For ErP requirements, Commission Regulation 1275/2008 has these two points:
(c) Availability of off mode and/or standby mode
Equipment shall, except where this is inappropriate for the intended
use, provide off mode and/or standby mode, and/or another condition...
and
(d) Power management
When equipment is not providing the main function, or when other
energy-using product(s) are not dependent on its functions, equipment
shall, unless inappropriate for the intended use, offer a power
management function, or a similar function...
Who determines and how does one justify "inappropriate for the intended
use" option?
I have two cases. One involves a touch panel for user input. Marketing
types say they cannot sell a touch panel that takes more than a second
to respond. The second case involves a wireless (2.4 GHz) function.
Again the marketeers say that they cannot sell something that takes 20
seconds to wake from standby. So where or how does one justify that? And
how does one get that justification "approved"?
Continuing, how does one write the DofC? Do you include the
Directive/standard used to show compliance and add a statement that ErP
is inappropriate? Or does one just leave the ErP Directive/standard out
of the DofC completely?
In a variation of the wireless case, consider wireless audio. The
receiver never knows when a user will send audio to the receiver. So the
receiver must be on all the time to be able to play that incoming audio
whenever the user requests it. But when the wireless is on, the unit
cannot consume less than the proscribed 0.5W. Close, but no cigar. So in
this case, can we say the unit is on all the time and we have a manual
(means to go standby or off)? And that there is no automatic means to go
standby or off because the radio is always listening for the incoming
signal? Is that compliant with Phase 2?
This years development cycle seems to be all about gray places. We are
not computers, servers, set top boxes or anything like that. But they
are adding wireless to a bunch of stuff that never had it before so
going to sleep has been vetoed by the marketeers. How does one make
compliant product in these type of cases?
As always, looking forward to your creative replies. And as always,
thanks in advance for your comments.
Regards,
Scott
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