G/TBT/W/616  
 
25 March 2019  
(19-1822) Page: 1/2 
Committee on Technical Barriers to Trade  Original: English  
 
EUROPEAN UNION - DRAFT COMMISSION REGULA TION LAYING DOWN ECO -DESIGN 
REQUIREMENTS FOR ELE CTRONIC DISPLAYS PUR SUANT TO DIRECTIVE 2 009/125/EC  
OF THE EUROPEAN PARL IAMENT AND OF THE CO UNCIL, AMENDING COMM ISSION 
REGULATION (EC) NO 1 275/2008 AND REPEALI NG COMMISSION REGULA TION  
(EC) 642/2009 (AND I TS ACCOMPANYING ANNE XES) " 
STATEMENT BY CHINA  TO THE COMMITTEE ON TECHNICAL BARRIERS T O TRADE  
6 AND 7  MARCH 2019 
The following communication, dated 25 March 2019 , is being circulated at the request of the 
delegation of China . 
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1.  After the comment period, the European Commission  revise d regulation and announced new 
version on 8  February 2019.  
2.  Compared with the original one , the new version is much stricter and add s several new 
requirements. For example : 
(1) The coverage  is expanded. Some  products that had been exempted are put back again . 
For example, the "Status Display and Control Panel " which was exempted in the 
G/TBT/N/EU/609 notification, was re -incorporated in the new version. Secondly, the 
requirement  is not clear enough. For the display  which is installed on equipment and 
which has been exempted  according to  the ErP Directive Execution R egulations, it's not 
clear whether it needs to fulfil the requirements ?  
(2)  Energy efficiency requirements are still too strict. The new version fix es parameter 
selection on 10 when calculating EEI value  of OLED display , it's too strict for trade.   
(3)  New requirements  for Halogenated flame retardants were established . The use of 
halogenated flame retardants is not allowed in the enclosure and stand of electronic 
displays in The New Version Annex II D part of "materials efficiency". This regulation is 
not only higher than the requirements of the RoHS directive, but also not clearly 
described. Without specifying the type and content of the flame retardant, it may 
confuse  the manufacturers.  
(4)  New r equirements of the maximum delivery time limit for  spare  parts were added. 
Availability and the maximum delivery time of spare parts were added in part D of 
appendix II of the New Version. It stipulates that spare parts such as external power 
supply and remote control shall be provided for at least seven years after the last 
product of this model is put on the market, and requires the manufacturer, importer or 
authorized representative to deliver spare parts of electronic display within 15 working 
days after receiving the request . For manufacturers outside the E U, taking into account 
the impact of customs clearance and transport time, the requirement of 15 working 
days for the delivery of spare parts is not practical.  
3.  Concern : Since  the new version of the Draft Regulation has been substantially  modified, many 
new requirements were established, we suggest EU to notify such new requirements to WTO once 
again and provide other Member s the opportunity for comment.  G/TBT/W/616  
 
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  4.  Second, we suggest  to further lower  the requirements for EEI limit value of OLED displays, and 
consider  cancel ling requirements which are too strict for trade, such as the provisions regarding 
halogenated flame retardants . 
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