Comments of EU experts on the revision of Energy criteria for

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Framework documents on the revision of the Energy Star specifications for than that required for Japanese and European EMC conformance should be avoided

EU Comments on the revision of the Energy Star criteria for

    computers and imaging equipment (20 September 2005)

Representatives of the US EPA and the EU Commission have discussed the revision of the

    Energy Star qualifying product criteria for computers and imaging equipment during a

    telephone conference on 14 August 2005. The discussion was based on the following


    ? Framework documents on the revision of the Energy Star specifications for computers

    dated August 17, 2005;

    ? Draft 1 Energy Star specifications (Version 1.0) for imaging equipment product dated

    August 10, 2005;

    ? Energy Star qualified imaging equipment, final draft test procedure operational mode

    approach dated August 31, 2005;

    ? Test conditions and equipment for determining the Energy Star qualification status of

    imaging equipment products dated August 31, 2005.

Regarding the revision of criteria for Energy Star qualifying computers, the Commission has

    expressed during the telephone conference that the following aspects are considered as being


    ? ambitious criterion for power supply efficiency is very important (80+ initiative) for

    first tier of new computer specifications;

    ? inclusion of criterion for idle-on mode (good approximation of on-mode energy

    consumption in common circumstances) is very important for first tier of new

    computer specifications (some of EU experts contribute to the development of a test

    method for idle-on mode);

    ? an allowance for wake on LAN functionality is acceptable since power management

    enabling rates are expected to be improved by wake on LAN;

    ? two product categories are adequate (desktop and notebook).

Regarding the revision of criteria for Energy Star qualifying imaging equipment, the

    Commission has expressed during the telephone conference that the following aspects are

    considered as being crucial:

    ? the number of criteria tables seems large and should be condensed;

    ? the method for defining criteria for ink jet printers according to functionality is not

    consistent with the remainder of the criteria and should together with the dropping of

    the standard test pattern be reconsidered;

    ? the dropping of the ready mode in the OM method although being foreseen to be

    measured should be reconsidered.

Before the telephone conference the Commission had asked European experts for comments

    on the documents listed above. The list of EU experts’ comments is given in the annex below

    for consideration.

    - 1 -

Annex: List of EU experts’ comments

The following list contains the input received from several EU member states and the chip

    manufacturer AMD Europe. Not all comments are shared by all of the parties having

    submitted input


Definition of qualifying products

    ? it is almost impossible to define the various product groups without overlap, i.e.

    desktop, desktop-derived servers and workstations form a continuous scale

    ? products on the market are subject to rapid innovation, therefore rigid categories may

    be problematic

    ? in particular: suggestion that workstations and desktops can be differentiated by

    specification is likely to introduce lengthy arguments

    ? therefore: two definitions are sufficient, one for notebooks and one for desktops

    including desktop derived servers and workstations

    ? notebook PCs should not be categorised by the power supply configuration which may

    be internal or external (as for all other PCs, there are examples of desktop PCs with

    external power supplies and notebooks with internal ones)

    ? clarification and consideration of thin clients as being part of the desktop computers

    would be appreciated

Hardware requirements

    ? requirements on power supply efficiency is key for energy savings (average savings

    potential estimated to be larger than 16%)

    ? one set of requirements for all internal power supplies

    ? test procedure for 80+ power supplies changed between 2003(version 1) and

    2005(version 5) to give the internal power supply rail loading levels quoted by EPA

    (although the 10% level is not included)

    ? rationale for this change would be appreciated

    ? large database of UK test results shows that the critical (extended period) efficiency

    performance area of the power supply is on-idle, so that the loading region 25% to

    50% is likely to be the most pertinent for efficiency testing

    ? therefore the original loading values of 25% 50% 75% and 100% seem adequate

    unless evidence would justify the change

    ? concerns of manufacturers regarding due availability of power supplies meeting the


    ? introduction of a power factor criterion that is being better than that required for

    Japanese and European EMC conformance should be avoided

    ? supply manufacturers have indicated at meetings of the EU Code of Conduct on

    external power supplies that an 80+ criterion is commercially feasible without

    referring to power factor conformance

    ? the significant energy efficiency advantage of 80+ must not be held up for Tier 1 on a

    power factor debate

On-idle state

    ? on-idle state levels have to be included in Tier 1 specification

    - 2 -

? new speed step processors' lower consumption levels should be taken into

    consideration when deciding the levels

    ? UK can provide an on-idle test procedure that consistently generates an on-idle value

    totally representative of the PC (including notebooks) average power requirement in

    normal office operations (word processing, spreadsheet manipulation, email etc.)

    ? relatively large UK test results database is available to support this for a wide

    specification range of PCs and notebooks

    ? Denmark has experiences on the idle mode test procedure from the Voluntary

    Agreement on computers with manufacturers

    ? Results of UK and Denmark possibly easily support on-idle conformance criteria for

    Tier 1

    ? UK test results show that the criteria may be significantly different to current EPA


    ? results may be forwarded to EPA for consideration

    ? a clarification of the term “other software” in the idle state definition would be


    ? suggestion: the machine is started with the operating system as shipped; in case of no

    operating system being installed, the machine should be tested with the operating

    system recommended by the manufacturer

    Sleep mode

    ? should not be the lowest level but rather the level after a certain time span since the

    lowest sleep level will be save to disk and the consumption typically corresponds to

    the soft off mode.

    ? integrated computers may meet the same levels as desktop computers, both in sleep

    and in off mode

    Standby mode

    ? reference is made to the IEC 62301 standard on the measurement of standby power

    ? “standby” definition of this standard may be confusing, because it is rather a

    “description of a situation” that can occur in various modes (note: IEC 62301 was

    developed for household appliances like washing machines)

    ? for comparison: Draft 1 Imaging Equipment (lines 297-300) states that “Standby (as

    defined in IEC 62301) usually occurs in off mode, however may occur in ready, sleep

    or hard off

    ? suggestion: wordings of the standard are not used for the definitions of the modes

    o modes should be defined according to the needs of the product group (as in the

    imaging equipment draft), i.e. off mode definition of imaging equipment can

    also be used for computers

    o if - besides that - the standby definition from the standard is needed this should

    be clearly noted

    On-modes other then on-idle

    ? energy efficiency index (EEI) concept based on the performance(index) of the

    machine and the energy or power consumption related to that index may be useful

    ? for the sake of not holding up the process, a possible EEI may be considered for Tier 2

    Wake on LAN (WOL)

    ? WOL particularly relevant due to the growing use of wireless LANs

    - 3 -

    ? concerns of manufacturers on possible requirement for an additional power allowance

    for the deeper sleep modes to support WOL

    ? test data input and liaison with Industry on this matter must be a priority since the

    inability of a PC to provide WOL without compromising work patterns is the primary

    cause of the disablement of power management

    ? disputes on amount of possible additional power allowance for WOL should not delay

    the criteria setting process since power management enabling is key to energy savings

    Imaging Equipment

    Draft 1 Specification

    ? requirements should be condensed into a lower amount of tables ? if a certain technology is more efficient and the most important functional

    requirements have been taken into account (speed) then Energy Star should favour this

    technology unless it is a proprietary technology of one manufacturer only ? the rationale and supporting data for not including requirement on the ready mode in

    the conformance criteria even though it is measured in the OM procedure would be


    ? OM Table 1: it may be possible to design products with network connectivity

    consuming not more than 1 W in standby (as is the case with fax machines). ? suggestion: keep the requirement for non network use (so the product must be tested

    without connection to a network - even if a network card is present) and add an

    allowance for the situation where the network card is connected. ? OM Table 2: the rationale for basing requirements for inkjet printers on functionality

    would be appreciated

    ? for consistency with the other products the Energy Star product speed approach seems

    the most appropriate

    Test procedure

    ? the rationale and supporting data for dropping a standard test pattern from the OM

    requirement would be appreciated

    ? a standard test pattern may be useful to avoid misunderstandings in debated

    conformance results

    Test conditions

    ? the rationale for requiring a more stringent AC line supply harmonic content than the

    IEC 62301 standard would be appreciated

    ? the harmonic content critically affects low standby power measurements and the IEC

    standard is in place for precisely such measurements

    ? given that the difference between the IEC standard and the test conditions is that

    between the statement 2% and the statement less than or equal to 2%, this seems an

    unnecessary qualification.

    - 4 -

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