In Regulation (EU)1275/2008 there is a requirement on power management (Annex II, 2d):
“[…] When equipment is not providing the main function, and other energy-using product(s) are not dependent on its functions, the power management function shall switch equipment after the shortest possible period of time appropriate for the intended use of the equipment,automatically into […].”
Many questions have dealt with the main function aspect. It is not defined in the regulation, but “active mode” is, quite recursively, by stating in definition 5 that it is a condition in which the main function is activated.
Is a condition that offers battery maintenance a main function? In the standby guidelines it is explained that it is not a standby condition (page 12):
“The role of battery maintenance"
The maintenance mode of the battery load in portable appliances (e.g. portable vacuum cleaners) is one of the key functions of the system (battery charge and portable appliance) to avoid discharge of the battery. This is a function beyond reactivation function and information display, and therefore not considered to be standby-mode.”
Answer:
The standby operating mode is defined rigorously as a mode that provides only the functions of reactivation, indication and information or status display, so the battery maintenance would not be considered standby.
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
Regulation (EU) 1275/2008 provides that a coffee machine should turn itself off within 40 minutes after the brewing cycle is complete. If the 40 minutes is interrupted by pouring coffee for example would this reset the timing and would then another 40 minutes be applied?
Answer:
The 40 minutes are not be interrupted by lifting the coffee pot.
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.
A MESH network is a communication network consisting of a router and a number of access points. The MESH access points are able to communicate with each other in a MESH structure. The access points communicate with electronic devices for instance computers and mobile phones. For instance, MESH networks are used in wireless audio systems.
Are routers and access points placed on the market for use in wireless MESH network systems covered by the requirements in Regulation (EU) 801/2013? The question only covers equipment types included in the scope of the regulation i.e. electrical and electronic household and office equipment.
Answer:
A MESH network is basically a system of routers and access points communicating with each other in a mesh or star structure. A MESH network is a communication infrastructure in line with the definition of network in the regulation. In addition, routers and wireless access points designated for MESH network do not differ from the definitions of routers and wireless access points in the regulation.
Therefore products designated for MESH networks are covered by Regulation (EU) 1275/2008 (as amended by Regulation (EU)801/2013) as long as they are within the scope and in line with the definitions in the regulation. According to the definitions in the regulation the equipment will be categorized as HiNA equipment.
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.
It is common for set-top boxes, that the manufacturer’s name/trademark is stated on the physical box, whereas the service provider often names and in addition changes the software before the product reaches the end-user.
Below two examples:
(1) A product where the manufactures trademark is stated on the box, but the dealers name is stated on the remote control, but not on the box. Furthermore, when the box is turned on the dealer’s trademark appears on the screen.
(2) A product where the manufactures trademark is stated on the box. The service provider trademark is not mentioned on the box or remote control. However, the box is marketed under the dealer’s name. Furthermore, when the box is turned on the service provider’s trademark appears on the screen.
Many of the service providers do not see themselves as the legal responsible for the products on the market. Who is the responsible of the conformity with the regulation of the boxes?
Answer:
A product, which has been subject to important changes or overhauls aiming to modify its original performance, purpose or type, after it has been put into service, may be considered as a new product. This has to be assessed on a case-by-case basis. The person who carries out the changes becomes then the manufacturer with all the corresponding obligations.
In addition, a modified product sold under the name or trademark of a natural person different from the original manufacturer should be considered as new, and the person under whose name or trademark the product is sold is responsible for ensuring compliance with all relevant regulations.
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.
Some complex set-top boxes have more than one standby setting, whereof not all of them comply with the regulation demands towards energy consumption. And although the suppliers refer to the different modes in the manual to guide end -users regarding settings and energy consumption, some suppliers have chosen to name these non-compliant standby modes with “normal” or “standard” and not giving additional information about the additional standby consumption. Is it allowed to name a standby-setting as ”normal” or ”standard” when this setting doesn’t comply to the regulation demands? Some suppliers even recommend using the setting with the non-compliant energy consumption, not giving information about the actual use of energy.
Answer:
The Standby Regulation (EU) 1275/2008 defines the networked standby mode and requires the presence of a power management function that switches the equipment into that mode (unless inappropriate for its intended use). Some complex products could indeed have other low-power modes, which do not comply with the provisions for networked standby. Those other modes, which could be of a very wide variety depending on the product, are not regulated therefore no specific provisions apply either in terms of name or energy consumption. However, the presence of such modes (customized by the producers) should not prevent the equipment to comply with the legal provisions regarding off-mode, standby and networked standby (including the power-down mechanism employed by the power management function). Non-compliant low-power modes shall not be called ‘standby’ or ‘networked standby’.
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.
‘Reactivation function’, as defined in the Regulation, means a function facilitating the activation of other modes, including active mode, by remote switch, including remote control, internal sensor, timer to a condition providing additional functions, including the main function. Many appliances, such as electric hot plates, are often designed with finger touch sensors to turn on/off the product. Are these touch sensors considered ‘internal sensors’ in the sense of the definition of reactivation function?
Answer:
An internal sensor, as considered by the definition of reactivation function, is a sensor that is incorporated in the product and can reactivate it without the need of a direct physical intervention of the end user on the product itself. The reactivation is realised either by the end user acting remotely, or by the product itself acting upon preset parameters. Examples of internal sensors include: infrared sensor, temperature sensor, voice activation sensor.
The touch sensors need the end user to directly touch the product. When integrated in soft switches (as is the case of many household appliances, including electric hot plates) they act in relation to placing a product in off mode rather than in standby, and alternatively turning it back on. Therefore, such sensors should not be considered ‘internal sensors’ that are contributing to the reactivation function, as mentioned in Regulation (EU) 1275/2008. In these cases the requirements on maximum power consumption in off mode should be observed.
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.
If an appliance (e.g. steamer or oven) has an integrated display indicating (among others) time, but the display and related clock is not activated by default when the product is placed on the market, should the standby consumption still include the consumption of the display?
Answer:
The product should comply with the requirements on power consumption of equipment with information or status display, which is a continuous function providing information, including clocks, as specified in definition Article 2(4).
The standard EN 50564 on measurement of low power modes provides, in clause 5.2 Preparation of product, says that:
“The product shall be prepared and set up in accordance with the instructions for use”.
“The product modes tested should be consumer relevant and representative of expected normal use. Where instructions for use provide configuration options, each relevant option should be separately tested.”
Thus, the measurement test does not refer to testing only a specific configuration (in which the product happens to be placed on the market by the producer). Instead all the relevant product modes and configuration options expected to be employed by the final users, as could also be documented in the user manuals, are to be tested.
Furthermore, according to the provisions of Regulation (EU) 1275/2008, for each of the product modes specified above the power management function should switch the product into standby or off mode, as applicable, after a period of inactivity in which the product is not providing its main function(s). In these cases the Ecodesign requirements for standby and off mode shall apply.
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.
Many electric hobs have a visual indicator (a luminous dot or letter) to warn user when a plate or cooking zone is hot, also when the appliance is not in active use. Once the plate cools down, the indicator is turned off.
Regulation (EU) 1275/2008, Article 2, point 4 says that “‘information or status display’ means a continuous function providing information or indicating the status of the equipment on a display, including clocks;” Does the indication of a warm plate fall under the definition of ‘information and status display’?
Answer:
The regulation explicitly requires “a continuous function providing information or indicating the status of the equipment on a display”. In the example, once the indication is (i.e. the “H”) is switched off, there is no “information or indication of the status of the equipment” anymore, so this cannot be considered as a continuous function. In addition, see also the published guidance document:
“[…] The definition of standby includes display, for which an additional allowance for power consumption is defined. A display is a field in which status information (e.g. the word “standby”) and/or time is displayed. As mentioned above a LED that is merely indicating off-mode condition, is not considered to be a 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.
Apartment blocks are often equipped with a common laundry room including one or several washing machines available to the tenants. These laundry rooms commonly included an automatic cashier system, which allows tenants to top up a credit in digital form and via network on a specific card (i.e. a kind of debit card). The latter is subsequently used to operate the washing machine.
Are these types of cashier systems for washing machines in common laundry rooms of apartment buildings included in the scope of the Regulation (EU) 1275/2008 (Annex I)?
Answer:
The scope of Regulation (EC) 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/updated in November 2014 guidelines mention that:
“End-user equipment is equipment which can be used by individuals directly, and 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 (EC) 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.