as durability, recyclability and flame retardants (see References in Annex 17). An external consultant was used to examine specific technical aspects.

Energy-relevant data about over 400 televisions on the market and other displays was also analysed 4 .

The Commission also established a dataset (see Annex13 for last dataset used) containing information about the environmental performance of electronic displays in support of the possible ecodesign and energy labelling measures, to support a proper ambition level and to reflect recent technology developments. The dataset was based on energy data been provided by industry representatives and integrated with additional data collected from official documentation of industry on the WEB. The different data sources have been compared to fine tune technology progress evolution and trends and update the impact assessment.

Based on these studies and this preparatory work, the Commission drafted the policy options presented in this Impact Assessment.

Stakeholder input received during the above review studies, the four Consultation Forums and the consultation on the Inception Impact Assessment for the Energy Label were also been taken into account.

Annex 2:    Stakeholder consultation 

This Annex gives a brief summary of the consultation process. Details are given of how and which stakeholders were consulted. In addition, it explains how it was ensured that all stakeholders’ opinions on the key elements relevant for the IA were gathered.

There has been extensive consultation of stakeholders during the review studies, and before and after the Consultation Forum meetings. Further external expertise was collected and analysed during this unusually long process. The results of four stakeholder consultation forums are further described in this section.

1.Review study, evaluation and stakeholder consultations 

In the period observed by the original preparatory study of 2006/2007 for the 2009 regulations and until 2008, the average energy consumption of displays did not decrease (see figure 2.1, from the 2012 preparatory study) and new technologies such as LCD panels with LED backlighting were considered just only a niche market. Since that time, the rapid development and market adoption of this technology and other energy saving technologies resulted in industry-led energy efficiency improvements faster than had been originally anticipated, with not efficient technologies voluntarily abandoned (such as "plasma" technology) by industry.

The new process of reviewing the ecodesign and energy labelling regulations on televisions and television monitors started in 2012 when stakeholders in the Consultation Forum agreed with the Commission that the existing regulations needed to be revised. EU and international stakeholders and Member State experts were consulted from the very beginning of the review work. Furthermore, displays other than televisions and television monitors, such as computer monitors or digital photo frames were included in the first Ecodesign Working Plan 2009-2011 (as ENER Lot 3) and possible measures were discussed at a Consultation Forum meeting on 8 October 2009.

The Review study was completed in August 2012. It provided the Commission with technical and market data used to evaluate the existing 2009 television regulations and to support the development of the new ecodesign and energy labelling proposals for electronic displays. Furthermore, market and technical data was acquired through several bilateral and multilateral meetings with stakeholders (in particular with DigitalEurope and EERA) from 2013 to 2017.

The review work included:

·analysis of power consumption of the products per unit of screen size for the various levels and label classes, in order to reassess minimum energy performance standards (MEPS) and energy classes and comparison with other non EU legislation for MEPS or voluntary labelling;

·discussion of the impact of the Ecodesign and Energy Labelling Regulations to that date, with a historical review of the market changes over the previous five years;

·an overview of the key issues that required consideration in the context of reviewing and revising the Regulations;

·discussion of scope of coverage and definitions, technology trends and product features (i.e., screen size, LED back lit LCD displays, 3D, smart products, automatic brightness control, fast start and stand-by);

·an overview of the existing ecodesign requirements and an analysis on test data for televisions;

·a brief discussion of the measurement methods.

Among the different aspects that emerged from the data collection, studies and review , the following are the most relevant in this context:

·test standards and possible “defeat devices” (gaming);

·Signage displays, a new market and out of scope starting to emerge on the market;

·Auto Brightness Control (ABC) started to emerge as a feature; unprecedented technology progress in the area of display panels was observed;

·Ultra High Definition (UHD) was starting to come to the market in "premium" products, possibly involving a higher energy use; Monitors without "an included tuner" were increasingly used to watch video content;

·a linear limit, as in the current Regulations, provides an advantage to the biggest displays; (the weight of components not depending from the display size is smaller) and a misleading signal to customers;

·additional needs to for justifying the urgency of update the existing test standard and compliance control methods in order to prevent "defeat devices" in new "smart" products;

·need to provide a more realistic energy efficiency calculation for the biggest displays, in light of the trend to increase size and eliminating what appearing as a kind of privileged treatment;

·need to improve treatment of displays under the WEEE Directive form displays, by making disassembling/dismantling quicker and more effective and improving the yields of recyclable materials;

·the existing test standard IEC 62087, based on measuring the energy use of a television or other display when inputting from an external player a video test loop made of a collection of typical broadcast content from broadcasters worldwide, appeared already as possibly prone to "gaming", i.e. "smart" displays could detect the typical luminance test pattern and modify their energy use patterns to give misleading results.

2.Working document and Consultation Forum

The Commission services prepared Working Documents with ecodesign and energy labelling requirements which were circulated to the members of the Ecodesign Consultation Forum for the meeting on 8 October 2009. New working documents, based on the results of the Review Study 2012, were circulated to the members of the Ecodesign Consultation Forum for the meetings on 8 October 2012 and 10 December 2014. The last version was circulated and discussed at the Ecodesign Consultation Forum meeting of 6 July 2017. The Ecodesign Consultation Forum represents all EU Member States and EEA countries, together with industry associations and NGOs in line with Article 18 of the Ecodesign Directive. The Working Documents and the stakeholder comments received in writing before and after the Consultation Forum meetings were posted on the Commission’s CIRCA system. Minutes of the Consultation Forum meetings can be found in Annex 5.

3.Results of stakeholder consultation during and after the Consultation Forums

The 2012 review study was first discussed with stakeholders during a Consultation Forum on 8 October 2012 (see minutes in Annex 5.3).

The proposal then presented was based on the findings that had already emerged at that stage: a rapid evolution of TV technology, the introduction of new types of TVs, demand for improved picture quality, as well as strong competition between manufacturers.

A majority of stakeholders, including Member States, were in favour of a review of the Regulations, with increased stringency in Ecodesign, the use of the same formula in the Labelling regulation, widening the scope to include computer monitors and signage displays, and not providing an advantage to the biggest displays. Some Stakeholders already asked for the introduction of "non-energy" requirements in Ecodesign and the use of flame retardants was signalled as hindering recycling.

An overwhelming majority of Member States and NGOs agreed on a proposed extension of the requirements to electronic displays other than TVs, including but not limited to computer monitors and digital photo frames, with manufacturers requesting exceptions for specialised displays with distinct characteristics.

The majority of stakeholders accepted the proposed approach for regulating on-mode power demand of electronic displays and were in favour of a proposal that was based on a logarithmic regression line 5 .

A majority of stakeholders were in favour of including in the proposal requirements on non-energy related aspects, including recyclability. At the same time they noted a need for proper measurement methods and questioned the enforceability of such requirements.

Results of the CF of 2014: The proposed ecodesign requirements for electronic displays were generally supported by Member States and stakeholders. A new Consultation Forum was held on 10 December 2014 (Minutes in Annex 5.2) with an improved ecodesign proposal including a first set of material efficiency requirements in the light of the "Circular Economy" strategy 6 adopted in the meantime. Stakeholders, however, suggested in the meeting to suspend the preparation of the labelling proposal because of the ongoing review, at that time, of the Energy Labelling framework Directive 7 .

Proposed resource efficiency requirements were supported by the overwhelming majority of stakeholders. Some specific requirements, however, criticized by industry representatives, were withdrawn from the draft proposal to avoid non-cost-effective burdens on the industry.

The working documents fully took on board comments expressed by Member States and stakeholders at and after the Consultation Forum meetings of 8 October 2012 and of 10 December 2014 (and thus differs in a number of aspects from the Commission’s original proposal as contained in the original working documents prepared for the consultation process).

Based on these inputs the Commission started reviewing the already approved 2013 Impact Assessment (see Annex 10) for the Ecodesign Regulation of electronic displays. Shortly after, the internal procedure was stalled again until the Commission adopted its Ecodesign Working Plan 2016-2019 8 where the revision of the implementing act for electronic displays is mentioned as one of the priorities. It also reports the situation that indeed the Ecodesign measure had been through the inter service consultation (ISC) and WTO notification and that a primary energy saving of 83 TWh was expected. In accordance with the “default” primary energy factor (PEF) of 2.5 set in the Energy Efficiency Directive (2012/27/EU) this means a saving of (at least) 33 TWh/year in electricity for the year 2030.

Public consultation

A previous version of the proposed ecodesign measure was notified in the "better regulation" web portal on 21 December 2016. 16 comments were received, mostly from manufacturers' representatives. A number of "position papers" were sent by manufacturer representatives to the Commission and members of the Consultation Forum as well.

Result of public consultations, WTO opinions and manufacturers positions expressed:

·the draft proposal included in the scope electronic displays "integrated" in a number of products subject to the WEEE Directive and possibly having a wide diffusion in future, such as computers refrigerators, vending machines, etc. however all manufacturers expressed concern about having different eco-design regulations on different components of the same product and clearly voiced a preference for "vertically" regulating the products (i.e. by including in the review of Ecodesign for a specific product the requirements for integrated displays, if any).

·Industries and associations of the chemical industry were against the specific wording in the draft proposal, referring to specific technology or techniques to glue components: this was mostly due to an unclear wording that has been corrected.

·Mandatory labelling of displays for presence or absence of mercury or cadmium was criticised, voicing for a mandatory requirement only for signalling "presence" of such dangerous substances.

·Environmental NGOs and recycling industries welcomed the proposal possibly banning use of welding or firm gluing for components to be removed at the recycling plant.

A further Consultation Forum was held on 6 July 2017 (Annex 5.1) where a new labelling proposal, in line with the new Energy Labelling framework Regulation 2017/1369 was discussed. The meeting also discussed a possible new label layout and the indicators to include, following the results of an on-going consumer understanding survey 9 .

During the Consultation Forum, the "disputed" aspects of the Ecodesign proposal were discussed with stakeholders and in particular:

·"vertical" regulation: the Commission announced to stakeholders the clear preference of industry for regulating displays in the context of the product where they are integrated into;

·Use of glue: the Commission presented a new wording for the dismantling requirement that found industry relieved but the recycling industry disappointed;

Plastic marking and flame retardants: the Commission proposed to set a limit for marking of plastics parts only above 50 grams; the comments of the main stakeholders on key features of the Commission services’ Working Document received during and after the Consultation Forum can be summarised as follows:

·Scope: stakeholders agreed that integrated displays should not be covered, but agreed to the inclusion of signage displays.

·Energy Efficiency Index: stakeholders were concerned that the label be easily understood and support for the proposed double scale showing the energy efficiency in HDR mode was therefore mixed;

·Energy label classes: as the consumer study was still on-going discussion was to some extent limited, but DE, IT, NL, SE, ANEC/BEUC, DIGITALEUROPE, ENEL, and EED said it would be complicated to explain to consumers the relevance of the standardised EPS;

Circular economy aspects: EURIC, supported by EERA and FEAC, stressed the need for better design to facilitate recycling and fully capture the 'circular economy' potential.

4.Open public consultation

An online public consultation (OPC) 10 took place from 12th February to 7th May 2018, with the aim to collect stakeholders' views on issues such as the expected effect of potential legislative measures on business and on energy consumption trends.

The OPC contained a common part on Ecodesign and Energy labelling, followed by product specific questions on (i) refrigerators, (ii) dishwashers, (iii) washing machines, (iii) televisions, (iv) electronic displays and (v) lighting.

1230 responses were received of which 67% were consumers and 19% businesses (of which three quarters were SMEs and one-quarter large companies). NGOs made up 6% of respondents, and 7% were "other" categories. National or local governments were under 1% of respondents, and 0.25% came from national Market Surveillance Authorities.

The countries of residence of the participants were predominantly the UK (41%) and Germany (26%), with a second group of Austria, Belgium, France, the Netherlands and Spain comprising together some 17%. Nine other Member States comprised another 9.5% of replies, but residents in 12 EU Member States gave either zero or a negligible number of responses. Non-EU respondents comprised around 5% of replies.

It should be noted that of the 1230 respondents, 719 (58%) replied only to lighting related questions as part of a coordinated campaign related to lighting in theatres. This was considered to significantly distort the replies, and for some questions the “lighting respondents” were removed from the calculation. Furthermore, as respondents did not have to reply to all questions, a high rate of “no answer” was observed (from 5% - up to 90%), in addition to those who replied “don’t know” or “no opinion”. To reflect better the actual answers, the number of “no answers” was deducted and the remaining answers treated as 100%.

4.1.Overall results

The first part of the questionnaire asked general questions aimed at EU citizens and stakeholders with no particular specialised knowledge of ecodesign and energy labelling regulations.

When asked regarding whether their professional activities related to products subject to Ecodesign or Energy Labelling, two-thirds (67%) of business respondents replied in the positive, and one-third (33%) in the negative, with no "no answer" replies. Almost the same percentages for "yes" (63%) and "no" (37%) were given when the business entities were asked whether they or their members knew of the Ecodesign requirements for one or more of the product groups concerned by the questionnaire, although this was reduced to 50% "yes" and 50% "no" when asked about Energy Labelling.

In reply to the question: "In your opinion, does the EU energy label help you (or your members) when deciding which product to buy?" 56% of the total respondents to the OPC gave a positive answer. Of the remainder, around 22% cited "don't know or no opinion", 3% did not reply and 19% responded negatively.

However, looking only at the ‘lighting respondents’ (526 of the total 1230), 73% of them replied ‘No’, ‘Don't know or no opinion’, or ‘no answer’. Given that the ‘lighting respondents’ mainly focused their comments on a narrow issue related to the current exemption for theatre lighting under ecodesign, the replies of these respondents to the earlier questions cannot necessarily be considered representative. Therefore, the calculation was also done with “lighting respondents” removed. Then, 84% of the respondents to the OPC agree that the EU Energy Label helps when deciding which product to buy. Of the remainder, around 7% cited "don't know or no opinion" or did not reply and 9% responded negatively.

When asked where they would look to find additional technical information about a product, respondents listed the following (more than one response permitted), ranked by the options provided: manufacturer's website (82%), the booklet of instructions (50%), [the Ecodesign] product information sheet (47%), internet user fora (39%), the retailer's website (18%), and consumer organisations (10%).

Some 63% of the participants were in favour of including Ecodesign requirements on reparability and durability, and 65% of respondents considered that this information should be on Energy Labels.

Regarding the reparability of products, participants valued mostly as "very important" to "important" (in the range 62%-68%) 11 each of the following: a warranty, the availability of spare parts, and a complete manual for repair and maintenance. The delivery time of spare parts was rated as 56% "very important" to "important".

Small and Medium Enterprises (SME) Consultation [SMEs < 250 employees]

One of the aims of the OPC was to gather specific information on SMEs' roles and importance on the market, and to acquire more knowledge on how the aspects related to the environmental impacts of these six product groups were considered by SMEs.

The quali-quantitative evaluation of the effect on SMEs of potential regulatory measures for the environmental impact of all six product categories gave the following results. Approximately 10.5% or replies were from SMEs. These SMEs were involved in the following activities (most popular cited first): (i) product installation, (ii) rent/ leasing of appliances, (iii) repair, (iv) retail of appliances or spare parts, (v) final product manufacture/ assembly, (vi) sale of second-hand appliances, (vii) "other" activities, and (viii) manufacture of specific components.

In the OPC responses, SMEs reported that they were aware of the Ecodesign and EU Energy Label requirements applicable to the products they were involved in. Nevertheless, SMEs mostly declined to respond (90%) or replied in "don’t know/ no opinion" (6%) when asked about the potential impact on their businesses per se, or potential impacts on SMEs compared to larger enterprises, of the introduction of resource efficiency requirements in the revised Ecodesign and Energy Labelling regulations. Of those SMEs who gave an opinion, some 3-4% considered that the impacts could be negative, and around 1% thought that the effects would be positive.

4.2.Responses relating specifically to electronic displays

The consultation was mainly intended to gather opinions about information to be included on a redesigned energy label for displays regarding energy efficiency and durability, intended to be clear, self-explanatory and helpful to consumers making purchase choices.

Electronic displays are a relatively complex product. The label has to be designed in order to make instantly comparable different products with possibly very different technical characteristics. The power use of a display is influenced by its screen area, its resolution level, its backlighting technology, possibly the use of high dynamic range (HDR), refresh frequency and more. The label needs to be clear and not excessively crowded by information not crucial for comparison (more complete information can be found in an associated information sheet).

To help assess the user relevance of the information to be put on the label, the following questions where asked and the responses are illustrated below:

A new standard for improving image quality is HDR (High Dynamic Range). A display may even double its power use when displaying content filmed and broadcast in HDR. Would the indication of the power consumption in HDR mode be a relevant information for your purchase choice?

The current energy label for televisions indicates the "annual" energy consumption of the television. What assumptions should be used if the same indication will be provided in the new label (for televisions, computer monitors or other displays)?

One of the components more likely to fail in electronic products is the power supply (e.g. because of electric surges). Would you prefer a display with a standardised external power supply (as a USB with type-C connector) that you could easily buy and replace yourself?

What information would you like to have clearly provided when you buy an electronic display (television, computer display or similar)?: Measured average power used when "on" in normal mode (Watt)

What information would you like to have clearly provided when you buy an electronic display (television, computer display or similar)?: Measured average power used when "on" in HDR mode (Watt)

What information would you like to have clearly provided when you buy an electronic display (television, computer display or similar)?: Diagonal size (cm/inches)

What information would you like to have clearly provided when you buy an electronic display (television, computer display or similar)?: Resolution (horizontal x vertical) in pixels

What information would you like to have clearly provided when you buy an electronic display (television, computer display or similar)?: Nickname of the resolution level (e.g. UHD, WQHD, …)

What information would you like to have clearly provided when you buy an electronic display (television, computer display or similar)?: The power supply is external and standardised (e.g. USB Type-C)

What information would you like to have clearly provided when you buy an electronic display (television, computer display or similar)?: Presence of a TV tuner (i.e. to distinguish a TV from another display)

What information would you like to have clearly provided when you buy an electronic display (television, computer display or similar)?: Presence of a processor (i.e. to distinguish a smart TV)

What information would you like to have clearly provided when you buy an electronic display (television, computer display or similar)?: Network interfaces (i.e. WiFi, RJ45, etc.)

5.Impact Assessment (IA)

An IA is required when the expected economic, environmental or social impacts of EU action are likely to be significant.

The data collected in the review studies, see Annex 1.4, served as a basis for the IA. Additional data and information was collected and discussed by the IA study team with industry and experts, and other stakeholders including Member States.

This impact assessment builds on the previous version that had been approved by the Impact Assessment Board on 4/9/2013 (see Annex 10). In light of the rapid technology evolution, an update of the Impact Assessment was then deemed necessary, based on updated data, provided by industry and representing the market situation in July 2014. This new database of energy data was the evidence basis for re-visiting the draft Commission proposals, in particular the energy efficiency index calculation and the parameters to be set as minimum requirements and for establishing the energy class boundaries.

Annex 3:    Who is affected and how?

This annex explains the practical implications of a potential ecodesign and energy labelling measures based on implementation of the preferred policy option, see Section 6.

1.PRACTICAL IMPLICATIONS OF THE INITIATIVE

The ecodesign regulation will apply to the manufacturers, importers and authorised representatives of displays (televisions and monitors) in the scope of the regulation.

The energy labelling regulations will apply to the suppliers and the dealers of displays (televisions and monitors) and signage displays in the scope of the regulations

They will need to with comply the ecodesign requirements summarised in the table below:

Summary of the Ecodesign requirements

2.SUMMARY OF COSTS AND BENEFITS

For the preferred option, Tables 3.1 and 3.2 present the costs and benefits that were identified and assessed during the impact assessment process.

Table 3.1: Overview of Benefits (total for all provisions) as compared to the baseline– Preferred Option



Annex 4:    Analytical model used

1.GENERAL INTRODUCTION

General data availability for the scenario analyses of electronic displays is not good. For sales, stock and prices of displays there are GfK-studies periodically acquired by e.g. NGOs such as TopTen. For energy efficiency, however, data have been compiled ad-hoc, either by DigitalEurope or by researchers such as Intertek, Bob Harrison, CLASP and VHK.

For the impact analysis the dataset for 2017 was added. The reliability of most data could be checked by various sources and ultimately the data were confirmed by stakeholder consensus in various stakeholder meetings, bilateral and plenary. Employment impacts are derived from revenue per employee, again checked against reported revenue totals for the sector and anecdotal information from annual reports of individual manufacturers.

As regards the various monetary rates, the impact assessment study conforms to the MEErP. This means e.g. that (industrial) energy prices were assessed from Eurostat data and for future projections an escalation rate of 4% was used. All prices and costs are expressed in Euro 2010, calculated with historical inflation rates and a 2% inflation for future projections. For investment-type considerations, a discount rate of 4% is used.

In addition, a sensitivity analysis was carried out that calculates energy costs and consumer expenditure at an escalation rate of 1.5%. In short, this means that electricity tariffs in 2030 are not €0.36/kWh, but €0.24/kWh (all in Euro 2010).

For greenhouse gas emissions, the emission rate (in kg CO2 eq./kWh) does vary over the projection period in line with overall EU projections as indicated in MEErP.

2.MAIN CHARACTERISTICS OF THE MODEL

The impact assessment uses a stock model developed by VHK first in the context of the MEEuP 2005 methodology and then further developed in the MEErP 2011 and the VHK EIA-studies for the Commission. It has been used successfully, i.e. to the satisfaction of stakeholders and Commission, in over 20 impact assessment studies for Ecodesign and Energy Labelling studies where VHK assisted the Commission.

The stock model has been specifically developed and paid for by the Commission (DG GROW and DG ENER) and is thus subject to the same intellectual property provisions as other contract work for the Commission.

Over the years, as it was part of various Commission contracts it has been scrutinised by many Commission officials of various DGs as well as experts from various stakeholder groups (industry, Member States and NGOs).

3.MODEL STRUCTURE

The general structure of the model follows the format and conventions as laid down in the VHK EIA-study 12 . The following figure gives an illustration of the parameters used. The parameters with extension BAU are used for the baseline scenario. The parameters with extension ECO are used for one or more policy options (ECO1, ECO2, etc.).

Figure 4.1: Structure of core calculation

The model is built in a spreadsheet, using a 1 year time step. Every parameter name corresponds to an Excel sheet. Auxiliary sheets are added for the calculations.

In the case of electronic displays, 4 scenarios are calculated: BAU, ECO, Leni(ent) and Ambi(tious) scenarios all with televisions, monitors and signage displays in the scope.

The tables hereafter give the details of main inputs and outputs of the model.

4.INPUTS

Table 4.1. Inputs scenario calculation

Economic and energy data split-up by display type in scope

SALES, in million units

1990

1995

2000

2005

2010

2015

2020

2025

2030

2040

TV No NA ('standard')

26

29

34

46

56

0

0

0

0

0

TV LoNA

0

0

0

0

9

21

13

0

0

0

TV HiNA ('Smart')

0

0

0

0

9

21

39

60

69

70

subtotal TV

26

29

34

47

74

42

52

60

69

70

PC Monitor

10

13

17

22

25

14

14

14

14

14

Signage display

0

0

0

0

0

2

4

3

3

3

total

36

42

51

69

99

58

70

77

86

87

STOCK, in million units

1990

1995

2000

2005

2010

2015

2020

2025

2030

2040

TV No NA ('standard')

215

259

323

356

327

231

92

0

0

0

TV LoNA

0

0

0

0

18

98

164

109

27

0

TV HiNA ('Smart')

0

0

0

0

19

98

241

411

581

700

subtotal TV

215

259

323

357

364

426

497

520

608

700

PC Monitor

13

69

100

129

172

130

98

98

98

98

Signage display

0

0

0

0

1

7

21

31

31

30

total

443

586

745

842

901

990

1114

1169

1345

1528

SURFACE/UNIT, in dm²/unit

1990

1995

2000

2005

2010

2015

2020

2025

2030

2040

TV average all types

10

11

13

19

28

43

51

59

68

92

PC Monitor average

5

6

8

10

11

13

16

18

20

25

Signage display average

16

18

21

32

46

71

84

97

113

151

sales wt.'d average

9

10

11

16

24

37

46

53

62

83

SURFACE EU28, in km²

1990

1995

2000

2005

2010

2015

2020

2025

2030

2040

TV all types

21

29

40

69

102

185

253

306

415

642

PC Monitor

1

4

8

12

20

18

16

18

20

24

Signage display

0

0

0

0

0

5

18

30

34

45

total

22

33

48

82

122

207

287

353

469

711

On-mode specific electric power consumption of SALES in W/dm2

TV HD:

1990

1995

2000

2005

2010

2015

2020

2025

2030

2040

BAU

8,85

7,69

7,71

5,56

3,70

1,27

0,97

0,79

0,65

0,44

Leni/ECO/Ambi

8,85

7,69

7,71

5,56

3,70

1,27

0,96

0,60

0,35

0,35

TV UHD/3D:

 

3D/UHD% stock

0%

0%

0%

0%

4%

20%

50%

75%

100%

100%

BAU

8,85

7,69

7,71

5,56

3,78

1,40

1,21

1,08

0,97

0,66

Leni

8,85

7,69

7,71

5,56

3,78

1,40

1,20

0,83

0,53

0,53

ECO/Ambi

8,85

7,69

7,71

5,56

3,78

1,40

1,06

0,69

0,42

0,42

 

 

Monitor HD:

1990

1990

1990

2005

2010

2015

2020

2025

2030

2040

BAU

8,85

7,69

7,71

5,56

3,70

1,27

1,16

1,05

0,95

0,78

Leni/ECO/Ambi

8,85

7,69

7,71

5,56

3,70

1,27

1,16

0,74

0,41

0,35

Monitor UHD:

 

 

 

 

 

 

 

 

 

 

UHD% stock

0%

0%

0%

0%

2%

10%

25%

38%

50%

50%

BAU

8,85

7,69

7,71

5,56

3,74

1,33

1,30

1,24

1,19

0,97

Leni

8,85

7,69

7,71

5,56

3,74

1,33

1,31

0,88

0,51

0,43

ECO/Ambi

8,85

7,69

7,71

5,56

3,74

1,33

1,22

0,80

0,45

0,38

Signage displays

as TVs multiplied by 2.

Standby mode electric power consumption of sales in W

 

1990

1995

2000

2005

2010

2015

2020

2025

2030

2040

TV No NA ('standard')

8,00

6,25

4,50

2,75

1,00

0,23

0,10

0,05

0,05

0,05

TV LoNA

0,00

0,00

0,00

2,00

2,00

2,00

2,00

2,00

2,00

2,00

TV HiNA ('Smart')

0,00

0,00

0,00

0,00

0,00

6,39

5,00

4,50

4,00

3,00

PC Monitor

9,00

7,07

5,14

3,20

1,27

0,41

0,25

0,15

0,15

0,15

Signage display

15% of on-mode energy use

Standby mode hours per day

All scenarios

1990

1995

2000

2005

2010

2015

2020

2025

2030

2040

TV

6,00

9,50

13,00

16,50

10,00

10,00

10,00

10,00

10,00

10,00

PC Monitor

4,00

4,00

4,00

4,00

4,00

4,00

4,00

4,00

4,00

4,00

Signage display

15% of on-mode energy use

Note 1: For TVs and monitors average viewing hours are 4h/day. For signage 12h/day (average with wide spread). 365 d/yr.

Note 2: Until 2009 the non-viewing hours are considered standby-hours are considered a mix of passive standby (No NA) and hard off-switch (0W); in 2010 and later networked standby is considered significant and the power values are a mix of passive standby and networked standby.

Note 3: Signage displays have a high share of networked standby. It is considered that larger sizes have added complexity in that respect and thus standby is calculated as a percentage of on-mode.

Note 4: Meeting (networked) standby test data is not critical for display makers. That is why all scenarios have the same values in the model (although small differences can exist, but no specific information could be found). Networked standby can be problematic at the level of service providers overriding power management

Retail prices (incl. VAT, in euros 2010 per unit)

 

1990

1995

2000

2005

2010

2015

2020

2025

2030

2040

TV

800

800

800

500

450

450

450

450

450

450

PC Monitor

200

200

200

200

170

170

170

170

170

170

Signage display

1600

1600

1600

1000

900

900

900

900

900

900

sales wt'd average

633

615

604

405

383

408

445

434

435

435

Electricity Rates applied for displays (residential rates), in €/kwh elec (inflation corrected to euros 2010)

 

1990

1995

2000

2005

2010

2015

2020

2025

2030

2040

Default (4% escalation)

0,18

0,18

0,16

0,15

0,17

0,20

0,25

0,30

0,37

0,55

Sensitivity (1,5% escalation)

0,18

0,18

0,16

0,15

0,17

0,19

0,21

0,23

0,24

0,28

escalation rate applies from 2014 onwards (before 2014 historical prices)



5.OUTPUTS

Table 4.2. Outputs scenario calculation

OUTPUTS

per year

 

 

 

 

 

 

 

 

 

 

 

On-mode specific electric power consumption of STOCK in W/dm2

TV HD:

1990

1995

2000

2005

2010

2015

2020

2025

2030

2040

BAU

8,83

8,32

7,93

7,22

4,72

2,52

1,64

0,93

0,77

0,52

Leni/ECO/Ambi

8,83

8,32

7,93

7,22

4,72

2,52

1,64

0,87

0,57

0,35

TV UHD/3D:

 

3D/UHD% stock

0%

0%

0%

0%

4%

20%

50%

75%

100%

100%

BAU

8,83

8,32

7,93

7,22

4,82

2,78

2,05

1,28

1,15

0,79

Leni

8,83

8,32

7,93

7,22

4,82

2,78

2,05

1,20

0,85

0,53

ECO/Ambi

8,83

8,32

7,93

7,22

4,82

2,78

1,80

1,00

0,68

0,42

Average TVs

 

BAU

8,83

8,32

7,93

7,22

4,73

2,57

1,84

1,20

1,15

0,79

Leni

8,83

8,32

7,93

7,22

4,73

2,57

1,84

1,12

0,85

0,53

ECO/Ambi

8,83

8,32

7,93

7,22

4,73

2,57

1,72

0,97

0,68

0,42

 

 

Monitor HD:

1990

1995

2000

2005

2010

2015

2020

2025

2030

2040

BAU

9,51

8,25

7,64

7,26

5,06

2,93

1,25

1,11

1,01

0,83

Leni/ECO/Ambi

9,51

8,25

7,64

7,26

5,06

2,93

1,25

1,00

0,59

0,35

Monitor UHD:

 

 

 

 

 

 

 

 

 

 

UHD% stock

0%

0%

0%

0%

2%

10%

25%

38%

50%

50%

BAU

9,51

8,25

7,64

7,26

5,11

3,08

1,40

1,32

1,26

1,03

Leni

9,51

8,25

7,64

7,26

5,11

3,08

1,40

1,18

0,74

0,44

ECO/Ambi

9,51

8,25

7,64

7,26

5,11

3,08

1,31

1,07

0,65

0,39

Average Monitors

BAU

9,51

8,25

7,64

7,26

5,06

2,95

1,28

1,19

1,13

0,93

Leni

9,51

8,25

7,64

7,26

5,06

2,95

1,28

1,07

0,66

0,40

ECO/Ambi

9,51

8,25

7,64

7,26

5,06

2,95

1,26

1,02

0,62

0,37

Signage displays

as TVs multiplied by 2. Leni and ECO follow TV BAU. Ambi follows TV ECO

 

 

 

 

 

 

 

 

 

 

 

Stock wt'd avg of the above, all types of displays

 

 

 

 

 

 

 

 

 

 

1990

1995

2000

2005

2010

2015

2020

2025

2030

2040

BAU

8,87

8,30

7,86

7,23

4,84

2,69

1,82

1,25

1,20

0,83

Leni

8,87

8,30

7,86

7,23

4,84

2,69

1,82

1,17

0,89

0,55

ECO

8,87

8,30

7,86

7,23

4,84

2,69

1,71

1,02

0,70

0,43

Ambi

8,87

8,30

7,86

7,23

4,84

2,69

1,51

0,87

0,62

0,39



 

OUTPUTS

per year

accumulative

EU electricity consumption (in TWh/a, of stock)

 

 

 

 

 

1990

2005

2010

2015

2020

2025

2030

2040

2021-'30

2021-'40

BAU

36

92

92

98

94

90

98

98

927

1922

Lenient

36

92

92

98

94

86

82

75

863

1619

ECO

36

92

92

98

92

80

76

73

813

1538

Ambi

36

92

92

98

83

64

59

53

651

1178

 

 

 

EU GHG emissions (in Mt CO2 eq./a)

 

 

1990

2005

2010

2015

2020

2025

2030

2040

2021-'30

2021-'40

BAU

16

39

38

39

36

32

33

29

332

648

Lenient

16

39

38

39

36

31

28

23

309

550

ECO

16

39

38

39

35

29

26

22

291

522

Ambi

16

39

38

39

31

23

20

16

233

401

Consumer expenditure (in bn Euros 2010)

 

 

1990

2005

2010

2015

2020

2025

2030

2040

2021-'30

2021-'40

BAU

30

43

54

43

53

60

73

90

619

1448

Lenient

30

43

54

43

53

59

67

78

598

1316

ECO

30

43

54

43

53

57

65

77

581

1285

Ambi

30

43

54

43

50

52

58

66

531

1144

Acquisition costs (in bn Euros 2010, incl. VAT)

 

 

1990

2005

2010

2015

2020

2025

2030

2040

2021-'30

2021-'40

All scenarios

23

28

38

23

29

32

36

37

325

691

Energy costs (in bn Euros 2010)

 

 

1990

2005

2010

2015

2020

2025

2030

2040

2021-'30

2021-'40

BAU

6

14

16

20

23

27

36

53

289

747

Lenient

6

14

16

20

23

26

30

41

268

615

ECO

6

14

16

20

23

24

28

40

251

585

Ambi

6

14

16

20

21

19

22

29

201

443

Note that the running costs include, apart from the energy costs, 0,5 bn euro annually in repairs. Accumulative 5 bn in 10 years, 10 bn in 20 years



6.BUSINESS IMPACTS

BUSINESS IMPACTS (All scenarios, revenues in bn Euros 2010. )

1990

2005

2010

2015

2020

2025

2030

2040

2021-'30

2021-'40

EU industry

4,0

2,5

1,5

1,0

1,0

1,0

1,0

1,0

10

20

Importers/ distributors

8

12

18

11

14

15

17

18

158

166

Retails

7,8

9,5

12,9

7,8

10,0

10,9

12,3

12,4

112

124

Total business revenue

19,4

23,8

32,2

19,4

25,0

27,3

30,7

31,1

280

310

 

 

 

 

 

 

 

 

 

 

 

Employment (All scenarios, in 1000 jobs)

1990

2005

2010

2015

2020

2025

2030

2040

EU industry

60

20

15

5

5

5

5

5

Importers/ distributors

15

15

15

17

19

21

21

21

Retails

155

190

258

155

200

218

246

249

Total business revenue

230

225

288

177

224

244

272

275

 

 

 

 

 

 

 

 

 

 

 

na=not applicable

Figure 4.2 below illustrates the rapid improvement in average efficiency, expressed in W power input per dm² viewing surface area. The names illustrate typical technologies, starting from CRT (8 W/dm²) and plasma (9 W) before 2005. The LCD TV with CCFL backlight (around 6 ±2 W) was the dominant technology during the preparation of the current measures and indeed the 2012 Ecodesign limit (3W) was ambitious at the time. Today, for LED LCD TVs a level of 1 W/dm² is typical.

The graph shows that the efficiency improvement is expected to slow down because technologies that thus far achieved the large efficiency improvements are nearing their limits. Experts have doubts whether Moore’s law, predicting a doubling of the number of transistors per surface area every 2 years, will keep up now that chips are nearing a form factor of 5 nanometres, which is about as small as you can get with electricity. The next step could be light chips, but there is still a long way to go. The LED-backlight at efficacies of 200 lm/W could maybe still bring some 20% more, but then it is nearing its limit.

The main area where a step-change in innovation could still take place is in eliminating the loss of light in all the filters and LCD-polaroids that are blocking the LED backlight. If we could directly look at the LED-subpixels, similar to OLED but at a much higher lighting efficiency, the efficiency could probably more than double. The problem is that the flawless mass-manufacturing of millions of LED subpixels is a huge technological challenge and requires massive investments. At the moment Samsung, calling it ‘microLED’, has produced a modular video-wall product for the professional market, but energy efficiency is not (yet) impressive and pricing is obviously nowhere near consumer market pricing.



Annex 5:    Minutes of the Ecodesign Consultation Forums

5.1    Minutes of the Ecodesign Consultation Forum on 6 July 2017

Meeting of the Consultation Forum under Article 18 of the Ecodesign Directive 2009/125/EC on energy-related products – Electronic displays

Brussels, 6 July (10.00 - 17.30)

Participants: see "Attendance List" in Annex

1.    Welcome and introduction

The Chair welcomed the participants to the Consultation Forum on the review of measures for electronic displays.

He gave a brief explanation of the current state of Ecodesign and energy labelling. He noted the adoption on 30 November 2016 of the Ecodesign Working Plan for 2016-2019, and the adoption of the energy labelling Regulation, which would be published on 28 July in the Official Journal of the EU and enter into force on 1 August. He noted the consequences of the new Regulation in particular as regards the rescaling of existing labels and the product registration database.

BE asked whether the Commission was considering updating the data on televisions so that requirements would not become obsolete after a short period of time. The Chair replied that the requirements were based on the most recent data available (mid 2016), and agreed that with a fast-moving product group there would always be a question about how up-to-date the data was. The Commission may further verify the data before the proposal is voted in the Regulatory Committee.

The UK asked whether the Commission could come forward with tentative dates on future meetings, noting that at least twelve remained for the rest of the year. The Chair responded that the Commission was in the process of confirming the dates and would contact Consultation Forum members as soon as they were set.

ORGALIME asked about the progress of the Steering group and sub-groups working on the product database which would have to be in place by 1 January 2019. The Chair replied that the first meeting of the steering group had been on 4 July and preliminary ideas where presented. The Commission plans to have regular meetings of the steering group to keep stakeholders involved.

2.    Adoption of the Agenda

The agenda was adopted with no changes.

3.    Approval of the minutes of previous meetings

The Chair noted that the minutes of the Consultation Forum of 27 March 2017 on water heaters and vacuum cleaners had been revised to include some written comments. The draft minutes were adopted.

4.    Presentation of the proposal for possible Energy Labelling requirements for electronic displays

The Commission policy officer responsible for electronic displays gave a presentation on the proposals.

On the scope, he noted that the proposed size lower threshold for displays was the same as for Ecodesign measures (i.e. 100 cm2 or about 6 inches) but that this was up for discussion given that in very small displays the difference in energy use for different classes may be negligible. Displays with very specific uses, for example medical products that are covered by other legislation, would be entirely out of scope. Displays integrated into any other product would be out of scope as well.

CLASP suggested that increasing the minimum size requirements from 100 cm2 would prevent substantial energy savings as it would exclude 7 or 8 inches displays which are already on the market.

IT and BE noted some of the difficulties of regulating and testing smaller-sized or specialised types of screens.

AT inquired as to why digital signage displays had been excluded from the scope, and whether displays integrated into desktop computers were also excluded.

NL noted the difficulty of assessing integrated displays for energy labelling purposes, as their energy use is difficult to be isolated but encouraged the Commission to consider ways in which for Ecodesign they should be kept into scope, particularly for non-energy requirements. NL also cautioned against introducing loopholes when exempting standalone displays sold with the intention to integrate them into another product, noting that it was possible that any screen could hypothetically fall under that definition. CECED offered in response to explain to NL how loopholes could be avoided while making the exemption clear.

DIGITALEUROPE expressed their support for a limitation of the scope to include only televisions and computer displays, but suggested that the exemptions in the scope were not clear enough. They requested a general exemption to exclude integrated displays. ORGALIME expressed similar reservations on the comprehensiveness of the exemptions.

UK, and subsequently CECED, agreed that integrated displays should not be in scope of the energy labelling Regulation under discussion, both suggesting that integrated displays should be regulated through vertical measures in each relevant product file.

AT and SE, supported by ECOS, suggested that the work on signage displays had not progressed sufficiently over the course of three years, and noted that a list of next steps and a study would be welcome. SE added that it was desirable to see signage products referred to in a review clause with a date for a final proposal, arguing that difficulties relating to measurements could be overcome.

In response the Commission, citing the difference in use and characteristics of signage displays, noted that signage displays would be addressed through a separate measure and study. The Commission added that although no specific date had been set for a review, signage displays were cited in the current Ecodesign Working Plan, which meant that they would need to be considered within the 2016-2019 period. Integrated displays should be not labelled separately. Finally, the Commission noted that it will consider improving the wording relating to business-to-business screens intended to be integrated into another product after the sale, e.g. by considering CECED suggestions.

DIGITALEUROPE stated that their position continues to be that signage displays should be tackled though a separate Regulation, and that many purchasers of signage displays already took energy efficiency into account, rendering a label less useful.

In response, SE argued that many smaller businesses that bought signage displays would be assisted by an energy label. Procurement would be facilitated as well.

The Chair, noting the comments made, committed to launching a dedicated study on signage displays.

IT asked the Commission to clarify at what point it intended to review the electronic displays measure, noting that the new energy labelling Regulation indicated that labels should be set to be applicable for ten years.

The Commission explained that the framework provisions did not necessarily mean that a given Regulation could not be revised within the ten years, just that rescaling could not happen within that time. Moreover, if signage displays were to be given an energy label, this could be done as well.

The discussion moved to the Energy Efficiency Index with a specific indication for High Dynamic Range (HDR) mode. The Commission outlined the proposed formula, noting that the new framework for energy labelling establishes a clear relation between Ecodesign and Energy Labelling, as the bottom class(es) in the label have to be greyed out when Ecodesign tiers come in force and exclude from the market the less performing products.

AT noted that an energy label should be as transparent and easy to understand as possible and suggested that the Commission's proposal with a two-scale label, one for normal screen use and one for HDR, now that HDR is unknown to most, may result confusing to consumers and asked about the pace of uptake. Similarly to vacuum cleaners or to washing machines, a less prominent scale at the bottom of the label could be considered.

IT, DE, UK, DK, and NL made interventions agreeing with AT, and were supported by ANEC/BEUC, variously expressing concern about the complexity of a two-scale label, the lack of current consumer knowledge of HDR technology, the potential future developments in technology (meaning HDR technology could be surpassed), and asking for the results of consumer testing on the proposed label.

BE questioned the figures on HDR doubling the energy consumption of displays, argued that quantum dot TVs and possibly OLED technologies should be kept in scope, and suggested that the Automatic Brightness Control (ABC) compliance allowance could be increased from 10% to 15% .

NL, supported by the UK, further suggested that an option for HDR would be to have a simple identifier on the label rather than a second scale, and to incorporate HDR into the general formula for determining efficiency.

DIGITALEUROPE advised caution on assuming a high rate of technological improvements in the future, stating that without a "breakthrough" in technology, the current classes A and B being proposed would not be filled by products in the next ten years. Digital Europe supported the double scale showing the energy efficiency in HDR mode. The alternative of having to use a common formula for ecodesign and labelling with an arbitrary share of HDR (based on insufficient data availability) may exclude new products from the market.

The Korean Electronics Association (KEA) made several points, arguing firstly that the requirement to put a label on the box packaging was unnecessary; secondly, that the year of manufacture requirement ought to be removed; that the requirement to include HDR mode power consumption be removed; that the criteria for efficiency classes A-C criteria were extremely difficult to delivery; and that the proposed QR code on the label be removed as causing delays for producers. Finally, it proposed removing several symbols from the label, given the need for the simplest possible design to assist consumer understanding.

The Commission explained that consumers needed to be informed accurately about energy consumption in real usage. HDR technology is just emerging onto the market (standardisation was completed in 2016) with a still unknown pace; it is likely that sometime between 2020 and 2030 HDR will become "the" standard mode of operation. The uneven impact of HDR on energy consumption in displays, because of different algorithms used, makes it important to include it in the label. Without an indication of the impact of HDR on energy consumption, there is a risk that customers would feel misinformed about consumption in "real usage". Conversely, it is impossible at this stage to predict the share of HDR and non-HDR in typical consumption both in time (pace of uptake of the technology) and use (in a computer display for office applications it would be never used but would be used about 100% of the time with gaming applications). The Commission expert consultant added that HDR is already a standardized EU broadcast standard and is very unlikely to fade after a few years. The power usage of some televisions barely changed when in HDR mode, while it more than doubled for others. The consumer, the Commission argued, therefore has a right to know the consumption and a double scale is already used in other product groups (e.g. tyres, heating/cooling products). The Commission also explained that the label needed to be on the box for situations where retailers do not display the product outside of the box, such as in hard-discount shops (common situation for cheap computer monitors or small TVs). The Commission agreed that year of manufacturing in the information sheet could be an issue. The Commission reassured KEA that the inclusion of a QR code would not delay production.

CLASP noted that there was substantial evidence to suggest that some screen models show increased energy demand in HDR mode (some up to 130%) and argued that it was very important for the Commission to take it into account. Furthermore, the shift to quantum dot technology provides huge potential for efficiency gains. Supported by ECOS, CLASP argued that the timelines of the Regulation are not ambitious enough, now that the Commission will have to adopt a delegated act by the end of 2018.

DIGITALEUROPE suggested that variation in energy use was down to some of the products having additional functionalities rather than being inefficient, and argued against including HDR in a single formula because a regulation possibly blocking products from entering the market should be based on currently available and well known technologies.

IT, BE, and DIGITALEUROPE supported the notion that labels were not needed on packaging. PT suggested that having them on both sides may seem excessive, while NL was in favour of the proposal as it stood, arguing that shops needed to stack packaging boxes so that the label would be visible to the consumer. The UK expressed concerns about possible confusion during the rescaling period.

SE noted the importance of ensuring consumers were informed about HDR and proposed three options: firstly, the two-scale approach proposed by the Commission; secondly, weighting the formula to reflect the HDR factor; and thirdly, a secondary "scale-behind-the-scale" approach. SE argued that the wide discrepancy in efficiency of HDR technology meant that the label deserved more than simply an identifier.

BE was in favour of two different labels, one for normal mode and one for HDR when available.

DIGITALEUROPE suggested that, for boxes printed in one colour and for on-line sales, there was confusion as to where the "coloured arrow" is intended to be displayed.

The Commission argued that it was perfectly possible that consumers might buy a boxed product without first looking at the product itself, particularly for cheap products, making labels on the box important: because of the quick sales of products in "promotion", compliance control would be difficult and training of staff unsuitable. It noted SE's suggestions of options relating to HDR.

The Commission continued its presentation, outlining the proposed physical design of the label, noting various different options and potential icon designs. The understanding of pictograms by consumers and the general understanding of the label is being tested. The Commission explained some of the pictograms proposed in the label below the A-G scale, namely: presence of auto brightness control (ABC), presence of movement sensor and standardised external power supply.

On the physical design of the label, AT suggested that it may be complicated to explain to consumers the relevance of the standardised EPS, given priority on other aspects. Also the screen size measurements are too large. DE, IT, NL, SE, ANEC/BEUC, DIGITALEUROPE, ENEL, and EED held similar positions, noting that pictograms could be removed or replaced with more useful information and that the screen size measure was too large.

The UK, supported by ANEC/BEUC, noted that it was only going to comment on the label design only once the results of the consumer survey were known.

IT asked the Commission to confirm that it was testing a one-scale label with consumers.

NL asked more prominence for the crucial section of the label, i.e. the coloured scale and dimension of the class and appreciated the option of using the displays itself to show the label, recalling the possibility of apps to get additional information from the database.

DE, ECOS, ANEC/BEUC were in favour of including annual consumption figures on the label, suggesting that measurement difficulties could be overcome.

However DIGITALEUROPE urged caution, citing the difference in usage patterns between TVs and computer monitors and, should annual energy use be included, it may mislead consumers. DIGITALEUROPE stated also that it is in favour of the double scale with HDR on the label as it is the best way of communicating to the consumer and requested tolerances in the design, as printing or displaying in different media may involve some fractions of millimetres of differences in respect to the label template. On the QR code, it stated that if it was placed on the label then it should not cause production issues.

BE suggested that the QR code on the label, intended to be linked to the product registration database, could be codified to incorporate extra information, such as for example language information.

EEB asked to shrink information such as display size and resolution and to add information about durability, such as extended warranty and availability of spare parts.

DE, IT, and ANEC/BEUC warned against the risk that EPS allowances meant that the same model of display could bear two different label classes, which was undesirable. FAIRPHONE offered to provide data on EPS, recommended earlier user testing in the future, and suggested that increasing consumer understanding was partly down to industry.

There was some discussion on market surveillance considerations for software updates, with DE seeking clarification, NL suggesting that market surveillance authorities could use their public warning function, and CLASP arguing that keeping a product in the same class as when it was bought, despite software updates, seemed reasonable.

CECED asked about a better differentiation of the label, to better communicate the rescaling done and not have consumers puzzled by the lack of A-plusses. SE recognised the relevance of ABC, movement sensors and external EPS but argued that in the Ecodesign measure, if maintained as communicated to the WTO, they get an allowance, so producers have already an incentive to provide the features.

The Commission stated that the consumer survey would be wide-ranging, and that some minor adjustments may still be possible. It noted the positions of the various participants, explaining that the most critical task was to choose a design that reflected what the consumer needed to choose between comparable displays. The Commission explained that diagonal size and resolution are relevant for energy use and should be indicated not to mislead consumers. As for a possibly overcrowded label, the Commission explained that the goal would be to have all crucial information in one place, thereby better attracting the attention of the consumer who may otherwise be distracted by additional retailer's labels. As regards additional or different features to be displayed on the label, the Commission added that a part of the ongoing survey is to verify if consumers consider that other information is missing that may be necessary for making an informed choice, including the annual energy consumption or extended warranty. So the final label layout may include different information that consumers deem relevant and the shrunk screen size and resolution section. It further stated that the QR code would lead to the database where a wide range of information is available in all EU languages (with the local language automatically proposed). As regards the pictogram for the EPS, the goal is not only material savings, but, potentially, enhancing durability, as a standardised EPS would be cheaper and more easily available as a spare part.

5.    Presentation of the proposed changes to the Ecodesign requirements for electronic displays

The Chair stated that the Commission had taken note of comments received so far (including through the WTO), and that it would present some of the changes it was considering introducing to the measure. In terms of timing, the ecodesign process would then be realigned with the labelling process.

The Commission explained that the bulk of comments so far related to the scope of the provisions, in particular to displays integrated into other products, but also to dismantling and disassembling provisions. The remaining remarks related to the ambition levels of the proposal, which risked excluding products from the market. The Commission elaborated that the aim with the scope as drafted was to avoid loopholes and to ensure alignment with the provisions of the WEEE Directive. An alternative proposed approach would be to narrow the scope to include only televisions and certain kinds of computer displays – namely, only those without processors (i.e. excluding integrated desktops). For the standby provisions, the aim was to include professional products too, although the wording would need to be adapted, including introducing a distinction between off mode and standby. It could also be considered to cover displays integrated into products "vertically" within the measure for each separate product.

DE expressed support for the "horizontal" provision in the display Regulation for displays integrated into other products as is now, provided it did not delay the Regulation. This was supported by NL, SE, EURIC, FEAD, and EEB, who noted that a horizontal measure would not overburden industry given that the requirement is limited to the extractability of a limited list of components. Moreover, the existing WEEE Directive already requires that LCD panels integrated into an appliance have to be separated.

IT gave support for horizontal measures, provided that the integrated display is clearly separable from other electronics.

BE suggested that a vertical approach may be better if more focus was put on reparability aspects.

EHI, ORGALIME, EGMF, and DIGITALEUROPE preferred a vertical, product-by-product regulatory approach, the latter noting their satisfaction with the revised scope.

EURIC, supported by EERA and FEAC, stressed the need for better design to facilitate recycling and fully capture the 'circular economy' potential: products are more and more difficult to be recycled, with less and less design for recycling taking place. EURIC defended a horizontal approach as any display has to be treated in the same way during dismantling for recycling, irrespective of the product into which it is integrated.

DIGITALEUROPE defended a vertical approach as giving more opportunities for product-specific requirements. It also requested more clarity on terminology such as welding and soldering. DIGITALEUROPE also asked the Commission to change its approach to network standby, which it argued would cause the industry to change its approach to network products.

IT argued that the energy threshold proposed for off-mode mode was not verifiable. Moreover, IT expressed support for the more recent text, although the previous text was acceptable if gluing was better defined. IT argued that requirements on time limits would be not verifiable by authorities. IT asked for clarification as to why functionality and safety provisions would be not be included in a new proposal.

The Chair requested examples from industry of where a safety exemption from the provisions was necessary. DIGITALEUROPE cited tumble driers as one example.

IFIXIT stressed that there is no confusion as welding means melting substrates of two components together, whilst soldering or brazing is a process to add a melted material to join two components. So soldering or brazing is rightly not mentioned in the current proposal. It also stressed a contradiction on Digital Europe's defence of a vertical versus a horizontal approach for the welding/gluing requirement: if tumble driers are used as the example for the need of firmly glued/welded integrated display (i.e. vertically regulated), then for televisions and computer displays this would not be necessary and hence gluing/welding should be prohibited.

TIE asked for confirmation that toys would not be in scope of the Regulation, noting that they were covered by other legislation.

The Commission continued its presentation, explaining that the proposed provisions on disassembling and dismantling derive from the WEEE Directive, which requires such requirements to be tackled 'upstream'. It noted that the wording of the proposal relating to welding and gluing was an attempt to have an easily verifiable requirement in the absence of a standard. The goal was to express the fact that the components must be quickly and easily removable from a product but an alternative wording referring to a "measurable/verifiable" effort may be more appropriate to avoid loopholes.

DE remarked that from a market surveillance perspective the regulation would need to do more than simply indicate what level of pressure needed to be applied in disassembly, but also which temperature to apply for how many seconds, which commonly available tools, which skills are needed by staff, etc.

IFIXIT expressed a preference for the original wording referring to the banning of glue and welding as necessary, arguing that it was very clear what "gluing" meant and is less clear and more difficult to verify what "reversible" or "easily reversible" means. It challenged the industry to suggest thresholds allowing for a distinction between products glued in such a way that they can be taken apart easily and those that cannot. More emphasis on dismantling is necessary as components harvesting is crucial for reuse. Gluing frequently makes repair unfeasible such as when it is used for the housing (not infrequent).

EURIC intervened in support, noting that the original proposal seemed preferable as gluing and welding pose problems for the recycling process for the safety of workers, the environment and the increasing of contamination of the waste stream, particularly PMMA boards.

FAIRPHONE, EERA Recyclables, EEB and ECOS also asked for gluing and welding to be explicitly mentioned in the text as being forbidden for the mentioned components, also because glue pollutes the recycled plastics and is an obstacle for recyclers to reach the imposed quotas of recycled materials. Welding and gluing are seen as options for "cheap", poorly designed products. Moreover, instead of asking the Commission to assess the consequences of regulating integrated displays as regards end-of-life requirements under ecodesign, the industry should itself assess the impacts on their recyclability of using integrated displays in products covered by the WEEE Directive.

NL, supported by ECOS, asked for a differentiation between disassembly and dismantling in the text, and stressed that a balance would need to be struck between making sure the product was safe while keeping it easy to disassemble and dismantle. ECOS also stated that a vertical standardisation mandate for displays is necessary, or an amendment of the horizontal M/453.

EGML expressed their support for the new Commission proposal. FEICA intervened in defence of use of glue and mentioned that research is ongoing for more compatible glue compositions making depollution and debonding possible.

BE asked more focus on reparability and argued for different requirements for integrated displays, depending on the type of equipment in which the display is integrated.

VHI supported vertical regulation for similar reasons (the core functionality and purpose of the display is relevant).

Continuing the presentation, the Commission explained some of the considerations relating to the marking of plastics and that it had mainly received requests for clarification rather than objections on the proposals relating to mercury and cadmium. It noted that it would attempt to align the requirements between the ecodesign and the energy labelling measures.

DE urged caution in setting requirements on plastic marking given the ISO standard and the difficulty of enforceability for market surveillance authorities, and suggested that "fingerprinting" for flame retardants was a possibility.

IT suggested that plastic marking needed to be "rethought", and asked the Commission to clarify where the technical documentation would be published and to consider whether it wanted mercury and cadmium content to be discouraged or simply highlighted.

BE expressed its support for plastic marking, but argued in favour of a different testing approach, noting the possibility of conducting a study on the matter in 2018.

EERA Recyclables, supported by EURIC, stated its support for complete prohibition of the use of flame retardants, noting that they largely reduce the recyclability of plastics from electronic equipement.

DIGITALEUROPE said that in principle they were not opposed to plastic marking, if it follows international standards.

Both FEAD and EURIC supported plastic marking and were in favour of provisions on mercury and cadmium.

EEB recalled that the review of the display regulation was mentioned in the communication for the circular economy in 2015, then in the Communication about the current work plan there was emphasis on the need of strengthening ecodesign in electronic products to implement the circular economy, with displays highlighted and finally the Council of environmental ministers urged the Commission to act on ecodesign, addressing resource efficiency. Besides repair, reuse and recycling are crucial for jobs creation in Europe.

As the discussion came to a close, the UK noted that its domestic industry preferred an implementation of the Regulation that was not on 1 January given the complications with sales, and EED made an appeal for the timely adoption of the Regulation.

The Chair noted that the Commission would allow until 1 September for written comments to be sent in, after which they would be analysed, the proposals and impact assessments would be finalised and taken through the Regulatory Scrutiny Board and Inter-Service Consultation, notified to the WTO, brought to the Regulatory Committee (ecodesign) and expert group (energy labelling), to be adopted on time. He committed to sending out a timetable for future meetings.

6.    AOB

Not applicable.



ANNEX – Attendance List of the ECF meeting on 6 July 2017


5.2    Minutes of the Ecodesign Consultation Forum of 10 December 2014

Meeting of the Consultation Forum under Article 18 of Directive 2009/125/EC on energy-related products

Review of the

Commission Regulations on ecodesign of televisions (No 642/2009)

and energy labelling of televisions (No 1062/2010)

Brussels, 10 December 2014 (10.00 – 17:30)

Participants: See “Attendance List” in Annex

EC Participants: Staff members of ENER C3, JRC and ENV.

Welcome and Presentation

The Chair welcomed the participants and introduced the previous steps in the process reviewing the Ecodesign and Energy Labelling Regulations on televisions.

2.Adoption of the agenda

The agenda was adopted without changes.

3.Approval of the minutes from previous CF meetings

The Chair invited participants to provide comments, if any, on the minutes of the Consultation Forum meetings on Commercial Refrigeration held on 2 July 2014 and on Electric Motors held on 29 September 2014. No comments were expressed and the minutes are adopted.

4.Working documents on Ecodesign and Energy Labelling of Electronic Displays, including TVs (ENER Lot 3 and 5)

The Commission services presented the draft ecodesign requirements, after which the documents were discussed by Member States and stakeholders.

BE expressed doubts on excluding PDP, OLED and Quantum Dot displays from tier 1. Although PDP is a declining market, OLED and Quantum Dot are predicted to be more energy efficient than LCD displays. Status displays that are very little should be completely out of scope.

UK criticised inclusion in scope of picture frames, a declining market where the same functions are increasingly performed by tablets.

NL proposed not to set requirements on Tier 3, as too far in the future; a revision in four years should set further requirements.

Digital Europe (DiEu) recalled that OLED displays are only available in classes B and A. Between 2012 and 2014 CCFL displays disappeared, so the largest potential for improvement for EE has been already exploited. The industry is uncertain about the possibility of further big improvements. On status displays, DiEu highlighted the risk of overlapping measures, e.g. tackling status displays embedded in equipment already covered by other legislation.

CECED suggested to exclude status displays from the scope, as vertical regulation on several domestic appliances already covers them. For example in a fridge, a status display may avoid opening the fridge, so the energy used by a display would be largely compensated by the savings from avoiding the opening of the door.

AT commented that PDPs have far higher energy use, however OLED and Quantum Dot are emerging technologies so we should not undermine their development.

ECOS welcomed the scope extension to different displays, in particular for resource efficiency requirements. It criticized the exclusion of PDPs from Tier 1 as this could reproduce a situation similar to the halogen lamps that invaded the market and are slowing down the switch to more efficient LEDs.

Moreover, ECOS would support resource efficiency and information requirements on signage displays. ECOS would recommend also not repeating the mistake of the consultations in 2008, when industry was too cautious on EE improvement potential that finally led to unambitious targets.

ANEC/BEUC supported inclusion of PDPs from tier 1 and highlighted a possible misalignment of scope for mobile equipment (recital 9 and scope).

DiEu suggested to remove the coverage of displays into integrated desktop computers as they may be covered by the review of the computer regulation in a couple of years. Ambiguous wording, such as "including but not limited to" should be eliminated. Signage displays are b2b products, therefore not to be considered in this regulation focusing on consumer products. On network stand-by, there is no justification for tightening requirements in respect to what is already in place. Finally, the APD requirement of 4 hours since last user interaction is already fully satisfactory, so changing it is not necessary. About the easily visible switch, the details put in the draft regulation would be better placed in transitional methods and/or in a mandate for standardisation. The scope should be limited to consumer products and the scope of resource efficiency requirements should match that of the energy efficiency requirements, as in the draft text for energy labelling. Given the limited market penetration of products such as broadcast or enhanced displays, the environmental impact could be not cost-effectively addressed.

AT expressed doubts on the inclusion of medical or enhanced performance displays in the scope of information and resource efficiency requirements. Information should be limited to standard criteria as used in the past.

UK highlighted a possibly inconsistent approach when excluding OLEDs because of lack of data on energy efficiency but including them for resource efficiency requirements. The explanatory memorandum mentioned the advantages of the draft Regulations but not the cost. A UK analysis suggests there are no clear benefits compared to costs, so a robust analysis will be needed, particularly for the new resource efficiency requirements.

NL suggested a minimum area below which displays such as status or picture frames could be excluded from the scope. Although big signage displays for outdoor use are not comparable to displays in scope, the group of signage displays using PDP or LCD panels, and physically resembling a television display, should be put in scope at least for information and resource efficiency requirements. NL agreed with DiEu on integrated displays, but disagreed on the restriction to non-consumer products as the market will not be able to regulate itself. Information requirements on energy use should be provided in the same way as for other products in scope. NL suggested that signage displays should be addressed both for information and resource efficiency requirements and be covered by the labelling regulation, although the scope should be limited to indoor displays of limited size.

BE formulated a detailed suggestion for defining the scope and simplifying certain definitions. BE also expressed concerns about the risk of cheap and inefficient plasma signage displays invading the EU market, if energy efficiency is not regulated and supported the proposal of NL for labelling them.

SE supported information requirements for signage displays and invited the Commission to investigate on existing standards to gather information for enforcing requirements in a future regulation.

AT also supported information gathering on signage displays and to integrate them in the current regulation, although with different, specific requirements. On the Auto Power Down (APD) requirement, AT recommended movement sensors to shorten the too long interval of 4 hours.

DiEu recalled that the data collected and provided for analysis do not include signage displays, so inclusion of them, as requested by some stakeholders, would not be based on a factual data.

PO expressed no strong position on the scope, however expressed strong interest and support for including resource efficiency requirements, as necessary steps in this direction.

PT referred that though understanding the importance of resource efficiency requirements as a way to ensure availability of critical materials, is still reflecting if the proposed scope ((2), article1) is the better approach to tackle such concerns.

AT confirmed that, for signage displays, they would only support energy information requirements.

EEB supported the draft proposal to not give allowances for a quick/fast start option. However there is a risk of a loophole: because of the testing standards, quickstart will only be captured if it is part of the initial set-up. But if the user changes the set up later, this is not captured. So a fine tuning of the language and of the standard is suggested. Tier 2 is less stringent that the current ENERGYSTAR, so if a tier 3 is not kept, then tier 2 should be closer to tier 3 compared to what is proposed now.

DE formulated a slight simplification in the formula. Tier 3 should be relaxed, as an improvement of 50% seems too ambitious.

DiEu pointed out that, comparing the 2012 and the 2014 data, an average improvement of 15% was observed. The proposed requirements are too ambitious and would push too many products out of market. DiEU proposed alternative formulas with progressive jumps from tier to tier, going beyond 15%. UHD should be specially considered, as broadcasters are referring now to UHD phase 2, with high definition ratio and higher frame rates. If these improvements, now used in cinema, come to the consumer market, more energy will be needed. DiEu noted that ENERGYSTAR draft version 7 has an allowance of 55% for UHD for two years. Taking out Tier 3 should be considered. 

EEB considered that Tier 3 is a proposal for 2021 and adopts requirements of ENERGYSTAR v.7 in force from 2015, so seems not so ambitious. On UHD, EEB pointed out that there are already some 55" UHD TV in the US market using 75 Watt and the US EPA is already envisaging to remove the allowance in two years. EEB pointed out that resolutions beyond UHD should be included in the scope.

CEA (Consumer Electronics Association, USA) considered that it is critical to have test procedures keeping pace with the market changes and policies keeping pace with consumer patterns. A regulatory approach has to keep allowances for innovation features, including those we cannot anticipate today. UK stated that it does not want a review scheduled before tier 3 comes into force.

KEA argued that as UHD displays use a higher number of pixels needing higher energy consumption, the Commission should devise a different formula for UHD displays, until a new technology becomes available.

BE supported a third tier and expressed scepticism to give an allowance for increased definition.

DiEu considered that without allowances there is a high risk of excluding new technologies. The Energy Label should be used to let consumers chose the most efficient displays.

ECOS stated that Tier 3 is crucial for giving a long term perspective to industry. Allowances should not be given, unless scientific evidence shows they are needed. If new functionalities will be added, this could be addressed in a review before Tier 3 comes into force.

SE supported ambitious targets, no allowances for UHD and a review before tier 3 comes into force.

AT also supported Tier 3, subject to a revision before it comes into force. A review 'package' should also look at developments on OLEDS, Quantum Dots, 8K etc. AT declared scepticism on the need to introduce allowances for UHD/4k displays.

DE considered that tier 3 (reviewed as necessary) is important as a signal to industry of the targets to aim for with their next products. DE also considered that a minimum value on peak luminance may be necessary.

DiEu stressed that the regulation for displays should be aligned with those for stand-by and on-mode. APD on computer displays should be not applied as this would require major IT changes.

CLASP recalled that the tier 3 curve does not go beyond best available technologies for small screens, as the 2014 data shows.

ECOS solicited stricter requirements for simple stand-by, i.e. 0.3 W or less. ECOS drew attention to the fact that the ComplianTV project has shown that, by reducing on-mode volume in testing situations, some manufacturers are claiming results that appear far below reality. As solution, ECOS suggested a peak-sound volume ratio in testing.

DiEU considered that any changes to tests should be made in the standard and not in the regulation.

Both DiEu and BE requested clarifications on the text about 3D testing, whilst NL questioned the need for this text as 3D television has so far remained a niche market.

Commission services presented the resource efficiency aspects in the draft text, illustrating the following:

·The WEEE Directive, requires (Article 8) that Member States, ensure separate collection and proper treatment 13 for a number of materials listed in Annex VII, some of which are typically found in televisions, computer displays, integrated desktops, etc. such as: mercury (used in CCFL backlighting), plastics containing flame retardants (e.g. BFR), LCDs and casing greater than 100 cm2 (about 6 inches), batteries, printed circuit boards (PCB), cables, capacitors, etc.

·Recital 11 of the WEEE Directive and Article 4 mention that Ecodesign requirements facilitating the re-use, dismantling, treatment and recovery of WEEE should be laid down in the framework of measures implementing the Ecodesign Directive.

·The draft measure includes a set of requirements aimed at enhancing the safe and efficient dismantling of hazardous substances and recovery of recyclable materials, assuming that a possibly marginal increase of cost at the design phase may result in a far cheaper and more effective treatment of the display at its end of life. Although future best available technologies may enable a safe removal of dangerous substances and an effective recovery of precious materials, such technologies are likely to be not affordable by most of the SMEs involved in the collection and treatment of WEEE all around Europe. Additionally, as studies by JRC have documented, a hybrid treatment, including partially manual operations before shredding, provides a far higher quality of recovered materials compared to pure shredding. The requirements proposed, consequently, aim at facilitating manual or robotized pre-treatment, to compensate the additional costs with a better recovery of the embodied energy and materials in the waste equipment.

·When, at end of life, an electronic display is disposed (so switched off and possibly broken), it is very challenging for any worker at the collection or processing site, to distinguish a television from a computer display, a medical display, a broadcast display or an integrated desktop. This will become virtually impossible once unified high-speed data/video connectors will replace the current different ones. For this reason, the ecodesign proposal widens the scope of resource-efficiency requirements to equipment not in scope for energy-efficiency aspects, assuming that no specific regulations will cover energy efficiency requirements for these products within at least the next few years.

·Extraction of key components should be possible in an cost-effective way. Information must be provided on disassembling, content of critical substances, presence of mercury, of flame retardant plastics and possibly other substances. The proposal focuses on recovery of materials with high embodied energy content (e.g. rare metals requiring increasingly enormous energy to be extracted) and aims at facilitating the development of a market of secondary materials, expectedly triggering the creation of jobs within the EU 14 and decreasing costs for disposal paid by citizens (externalities).

The Commission services presented the draft requirements on resource efficiency, after which the proposals were discussed by Member States and stakeholders.

AT welcomed the proposed resource efficiency requirements, but cautioned against overly ambitious requirements,

EERA (European Electronic Recyclers Association) considered that brominated flame retardants (BFRs) should disappear from plastics as they pose risks to health of workers and to the environment.

MWE (Municipal Waste Europe)welcomed the introduction of the measures to facilitate end-of life treatment. Producers' responsibility is important, in particular because displays are fast-moving consumer goods that become waste only a few years after having been placed on the market. The manufacturers need to be involved and collaborate with the recycling sector, to assure that collection and extraction of valuable materials is done in a proper way, as high costs are involved otherwise.

BE also supported requirements on resource efficiency but encouraged a better formulation of the recyclability index and suggested that this information is made accessible in a centralised "products registration database", where recyclers could retrieve the relevant information many years after the product was placed on the market.

SE also welcomed the requirements, recalling that all requirements put on producers would have to be correctly used and exploited by the recycling industry. SE suggested treating cadmium and lead in the same way as mercury.

EEB strongly welcomed these requirements as an important step forward and supported the establishment of a "product registration database" to make recycling information easily available. EEB suggested to simplify certain requirements, e.g. by better defining what is recyclable.

DiEu considered that end-of-life requirements should be proportionate and should follow agreed standards. Moreover, information requirements should only cover those issues requested by recyclers and information should only be made available to qualified users.

ECOS recalled that the attempt by the Commission to establish a standardisation mandate on material efficiency was refused by CEN/CENELEC.

IT recommended a thorough analysis of these requirements against costs from the perspective of producers, recyclers and market surveillance authorities. On BFRs, IT also requested that the logo should be required even for a minimal quantity of BFR in very small parts. Finally, labelling for the presence of fluorescent lamps would be confusing and the logo should be applied to the lamps containing mercury and not to the entire display.

UK welcomed in principle the introduction of resource efficiency and end of life requirements, but cost-effectiveness needs to be kept in mind. The UK supported mercury labelling (possibly extended to cadmium) and considered that additional work on BFR labelling was needed.

CEA considered that, based on the experience of IEEE 16802 (green purchasing standard), relevant information should be agreed with recyclers to ensure the added value of the information provided and avoid overloading them with useless data

EERA pointed out that a video would not be used by recyclers.

DE welcomed the resource efficiency requirements and recommended to verify coherence with the WEEE Directive to avoid overlap. Care has to be taken that any requirements are enforceable at limited cost. DE questioned the usefulness of the recyclability index and suggested that on mercury a limit could be introduced in line with what is already foreseen in the RoHS Directive. On BFR labelling, DE supported the IT position.

AT welcomed the information requirements, which should be tailored to the different target groups (e.g. recyclers, manufacturers, consumers, authorities). Standardisation of the information is a crucial aspect.

NL also welcomed the resource efficiency requirements and endorsed previous comments on recyclability index and size of parts containing flame retardant plastics. NL disagreed with Italy on the mercury logo as it must be applied to the display as CCFL lamps are fully integrated in LCD panels. Disassembly instructions should be required by model family and not for individual models.

ECOS echoed DE, AT and NL comments on the need to provide targeted information, ideally from a centralised source such as a "product registration database" and would welcome a standardised format.

BE provided a presentation showing a higher yield, quality and purity of recovered materials when "disassembly" is used as compared to "shredding". Incentives for design for disassembly may be appropriate to stimulate a market for recycled plastics. As regards labelling, comprehensive information on additives could be added in the mould (using the relevant ISO standards) could be considered.

EEB highlighted the importance of providing information not only to recyclers and authorised repairers but also to customers/consumers.

ANEC/BEUC welcomed the resource-efficiency requirements and stressed the need of not limiting the information to professionals only.

ORGALIME expressed concerns about the resource-efficiency requirements, particularly related to enforceability and measurability.

CECED stated that it has to be ensured that additional design and information requirements on manufacturers is used by recyclers, bearing in mind that freely provided information could be sensitive.

BE supported the compulsory indication of disassembling time and plastics content. Next to the recyclability rate, a limitation on the number of different polymers, at least in big plastic parts, could be considered.

DiEu mentioned that some new displays use up to 25% of recycled plastics and recyclers have the technology to differentiate different kind of plastics, without using logos. Freely providing disassembly information to end-users may pose safety and liability risks. DiEu considered that limiting the number of plastics to be used was unacceptable.

CECED recommended that the impact assessment should include projections on which technology would be used by recyclers in 15-20 years from now.

EURIC (European Recycling Industries’ Confederation) expressed support for the resource efficiency requirements.

The Commission services presented the draft Labelling Regulation, after which the document was discussed by Member States and stakeholders.

DE recalled that today the vast majority of televisions sold are in the classes A or above, with less than 1% in classes below B. This situation is unsustainable for an additional 4 to 5 years. Moreover, computer displays would get, for the first time, an energy label and overpopulating the top classes would give the wrong signal to consumers. Therefore, DE recommended rescaling the label to A to G (with an updated formula, also for ecodesign) so that consumers would have a label that provided useful information.

NL supported the DE proposal to avoid overcrowding of the highest classes.

AT proposed to include the display labelling regulation in a package with the revision of all relevant labelling regulations in line with the outcome of the revision of the Energy labelling Directive.

DiEu supported Commission proposal as a compromise-solution, but would prefer an alignment of the labelling with the revised Directive and label format.

ANEC/BEUC endorsed the DE proposal. If not acceptable, the compromise solution proposed by the Commission would prolong the life of a label that is already "dead".

CEA mentioned that in the US the energy label is considered a success story, with a clear impact on efficiency. CEA suggested the possibility of 'dematerialising' labels by replacing them in shops with information shown on electronic displays.

EEB supported the DE proposal and recommended a formula that would provide a clear signal to consumers about the higher energy use of bigger displays. EEB also supported a "digitalisation" of the label.

SE suggested to agree on the principles of a new label lay-out now and adapt if a layout different from A-G is finally chosen. To ensure technology neutrality, no allowances should be included in the labelling proposal.

BE supported the DE proposal, without any allowances. BE asked to assess the impact of the labelling Regulation for displays on the ENERGYSTAR label for the same product group.

UK endorsed previous comments about rescaling and simplification using a single formula and aligning the display labelling with the new Directive.

IT opposed any rescaling, preferring to wait for the revision of the Labelling Directive and requested this approach to be adopted also for any other products for which a revision of labelling is in the pipeline (refrigerators, washing machines, etc.).

The Commission concluded the discussion, outlining the timeline for next steps and requested written comments to be sent to the Commission at the latest by 20 January 2015.

5.AOB

Presentation from Sweden on results of testing clear, non-directional LED lamps

SE presented a market study on LED lamps, undertaken together with BE, CLASP and ECEEE, in view of the upcoming Regulatory Committee on the draft amending Regulation of Regulation 244/2009 and 1194/2012 to postpone the coming into force of the stage 6 requirements to 1 September 2018. The main findings were that the prices of LED are falling faster than predicted while the technological development is happening faster than previously expected. Furthermore, the main obstacles such as dimmability are already addressed by some products on the market and new products such as LED-filament lamps are also appearing. SE stressed the importance of these findings for the decision on the stage 6 postponement.

The Commission thanked SE for the presentation and opened the floor for comments, noting that a discussion on the draft amending Regulation was not foreseen.

IT welcomed the study and asked for more data on the individual test results rather than just the averages. IT requested further clarifications on the three models that would have failed market surveillance testing according to the energy labelling requirements, and on products with high lumen output above 500lm on which the study contained little data.

SE agreed to provide the individual testing data. The market study was not a market surveillance exercise and so any non-compliance issues were not followed up. Products above 500lm were not chosen because these are not very common on the market.

AT reported on its PremiumLight testing project and confirmed the observation that LEDs of well-known brands performed quite well. Nonetheless, the LED-filament lamps show novel problems such as a changed light distribution compared to an incandescent light bulb. In addition, problems such as flicker remain an issue.

CLASP added that in the appendix of the market study photometric plots are shown, given an indication of the light distribution also of LED-filament lamps.

DK welcomed the study and mentioned that the results are in line with similar testing undertaken in Denmark.

The Commission requested DK to share these results with the Consultation Forum.

EEB questioned why "D"-class halogen lamps are allowed to be marketed and sold as 'eco-saving lamps'. Moreover, in the USA high lumen output bulbs (e.g. 60W equivalent bulbs) are available on the market, and testing data from the Energy Star programme could be used as additional data source for this discussion.

EuroCommerce stated that they invest heavily in LED and retailers such as IKEA have decided to only sell LEDs from 1 September 2015 to support energy efficient lighting technologies.

BE asked for the date of the Regulatory Committee meeting and asked LightingEurope about their knowledge on LED-filament lamps.

Presentation from Lighting Europe

LightingEurope responded by presenting remarks on the report: according to their understanding, 46% of all tested lamps were not in compliance with regulatory requirements, and, given that the switch to LEDs is happening anyway, argued that no phase-out of halogen lamps is necessary. The testing of a halogen lamp for 240V from the British market with 230V raises questions about the correct testing. The focus on low-lumen output lamps does mean that data on replacements for many high-lumen halogen lamps is missing. Furthermore, there are many specific halogen lamps for which no LED replacement exists, e.g. because of the external dimensions. LED-filament lamps are still not mature and many manufacturers experience problems. Hence, mainly 'no-brand' manufacturers are bringing them on the market, because the well-known brands do not want to impose low quality products on their customers. Overall, LEDs cannot yet fully replace halogen lamps.

SE assured that it will re-check the halogen lamp testing (230V/240V) and informed the Consultation Forum that members of LightingEurope would visit the Swedish testing lab in the following week.

IT reminded LightingEurope not to use an 'eco' branding for halogen lamps, because they are only "D"-class lamps.

EEB stated that there are also LED-filament lamps with a heat sink and that this technology is maturing fast.

BE reiterated that the market study did not fully resemble a market surveillance test, hence one should be cautious about drawing conclusions on compliance from the study. In the one case where the labelling was clearly wrong, the study team informed the respective national market surveillance authority.

EEB asked whether halogen lamps do not have premature failures.

DE added that according to their experience halogen lamps do not perform significantly better in overall compliance tests than LEDs.

LightingEurope replied that every product can fail prematurely but its manufacturers guarantee that the failure rate is within the legal limit.

IT informed the Commission of problems with the Italian language version of the energy labelling regulation, and the templates on the Commission's website do not correspond to the requirements in the regulation.

VHK informed participants that a preparatory study on lighting is ongoing and the project's website is www.ecodesign-lightsources.eu where interested parties can find the task reports and register for stakeholder meetings. Another study on fans can be found on www.fanreview.eu .

The Commission stated that no date has yet been fixed for the Regulatory Committee meeting. Furthermore, it will keep stakeholders informed about the start of new studies and adoptions through the Consultation Forum.

The Chair thanked the Members of the Consultation Forum for their participation and closed the meeting.



ANNEX – Attendance List

 

5.3    Minutes of the Ecodesign Consultation Forum of 8 October 2012

Minutes of the Ecodesign Consultation Forum meeting on Televisions and Displays

Subject: Ecodesign Consultation Forum established under Article 18 of Ecodesign Directive 2009/125/EC

Venue: Centre A. Borschette, Brussels

Chair: ENER C3

Participants representing the EC from: ENER C3, DG ENTR and DG ENV

Participants representing stakeholders: Annex I

Abbreviations: Ecodesign (ED), Energy Labelling (EL), Energy Efficiency (EE), ENERGY STAR (ES)

1.    Agenda points 1 & 2 - Welcome of participants and approval of the agenda

CHAIR welcomed participants and apologised for Paul Hodson's (Head of C3 Unit) absence. Minutes from the previous CF meeting on online labelling (held on 10 July) were adopted without changes. An agenda of the meeting was adopted without changes.

The Commission services (EC) distributed the updated information on a) responsibilities within the EC's Ecodesign Team and b) the ongoing and future legislative work.

2.    Agenda point 3 - Discussion about the review of EL and ED Regulations on televisions    (presentation on CIRCA)

The EC draw attention of the participants to the 'Discussion paper on the review of the Ecodesign and Energy Labelling Regulations for televisions and on the draft Regulation on electronic displays, including computer monitors' that had been distributed on CIRCA and thanked stakeholders for their position papers that had also been uploaded on CIRCA.

The EC reviewed the application of the ED and EL Regulations. It pointed at trends and developments that had taken place since the entry into force of the Regulations, including a rapid development and market adoption of energy efficient technologies, a higher number of display devices per household, an overall increase in the average size of television screens and computer monitors, longer daily use of display devices, and the introduction of new features. The EC also noted that despite these developments, the total energy consumption by TVs has decreased, mainly because of their increased energy efficiency.

Moreover, the EC stressed that available data and experts indicated that ED and EL Regulations have had a limited impact on the TV market. The rapid evolution of TV energy efficient technology exceeded expectations of both Regulations. The introduction of new types of televisions was mainly driven by the availability of relevant technologies, a demand for improved picture quality and design, as well as a competition between manufacturers and thus it happened largely independently of the ED and EL requirements.

The EC concluded that there was a need for a revision of the two TV Regulations and that it would present a proposal for new measures.

SWEREA IVF supported the need for a revision and noted that industry had realised the importance of EE. It also mentioned that the revised Regulation should include requirements on recycling.

IT did not agree that there was a need for a revision of EL Regulation but noted that some minor modifications would be necessary.

DE stated that a full-scale revision of EL Regulation would be premature. It noted however, that some modifications were required, e.g. the earlier introduction of top three EE classes (A+, A++, A+++).

ECOS agreed that the market development had not been correctly predicted and that the requirements were not sufficiently stringent. ECOS supported a full revision of EL Regulation. Should the latter not be possible, the top three EE classes should be introduced earlier.

BE agreed with comments made by IT and DE that it would be too early to proceed with a full revision of EL Regulation.

DIGITAL EUROPE expressed its major concern about the scope of the new proposal to be discussed later during the day (i.e. TVs and other displays).

NL agreed that the predictions in the preparatory study were wrong, and future studies should prevent this happening again. It pointed at a need to receive reliable information also on non-energy related aspects of displays. It supported a full EL revision in a few years but recommended faster entry into force of the top three EE classes.

UK supported a revision of ED Regulation which should also include non-energy related aspects. It objected to a full revision of EL Regulation.

CLASP agreed with the proposal to revise both Regulations and to apply the same formula/equation for ecodesign and energy labelling. It also stressed the need to set out the requirements at a proper level of stringency.

SE was in favour of a full revision of both ED and EL Regulations. The future ED should also include some requirements on non-energy related issues.

FR was of the opinion that it was too soon for a full revision of EL Regulation.

ANEC supported the revision of EL and ED Regulations.

CECED disagreed with a view that the development of TVs has not been influenced by the existing EU Regulations. It explained that industry had been working on new energy efficient technologies already during the consultation phase preceding the adoption of the Regulations. It also proposed that the EU Regulations should contain a mechanism allowing for an automatic adjustment of the requirements without a need for a revision.

DIGITAL EUROPE pointed out that the sample size of 412 TVs currently on the market was quite small. Furthermore, it stressed that improvements in 2011 and 2012 slowed down and thus the curve was more flat than in the previous years. It was in favour of keeping the current A-G scale.

DK supported the proposed revisions, particularly of ED Regulation.

AT expressed its opinion that EL Regulation can be improved but it should not be subject to full revision. The A+++ class should be introduced earlier to use the current EL in an efficient way.

NL agreed that the average EE index was flattening out, but further improvements would be achievable. It pointed out that larger screens could obtain a better EE rating more easily than small screens.

DIGITAL EUROPE pointed out that computer displays were already governed by the ENERGY STAR.

The EC summarised the discussion and concluded that stakeholders were in favour of the full revision of ED Regulation and of the introduction of a new set of ecodesign requirements. Furthermore, stakeholders were in favour of specific modifications of EL Regulation (e.g. earlier entry into force of the top three EE classes) but they (with the exception of NGOs, SE and DK) had not supported the idea of a full revision Regulation.

3.    Agenda Point 4 - New proposal for the Commission Regulation laying down ecodesign requirements for electronic displays and a new proposal for the Commission Delegated Regulation laying down energy labelling requirements for electronic displays (presentation on CIRCA)

3.1 Ecodesign

The EC presented the scope of a draft proposal for a new ED Regulation on electronic displays and justified the merger of TVs (lot 5) with computer monitors (lot 3). In principle, the draft Regulation would apply to all displays, including TVs, computer monitors and digital photo frames. Certain categories of products, e.g. high performance electronic displays, products covered by the computers Regulation and projectors may however have to be excluded from the scope of the Regulation.

AT supported the proposal to regulate TVs and computer monitors together. AT asked whether a manufacturer or a retailer should decide on a classification of a product as a TV or a computer monitor.

The EC clarified that the manufacturer or retailer should not decide on the product classification. Such decision should stem directly from the Regulation and provided definitions. Under the draft Regulation, the classification of products will not be as relevant as it is under the current legal regime, because the same requirement will apply to all electronic displays (including TVs and computer monitors).

DIGITAL EUROPE did not agree on laying down one set of requirements for TVs and computer monitors. It stressed that ES applied in the EU to computer monitors. Consequently, two separate Regulations should be prepared.

SE supported the EC's proposal, and noted a need for precise definitions of exemptions.

NL supported the EC's proposal and pointed out voluntary aspect of ES.

IT argued for two separate Regulations for TVs and computer monitors.

ECOS supported the EC's proposal. It proposed that the EC should ask CENELEC to prepare measurement methods that could be used for all displays. ECOS also suggested that, if necessary, the entry into force of the requirements for computer monitors could be postponed (compared to TVs).

DK supported the EC's proposal to review EL and ED, and asked the EC to provide more information on high-performance products and to consider a decision of including them in the scope.

UK supported the EC's proposal provided that common measurement methods would be established. Precise definitions of products exempted from the draft Regulation should be provided.

DE supported the EC's proposal. It stressed, however, that different criteria should apply to special-use displays.

ANEC supported the EC's proposal.

BE informed that it was not against the EC's proposal. It proposed that the draft Regulation should contain two chapters, one on TVs and the second one for computer monitors.

Hewlett Packard stressed that ES has been successful for many product groups including computer monitors. Therefore, its requirements on computer monitors could be included in the draft Regulation. It objected to merging TVs and computer monitors.

Hewlett Packard informed that computer display manufacturers were not involved in the standardisation work and that the mandate 477 should be broadened.

The EC clarified that it would amend the mandate 477 given to CENELEC so that the latter could prepare a new measurement method applicable to all electronic displays (including TVs and computer monitors).

LG stated that the design of TVs and computer displays was different. This fact should be taken into account when developing harmonised measurement methods.

ECOS noted that new technologies (for example internet-enabled TVs which have a huge stand-by power consumption) were not covered by current test standards. A particular TV model was mentioned as an example.

DIGITAL EUROPE explained that the TV model mentioned by ECOS was old and no longer available on the market.

LG pointed out a difference in testing methods for TVs and computer monitors, which could result in unfair treatment of certain models. It promised to submit its own testing data.

Bob Harrison (the EC's expert) clarified that following the receipt of the amended mandate 477, CENELEC would start the work on harmonised measurement methods that could be applied to TVs and computer monitors. According to BH, establishment of the harmonised method ('dynamic test loop') seems feasible. So far, luminance has been identified as a major issue in the standardisation work.

The EC concluded that a majority of stakeholders supported the EC's proposal to prepare one set of ecodesign requirements for TVs and computer monitors. Furthermore, the EC explained that it would request industry to provide more test data particularly on computer monitors and that it would consider changes to mandate 477 so that CENELEC could prepare proper measurement methods.

The EC presented the requirements on on-mode power consumption. The draft Regulation proposes two new equations/formulas (for displays below and above 16.5 dm²). The equations were established on a logarithmic regression line that is technologically neutral and does not favour any product group or technology. Three Tiers were proposed.

DIGITAL EUROPE informed that the EE index should follow (as in the current Regulation) a linear curve. It also proposed to lower the stringency of requirements and to introduce separate sets of requirements for plasma TVs and LCDs. Finally, it stressed that plasma TVs and small screens would have problems to meet the proposed requirements, what could have an impact on jobs.

IT stated that the linear regression line should be maintained.

EEB supported the EC's proposal and proposed that a review clause could be introduced before the entry into force of Tier 3 (T3) requirements. The proposal should also include non-energy related aspects.

ECOS/NRDC supported the EC's proposal and noted that year 2017 would be very different from today, mainly because of the development of EE technologies such Organic LEDs. It supported the application of the logarithmic regression line. Furthermore, it noted that the requirements might be too stringent for small displays.

UK supported the proposal to set out less stringent requirements for small displays.

NL supported the EC's proposal and assessed DIGITAL EUROPE's predictions as unrealistic. It noted the issue of the stringency of the requirements for small displays.

SE supported the EC's proposal including the application of the logarithmic approach, but pointed out that the proposal could have been even more ambitious.

ANEC supported the application of the logarithmic approach, but asked for more ambitious requirements on large screens. It noted an issue of the stringency of requirements for small displays.

DE expressed a view that T3 requirements might be too stringent.

PANASONIC stated that the proposal would have a negative impact on plasma TVs which would struggle to meet T2 requirements. It noted that industry has not yet managed to recover the R&D and fabrication costs. The plasma technology is especially important for large screens.

UK stated that the assessment of the requirements should be linked with an assessment of the costs.

The EC replied that this issue would be addressed in the impact assessment.

DK supported the EC's proposal with its logarithmic approach, and asked the EC to consider more stringent requirements.

LG confirmed the willingness of industry to develop EE TVs - however, the proposed requirements were too stringent.

AT noted that additional data on computer monitors would be very useful. Furthermore, it informed that T1 and T2 requirements seemed reasonable, but T3 needed further discussions.

INTEL stressed the need to lower the stringency of requirements, particularly for T1, and raised the issue of signage products.

CLASP informed that foreseen future developments of the LED technology would drive the EE of displays.

EEB proposed that if no compromise can be reached, a solution could be to establish the requirements for computer monitors on the basis of ES version 6.

ECOS stressed that more data should be made available to stakeholders. California is going in a promising way with its legislation, and uses test methods working with recent developments such as 3D TV and 4K.

The EC summarised the discussion and concluded that a majority of stakeholders supported the proposal. However, further considerations should be given to small displays (including computer monitors) and plasma televisions. The EC informed that it would request industry to provide more test data to ensure that the requirements (particularly in T3) are set out at the right level.


EC presented the requirements on off-mode, standby mode, availability of off & standby modes, Auto Power Down (APD), home mode, peak luminance ratio and networked standby.

ECOS pointed out that the off-mode should also include features such as internet-TV.

DE commented that APD appeared not to be included in the case of quick start.

NL stated that the possibility for disabling APD should not be applied; some exemptions could, however, be foreseen in special purpose TVs.

LG mentioned that APD may be an issue for signage products. This function should be removed from signage products.

The EC summarised the discussion and concluded that majority of stakeholders supported the proposed requirements. APD in signage products will be further considered.


The EC presented non-energy related aspects, including dismantlability, recyclability and an information requirement that could be considered for a new Regulation. The EC explained that these aspects originate from a recent JRC study and that the potential requirements would come into force only in T2. The EC invited all stakeholders to provide comments on the results of the JRC study.

NL asked for the inclusion of non-energy related aspects in the new Regulation.

SE stated that non-energy related aspects should be included in the draft Regulation and that it would be happy to provide comments on a concrete proposal.

ANEC/BEUC was in favour of including non-energy related aspects in the draft Regulation.

IT stressed the importance of resource efficiency and its enforceability. IT expressed its doubts whether the requirements on non-energy related aspects could be enforced by market surveillance authorities.

DE agreed with IT regarding market surveillance and enforceability of such requirements.

ECOS mentioned the issue of flame retardants in TVs.

DIGITAL EUROPE informed the meeting about the industry's problems with the implementation of WEEE Directive and with the re-use of plastics from TVs.

CECED informed the meeting that industry was ready to accept requirements on recycling provided that the enforcement of the provisions would be strengthened. Otherwise, this would be harmful to industry playing by the rules.

NL agreed that enforceability of the requirements was of great importance.

ANEC informed about challenges faced by recyclers in the application of WEEE Directive.

ORGALIME pointed out that ED requirements should not create excessive costs and raised an issue of manual dismantling.

DIGITAL EUROPE disagreed with the figures from the JRC study. It also found it difficult to accept the situation where legal provisions (binding industry) on non-energy related aspects are proposed without a proper methodology or verification mechanisms.

3.2    Energy labelling

The EC presented a draft proposal for a new EL Regulation on electronic displays. It clarified that EL Regulation would apply to TVs and other displays including computer monitors. Furthermore, the EC informed that the draft Regulation would include new equations/formulas (the same as in ED Regulation).

UK supported the EC's proposal to cover both TVs and other displays, including computer monitors, and to introduce a new equation that would not however result in changing the distribution of EE classes among products available on the market.

IT proposed that current equations were maintained and no other changes resulting in different distribution of EE classes were made.

DE agreed that a full revision of the Regulation would be too early. It supported the EC's proposal as regards the scope of the draft Regulation, and the introduction of the new equation.

DK supported all aspects of the EC proposal, including the scope and the new equation. It was of the opinion that changes in the distribution of EE classes were necessary.

SE also supported all aspects of the EC proposal.

NL supported the EC's proposal regarding the scope and the new equation. It was not in favour of changing the distribution of EE classes. However, it pointed out that top EE classes could enter into force earlier than foreseen in the current Regulation.

DIGITAL EUROPE did not support any changes in the distribution of EE classes.

ECOS agreed that the top EE classes should enter into force sooner.

BE agreed with ECOS's comment. It was not, however, in favour of changing the equation and any changes in the distribution of EE classes.

AT agreed with the extension of the scope of the new Regulation to other displays. It also proposed that changes to the distribution of EE classes should be considered taking into account the market data.

ANEC was strongly in favour of changing the distribution of EE classes.

ECOS was in favour of applying the EL requirements to computer monitors.

DIGITAL EUROPE pointed out at the success of the ES, and restated its disagreement on a merger of TVs and computer displays. It also re-stated that an 18 month period between the Tiers was too ambitious.

The CHAIR asked stakeholders for additional written comments (if any) on the EC's proposal. These should be submitted within 30 days after the meeting. The CHAIR closed the meeting.



ANNEX – Attendance List

 

5.4    Minutes of the Ecodesign Consultation Forum of 8 October 2009

Subject:    Ecodesign of EuPs Consultation Forum – Computers and Displays

Place:    Centre de Conférence Albert Borchette, Brussels

EC Services:    TREN/D3, ENTR/B1, ENV/G1

Consultation Forum – Computers and Displays

1.Welcome and introduction

The Chairman welcomed the participants and presented the agenda and the participants from the Commission.

2.Adoption of the agenda

The agenda was adopted without changes.

3.Working document on possible ecodesign requirements for Computers

The Commission services presented the main aspects of the working document and the rationale of the approach for discussion (see presentation circulated together with these draft minutes). It was explained that the aim would be to align as much as possible minimum ecodesign requirements with Energy Star. Practically, it is suggested to introduce requirements in two steps, with a first tier based on Energy Star 4.0 and a second tier based on Energy Star 5.0 entering into force in 2013 (with several adjustments).

Scope

At the request of ANEC the Commission services clarified that no size limit was included in the definition of netbooks, which are covered under the notebook definition.

AT indicated that Energy Star did not include provisions regarding notebook screens, and asked whether these should be included in the Commission’s proposal. The Commission services and MTP (The UK Market Transformation Programme providing support on this project) acknowledged that important work would be needed on furthering Energy Star test-methods for notebook screens. It was suggested that this element should be driven by Energy Star.

Workstations and thin-clients were not included in the initial study and workstations have a very limited compliance rate with Energy Star at the moment. These two product group should be excluded from the scope given that it would be difficult for such high-end products to comply with the proposed requirements and also considering that these represent less than 10% of the computers market. The effect might be that high-end products will be assembled by the consumer from parts bought separately (DIGITALEUROPE).

ECOS enquired about a potential preliminary study on servers. The Commission services indicated that it is still being considered what additional studies could be launched. In the short term however it should be considered to include servers in the measure on computers with a requirement on the efficiency of the internal power supply. This would be technically feasible, cost-effective and would capture the majority of the energy-saving potential for this product group. AT supported such an approach in the short term but further work on the other aspects should be done in the future.

Although it is necessary to harmonise possible ecodesign requirements as much as possible with Energy Star simply importing the specifications from one of the Energy Star versions would lead to a situation where requirements for some product categories would be much less stringent than others therefore further adjustments would be needed (DK).

At the request of BE the Commission services indicated that it was legally possible to have a higher level of stringency of ecodesign requirements than those specified in Energy Star but that this will be further consulted with the Commission Legal Service.

Definitions

The Commission services suggested that definitions be drawn directly from Energy Star albeit with the necessary adjustments.

The product group should be taken out of the scope of the 'Standby regulation' as the definitions of 'standby' and 'off mode' in the 'Standby regulation' are not suitable for computers. The mode definitions should be drawn from Energy Star. It is acknowledged that the presence of two different definitions of 'off mode' in two regulations within one single framework directive might prove problematic (Commission services).

'Off mode' as defined in Regulation 1275/2008 is suitable for computers and the other operating modes which don't correspond to the definitions laid out in Regulation 1275/2008 should be clearly defined in the product-specific legislation. The definitions that will be drawn-up in a future measure on 'networked standby' should be anticipated. The definitions of the 'off mode' proposed in the Working Document were inspired from the 'old definitions' of the IEC standard which gives a lot of scope for interpretation and which is currently being revised towards an approach where 'off mode' means 'no function provided' (NL). The definitions under Regulation 1275/2008 are horizontal and, in line with the approach in standardisation can be adapted for product-specific needs. It is important to be coherent in that respect with the Energy Star Programme since it relates to exactly the same product (IT). With 'wake-on-lan' (WOL) disabled 'off mode' as defined in Regulation 1275/2008 is suitable for computers (DIGITALEUROPE). If 'off mode' for computers is defined as in Regulation 1275/2008 WOL would need to be treated as a separate functionality (Commission services).

The computer measure should be harmonised as much as possible with Regulation 1275/2008 and this product group should not be taken out of the scope of the Regulation. This should be complemented with additional product-specific definitions in the product-specific regulation (DK, UK, DE). WOL should be switched off as default (DK).

AT enquired about the possibility to extend the scope of Regulation 1275/2008 to office equipment. AT remarked that standby levels for computers as described in the horizontal regulation would be equivalent to 'S4' according to SCPI, which is not yet covered by either Energy Star or the horizontal regulation. DIGITALEUROPE clarified that 'domestic' did not mean 'at home' per se, but rather, relates to levels of radiations acceptable in offices and at home, as opposed to computer rooms for example.

Having all product-specific requirements in product-specific regulations gives legal clarity (NL). The Chairman stated that the goal was to provide a legislation that is both comprehensive and user-friendly.

In line with the comments provided by Member States definitions taken from Energy Star will need to be adjusted and any requirements should be included in the annexes of the regulations (Commission services).

Timeline

The Commission services presented the proposed timeline for the entry into force of the requirements as well as the underlying assumptions regarding the levels of compliance with the Energy Star criteria.

DIGITALEUROPE asked for clarification on the expected future Energy Star compliance rates included in the Working Document and asked whether non-standard equipment configurations were factored in these figures. NL asked for a clarification whether these figures factored in the fact that office equipment (i.e. the one registered under Energy Star) might have different configurations than home equipment. The Commission services and MTP clarified that the said figures originated from the Environment Protection Agency data and a survey by IDC. These were partially based on sales percentages therefore included also home (i.e. higher specification) equipment.

Tier 1 requirements should be applicable 12 to 18 months after entry into force of the regulation, so as to give the industry enough time to redesign products (DIGITALEUROPE)

The second tier should be introduced earlier than proposed in the Working Document (AT, NL, UK, SE, DK). It would be preferable to base first tier requirements on Energy Star 5.0. These should be applicable 1 year after the entry into force of the regulation followed by a tier 2 based on Energy Star 6.0 requirements when these are released (ECOS, ANEC). The revision should be carried earlier than proposed and be harmonised with the entry into force of Energy Star 6.0 (SE).

Ecodesign requirements

The Commission services outlined the content of the proposal.

Requirements on product components such as the internal power supplies (IPS) should be avoided. Furthermore seeking improvements on internal power supplies energy efficiency was not always necessary, considering that certain products already achieve targets without requiring modified internal power supplies. In the case of low-end computers forcing a requirement on internal power supplies’ energy efficiency would result in higher prices for SMEs and marginal energy efficiency gains. This should be factored in the impact assessment of the proposal (DIGITALEUROPE). The Chairman remarked that IPS represent a significant and cost-effective saving potential and applying specific requirements on components makes sense for equipment assembled by users.

In this particular case there is a strong rationale for placing a requirement on IPS. The price difference between efficient and inefficient IPS is small and is expected to decrease to almost null once these requirements become mandatory (SE, DK, DE, AT, UK, NL, ANEC).

Requirements for the different operating modes should be maintained beyond the first tier. The TEC approach for ecodesign might be not appropriate as usage-patterns vary greatly (AT).

The introduction of idle limits (be in n the mode approach or through the TEC) would be problematic especially for the segment of high-performance PCs. This was supported by the findings of the preparatory study (DIGITALEUROPE). A first assessment indicates that cost-effective solutions to limit the idle consumption across the whole range of products do exist but this matter will be investigated further as part of the impact assessment (Commission services).

Other environmental impacts

This measure should be complement by specific limits related to the content of mercury under the RoHS Directive by establishing requirement on according information (in mg) at the point of sale and marketing materials. Cold cathode-fluorescent lighting (CCF) used for LCD screens should be removed from the exceptions list under the RoHS Directive, as they offer energy efficiency and other environmental advantages. This should be done in coordination with the specific committee working in the framework of the RoHS Directive (SE, BE, UK, EEB).

Issues related of waste and dangerous materials should be dealt with under the relevant legislation, and not Ecodesign. The problem doesn't originate from the design of computers but from the way the recycling industry handles the products (DIGITALEUROPE).

RoHS and WEEE requirements are not sufficient. Other environmental impacts of computers, including PVC, plastics, use of metals, upgradeability of computers, energy embedded in production processes could be addressed through generic ecodesign requirements (ECOS, ANEC). There exist standards that could be used as a basis for it (UK). Since the Article 4 of the WEEE draft recast refers no longer to recycling, but to recovery, there is a need to include requirements linked to recycling in the Ecodesign regulations (EEB).

Information requirements

The Commission services introduced the elements related to information requirements.

There will be always a difference between benchmark models and market average therefore there is a rationale for informing consumers about energy consumption. Even though an 'A to G label' might not be feasible basic information (TEC or mode consumption) could be displayed at the point of sale and websites (ECOS). The TEC might be misleading as the usage patterns very greatly (AT).

The Chairman reminded the participants about the Council Decision of 18 December 2006 on the coordination on energy efficiency labelling programs for office equipments between the EC and the US. This agreement does not prevent the setting-up of new schemes in addition to Energy Star. It should be however considered whether a new scheme for such equipment would add value and would not undermine the current scheme. It is uncertain if an Energy label would be justified in terms of the differences in the energy consumption of equipment on the market (especially for displays).

Energy Star and a possible Energy label have different target groups. It has to be also noted that Energy Star is also moving in the direction of a comparative label with a 'golden star' for the best 10% (NL). The UK and AT supported in principle the introduction of a possible Energy label for displays.

An accumulation of labels would entail a risk of confusing consumers (DIGITALEUROPE).

Revision

The Commissions services acknowledged that is should be brought forward. The revision date should be harmonised with the work on new Energy Star criteria (NL).

Benchmarks

Eco-label criteria should be introduced for the other environmental aspects in the benchmark (SE, ANEC).

4.Working document on possible ecodesign requirements for Displays

The Commission services presented the main aspects of the working document and the rationale of the approach for discussion (see presentation circulated together with these draft minutes). The aim is to align the requirements with Energy Star as much as possible. Tier 1 requirements (based on Energy Star 4.1) would enter into force six months after entry into force of the directive. Second stage would kick-in from October 2013 based on Energy Star 5.0. The requirements for 'off mode' would be aligned with Regulation 1275/2008.

Scope

Screens above 30 inches to be included in the scope as such monitors (e.g. signalling screens) are already present on the market and there is no technical justification for excluding them notwithstanding what kind of requirements are suitable for such screens (NL, ECOS).

Definitions

'Off mode' should be defined as in Regulation 1275/2008 and this should be used consistently across product-specific implementing measures (NL).

DE enquired about the relationship with the television product group, notably whether a display with an HDMI interface would be considered as a TV set. The Commission services acknowledged that this issue needs further analysis.

The Chairman asked the participants for suggestions on how to best differentiate displays from TV sets. This could be solved by placing an upper limit for the size of displays falling under the draft measure (DIGITALEUROPE).

Timeline of requirements

Tier 1 requirements should start to apply twelve months after the entry into force of the Regulation to allow for redesign (DIGITALEUROPE).

While harmonization with Energy Star would be a positive move, strictly following each and every specification would not be the best approach (DK, ANEC).

The deadline for the implementation of Tier 1 should be set earlier (ANEC). Tier 1 should be removed and Tier 2 deadlines to be advanced (ECOS).

Moving from a voluntary scheme (Energy Star) to mandatory requirements would entail serious consequences on the market, leading potentially to the exclusion of some types of products and functions from the market (DIGITALEUROPE). Consistency between these two tools would reinforce both of them (Chairman). It can be envisaged to move straight to the current Tier 2 and a second tier possibly based on Energy Star 6.0 when the latter is available (UK).

87% of the monitors in EU Energy Star database consume less than 1 watt in sleep mode so it would be possible to make this mandatory in the first tier (DK). This figure to remain at 2W as some monitors would have difficulties to meet this threshold (DIGITALEUROPE).

Specific requirements

The auto-power down (APD) of digital photo frame could be set after 2 hours of user inactivity, instead of 4 as proposed in the Working Document. This should be preceded by warning message (ANEC). The APD should be set as default and it should be impossible to disable it (as in the regulation on simple set-top boxes). It should be ensured that consumers are informed about the energy consumption of these devices (ECOS). Retailers need to have digital photo frames on for several hours therefore there has to be a possibility to disable this function (DIGITALEUROPE).

Energy Star 5.0 includes provisions for automatic brightness control and that option should be included in the regulation (DIGITALEUROPE). Tests had shown that this option provided for limited savings only (Commission services, MTP).

Other environmental impacts

SE reiterated its comments from the morning session related to mercury and cold cathode-fluorescent lighting in displays.

DIGITALEUROPE stated the industry would discuss these issues internally and suggest possible options for better design in that respect.

Information requirements

Adding new labels o existing ones would add cost and would not be beneficial for the consumer (DIGITALEUROPE). ECOS pointed out that DIGITALEUROPE was supportive on the Energy label for TVs. The introduction of an Energy label for displays would be useful, also taking into account the similarity of this product group with TVs and the fact that that TVs and displays are evolving in the same direction (NL, SE, ECOS, ANEC).

The Energy Efficiency Index (EEI) under the Energy labelling measures should have a progressive component which would make it more difficult for bigger devices to have the highest energy classes (SE). The formula used under Energy Star 5.0 makes it rather difficult for big screens to achieve high energy efficiency indexes (NL). In the labelling measure on TVs it was decided to have a linear, as opposed to a progressive approach (Chairman). A progressive approach is not needed as consumers understand the difference between different size products (IT). This discussion cannot be applied to displays because for practical reasons (e.g. size of the desk) there will not be a move towards eve-bigger displays (DIGITALEUROPE).

At the request of SE, DIGITALEUROPE reported a 10% to 15% increase in energy efficiency of notebooks following a replacement of backlighting by LEDs.

Participants

FEDERAL INSTITUTE FOR MATERIAL RESEARCH AND TESTING

ADEME

European Environmental Bureau

FEDERAL MINISTRY OF THE ENVIRONMENT

Ministère écologie énergie et developpement durable

MINISTRY OF ECONOMIC ENERGY TOURISM

INFORSE Europe

DEFRA

Ministry of Environment Belgium

FEDERAL MINISTRY OF ECONIMICS AND TECHNOLOGY

WWF European Policy Office (EPO)

NORVEGIAN WATER RESOURCES AND ENERGY DIRECTORATE

BEUC

FEDERAL ENVIRONMENT AGENCY

Swedish Energy Agency

Ministry of Economy Slovakia

EFTA

AMD (digitaleurope)

MINISTRY OF ECONOMIC AFFAIRS & COMMUNICATIONS

TEST ACHAT

Ministry of Environment Romania

Swedish Energy Agency

INTEL (digitaleurope)

ANEC/BEUC

DEFRA

Ministerio dello Sviluppo Economico

DELL (digitaleurope)

DANISH ENERGY AGENCY

ENEA

ANEC

ÖKOPOL (ECOS)

AUSTRIAN ENERGY AGENCY

Ministry of Environment Belgium

HP (digitaleurope)

SENTERNOVEM

Enterprise Ireland

ECOS

DANISH ENERGY AGENCY

ATUITIVE

DEFRA



Annex 6:    The market of electronic displays

1.SALES

Overview

Figures hereafter summarise the historic sales and stock data for electronic displays (TVs and computer monitors) for the period between 1990 and 2016, as well as the baseline projections for the period between 2017 and 2030. The graph shows a peak in sales in 2009 with 105 million units, and a rise of the stock to 700 million units by 2030.

The 2017 EU market value of electronic displays in consumer prices is estimated at around €19bn (€16bn TV, €3bn monitors).

Figure 6.3: Energy use electronic displays in the EU (BAU, including signage)

In the previous 2013 impact assessment digital photo frames (DPFs) were included in the intended scope 15 , but today the market for DPFs is almost non-existant and considered too small to be rgulated.

The figure below, also included in the main IA, gives an overview of the total surface of electronic displays in 2020, both within and outside the scope of the proposed policy measures. Notebooks and tablets, status displays, mobile devices, projectors and partially “public” displays are not in the scope (i.e. about 12-15% of total surface).

Figure 6.4: Share of electronic display surface per product group (EU 2020, source VHK)



Table 6.2. Forecast of electronic display surface area in EU 2020 (VHK estimate)

Display

Surface

Stock

Total area

Note

 

diag.

area

units

 

 

inch

dm²

million

km²

 

Television

44

53

494

262.4

 

Regular TV

44

53

 

477

 

255

 

EIA, stock 2020 [Note 1]

Hospitality TV

36

36

 

16.7

 

7.4

 

hotel rooms & other lodgings

40

44

 

14

 

6.2

11.6 m beds (MEErP)

hospital beds

40

44

 

2.7

 

1.2

2.7 m curative beds (MEErP)

Regular monitors

24

16

81

12.7

 

desktop PC

24

16

 

64

 

10.2

 

EIA, stock 2020

thin client

21

12

 

4.8

 

0.6

 

EIA, stock 2020

notebook external

24

16

 

11.7

 

1.9

 

remainder

Special monitors

24

16

8.5

3.3

 

security monitors

33

60

 

3.7

 

2.2

 

[Note 2]

medical displays (incl. integrated)

27

20

 

0.8

 

0.2

 

[Note 3]

broadcasting displays

27

20

 

0.8

 

0.2

 

[Note 4]

professional displays (CAD, Graphics)

28

22

 

3.2

 

0.7

 

EIA, stock 2020

Regular signage display

55

83

30

24.4

 

retail & banks (indoor, excl. ATM)

43

50

 

11

 

5.7

 

[Note 5]

meeting rooms (incl. video conference)

75

155

 

5

 

7.8

 

5 m meeting rooms (169 million m² floor area)

classrooms (incl. smart boards)

70

135

 

5

 

6.8

 

5 m class rooms (93 m students + vocational)

airport/train/metro stations

55

83

 

1.2

 

1.0

 

[Note 6]

bars, hotels (public area), restaurants

44

53

 

2

 

1.1

 

0.2m hotels, 0.8 m restaurants, 0.7m bars

waiting rooms (e.g. healthcare)

44

53

 

2

 

1.1

 

10k hospitals, 2 m doctors

outdoors

55

83

 

1.1

 

0.9

 

estimate (10% of retail)

Special signage display

 

 

 4

7.1

 

superlarge (>100", video-wall)

110

333

 

0.02

 

0.07

 

estimate

projectors

80

176

 

4

 

7

 

EIA, stock 2020

Integrated displays

 

 1605

 

23.2

 

Mobile devices

5.5

0.8

 

1000

 

 

7.6

 

EIA, stock 2020

cell phones

5

0.6

 

500

 

3.2

estimate (>100% penetration)

GPS (incl. car-systems)

7

1.3

 

250

 

3.2

estimate (number of cars)

(video) cameras

4

0.4

 

150

 

0.6

estimate (3/4 of households)

other mobile display (games, MP3, etc.)

5

0.6

 

100

 

0.6

estimate

Integrated status (pixel) display

7.2

1.35

198

 

2.9

 

[Note 7]

ATMs (banks)

30

25

 

1

 

0.3

0.42m ATMs (source: EAST)

pro (EP colour) copier/printer

6

1

 

14.2

 

0.1

10% of 145 m imaging equipment

premium vending machines

9

2

 

0.38

 

0.01

10% of 3.77 m units (www.vending-europe.eu)

commercial & pro refrigeration

6

1

 

2.1

 

0.02

10% of 21 m units

Industrial tools/ovens/laundry

9

2

 

10

 

0.2

maximum estimate VHK

heating boilers/thermostats

6

1

 

12.8

 

0.1

10% of 128 m boilers

central air conditioners

8

1.6

 

2.3

 

0

30% of 7.5 m units

smart meters/domotique

8

1.6

 

45

 

0.7

30% of 150 m meters/dedicated panels

ventilation units

6

1

 

5.6

 

0.1

10% of 56 m units

hh el. ovens

6

1

 

21

 

0.2

10% of 209 m electric household (hh) ovens

hh microwave

6

1

 

10

 

0.1

10% of estimated 100 m units

hh refrigeration

9

2

 

30.8

 

0.6

10% of 308 m units

hh (dish) washing, drying

6

1

 

39.5

 

0.4

10% of 395 m units

hh audio systems (fixed)

6

1

 

4

 

0.04

2% of 200 m units in use

Integrated computer displays

 

 

401

 

12.2

 

all-in-one PC

24

16

 

2

 

0.3

2.4% share of desktop (DigiTimes 26.8.2014)

notebook

14

5

 

62

 

3.1

EIA, stock 2020

tablet (incl. E-book readers)

10

2.6

 

337

 

8.8

EIA, stock 2020

In