G/TBT/W/699  
 
27 November 2019  
(19-8149) Page: 1/2 
Committee on Technical Barriers to Trade  Original: English  
 
EUROPEAN UNION - DRAFT COMMISSION REG ULATION LAYING DOWN ECO-DESIGN 
REQUIREMENTS FOR ELE CTRONIC DISPLAYS PUR SUANT TO DIRECTIVE 2 009/125/EC OF 
THE EUROPEAN PARLIAM ENT AND OF THE COUNC IL, AMENDING COMMISS ION 
REGULATION (EC) NO 1 275/2008 AND REPEALING COMMISSION  REGULATION (EC) 
642/2009 (AND ITS AC COMPANYING ANNEXES)  
STATEMENT BY ISRAEL TO THE COMMITTEE ON TECHNICAL BARRIERS T O TRADE  
13 – 15 NOVEMBER  2019 
The following communication, dated 13 November  2019, is being circulated at the request o f the 
delegation of Israel . 
 
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1.  Annex II of the new Eco -design Regulations for Electronic Displays was adopted by the 
Commission on 1 October this year. It imposes a new set of "material efficiency" requirements on 
covered electronic display s, effective early 2021. Under Point D, Paragraph 4 of Annex II, the use of 
halogenated flame -retardants, or HFRs, will be prohibited in the enclosures and stands of electronic 
displays.  
2.  Previously in this committee, Members raised their concern that the notified draft regulation 
allowed for the use of HFRs as long as the technical file accounted for them. But then, the final 
version of this regulation, bans HFRs from frames around televisions and from stands of displays. 
Members urged the EU to re -notify the measure to reflect the amended final requirements where it 
substantially departed from the text notified to the WTO in October 2018. One of these departures 
was the provision on HFRs. The EU did not re -notify and therefore provided no opportunity for t he 
International community to comment on this new provision.  
3.  Also raised previously, was the lack of an impact assessment and scientific base for the ban on 
HFRs. The EU published an impact assessment concurrently with the final regulation on the 1st of 
October. The impact assessment 's suggestion that elimination of the external candle flame presumes 
no fire risk, is flawed for the following reasons:  
• First, many displays still contain internal power supplies or could have external power 
supplies placed clo se to unprotected plastic casings by users when hanged or placed on 
stands;  
• Second, displays still contain internal electrical components that can fail and easily ignite 
non-protected plastic enclosures. This is especially true in modern thin walled units where 
these components are in much closer proximity to the casing; and  
• Finally, the act ignores compliance impacts on new fire safety standards specifically IEC 
62368 -1 ed3 which goes into effect in 2020.  
4.  While Israel understands the intent of the proposed measure for electronic displays, we believe 
that t he ban does not improve recyclability or that it fosters a move to a circular economy. At the 
same time, as described above, the measure may undermine consumer safety.  G/TBT/W/699  
 
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  5.  Israel raised these concerns  with the EU both bilaterally and in writing. Up until now no answer 
was received from the EU. We therefore  felt it necessary to reiterate our concerns as this measure 
will seriously impact the ability of our industry to conduct business in the EU market.  
6.  The measure was not appropriately notified to the WTO and no opportunity was afforded to 
Members to comment on provisions such as the ban of HFRs. The ban will negatively impact trade 
without a sound scientific base  and will undermine international produc t safety and performance.  
7.  Israel therefore urges the EU to notify the final regulation to the TBT Committee, to consider the 
comments received from WTO Members and to address these concerns by amending the regulation.  
 
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