Comments following the Consultation Forum Meeting on 6 July 2017 on possible Ecodesign and Energy Labelling requirement for electronic displays

Orgalime contributed to the public consultation organised by the European Commission on the draft Ecodesign Regulation on electronic displays in January 2017. This was followed by the Commission reconvening the Consultation Forum on 6 July. Orgalime has now published this position paper summarising its comments on the possible ecodesign and energy labelling requirement for electronic displays.

Due to the lack of a thorough impact assessment, Orgalime welcomes the intended changes to the draft regulation for eco-design requirements, as presented at the Forum meeting, and would like to see the following Commission’s proposed scope exclusions confirmed in the final text:

• Displays for industrial use (separated or to be integrated into).
• Displays covered by other regulation (for example medical products).
• Displays that are out of scope of Directive 2012/19/EU (WEEE).

We support the inclusion of TVs and computer monitors for domestic and office applications in the scope.
With regard to the proposed energy labelling requirements, Orgalime particularly welcomes the proposed scope exclusions h), j), q) as these particular displays are characterised by low energy consumption and therefore do not contribute towards the regulatory objective of the energy efficiency label. Orgalime urges caution not to overburden the planned label with numerous and difficult to comprehend icons.

With regard to the proposed resource efficiency requirements in the draft eco-design regulation, we stress the need that any such requirements are measurable, enforceable and bring true environmental benefit. Product functionality, safety, human health or confidential business data and Intellectual Property (IP) cannot be compromised.