Purpose and Objectives

Transcription

1 Purpose and Objectives The purpose of this consultation is to provide stakeholders with an opportunity to provide feedback to the ongoing work devising an Ecodesign Directive Impact Assessment for Sound and Imaging Equipment. The work is closely linked to an earlier published Preparatory Study ( Within the over arching product group Sound and Imaging Equipment, there are three main sub product groups: Game Consoles Projectors Video recorders A separate questionnaire has been devised for each sub product due to the very different nature of each. In the context of this work, stakeholders include public authorities, Member States authorities, private organisations, industry, SMEs, European Technology Platforms, Joint Technology Initiatives, research institutions and universities, research funding organisations, international organisations, consumer advocacy groups and other interested parties. The general objectives of the initiative are to contribute to the EU climate and energy targets (20/20/20 targets). More specific objectives are: Raising awareness on energy efficiency and environmental performance among purchasers and users of sound and imaging equipment Gradually removing the worst performing products from the EU market Encouraging manufacturers to sell equipment with higher added value, including by investing in innovation and new technologies The policy options will be assessed against specific objectives, as required by Article 1 of the Ecodesign Directive, such as the absence of any negative impact on the functionality, affordability and safety of the products and on the industry s competitiveness. This survey will be open for participation until 2nd vember Remark: Some of the sections pose questions offering respondents the opportunity to state whether they agree or not. Where you have alternative views to those presented in this questionnaire, or additional insights to provide on any issue, we invite you to provide additional evidence using the address: ecodesign@pe international.com. Please also use this address if you would like to discuss the question further. Page 1

2 Identification of the respondent What is your field of activity? Environmental n Governmental Organisation (NGO) Consumer NGO Other NGO National authority in charge of market surveillance National authority in charge of the implementation of the ecodesign directive Other national authority Independent technical expert Manufacturer of game consoles Other industry (please indicate) In which country is your organisation headquartered? Page 2

3 Products Affected Before asking specific questions on game consoles, we would like to ask some general questions on sound and imaging products in general. There is a wide range of products available for the presentation of video images. This consultation focuses on the three product types that have been investigated by the preparatory study: video players/recorders, video projectors, and video game consoles. Video players/recorders: Products within this sub group include DVD players / recorders, Blu ray (BD) players / recorders and hard disc drive (HDD) based devices. For the purposes of this impact assessment, these are: Mains powered stand alone devices whose primary function is to decode video from recorded or recordable media via a powered or integrated media interface such as an optical drive, USB or HDD interface to an output audio/video signal. Video recorders have no tuner unless it records on a removable media in the standard library formats DVD and/or Blu ray. Products with displays for viewing video or designed for a broad range of home or office applications are excluded. Projectors: Products within this sub group include school projectors, office projectors and home cinema projectors. For the purposes of this impact assessment, these are: Mains powered, optical devices, for processing analogue or digital video image information in any broadcasting, storage or networking format to modulate a light source and project the resulting image onto an external screen. Audio information, in analogue or digital format, may be processed as an optional function of the projector. Game consoles: Products within this sub group include current generation consoles (Xbox30, PS2&3, Wii) as well as future generations of game consoles. For the purposes of this impact assessment these are: Mains powered stand alone devices providing video game playing as the primary function through an external screen. Products with integrated screens, conventional PC operating systems or internal batteries for powering products over extended periods of time are excluded. Do you agree with the list of products included in scope for the impact assessment? (If you already answered to this question in another questionnaire of this consultation, then please skip to the next question.) Page 3

4 Are there other products that ought to be included in a future action? Unsure Page 4

5 Action Required What other products ought to be included and why? Reasons might include energy consumption, stand by losses, material use, other life cycle impacts. Please state. Do you believe that action is needed in Europe to improve the environmental performance of sound and imaging equipment? I don't know What type of action in your view is best suited to sound and imaging equipment? Please tick all those that apply. gfedc gfedc gfedc gfedc gfedc gfedc Voluntary measure e.g. an ecolabel or agreement Energy Star Mandatory Energy Label Mandatory Ecodesign WEEE Directive Other (please state) Page

6 Market & Policy Scope Re assessing the analysis of the preparatory study completed in 2010, it has been determined that the market for game consoles is continuing to grow, with more products in stock and increasing functionalities being offered. Sales of existing consoles have not tailed off as quickly as previously thought one of the main game console manufacturers reported only small drops in sales in 2012 compared to 2011). Indications are that: Sales of the next generation of game consoles are expected to exhibit similar sales patterns and volumes as witnessed for the current generation of high definition game consoles. The launch date of the next generation of game consoles may be delayed until as far as 2014 for some models. This delay is partly responsible for the sustained sales levels for existing consoles. There has been a continued growth in the usage of game consoles for functionalities other than gaming, such as video streaming, which will impact future use profiles. This increase in usage is assumed to have occurred due to extra functionalities, such as video on demand services, being included and advertised on game consoles. The availability of motion detecting peripheral devices (Kinect, Move etc) is also likely to have been partly responsible for expanding the potential audience for game consoles and hence slowing the decrease in sales of the current generation of game consoles. Without policy intervention a game console will continue to have relatively high power demand during use and inactive modes, and the market would fail to design products that operated as efficiently as other products that offer similar functionality (e.g. gaming notebook computers). Page

7 Do you agree with this broad view of the status quo? Please state your reasoning below. Page 7

8 Policy options An impact assessment is based on an integrated approach which analyses benefits and costs and addresses the significant economic, social and environmental impacts of possible new initiatives. Impact assessment helps to explain why an action is necessary at the EU level and why the proposed response is an appropriate choice. It may demonstrate why no action at the EU level should be taken. In an impact assessment several alternative policy options are considered and compared to a baseline scenario. The two options identified below were included in the initial options list but, as the commentary describes, are not considered appropriate: Mandatory energy labelling (applying an A to G categorisation) under Directive 2010/30/EC Energy labelling has advantages in terms of transparency, consumer information, consistency with approaches for other products etc. However, it was discounted as there are only three main product types/models, one produced by each manufacturer, and the product architectures vary widely between the three different products. This means considerable differences in functionality and power consumption between products that would make application of an across the board categorisation unrepresentative EU coverage of the voluntary ENERGY STAR label for game consoles The EU ENERGY STAR agreement (covering office equipment) is currently in the process of being re negotiated and this revision could have provided the opportunity to widen the product scope to cover game consoles. However, the game console specification is not complete, and as public procurement is not relevant to the console market, the influence of the label may be limited. Do you agree with these policy options being discarded from analysis? Please state your reasoning below. Page 8

9 Policy options A business as usual option provides the baseline from which to assess the main policy options. This would involve no action barriers to game console efficiency improvements would persist, and it is likely that the trends observed historically would continue to repeat (as detailed earlier). The three main policy options being assessed for these products are: 1) Mandatory ecodesign requirements (regulation): This option would involve setting mandatory maximum levels for the power consumption/efficiency of game consoles. The aim is to: Set limit values at a level providing the highest energy savings while ensuring no negative impact on the functionality and affordability of the products. Specify implementation timing so that the cost effective potential is realised as early as possible while ensuring that the industry has sufficient time to redesign the affected products. To date, no draft regulation has been produced. The ErP preparatory study specified some potential requirements (which have been updated). Levels suggested subsequently represent one of a number of sub options of varying levels of stringency being addressed. The levels are largely based (in the first instance) on what is achievable by current product models, assuming that future designs will not perform worse than this level. A regulatory approach would take some time to outline and agree with member states, and would require a verification procedure for market surveillance, provision of information on power demand and power supply efficiency by manufacturers in technical product documentation/websites. 2) Industry proposal: At the beginning of August 2012, the 3 game console manufacturers presented a Draft Outline proposal to further improve the energy consumption of Games Consoles with draft energy efficiency criteria (the criteria proposed are summarised later in this questionnaire). An industry led approach means less administrative burden, and greater flexibility to update requirements as products change over time. However, the European Commission would have less control over this initiative than a regulatory approach and so feasibility of this alternative would depend on: Sufficiently stringent requirements that result in an improvement over the business as usual scenario and a clear commitment to future revisions as products evolve (there is a risk that requirements as currently specified do not result in change in the market, especially as there are a number of clauses that allow for innovations not to be constrained by the agreement). Participation of all 3 manufacturers (there is a risk that if just one manufacturer was to default then the failure rate would be 33.33%). An appropriate legal framework being specified for administrative aspects of the agreement (there is currently no clear legal commitment by the 3 manufacturers in the draft document). 3) Internationally recognised agreement: The potential for an international agreement on game console energy efficiency, (brokered by the Australian DCCEE under the IEA banner within the 4E implementing Agreement) is under exploration. An international agreement could involve as a minimum for example the EC, the Australian DCEEE Page 9

10 and the Californian Energy Commission. The chosen requirements could be the most robust of the requirements from the EC and Australian industry initiatives. There are advantages in this approach for manufacturers, as there will be less variation in requirements placed upon them among countries. There would need to be active input from the European Commission and other collaborating countries to ensure that the end agreement complied with the principles of effectiveness, efficiency, and consistency. Please score the policy options in order of preference (1=first preference, 3= last preference): Mandatory ecodesign requirements (regulation) Industry proposal Internationally recognised agreement Please state your reasoning below. Page 10

11 The previously listed policy options on game consoles include power demand requirements on a range of different power modes but none address energy use in the main game play active mode. Users, who often equate power demand with performance, expect a high level of performance in the active play mode. Whilst a significant amount of the energy use in a game console stems from use in active mode, setting power demand requirements on this mode could limit the functionality of future game consoles (as power demand often increases with levels of functionality). In addition, the measurement of power demand in this mode is technically complex, as is the regulation of power demand in this mode. Do you agree with not placing requirements on the active gaming mode in order to safeguard future levels of functionality in new products? Please state your reasoning below. Page 11

12 Industry Proposal The industry proposal only applies to products consuming more than 20 watts in Active Game mode. The auto power down (APD) requirements are similar to those previously discussed under ENERGY STAR, with a number of exceptions to allow leniency in various areas. The requirements in the various operational modes are specified in the following table: Page 12

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14 Please indicate your opinion concerning the proposed requirements as follows: Strongly agree Agree Disagree Strongly disagree Tier 1 Tier 2 Media Playback mode Navigation mode Networked Standby Standby (only reactivation and indication of enabled reactivation) Standby (information and status display) Additional functionality allowance (NUI) Game play Please state your comments to the industry proposals here. Page 14

15 Media playback requirements in the industry proposal would only be applied to a pre defined list of media formats (e.g. high definition playback), with more power allowed to be used when supporting future media formats (e.g. for ultra high definition playback). Do you agree with an approach that does not place power demand limits on game consoles when providing playback of future media formats? Please state your reasoning below. Page 1

16 Potential for Regulation A regulatory approach would aim to improve the environmental impact of game consoles by setting mandatory maximum levels for their power demand. If regulatory requirements were to be specified for these products, preliminary levels could be as in the following table, although other sub options with varying levels of ambition are also being considered: Page 1

17 te: The modes listed above are the same as those of the industry proposal, and represent modes where reductions in power demand are unlikely to have significant impacts on usability. The levels for each mode are based on power demand values seen in other similar products performing the same functionalities, except for the NUI allowances, which are based on aspirational targets. These requirements differ significantly from the suggested requirements listed in the ErP preparatory study. The ErP preparatory study also suggested placing requirements on the active mode (efficiency only) and game play pause. These two power modes were dropped from the requirements due to complexities in developing suitable levels and potentially negative impacts on usability. The proposed requirements in the ErP preparatory study are, in general, more ambitious than those listed above (the exception being the tier II sleep mode requirements). The levels of ambition have been brought down due to concerns from industry that the requirements listed in the ErP preparatory study were too stringent. Page 17

18 Please indicate your opinion concerning the proposed requirements as follows: Strongly agree Agree Disagree Strongly disagree Tier 1 Tier 2 Media Playback mode Navigation mode Networked Standby Standby (only reactivation and indication of enabled reactivation) Standby (information and status display) Additional functionality allowance (NUI) Internal power supply Power management Game play Page 18

19 Do the proposed levels seem reasonable? Please state your reasoning below. Page 19

20 Potential for Regulation Other products on the market provide similar functionalities to game consoles. Power demand in some of these products can be significantly lower or higher than in game consoles. For example: A Blu ray player provides media playback and desktop and notebook gaming personal computers provide most of the same functions as games consoles. The proposed ErP requirement on standalone high definition video players during video play back is 20W, compared to the 70W level being discussed for game consoles. The draft ErP requirements on high performance desktop gaming PCs are significantly less stringent that the proposed mandatory measures on game consoles (game console architectures are different to computers and can allow for more efficient overall design specific for gaming purposes). Given that game consoles have specific architectures and wide ranging functionalities it is not always possible for them to achieve power demand values matching the levels seen in single function products, but sometimes they can be more efficient in power demand than multi function products. Is it reasonable therefore to set power demand limits for game consoles independently of any power demand levels on other products offering the same functionalities? Please state your reasoning below. Page 20

21 Network Standby The Lot 2 draft amendment (27/07/2011) to the ErP standby regulation (EC) 127/2008 proposes requirements for network standby of a range of products depending upon their network connectivity. Would you assume that the high or low network availability network standby requirements would apply to the low powered network condition of game consoles? Please indicate below. High Network Availability Low Network Availability Unsure Please state why: Page 21

22 Additional Considerations In addition to energy considerations, there are other environmental impacts associated with consumer electronic products such as resource use, end of life impacts, toxic content, recyclability, etc. Are there any non energy considerations that you feel this evaluation should address? Please state your reasoning below and identify the impacts. Is the development of regulation likely to impact the competitiveness of EU business and SMEs? Page 22

23 Additional Considerations What is that impact likely to be and what might be its magnitude? The potential for an international agreement on game console energy efficiency, has already been discussed. There are advantages to this approach for manufacturers, as there will be less variation in requirements placed upon them between countries. It is assumed that outcomes would be the same as under either the Industry proposal approach or under the mandatory ecodesign option. Do these assumptions seem reasonable? Please state your reasoning below. Do you support efforts to negotiate further towards an international agreement on game console energy efficiency? Please state your reasoning below. Page 23

24 Many thanks for your valuable input! Do you have other comments or suggestions? Please state below or send your comments to international.com. Page 24