I am in need of a jury of my peers...  I will not hold you responsible for
your opinion in any way, but the input is appreciated.
 
In your judgment, relative to the ECO design directive in the EU, specifically
to the power supply regulation, is the following an ITE equipment?   To be
clear I'm only asking about the ECO design directive and supply efficiency
regulations that go into force on the 27th.
 
A pet door with an on board processor, RFID reader, serial port/USB port, and
may be powered by battery or optional power supply.  The device reads an
implanted RFID chip that is in the pet, then operates a latch based on
comparing the detected ID to a stored list of allowed IDs.   In addition the
device optionally connects to a PC located nearby to monitor, log, and control
the latch mechanism remotely.
 
The definition of ITE equipment provided in the ECO directive: 
" ‘information technology equipment’ means any equipment which has a
primary function of either entry, storage, display, retrieval, transmission,
processing, switching, or control, of data and of telecommunication messages
or a combination of these functions and may be equipped with one or more
terminal ports typically operated for information transfer;"
 
Guidance provided in the document "Guidelines accompanying Commission
Regulation (EC) No 1275/2008 of 17 December 2008 implementing Directive
2005/32/EC of the European Parliament and of the Council with regard to
ecodesign requirements for standby and off-mode electric power consumption of
electrical and electronic household equipment (October 2009)", states the
following: "Annex I limits the scope for ITE to those products intended
primarily for use in the domestic environment, i.e. EMC Class B IT equipment.
The definition of “information technology equipment” and “domestic 
environment” is identical EN 55022 covering essential requirements of the
"EMC" Directive 2004/108/EC.The EMC classification can be used as an indicator
to decide if an ITE product is in scope or out of scope of the Regulation.
Because the EMC classification is part of the self declaration of CE
conformity for IT equipment, it is a consistent indicator."

Many thanks,

Clif Brick

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