We are all probably aware by now of the EuP Directive (or should be 
anyway). There are two regulations in particular that implement the 
requirements of the Directive:

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).


Having read and re-read both regulations multiple times, one of my 
engineers posed a question I am not sure of the answer for. If the first 
regulation deals with products with built-in power supplies, and the 
second regulation deals with external power supplies, which regulation 
covers the products the external power supplies feed power to?

I do not find anywhere in the second regulation where it mentions that 
the product connected to the EPS and the EPS together must meet the 
requirements of the regulation. It only seems to be concerned with the 
EPS itself.

For example, I have a gadget that uses an EPS. The EPS by itself when 
plugged into the mains and not connected to the product consumes 0.4 W. 
But when you connect the product to the EPS, the pair consume 1.1 W when 
the gadget is in standby mode.

I think this is a hole in the regulations. If you were to tell me that 
the first regulation covers the pair of gadget plus EPS, I would argue 
then why did they make a separate regulation just for EPS? And if the 
effective date for the first regulation is January 7, 2010, and the 
effective date for the second regulation is 27 April 2010, then how can 
the combined pair possibly be required to comply under the first 
regulation more than three months before the EPS regulation takes effect?

Or, is there a remote possibility that if, I say IF, my EPS complies 
with the  regulation by itself with no gadget connected to it, then I am 
done and do not need to worry about the combination of EPS and gadget? 
Or is it more likely that the EPS Regulation requires the pair to be 
compliant and I just can't see it?

I look forward to hearing the comments of you EuP experts out there.

Best regards,

Scott Douglas

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