A little anecdote. A couple of years ago I purchased a very cheap DVB-T 
(Freeview) receiver, DVD player and hard-drive video recorder combo. To my 
amazement, it had a good old-fashioned mechanical on/off switch on the front 
panel which actually disconnects the mains supply from the internal PSU. I 
hadn’t seen such a switch on consumer electronic equipment for years, 
particularly budget products where they scrimp and save every possible penny.

Then my penny dropped... It was their cheapest possible way of complying with 
ErP Regulations. Very clever.

In the two years plus since I installed the receiver, I can’t ever recall 
having switched the unit off. It just gets put (or automatically times out) 
into stand-by and woken up via the usual red power button on the remote 
control. I estimate it’s used for 20 minutes every four days or so to watch 
some news some mornings. I don’t want to wait 30 seconds for it to boot from 
‘off’. From standby however, the programme’s there as soon as the TV connected 
to it has powered up.

So, whilst you have to give consumers the ‘off’ option, the real eco-benefit 
would be educating consumers to use it.

Perhaps we should have Commission Directive 2014/666/EC, Compulsory Use of the 
Off Function on Domestic, Office and Light Industrial Equipment. It will be 
policed and enforced by all those Smart Meters our Authorities are insisting we 
install with hefty (stealth-tax) penalties for offenders.

;-)
T
----- Original Message -----
From: Scott Douglas
Sent: 08/01/13 04:16 AM
To: [email protected]
Subject: [PSES] ErP and Inappropriate for Intended Use

For ErP requirements, Commission Regulation 1275/2008 has these two points: (c) 
Availability of off mode and/or standby mode Equipment shall, except where this 
is inappropriate for the intended use, provide off mode and/or standby mode, 
and/or another condition... and (d) Power management When equipment is not 
providing the main function, or when other energy-using product(s) are not 
dependent on its functions, equipment shall, unless inappropriate for the 
intended use, offer a power management function, or a similar function... Who 
determines and how does one justify "inappropriate for the intended use" 
option? I have two cases. One involves a touch panel for user input. Marketing 
types say they cannot sell a touch panel that takes more than a second to 
respond. The second case involves a wireless (2.4 GHz) function. Again the 
marketeers say that they cannot sell something that takes 20 seconds to wake 
from standby. So where or how does one justify that? And how does one ge!
 t that justification "approved"? Continuing, how does one write the DofC? Do 
you include the Directive/standard used to show compliance and add a statement 
that ErP is inappropriate? Or does one just leave the ErP Directive/standard 
out of the DofC completely? In a variation of the wireless case, consider 
wireless audio. The receiver never knows when a user will send audio to the 
receiver. So the receiver must be on all the time to be able to play that 
incoming audio whenever the user requests it. But when the wireless is on, the 
unit cannot consume less than the proscribed 0.5W. Close, but no cigar. So in 
this case, can we say the unit is on all the time and we have a manual (means 
to go standby or off)? And that there is no automatic means to go standby or 
off because the radio is always listening for the incoming signal? Is that 
compliant with Phase 2? This years development cycle seems to be all about gray 
places. We are not computers, servers, set top boxes or anything!
  like that. But they are adding wireless to a bunch of stuff that never had it 
before so going to sleep has been vetoed by the marketeers. How does one make 
compliant product in these type of cases? As always, looking forward to your 
creative replies. And as always, thanks in advance for your comments. Regards, 
Scott - ---------------------------------------------------------------- This 
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This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
<[email protected]>

All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

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