Hi All,

The product is a wall mounted touch panel and the question relates to ErP,
specifically for the EU and California. The display is only 4" big. The
unit is powered by two possible means. One is by Power over Ethernet, the
other is a barrel connector for plugging in a wall-wart. We do not sell or
ship the wall-wart with the product. Our installation instructions show
both methods of powering the panel however.

We required ErP testing on the product. The manufacturer is pushing back
saying ErP is not required for this product. They cite two points making
that claim. First is Regulation 1275/2008, Article 1.(c). "is dependent on
energy input from the mains power source in order to work as intended;
and...".

Second point they cite is from the "Guidelines accompanying Commission
Regulation (EC) No 1275/2008..." page 5 (decision tree) and page 9, Article
2, point 1c:

Examples for energy input other than from the mains power source:
· power over Ethernet
· power over a telephone land-line
· DC-powered products, and power over USB
· non-rechargeable batteries.

I know guidelines carry no legal weight, so my question  is - is such a
device required to meet ErP and have a 3rd party test lab report? They say
no because it is not powered by AC Mains. But we have had other products
powered by wall-warts and was told that we had to test the product and the
EPS together under 1275/2008. In addition, we had to test the EPS
separately under 278/2009. So I have never gotten a clear definition
whether these kinds of product need ErP test as a product. (I always
expected to have to get 278/2009 testing done for the EPS itself if we sold
the EPS.)

Hoping someone can provide more clarity on this one. Thanks for any
comments in advance.

Scott

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