Scott, unfortunately like most everything else in EU regulation, EuP is self-declaration so it is up to you to successfully argue inappropriate of us. For the most part, if you deal with big retailers, they will have their own subset of requirements. For almost all telco customers, there is defacto requirement of Code of Conduct, which is much more details oriented and straight forward. EC is currently finishing up subset of 1275/2008 for networking products. We have spend thousands of $ on EU lawyers trying to sort it all out and to get some backing for inappropriate of use statement and you can imagine their final say was: it's up to you, it's your product. If you choose this path, you will have to document your position: customer requirements for continuous use, unavailable technology or bankruptcy like effort to do it otherwise, requirements for continues traffic, for example business switch or access point and so on, bottom line is beef-up your TCF. Our understanding if you have the feature: standby, reduced power, "off" they all have to comply; if you only have one, that feature must comply. and unless you are claiming inappropriate for use, you must have at least one feature. Mark
________________________________ List-Post: emc-pstc@listserv.ieee.org Date: Mon, 29 Aug 2011 23:59:07 -0400 From: sdoug...@radiusnorth.net To: emc-p...@ieee.org Subject: EuP Off-Mode and Standby Mode Question on REGULATION (EC) No 1275/2008 stand-by and off-mode consumption of products. >From Annex II, 1.(c) Equipment shall, except where this is inappropriate for the intended use, provide off mode and/or standby mode, and/or another condition which does not exceed the applicable power consumption requirements for off mode and/or standby mode when the equipment is connected to the mains power source. If my product has a Standby mode which exceeds 1.0W and it has an Off-mode that is less than 0.5W (typically 0.0W), does that mean it is compliant to today's requirements? The argument from one side is that it has both Standby and Off modes so both modes must be compliant. The other side argues that it has a compliant Off mode, so Standby mode does not matter. Who is right? Second question, has anyone argued the "except where this is inappropriate for the intended use" statement yet? If you have, I'd like to hear about it off-line if you would be willing to share. Thanks to everyone for your comments. Scott Douglas - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at http://product-compliance.oc.ieee.org/ Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org> David Heald <dhe...@gmail.com> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at http://product-compliance.oc.ieee.org/ Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org> David Heald <dhe...@gmail.com>
