G/TBT/W/651  
 
16 July 2019  
(19-4728) Page: 1/2 
Committee on Technical Barriers to Trade  Original: English  
 
EUROPEAN UNION - CONCERNS ON REGULATIONS  WITH REGARD TO ECO -DESIGN 
REQUIREMENTS FOR VAR IOUS PRODUCTS IN EU  
STATEMENT BY CHINA TO THE COMMITTEE ON TECHNICAL BARRIER S TO TRADE  
20 AND 21 JUNE 2019  
The following communication, dated 15 July 2019, is being circulated at the request of the delegation 
of China. 
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We noticed that the EU issued a number of eco -design regulations on servers and data storage 
products, washing machines, washer dryers . These Requirements stipulate the e cological design 
requirements, conformity assessment and market supervision verification procedures for related 
products.  
We appreciate the EU's efforts in ecological protection. But we have the following concerns : 
1  CONCERNS ON COMMISSI ON REGULATION LAYING  DOWN ECO -DESIGN 
REQUIREMENTS FOR HOU SEHOLD WASHING MACHI NES AND HOUSEHOLD WA SHER -
DRYERS  (G/TBT/N/EU/615 ) 
There are significant uncertainties in the scope of products subject to the regulations. And some 
terms will cause misunderstanding thereby unnecessary obstacles to trade. We hope that the EU 
will: 
a. clarify whether the was hing machines without heating function are subject to the 
eco-design requirements .  
b. cancel requirement of Maximum delivery time of necessary spare parts  (it stipulate s the 
manufacturer or importer shall deliver the necessary spare parts for household washi ng 
machines and household washer -dryers to professional repairers within 15 working days 
after having received the order. We think spare parts delivery is a commercial concern, 
and it should be adjusted by market demand. 15 days is impossible for overseas 
manufacturers, that will cause unnecessary cost for trade thereby barrier to trade) .  
c.  re-adjust the formula of EEI .  
2  CONCERNS ON COMMISSI ON REGULATION LAYING  DOWN ECO -DESIGN 
REQUIREMENTS FOR HOU SEHOLD DISHWASHERS  (G/TBT/N/EU/611 ) 
We hope that the EU will clarify whether the eco -design requirements and specific applicable 
methods are applicable to the dishwashers without drying function. It is strongly recommended that 
the EU cancel the time limit requirement for the delivery of necessary spare parts and extend the 
transition period for the effective date of the regulations.  G/TBT/W/651  
 
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  3  CONCERNS ON THE "DRAFT COMMISSION REG ULATION LAYING DOWN ECO-DESIGN 
REQUIREMENTS FOR LIG HT SOURCES  (G/TBT/N/EU/606 )" AND "REGARD TO THE 
ENERGY LABELLING OF LIGHT SOURCES (G/TBT/N/EU/607 )" 
The test methods for some parameters in the regulations  are inconsistent with international 
standards, and it is even missing. Some clauses are beyond the limits necessary to achieve 
legitimate goals. We hope that the EU can:  
a. clarify whether the test method for lumen maintenance rate can adopt the internation al 
standard test method (IEC 62612) ; 
b. give clear and definite test method for the scintillation flicker level (Pst LM) and the 
stroboscopic effect visibility (SVM);  
c. adjust the light source energy efficiency rating table ; and  
d. extend the transition period t o avoid unnecessary impact on trade.  
4  CONCERN ON G/TBT/N/EU/581  - COMMIS SION REGULATION 2019 /424 LAYING DOWN 
ECO-DESIGN REQUIREMENTS FOR SERVERS AND DATA  STORAGE PRODUCTS PU RSUANT 
TO DIRECTIVE 2009/12 5/EC OF THE EUROPEAN  PARLIAMENT AND OF T HE COUNCIL AND 
AMENDING COMMISSION REGULATION (EU) NO 6 17/2013.  
We want to make the fol lowing suggestions:  
a. Based on the text of 2009/125/EC (3), it is suggested that the EU delete Annex 1 (12)  (e), 
i.e. the requirement of "having the same number of available processor sockets and 
number of available processor sockets populated" in the defini tion of "server product 
family ". 
b. Based on the principle of harmonization with market demand, it is suggested that the 
verification procedure on a randomly selected or ordered model configuration for market 
surveillance purposes be consistent with the eco -design requirements (Annexes II 2.1 
and 2.2). 
c. The regulation requires manufacturers to provide product information when the server -
related products are put on the market. It is suggested that the EU clarify that electronic 
manuals in the form of website links, QR codes, electronic CD -ROMs, etc., can be taken 
as the attached information carriers for environmental protection considerations.  
 
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