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.