This condition is not considered as being 'standby', because the condition is part of the active mode. Furthermore, it provides an extra functionality other than reactivation function and information display.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
According to the standard if the dryer has an automatic program for the cupboard dry cotton textiles then this must be used when testing.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
The scope of Regulation (EU) 1275/2008 is ‘electrical and electronic household and office equipment’ as defined in Article 2(1). According to that definition this equipment:
“(a) is made commercially available as a single functional unit and is intended for the end-user;”
The Commission guidelines clarify what it means that the product “is intended for the end-user”. As the November 2014 guidelines say:
“This is equipment, which can be used by individuals directly. In particular, the end-user has direct control over activation and deactivation of the product.”
In addition, the October 2009,with up-date November 2014 guidelines mention that:
“End-user equipment is equipment which can be used by individuals directly, and is used "physically" by the end-user. In particular, the end-user has direct contact with the product and has control over activation and de-activation of the product: he/she may for example want to switch it on to do something with the product or, on the other hand, switch it off because he is not going to use the product for a while.”
From the description provided for this product, it appears that several users use it, none of them having direct control on the activation or the deactivation of the product. Based on the above the product in question seems to be out of the scope of Regulation (EU) 1275/2008.
The same applies to other cashier systems, where several users use it, none of them having direct control on the activation or the deactivation of the product.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
The multi-drums washing machines currently reaching the EU market are basically multidrums in separate units or multi-drums in one casing machine. The Ecodesign delegated acts on washing machines currently do not contain specific provisions for these kinds of washing machines (when reviewing the regulations such specific provisions will be considered).
Multi-drums in separate units
In these machines, the main drum part can be completed optionally with separate extensional units ('modules'), which may or may not be able to operate individually without the main unit.
The main unit of this type of multi-drums washing machine is clearly in the scope of the Ecodesign and Energy Labelling legislation. However, there is some uncertainty concerning the coverage of the additional washing modules.
Different cases should be considered:
- If the additional washing module is not capable of functioning as a stand-alone unit (i.e. physically separated from the main unit) and has a limited number of washing programmes that are not able to clean normally soiled cotton laundry or similar fabric/textile (and thus not suitable for common use and associated programme cycles used for determination of compliance), then this module cannot be considered as a separate washing machine but as a functional complement to a primary washing machine appliance (and the primary washing machine appliance is subject to the Ecodesign delegated acts 1015/2010 and 1061/2010). This washing module is not subject to power consumption, washing performance or other requirements of the regulations. With the aim to consider individually the main drum disregarding any synergetic effects from multi-drum operation, the module should be deactivated when assessing the compliance of the primary washing machine with the Ecodesign and delegated acts:
− by means of selection knobs, if this is feasible, or
− by physically disconnecting it from the primary washing machine
- If the washing module is not capable of functioning as a stand-alone unit but it is able to clean normally soiled cotton laundry or similar fabric/textile, then this module should be considered as a separate washing drum which should have the programme cycles used for the determination of compliance (i.e. programme cycles for cleaning normally soiled cotton laundry at 40°C and 60°C, as mentioned in the booklet of instructions provided by the manufacturer) and comply with the Ecodesign and the Energy labelling requirements. In this case, the main drum and the additional washing module should be considered individually and separately disregarding any synergetic effects from multi-drum operation. Each drum should comply individually and separately with the Ecodesign and the Energy labelling requirements (including a label for each drum).
- If the module is capable of functioning as a stand-alone unit, then it should be considered as a washing machine and should comply with the Ecodesign and the Energy labelling requirements.
Multi-drums in one casing machine
In these machines, different drums are located within one casing and have the possibility to share the use of the same internal components and resources. See below an example of such a machine.
There are a priori various possibilities to deal with these machines and to apply the Ecodesign and Energy labelling requirements, as for instance:
- To consider only the main drum;
- To deal with each drum individually and separately;
- To consider the adding performance of all drums running at the same time one single 'standard cotton programme';
- To consider the weighted average performance (energy efficiency index, washing performance, noise, remaining moisture content) of the various drums to determine a single level of performance for the complete machine (for which the rated capacity, energy and water consumption have been summed up);
- To combine some of these approaches.
Each drum could, a priori, fall under 'an automatic washing machine which cleans and rinses textiles using water which also has a spin extraction function', the definition of household washing machine in the Ecodesign and Energy labelling legislation.
For that reason, it appears reasonable to consider individually and separately the various drums disregarding any synergetic effects from multi-drum operation. This would imply that each drum should comply individually and separately with the Ecodesign and the Energy labelling requirements including a label for each drum (see the similarity to domestic ovens with different cavities for which separate labels are issued for each cavity) and the availability for each drum of the standard programme cycles used for cleaning normally soiled cotton laundry at 40°C and 60°C (which should be indicated in the booklet of instructions provided by the manufacturer).
However, if one of the drums has a limited number of washing programmes that are not able to clean normally soiled cotton laundry or similar fabric/textile (and thus not suitable for common use and associated programme cycles used for determination of compliance), then that drum cannot be considered separately and should be considered as a functional complement to a primary drum (and the primary drum is subject to the Ecodesign and Energy labelling delegated acts 1015/2010 and 1061/2010). This secondary drum is not subject to power consumption, washing performance or other requirements of the regulations. With the aim to consider individually the main drum disregarding any synergetic effects from multi-drum operation, the complementary drum should be deactivated by means of selection knobs when assessing the compliance of the primary washing machine with the Ecodesign and Energy labelling delegated acts.
In the case where multiple drums are suitable for cleaning normally soiled cotton laundry or similar fabric/textile, but there is no possibility to run them separately, only in parallel, then all such drums should be considered as one single washing machine in which the 'standard cotton programme' should cover all such drums. One single energy label should cover this multiple-drum washing machine. The Ecodesign requirements for energy and water consumption should be met by multiple-drum washing machine as a whole. The energy and water consumption of the overall washing machine should be evaluated as the total performance of all those drums (summing up rated capacity and considering overall energy and water consumption). The Energy Efficiency Index (EEI) should be calculated considering the overall rated capacity and energy consumption, and the related low mode powers. For the spinning performance, the weighted average (according to each drum load capacity) should be considered. Each drum should, however, comply individually and separately with minimum washing performance requirements according to individual load capacity of the drums.
Finally for information, current standards are able to perform tests on the various drums of the multi-drums machine.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.