Recommenda)ons and evidence from European Environmental NGOs for the vote of Ecodesign requirements for computers and servers February 2013 Contact: Stama5s Sivitos, ECOS [email protected] 1 SUMMARY OF RECOMMENDATIONS •  Reduce all TEC limits for desktops and notebooks by 20% at both )ers •  Reduce very substan)ally the allowances for graphic adders •  Ensure that no provision is discouraging the use of switchable graphic adders •  Remove (or )ghten) the exemp)ons for high-‐end PCs at )er 2. In the mean)me, submit these high-‐end PCs to )ghter requirements on power supply eﬃciency and other environmental aspects, so that they become front runners of green tech. •  Reduce sleep mode limits to 2.5 W for desktops and 1.5 W for notebooks •  Keep requirements on power supply eﬃciency •  Set informa)on and minimum requirements on other ecological aspects, such as life-‐cycle energy/CO2 impact, marking and recycling of plas)cs, use of recycled material, easy disassembly, hazardous content, life)me extension, standardisa)on of baZeries •  Ensure beZer centralisa)on of market data for market monitoring 2 These levels would have no eﬀect on the market, they are now largely outdated. According to an evalua)on made by NRDC on a sample of models from 2012 in the high consuming range, only 1 desktop out of 20 was not mee)ng the levels planned for 2014. In addi)on, only 4 out of the 20 units were not mee)ng the limits planned for 2016. RECOMMENDATION: Reduce these limits by 20% From 1 July 2014: (a)  Category A computer: 118.00 (b)  Category B computer: 140.00 (c)  Category C computer: 167.00 (d)  Category D computer: 187.00 •  Only 1 out of 20 models in random sample failed to meet the draD limits •  On average, desktops in sample passed the EC limits by a margin of 32% 3 Source: NRDC Allowances for discrete graphic adders are extremely high and inconsistent with the performance of the products on the market today. According to a tes)ng campaign by CLASP & NRDC, graphic cards sold in 2012 were way below these levels. Source: CLASP-‐NRDC RECOMMENDATION: Strongly reduce the graphic adder allowances in line with current performances: 4 Ar)cle 1.1.3 needs to be further clariﬁed. What does ‘enabled during tes.ng’ exactly mean? Ecodesign requirements should encourage the use of switchable technologies that can automa)cally switch oﬀ (and reduce energy consump)on) when not in use. The formula)on could be detrimental to this. RECOMMENDATION: Find a beZer formula)on for this point. Eventually, switchable graphic cards that are oﬀ in idle mode could be rewarded by a small allowance (for instance 50% of the G1 capability adjustment men)oned earlier). Exemp)on for high-‐end PCs speciﬁed in point 1.1.4 should not last forever but be limited in )me. In addi)on, high-‐end PCs should not be given a complete free ride but should be subject to tougher requirements on power supply eﬃciency and other environmental aspects. RECOMMENDATION: -‐ Remove (or )ghten) the exemp)on for high-‐
end PCs at )er 2 (2016). -‐ Set )ghter power supply eﬃciency requirements for high-‐end PCs: 88% eﬃciency at 50% load, and 85% at 20% and 100% load -‐ Set )ghter requirements for these PCs on 5 other environmental aspects RECOMMENDATION: Reduce these limits by 20% From 1 January 2016: (a)  Category A computer: 94.00 (b)  Category B computer: 112.00 (c)  Category C computer: 134.00 (d)  Category D computer: 150.00 RECOMMENDATION: Strongly reduce the graphic adder allowances in line with current performances (see levels proposed on slide 4) 6 Notebook computers are performing way beZer than the proposed requirements. The inadequacy is probably even more extreme than for desktop PCs. RECOMMENDATION: Reduce these limits by at least 20% From 1 July 2014: (a)  Category A computer: 32.00 (b)  Category B computer: 42.00 (c)  Category C computer: 71.00 7 Allowances for discrete graphic adders in notebooks are also way too high here. RECOMMENDATION: Strongly reduce the graphic adder allowances in line with current performances: 8 Same remark as before about exemp)ons. Exemp)on for high-‐end notebooks speciﬁed in point 1.3.4 should not last forever but be limited in )me. In addi)on, high-‐end notebooks should not be given a complete free ride but should be subject to tougher requirements on power supply eﬃciency and other environmental aspects. RECOMMENDATION: -‐ Remove (or )ghten) the exemp)on for high-‐
end notebooks at )er 2 (2016). -‐ Set )ghter power supply eﬃciency requirements for these high-‐end notebooks -‐ Set )ghter requirements for these notebooks on other environmental aspects 9 RECOMMENDATION: Reduce these limits by at least 20% From 1 January 2016: (a)  Category A computer: 26.00 (b)  Category B computer: 34.00 (c)  Category C computer: 56.00 RECOMMENDATION: Strongly reduce the graphic adder allowances in line with current performances (see levels proposed on slide 8) 10 These sleep mode limits are very high. As an illustra)on, they are almost twice as high as the highest sleep mode consump)on found in a sample of computers put on the market in 2011. With current technologies, it is possible to go much below these limits very easily. RECOMMENDATION: Reduce the power limits for sleep mode as such: -‐  2.50 W for desktop computers -‐  1.50 W for notebooks 11 Source: NRDC Requirements on power supply eﬃciency are indispensable and set at a credible level. They should be kept in the regula)on. RECOMMENDATION: -‐  Keep these requirements as they are. -‐  Add )ghter requirements for high-‐end computers that will be exempted from TEC limits: 88% eﬃciency at 50% load, and 85% at 20% and 100% load 12 Requirements on other environmental aspects are missing! Resource eﬃciency is a priority, that is supposed to be reﬂected in Ecodesign measures. A recent study provides again evidence that the manufacturing phase of computers – in par)cular notebooks – ooen casts a signiﬁcantly higher impact than the use phase. The study recommends that the focus of mandatory product policy should be expanded to measures related to possibili)es of hardware upgrading, modular construc)on, recycling-‐
friendly design, availability of spare parts, standardisa)on of components and minimum warranty periods (study by Öko-‐Ins)tut and Fraunhofer IZM for the German Federal Environment Agency, 2012 -‐
www.oeko.de/oekodoc/
1584/2012-‐440-‐en.pdf ). RECOMMENDATIONS: Add requirements on the following environmental aspects. They can take the form of informa.on requirements (by 2014) and limit values (by 2016): -‐ Measurement of the life-‐cycle energy/CO2 according to standardised methodologies -‐ Marking of plas)cs for recycling, with a target of 90% on the share of plas)cs that are eﬀec)vely ﬁt for available recycling streams. Ra)onalising the number of polymers. -‐ Increase use of recycled plas)cs. -‐ Target on maximum )me for manual disassembly and/or material separability, especially regarding circuit boards. -‐ Standardised presenta)on of the bill of material and disassembly instruc)ons for recyclers. -‐ Removal of hazardous content such as brominated ﬂame retardants, phtalates and beryllium. -‐ Requirement to provide extended warranty services, spare parts and sooware updates to extend the life-‐)me. -‐ Standardisa)on of power supply / baZery interfaces. These requirements could be supported by the use of relevant standards (IEC 62075, ECMA 370, IEEE 1680). 13 Ensuring the availability of informa)on on the performance of products put on the market is essen)al. We support informa)on requirements. However, as it is draoed, the requirement does not facilitate market monitoring and a large poten)al for using this informa)on is wasted. This is due to the fact that the informa)on will be provided in diverging formats on a mul)tude of websites. RECOMMENDATION: Change the ﬁrst sentence of point 7.1.1 into: ‘Manufacturers shall provide in the technical documenta)on, make publicly available on free-‐access websites, and upload on a centralised web system in a standardised format to be speciﬁed by the European Commission the following informa)on: (…)’ 14