Review summary for
Audiovisual equipment
Draft to version 3.0
2008-12-18
Nordic Ecolabelling
Swanlabelled Audiovisual equipment – Review summery
071/3.0, 2008-12-18
1 Summary 1
2 The review 1
3 Summary of received comments 1
4 Comments to the criteria in general 4
Comments on Swan labelling of Audiovisual Equipment 4
5 Comments to the criteria in detail 6
5.1 Which products can be Swan labelled? 7
5.2 R2 Energy efficiency 7
5.3 R4 Maximum energy consumption 9
5.4 R5 Energy efficiency 10
5.5 R7 Specific requirements for DVD/HD-DVD/Blu-ray players and Stereo systems. 10
5.6 R8 Specific requirements for Set top boxes 10
Hazardous Materials 11
5.7 R9 Heavy metals and flame retardants 11
5.8 R10 Mercury content in LCD displays 15
Design 19
5.9 R11 Dismantling 19
Customer information/life-time extension 19
5.10 R12 Requirements regarding life-time extension 19
5.11 R13 Operating instructions 19
Quality and regulatory requirements 20
5.12 R21 Legislation and regulations 20
5.13 R22 Marketing 20
Requirements on test institute/analysis laboratory 20
6 Analyses of received comments 21
7 Discussions and conclusion 21
Sida 20 av 20
1 Summary
The criteria were sent out on review from 2008-02-14 to 2008-04-15. 19 answers were received. After the hearing the work of implementation of the Ecodesign Directive 2005/32/EC regarding directives for Stand By, Simple Set Top Boxes and Televisions proceeded very fast. This work leads to coming legislation within EU. The content of these implementations also has influenced the final version of the criteria.
Late in the process, the EU ecolabel for television sets were established (4th of December 2008) and since the aim of the Swan ecolabelling of Audiovisual Equipment also was to harmonize with the EU Flower, quite many changes were made due to the final criteria.
The criteria for decision are for all those reasons changed in many aspects from the criteria sent for hearing.
Also the processes for the Ecodesign Directives are not finished, so the Swan criteria are proposed to have a short validity in order to adjust to the coming legislation.
2 The review
The criteria were sent out on review from 2008-02-14 to 2008-04-15.
Differences between version 2.3 and the proposal for version 3.0
- The biggest change is that we try to harmonize the criteria with the EU-flower criteria for television.
- Change regarding mercury in backlight. The old requirement was not based on correct background information and this mean that LCD products did not have any possibility to be approved. The requirement is now harmonized with the EU-flower and also the Swan criteria of PC.
- We also made it possible to Ecolabel Videoconference system and blu-ray players.
In this review summary we like to also include the latest studies regarding the EuP directive, EuP Preparatory Studies “Televisions” (Lot 5) Final Report on Task 6 “Technical Analysis BAT” the work with the new revised television criteria for the EU-flower will be based on this study, See appendix 1.
3 Summary of received comments
Country / Sent to: / Comments from: / Answer %Finland / 3
Sweden / 9
Denmark / 1
Norway / 2
Germany / 1
Japan / 1
Great Britain / 1
Belgium / 1
Total / 19
Organisation/
Company / Country / Support / Support with comments / Reject / Comments without support or rejection / Refrains from giving comments /
AEA Technology plc / Great Britain / X
Energimyndigheten / Sweden / X
Sveriges Kommuner och landsting / Sweden / X
Kemikalieinspektionen / Sweden / X
Svensk Fjärrvärme AB / Sweden / X
Miljømærking, Dansk Standard / Denmark / X
Miljømerking / Norway / X
Intertek / Sweden / X
TANDBERG / Norway / X
Konsument vägledarnas Förening / Sweden / X
Arbetsmiljöverket / Sweden / X
SHARP / Japan / X
EFRA / Belgium / X
Siemens Osakeyhtiö / Finland / X
Sesko Oy
(The SESKO Electrotechnical Standardization in Finland) / Finland / X
Tukes , Safety Technology Authority / Finland / X
Konsumentverket / Sweden / X
27 M / Sweden / X
SHARP European Headquarter / Germany / X
Total amount (x) / 5 / 11 / 3
4 Comments to the criteria in general
SHARP.
The comments from SHARP are based on the EU-flower television criteria draft. We find it important to include them because the Nordic Swan draft is based on the EU-flower criteria draft.
Conclusion:
1) I am concerned that the proposed criteria seem fit for small screen TVs andmore popular screen sizes will fall outside the requirements.
2) I strongly recommend thatthe Sharp proposals are given due consideration andimplementedto ensure top 20% to 30 %of TVs on the marketpass allthe new proposed eco-label criteria.
3) The currently proposed criteria, if adopted, may make a limited number of TVs suitable for eco-labelling. This could diminish itsvalue in the EU.
4) Continuation of eco-labelling TVs is very important and Sharp has worked hard to raise the awareness of the eco-label amongst customers more than any other producer of consumer goods. It is therefore right to take Sharp's views accordingly.
5) Restricting screen sizes will leave themlimited only by EuP requirements. In addition customers determined to purchase large screens will do so with or without eco-label. To this end it is better tooffercustomersa choice that includesenvironmental featuresregardless of screen sizes.
All in all we strongly ask you to reconsider the criteria and to change them in a way that at least 20 to 30 % of the products on the market can comply with them in order that the eco-label is a real guide to the consumer.
Answer from Nordic Ecolabelling to comments:
– The Nordic Swan Ecolabelling scheme is a voluntary system that sets requirements with the goal that 20-30% of the products on the market shall be possible to Ecolabel. This does not mean that 20 – 30 % of each screen size will pass the criteria. The Swan’s (and also the EU Flower’s) limit means that it can be hard for the large screens to pass the criteria with today’s technology.
– The EuP is a different system than Ecolabelling.
Konsumentverket, KO, Sweden
Comments on Swan labelling of Audiovisual Equipment
The Swedish Consumer Agency look positively on Swan labelling of Audiovisual Equipment and consider the criteria to be of significant consumer interest. We do not have the competence to comment on all criteria, but from a consumer viewpoint some of the criteria can be discussed.
....Here some text was left out and pasted to specific requirement.
Resource use, Environmental and Social effects. Many consumers expect that environmentally labelled products don’t have negative effects on workers/populations in other countries and on their environment. E.g. they may believe that the working conditions are acceptable in the production of diffent metals for audiovisual equipment. Hence The Swedish Consumer Agency finds it desirable that the Swan Label can include some criteria in this respect.
Nanoparticles. A new report from the Swedish Chemicals Agency stressed that the rapid development of new fields of application of nanomaterials and the great lack of knowledge calls for caution. It calls for precautionary measures especially for nanoparticles, as results from animal tests suggest that certain nanoparticles, when inhaled, could be harmful to human health. The problem is that no methods have yet been developed for testing the hazardous properties of nanomaterials with respect to human health and the environment. Whether or not nanoparticles are used today in the production of audiovisual equipment, it would be advantageous to be pro-active and add a criterion that nanoparticles are not allowed in Swan-labelled products. This criterion can then be removed later if future research will show that nanoparticles are not hazardous to health or environment. The Swedish Consumer Agency believes that use of the precautionary principle is appropriate in this case.
Answer from Nordic Ecolabelling to comments:
– Thank you for your support of the Swan-labelling.
– Nordic Ecolabelling also finds it important with the environment for workers of the ecolabelled products. However it is an area where it is difficult to check that the criteria is fulfilled and Nordic Ecolabelling therefore is cautious, though some criterion were included in Swan-labelling of Textiles. The criteria for Audiovisual Equipment are also almost fully harmonized with the EU Flower which don`t has this criterion.
– The effect of nanoparticles needs to be more explored. As far as we know nanoparticles are not used in the production of Audiovisual Equipment. The criteria for Audiovisual Equipment are also almost fully harmonized with the EU Flower which don`t has this criterion.
Energimyndigheten
In Swedish:
Answer from Nordic Ecolabelling to comments:
– The EuP draft for standby, simple set top boxes and television sets in an early stage have now been implemented in the revised criteria. Also harmonization with the EU Flower have been done regarding standby och television sets, and the suggested requirements are a little sharper than the EuP. However, the suggested EuP requirements for Simple set top boxes are extremely difficult to fulfil. No sharpening of that requirements is possible, and the Swan Criteria immediately will adopt possible lowering of requirements for simple set top boxes. The standby EuP has been implemented as in the draft for decision.
- We recommend that the criteria gets a very short validity so the different EuP directives (also the one for Televisions is under development) can be properly implemented in the next criteria version.
5 Comments to the criteria in detail
First we would like to thank SESKO for their very useful comments in detail, mostly of editorial type but also some technical clarifications. Many of the comments have been adopted and improved the criteria. Since they were very detailed and on 8 pages, only a few of the comments were inserted in this document. For those who would like the whole document, please contact the secretariat for a copy.
5.1 Which products can be Swan labelled?
SESKO, Finland
As far as we can understand, the sentence ”Televisions, Videoconferencing systems, Televisions in combination with outher equipment with CRT-displays are excluded” is in contradiction with the fact that televisions and videoconferencing systems are included int the scoope. Maybe the intention is to say that all equipment combined with CRT-displays is excluded.
Answer from Nordic Ecolabelling to comments:
– Thank you for your question, the text in the criteria has been changed so all equipment with CRT displays are excluded.
Miljømerking, Norway
In Norwegian: Stilles de samme krav til fjernkontroll som til TV i øvrigt?
Answer from Nordic Ecolabelling to comments:
– The requirement is also valid for remote control. Clarification has been done in the product group definition.
5.2 R2 Energy efficiency
Konsumentverket, KO, Sweden
R2 Specific requirements.... Much work has been done to teach consumers to use the hard on-off switch that gives an energy consumption of zero watts. The Swedish Consumer Agency therefore believes that it is of great importance that all equipment has a hard on-off switch, ant that it is placed clearly visible on the front.
It is important that energy saving is always “built in” so that the consumer doesn’t have to make a choice of using an energy saving mode. E.g. it is better not to have two different kinds of on-off switches that the consumer has to choose between.
It is important that when the equipment is turned off with the hard on-off switch, the equipment doesn’t “forget” information that has been programmed by the consumer.
A low electricity consumption in stand-by is desirable, as the levels proposed in the criteria.
SHARP
2) Maximum power consumption value in deep sleep mode
We again propose you to have tiered approach on the maximum power consumption value in deep sleep mode as below.
- 1st tier with compliance from effective date to 2010 : ≤ 500mW
- 2nd tier with compliance from 2011 to 2012 : ≤400mW
- 3rd tier with compliance later than 2013 : ≤300mW
<Reason>
The power consumption value of most of the current televisions on the market is 600mW to 800mW. Therefore, if it is set “300mW” as criteria, we believe that few models in market could pass EU ecolabel criteria.
Using our best available technology, we expect that we can improve it to 500mW at expected effective date. We worry that if you will not change the standard from 400mW to 500mW, there become a period that no models have ecolabel on the market.
Regarding 1) and 2) we also want to point out to EUP Lot 5 Task 5, Fig. 17– from which you can see the amount of standby compared to the total energy consumption of a TV.
Soft On-OFF switch
In reading the 4th discussion paper I understand that onlyone member of the AHWG proposed a limit of 300mW, and following the majority objection from the EUEB members the limitwas increased to 400mW. Bearing in mind that the limit established from the sampling exercise was 380mW,the proposed limit of 400mW does not appear to be a reasonablecompromise. I believe the Sharp's proposal is a good solution that will offer a strong eco-label and environmental benefits whilst working towards stricter requirements, thusencouraging producers to design for future advanced environmental credentials.
On-off Switches
“All televisions shall have a clearly visible on-off switch. When the switch is operated to the off position, the television’s energy consumption shall be zero watts.”
We kindly request you to change this requirement as below.
“All televisions shall have a consumer accessible on-off switch or soft on-off switch.”
<Reason>
Recent TVs have lots of functions thanks with technology development.
If power consumption of a TV goes completely zero, users can not receive those benefits such as “on air download function / EPG reserving function” of digital data receiving functions.
We, TV manufacturers need to satisfy both users benefit and environmental protection.
To realize it, we would like to propose you to change the criteria as above mentioned.
Otherwise, we will be not able to apply ecolabel anymore, since we can not ignore user benefits.
Answer from Nordic Ecolabelling to comments: