G/TBT/W/694  
 
26 November 2019  
(19-8080) Page: 1/2 
Committee on Technical Barriers to Trade  Original: English  
 
 EU REGULATION ON ECOLOGICAL  DESIGN REQUIREMENTS  FOR EXTERNAL POWER 
SUPPLY  
STATEMENT BY CHINA 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 of the 
delegation of China . 
 
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1  BACKGROUND  
1.1.  On 5 October 2018, the European Union issued the technical and trade measures notice 
(G/TBT/N/EU/605)  of the regulations on ecological design of external power supply, which increased 
the disclosure information and test requirements of external power supply products, and improved 
energy consumption performance indicators.   
1.2.  On 1 October 2019, the EU review ed and approved the final amendment, and issued the official 
journal (OJ) on 25 October, which is scheduled to enter into force on 14 November . Compared with 
the original version, the revised version added new requirements such as output voltage, output 
current and output power on the product nameplate. At the same time, the transition period provided 
for manufacturers is insufficient.  
2   CONCERNS  
2.1.  Cancel the mandatory requirement to place "output power" on the nameplate . The notifi cation  
(has no mandatory req uirement for putting output power on nameplate , which  only requires the 
information of output power to be written in user's manual and manufacturer's website. However, 
the revised  version stipulates the output powers shall be placed on the product nameplat e. We don't 
think it is necessary to mark the output power on the nameplate for the following reasons:  
• IEC standards related to external power supply, such as IEC 60950, have required to mark 
the output voltage and current on the nameplate, but there is no  mandatory requirement for 
the output power. And output power could be calculated through output voltage multiply by 
output current (output power = output voltage * output current). When the output voltage 
and output current have been marked, the output po wer can be easily obtained, and it is not 
necessary to mark the output power redundantly.  
• The external power supply of some consumer products is quite small in size, and it is difficult 
to add too much information on the nameplate (especially for the exter nal power supply with 
multiple outputs).  
• According to the current operation of the external power industry, most of the nameplates do 
not provide output power information. The sudden change may remove most of the existing 
products.  
2.2.  We believe that this req uirement violates the principle of minimizing trade restrictions in 
Article  2.2 of the TBT Agreement.  G/TBT/W/694  
 
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  2.3.  Extension of the transitional period of the Regulations, it's suggested that  the EU provide a 
transition period of one year after the formal promulgation of the Regulations . The final version was 
published on  25 October 2019 and will be applied on 1 April 2020. The transitional period of the 
regulation is less than six months. The manufacturer needs to carry out technical improvement to 
meet the new requirements, adjust specifications, prepare technical documents and carry out testing 
and certification, but the new testing Standards have not been published. Such short t ransitional 
period makes great difficulties to manufacturers, which does not meet the requirement of Article 
2.12 of the TBT Agreement that "Members should set a reasonable time interval between the 
publication and entry into force of technical regulations ". In this regard, it is suggested that the 
transition period should be at least one year after the formal promulgation of the Regulations. At 
the same time, relevant implementing standards should be published as soon as possible.  
 
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