Scott
1275/2008 is a framework directive. The Directive is implemented via a number of (product/sector specific) Commission Regulations. Some more information: http://www.bis.gov.uk/nmo/enforcement/ecodesign/legislation http://ec.europa.eu/energy/efficiency/ecodesign/doc/overview_legislation_eco-design.pdf http://ec.europa.eu/enterprise/policies/sustainable-business/documents/eco-design/guidance/files/faq_en.pdf The regulations also contain more detail as to exactly what is in and out of scope. regards Charlie -----Original Message----- From: Scott Douglas [mailto:sdoug...@radiusnorth.net] Sent: 01 August 2013 04:17 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] ErP and Inappropriate for Intended Use 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 - ---------------------------------------------------------------- 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<mailto:emc-p...@ieee.org>> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. 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<mailto:emcp...@radiusnorth.net>> Mike Cantwell <mcantw...@ieee.org<mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org<mailto:j.bac...@ieee.org>> David Heald: <dhe...@gmail.com<mailto: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://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. 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>
