First, thanks again to all who commented on my original query.

I sent the question to a contact in the EU and they shared it with 
several people who are in a position to know the answers but prefer to 
remain anonymous. This is not "official" but as close as you will get 
without getting it in writing from the Commission.

First the references:

COMMISSION REGULATION (EC) No 1275/2008 of 17 December 2008 implementing 
Directive 2005/32/EC with regard to ecodesign requirements for standby 
and off mode electric power consumption of electrical and electronic 
household and office equipment.
 
COMMISSION REGULATION (EC) No 278/2009 of 6 April 2009 implementing 
Directive 2005/32/EC as it relates to external power supplies (EPS).

The comments paraphrased:

The first regulation applies to "electrical and electronic household and 
office equipment". This from Article 1 - Scope of the regulation. It 
covers products with built-in and external power supplies.

The second regulation applies to "power consumption in no-load condition 
and average active efficiency" for external power supplies ONLY. 
Emphasis on ONLY added by me. This from Article 1.1 - Scope of the 
regulation.

There was not a lot of comment on the date problem other than to say if 
it's a product then it must comply by January. If it's an EPS only, it 
must comply by April.

So the take-away here is that a product sold with an EPS must comply by 
January with the first regulation with regard to standby and off mode 
consumption. Then the EPS you sold with that product must meet the 
no-load and efficiency requirements for EPS by April.

So there you have it from a guy who knows a guy who knows a guy.

Regards,
Scott Douglas

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