The amount of energy wasted by devices in standby and off-mode has become a major concern in recent years. An increasing proportion of consumer equipment is now designed to be left on standby or rely on "soft” off switches, sometimes for reasons of function but often unnecessarily. These products consume power 24/7, sometimes as much as 25 or 30 W.

Although the losses per product are small, this soon mounts up. It is estimated that US households waste around $3.5 billion each year on avoidable standby and off-mode losses. This equates to about 70 to 125 W of power drawn continuously by 20 to 25 products per home. Researchers in the US have proposed a global initiative to reduce standby power consumption for most electrical products to 1 W or less. That approach has begun to appear in the US EPA’s Energy Star® specifications, starting with set-top boxes.

In view of this, the European Commission decided to address standby and off-mode losses within the EuP Directive. In October 2007, the Commission published a draft Implementing Measure which proposes stringent EcoDesign requirements for stand-by and off-mode power consumption of electrical and electronic household and office equipment.

Scope

The draft Implementing Measure applies to standby and off-mode power consumption of electrical and electronic household and office equipment which are dependent on energy input from a mains power source. In particular, office and household equipment which falls within Annex 1B of the WEEE Directive and have a voltage rating of less than 380 V. Industrial, medical and commercial equipment is specifically exempted from the scope of the implementing measure, which mentions the following examples: monitoring and control instruments used in industrial installations, coin slot machines, medical devices and automatic dispensers. The draft Implementing Measure cites one indication that equipment is intended for commercial equipment as that it may be sold in small quantities and may have "standby” functions which are critical for safety aspects.

One issue where further clarification is required is how this draft implementing measure will relate to other, product-specific implementing measures.

The body of the draft Implementing Measure states that equipment must meet the EcoDesign requirements in the Implementing Measure "unless product specific implementing measures adopted after this implementing measure establish different requirements".

However, the explanatory notes to the draft Implementing Measure state that if a product is in the scope of both a vertical (i.e. product specific) implementing measure and a horizontal implementing measure (such this draft implementing measure for standby and off-mode losses) then the product has to comply with both the horizontal and the vertical implementing measure. The note goes on to explain that vertical measures prevail in the sense that more operational modes can be addressed (e.g. networked standby, ready, sleep, etc), and that differing requirements on (passive) standby and off-mode can be defined at a later stage if appropriate. These will usually be more stringent than the horizontal measure unless a justification for less stringent measures is provided. The issue here is that preparatory studies for other vertical measures (e.g. Group 3: Personal Computers and computer monitors) have proposed less stringent standby and off-mode measures, without providing a justification for this.

It is understood that more clarity on these issues will be provided as these Implementing Measures are further developed.

Definitions

The draft Implementing Measure contains the following definitions:

1. "Electrical and electronic household and office equipment dependent on energy input from the mains power source", in the following abbreviated as "equipment", means equipment:
   • falling under the product categories specified in Directive 2002/96/EC, Annex IB, with the exception of equipment not corresponding to household and office equipment
   • and intended for the end-user,
   • and dependent on energy input from the mains power source in order to work properly,
   • and designed for use with a voltage rating not exceeding 380V
   This definition also includes electrical and electronic household and office equipment which is marketed for non-household or non-office use.
2. "Off mode" means that the equipment is connected to a mains power source and provides no function. This includes an indication that the equipment is in off-mode, for example by using an LED signal lamp to show that the equipment is switched off. Using an LED in this way is not regarded as "Information or status display".
3. "Standby" means that the equipment is connected to and drawing energy input from a mains power source and provides one or more of the following functions:
   • reactivation function, or reactivation function and an indication of enabled reactivation function,
   • information or status display
   The following functions are not considered as being standby functions:
   • preheating functions,
   • sensor-based safety functions,
   • network reactivation and network integrity functions.
   This definition also covers standby for those EuPs using electricity but whose main function(s) is powered by gas or oil (e.g. passive standby of a gas-fired tumble dryer). This definition does not cover "standby" which is not powered electricity from the mains (e.g. a flame keeping the water heating function of a gas-fired boiler/water heater in "standby", battery backup)
4. "Information or status display" means a function intended to provide information or indicate the status of the equipment on a display, but where the display of this information is not the main function of the equipment.
5. "Main function(s)" means a function or functions which the equipment is intended to service
6. "Reactivation function" means a function intended to switch the equipment by remote switch, internal sensor, or timer to a condition providing additional functions, including the main function.

The above definitions are in line with the revision of IEC 62301 and proposals for energy efficiency legislation in the US.

EcoDesign requirements

The draft Implementing Measure proposes measurable limits for standby and off-mode power consumption and also a requirement for equipment to have a power management system that provides automatic fast transition to a lower consumption standby condition.

The timing of entry into force of these requirements has been chosen to allow for redesign of equipment. The first phase is regarded as the adoption of readily available current state-of-the-art technology. As a result, the draft Implementing Measure requires industry to comply with the first phase requirements within one year after the Implementing Measure has come into force.

The second phase represents adoption of Best Available Techniques by industry. The draft Implementing Measure requires industry to comply with these second phase requirements within three years after the Implementing Measure has come into force. This timing is roughly in line with implementation timing for legislation in other parts of the world, for example Australia has proposed similar requirements for standby and off-mode power consumption which are scheduled to come into force in 2012.

Limits for "off mode" and "standby"consumption

1. One year after the implementing measure has come into force:
   • Power consumption of equipment in any off-mode condition shall not exceed 1.0 Watt.
   • Power consumption of equipment in any standby condition providing only a reactivation function, or a reactivation function and a mere indication of enabled reactivation function shall not exceed 1.0 Watt.
   • Power consumption of equipment in any standby condition providing information or status display, or a combination of reactivation function and information or status display shall not exceed 2.0 Watts.
2. Three years after this implementing measure has come into force:
   • Power consumption of equipment in any off-mode condition shall not exceed 0.5 Watt.
   • Power consumption of equipment in any standby condition providing only a reactivation function, or a reactivation function and a mere indication of enabled reactivation function shall not exceed 0.5 Watt.
   • Power consumption of equipment in any standby condition providing information or status display, or a combination of reactivation function and information or status display shall not exceed 1.0 Watt.

The power levels for standby distinguish between reactivation function only, and reactivation and information and status display. This reflects the need for additional power for the latter functions.

The power consumption shall be measured according to the procedure specified in IEC 62301, first edition 2005-06, sections 4 and 5.

The manufacturer shall declare in the technical documentation file all conditions of the equipment classified as passive standby and off mode according to paragraph "Definitions", second and third subparagraph and the corresponding energy consumption measured according to the procedure in IEC 62301, first edition 2005- 06, sections 4 and 5.

Requirement for power management

Equipment shall, without prejudice to good engineering practice and unless inappropriate for the intended use, offer a power management function, or a similar function that switches equipment after the shortest possible period of time appropriate for the intended use of the equipment, automatically into a condition with reduced energy consumption when the equipment is not providing the main function, or when other energy-using product(s) are not dependent on its functions.

Verification procedure for market surveillance purposes

The EuP Directive requires Member States to carry out market surveillance, including carrying out compliance checks on a number of manufacturers by taking samples of products and subjecting them to compliance checks.

The Implementing Measure specifies that the Member State authorities must start by testing the passive standby and off-mode power consumption of a single unit, using the procedure set out in IEC 62301, first edition 2005-06, sections 4 and 5. The unit shall be considered to comply with the implementing measure if the off-mode and passive standby power consumptions do not exceed the limit values set out in section 2.3 by more than 10%.

If the single unit fails to comply then the Member State must test a further three units. The model shall be considered to comply with this implementing measure if the average off-mode and passive standby power consumptions for the latter three tests do not exceed the limit values set out in section 2.3. Otherwise, the model shall be considered not to comply.

The draft Implementing Measure for standby and off-mode losses was discussed at the Consultation Forum meeting on 19th October 2007. The Consultation Forum required the Commission to resolve outstanding issues concerning the scope and the definition of standby mode.

In regard to the scope, the Commission has recognised the difficulties in narrowing the scope from the range of product categories in the WEEE Directive by referring to such descriptions as "commercial” equipment. Instead, the Commission has agreed to include a list of in-scope products in the Implementing Measure.

The issue with respect to the definition of standby mode arises from industry concerns over meeting the proposed power consumption limits. In particular, the industry is concerned about the three year limit of 0.5 Watts for standby with reactivation, when there are differences in interpretation within industry sectors on what "standby” should mean. The Commission has agreed to address this issue in the Impact Assessment phase.

The current timetable is for the Commission to carry out the Impact Assessment and have a draft legal text of the Implementing Measure prepared within the next four months, with the intention of presenting this to the EU Regulatory Committee in July 2008.

Consultation Forum

The Consultation Forum comprises a group of 60 experts including one representative from each Member State and acceding country (in the case of the UK, an official from Defra). It is also open for observers from candidate and EEA countries. The Consultation Forum reports to the Regulatory Committee, which has the final decision on implementation of the EcoDesign requirements.

DEFRA leads on the transposition of the Directive into UK legislation and on EcoDesign requirements for particular product groups such as standby and off-mode losses, working closely with BERR and industry stakeholders.

Defra Contact:
Martyn Webb
Environment, Business and Consumers Division
Department for the Environment, Food, and Rural Affairs
Ergon House, Horseferry Road
London SW1P 2AL

Tel. +44 (0)20 7238 6000 ( Main Switchboard Ergon House)
E-mail: martyn.webb@defra.gsi.gov.uk

BERR Contact:
Peter Askew
Eco-design and Product Regulation Unit
Department for Business, Enterprise and Regulatory Reform (BERR)
Bay 384, 1 Victoria Street
London SW1H 0ET

Tel. + 44 (0)20 7215 3794
E-mail: peter.askew@berr.gsi.gov.uk

DEFRA aims to consult stakeholders on their views ahead of any discussion at the Consultation forum in order to inform the UK Government’s thinking. However, this did not happen for the draft Implementing Measure for standby and off-mode losses. Instead, the Commission only published the draft Implementing Measure at the end of September, for discussion at the Consultation Meeting on 19 October.

The next DEFRA stakeholder meeting will be held on 11 December 2007. To be added to the mailing list for details of this and other meetings send an e-mail to sustainability@berr.gsi.gov.uk

Regulatory Committee

The current timetable is for the Commission to carry out an Impact Assessment and have a draft legal text of the Implementing Measure prepared within the next four months, with the intention of presenting this to the EU Regulatory Committee in July 2008 for approval. The EU Regulatory Committee consists of the Commission and the 27 Member States.

DEFRA will aim to hold a consultation meeting to discuss the draft Implementing Measure in advance of this EU Regulatory Committee meeting.

DEFRA has advised that the Implementing Measure for standby and off-mode losses is likely to be an EC Regulation. This will have immediate effect across all Member States and will not require to be transposed into national regulations.

If vote at the EU Regulatory Committee meeting is successful, the Implementing Measure would then be submitted for scrutiny by the European Parliament and adoption by the European Commission and later in 2008. It can take about 5 months to prepare the written procedure and complete the necessary translations.

The final Implementing Measure will specify:

• The products covered
• Application dates
• Generic and specific EcoDesign requirements
• Measurement standards/methods
• Conformity assessment procedures
• Information requirements

Manufacturers’ obligations under the Implementing Measure will include:

• Designing the product in compliance with eco-design requirements
• Carrying out conformity assessment - generally by self assessment
• Affixing the CE mark and issuing an EC Declaration of Conformity

There are two main strategies for reducing standby energy consumption:

• Minimizing the power consumption of each standby mode and the associated set of standby functions
• Faster transitioning from a higher standby mode to a lower stand-by mode, or to off-mode

The standby mode should be designed so that it provides the standby functions to the user with minimum energy consumption.

In principle, the off-mode should not consume any energy, as in this mode the product is not delivering any function to the user. Off-mode losses should be eliminated by installing a primary side hard-off switch instead of a soft-off switch (or no switch at all).

In some cases it is not possible to place all of the active circuitry behind a primary side hard-off switch. For example, EMC or power factor correction circuits. In this case, off-mode losses should be reduced by minimizing the active circuitry and in particular increasing the efficiency of the power supply under the remaining off-mode load.

Table 1 presents a range of design options that manufacturers should consider to reduce off-mode losses and improve standby energy efficiency.

Table 1: Design options to reduce off-mode losses and improve standby energy efficiency

Option	Design Option	Comments and Guidance
Reducing off-mode losses
O1	Hard-off switch on the primary side.	Many products do not have hard-off switches, for example so that they can keep some functions available all of the time. However, a primary side hard-off switch can be installed in almost every product to eliminate off-mode losses. Of course, this relies on the user to switch off the equipment when not in use. To reduce losses when using switches, they should be situated on the primary side of the input transformer and in front of any primary circuit protection such as filters or transient suppression devices, that will also give rise to losses if left connected.
O2	External or internal power supply with minimized off-load losses.	If a hard-off switch can not be used, then off-mode energy losses will arise from the power supply and secondary side electronic soft-off switch, which requires a continuous power supply to operate the switch. This can be reduced by choosing a power supply with minimized off-mode losses. New developments in power supply topology and controller ICs allow losses below 200mW. This is also beneficial where the user chooses not to use the hard-off option.
O3	Automated transitioning to standby or off-mode when function not required	The draft Implementing Measure requires that all equipment shall, without prejudice to good engineering practice and unless in appropriate for the intended use, offer a power management function (or similar function) that automatically switches equipment to a condition with reduced energy consumption (i.e. standby or off-mode) when the equipment is not providing the main function, or when other energy-using product(s) are not dependant on its functions. Auto-standby or auto-off functions are particularly applicable to job-based products.
O4	Use of external switch (power strips, master/slave outlets).	To avoid off-mode losses or to switch off a device which normally does not have an off-mode, power strips with switches can be used. This option is equivalent to the user unplugging the device but is more practicable for the user and therefore likely to be used more often. Alternatively, a form of power strip called a master/slave outlet can be used. This will detect the change in current for the master outlet and will automatically cut off the power supply for all outlets when the current of the master outlet drops below a certain level.
Improving standby energy efficiency
S1	External or internal power supply with minimized power consumption in standby.	Choosing a power supply with minimized power consumption in standby mode. This is also beneficial where the user chooses not to use the hard-off option.
S2	Provide power for standby mode using a secondary power supply which has high efficiency in the low power range needed for standby functions.	In this option the secondary power supply provides power to the standby circuit without keeping the main power supply activated. This approach is particularly beneficial where the main power supply has poor energy efficiency in the low power ranges, and where a hard-off option is not available.
S3	Using batteries or super capacitors as a secondary power supply for standby functions.	The batteries or super capacitors (also known as super caps) will charge during on-mode and discharge during standby and off-mode. It is important check whether these options really do lead to reduced energy consumption, or whether the energy consumption is only shifted from one mode to another or, in the worst case, the energy consumption actually increases due to additional losses.
S4	Using an autarkic secondary power supply for standby mode	Autarkic (self sufficient) supplies harvest energy from their environments. Photovoltaic cells can be used to harvest solar energy. Thermoelectric converters can generate electricity from temperature gradients. Piezoelectric generators can generate electricity from vibrations. Other forms of static autarkic energy generation include turbine for wind and hydro power.
S5	Automated transitioning to standby or off-mode when function not required	The draft Implementing Measure requires that all equipment shall, without prejudice to good engineering practice and unless in appropriate for the intended use, offer a power management function (or similar function) that automatically switches equipment to a condition with reduced energy consumption (i.e. standby or off-mode) when the equipment is not providing the main function, or when other energy-using product(s) are not dependant on its functions. Auto-standby or auto-off functions are particularly applicable to job-based products.
S6	Improved circuit design of the standby function, possibly with more integrated ICs or dedicated microcontrollers.	New and optimised microcontrollers with integrated power save functions can lead to less components and therefore to less “side losses” and a reduced energy consumption. By installing additional microcontrollers which are more dedicated to the standby functions, the standby energy consumption can be reduced, because only the microcontrollers need to be powered.
S7	Reduced number of circuits powered during standby conditions (e.g. by using electronic switches or relays).	Installing electronic switches or relays that isolate non-standby circuits from the power source leads to a reduced standby energy consumption.
S8	Providing users with options to switch off circuit blocks which are not needed during standby	If a user does not require a function to be available in standby mode, it should be possible for the user to permanently disable the function during standby.
S9	Not allowing the user to disable auto-standby or auto-off functions	In some applications this may not be desirable for the user or network administrator.
S10	Use of very low power (or no power) display technologies to indicate equipment status	For example, zenithal bistable displays (ZBDs). These displays use a grating structure to hold the liquid crystal molecules at the surface in one of two stable orientations, one of which is black and the other white. Molecules can only be switched from one orientation to another by a voltage pulse of appropriate polarity. This ‘bistability’ is not affected by thermal or mechanical effects, so that once a pixel is switched from ‘black’ to ‘white’, or vice versa, it remains in that state, even when the power is switched off. ZBDs only require power when the image is updated, which results in enormous power savings. By comparison, most conventional LCDs require continual application of a voltage to each pixel to maintain the required liquid crystal orientation – even if the displayed image is static.
S11	Use of more efficient signal lamps	LEDs are more energy efficient and durable than incandescent bulb signal lamps (including halogen and Krypton lamps). An incandescent bulb uses about 100 W to produce the same amount of light as an LED lamp that uses about 12 W – an energy saving of 88%. LEDs emit colored light which eliminates the need for colored lenses.
S12	Avoiding continuous preheating (not necessary for modern CRTs/printers etc.)	Old CRT displays preheat continuously to enable a fast reactivation. This is not necessary today due to new optimised components and a different circuit design.
S13	Use of non-volatile memory	This would eliminate the need for power to be supplied continuously to the memory e.g. to maintain settings.
S14	Minimize the power level requirement for necessary safety functions	A review of safety functions in standby may identify opportunities to reduce power requirements to meet necessary safety levels.

The applicability of the design options in Table 1 to different products can be grouped depending on the nature of the product. In particular, whether the product is generally used:

• In an on/off manner, such as a radio or electric toothbrush
• In an on/standby manner, such as a cordless phone or TV set
• Job-based manner, such as a washing machine

Table 2 uses these 'product use cases' to indicate the different combinations of design options which are appropriate to different types of product.

Table 2: Applicability of design options to different products

Products	Generally Applicable Design Options
On/off products
Power supply for a mobile phone	O1, O4, Primary side regulation IC
Lighting (e.g. low voltage halogen lamp)	O1, O4, Improved transformer efficiency
Radio	O1, O2, O4, S1
Electric toothbrush	S1, S5
On/standby products
Electric oven	O1, S2, S10, S11
Cordless phone	O1, O2, O4, S1, S10, S11
TV, set top box	O1, O3, O4, S2, S7, S8, S9, S10,S11
Job-based products
Washing machine	O1, O3, O4, S2, S5, S10, S11
DVD	O1, O3, O4, S2, S5, S9, S10, S11
Audio mini system	O1, O3, O4, S2, S5, S10, S11
Fax machine	O1, O3, S5, S7,S8, S9, S10, S11, S12
PC	O1, O3, O4, S2, S3, S5, S7,S8, S9, S10, S11
Laptop	O1, O3, O4, S2, S3, S5, S7,S8, S9, S11
CRT monitor	O1, O3, O4, S5, S7, S9, S10, S11
LCD monitor	O1, O3,
Laser printer	O1, O3, O4, S2, S5, S7, S8, S9, S10, S11, S12
Inkjet printer	O1, O3, O4, S2, S5, S7, S8, S9, S10, S11, S12

The major impact of the proposed EcoDesign requirements will be on the design function and procurement function of the final equipment manufacturers, which in turn will impact their supply chains.

Manufacturers should assess the current standby and off-mode power consumptions of their equipment, and identify the most appropriate design options that will achieve the power consumption restrictions. Manufacturers should then develop a plan for how they will implement these design options to comply with power consumption restrictions by the deadline dates.

When specifying external or internal power supply modules with higher efficiencies at low or no load at the design concept stage, designers must consider whether they can be sourced effectively from their existing suppliers or whether they need to identify new suppliers. The same is true where secondary high efficiency power supplies or Autarkic power supplies are specified at the concept stage, but here the designer should also consider the additional design effort required at the detailed design stage to successfully integrate these power supplies into the overall design.

Manufacturers should keep track of emerging power supply technologies that will deliver improved energy efficiency, and whether these may become commercially available in time to meet the deadline dates for the power consumption restrictions.

Manufacturers should consider whether they have the necessary design expertise to implement the design changes that will be required to comply with the power consumption restrictions. Fitting hard-off switches should not present too much of a problem except perhaps in ensuring that they are suitably located. However, adopting other design options will require specialized circuit design expertise which may not currently be available in-house.

Assessing whether the manufacturer has the necessary design expertise is particularly important in implementing automatic transitioning to standby or off-mode. This is a specific requirement in the draft Implementing Measure unless it can be shown to be inappropriate for the intended use or prejudicial to good engineering practice. Where manufacturers do not already have experience of designing automated transitioning to standby or off-mode, manufacturers should consider how they will obtain the specialized design expertise and knowledge.

It is also important to remember that this design, specification and procurement work cannot be done in isolation. Manufacturers should consider how they can implement the required design changes without prejudicing other regulatory requirements such as EMC or Safety.

Regarding supply chain issues, manufacturers should consider how and where they will source components such as high efficiency primary or secondary power supplies, Autarkic secondary power supplies if appropriate, low power display technology, higher efficiency indicator lamps, microcontroller ICs and non-volatile memory devices, etc. Manufacturers will also need to ensure that any new components or materials they use to achieve the required standby and off-mode power consumption limits must comply with the RoHS materials restrictions. Manufacturers will also need to monitor the implementation of any future materials restrictions. These may arise from the review of the RoHS Directive in 2008 or from the implementation of the REACH Regulations.

Conformity assessment against the Implementing Measure will be based on self-assessment. Manufacturers will be required to prepare a technical file or dossier containing a record of the design measures introduced, any harmonised standards used and any measurement or test data. The draft Implementing Measure for standby and off-mode losses specifies the use of IEC 62301, first edition 2005-2006, sections 4 and 5. The manufacturer can then sign an EC Declaration of Conformity with the implementing measure and affix the CE marking to the product. As it is likely that these products are already CE marked under product safety and EMC legislation then the manufacturer must integrate the new EcoDesign requirements into his CE marking regime without impinging on these other requirements.