EN    EN  
 EUROPEAN  
COMMISSION 
Brussels, 22.4.2015  
SWD(2015) 89 final 
  
COMMISSION STAFF WORKING DOCUMENT 
IMPACT ASSESSMENT 
Accompanying the document  
Report from the Commission to the European Parliament and the Council on the 
voluntray ecodesign scheme for games consoles 
{COM(2015) 178 final} 
{SWD(2015) 88 final}  
 
EN 1   EN TABLE OF CONTENTS 
1. PROCEDURAL ISSUES AND CONSULTATION ................................................... 6 
1.1. Introduction.............................................................................................................. .... 6 
1.2. Organisation and timing............................................................................................... 6 1.3. Consultation process .................................................................................................... 7 2. PROBLEM DEFINITION ........................................................................................... 8 2.1. Introduction.............................................................................................................. .... 8 
2.2. Product scope ............................................................................................................. .. 8 
2.3. Market failures ........................................................................................................... .. 8 
2.4. Related initiatives at European Union and Member State levels................................. 9 
2.5. Legal basis for EU action........................................................................................... 10 2.6. Who is affected by ecodesign requirements and how? .............................................. 10 2.7. Market Situation for Sound and Imaging Equipment ................................................ 10 2.8. Baseline scenario........................................................................................................ 1 0 
2.9. Improvement Potential............................................................................................... 12 3. OBJECTIVES ............................................................................................................ 12 4. POLICY OPTIONS ................................................................................................... 13 4.1. Game Console Policy Options ................................................................................... 13 4.1.1. Option 1: No new EU action/ Baseline...................................................................... 13 4.1.2. Option 2: Industry Proposal – Self-Regulation.......................................................... 13 4.1.3. Option 3: Mandatory ecodesign requirements ........................................................... 14 4.1.4. Option 4: Mandatory energy labelling ....................................................................... 15 4.1.5. Further Discarded Options ......................................................................................... 16 4.1.6. Summary and level of ambition of the game console options ................................... 17 4.2. Video Players/ Recorders Policy Options.................................................................. 17 4.2.1. Option 1: No new EU action/ Baseline...................................................................... 17 4.2.2. Option 2: Self-regulation via a voluntary agreement................................................. 18 4.2.3. Option 3: Mandatory Ecodesign requirements .......................................................... 18 4.2.4. Option 4: Mandatory energy labelling ....................................................................... 18 4.2.5. Option 5: EU ENERGY STAR coverage .................................................................. 19 4.2.6. Summary of the Video Players/  Recorders Policy Options ....................................... 19 
4.3. Projector Policy Options ............................................................................................ 19 4.3.1. Option 1: No new EU action/Baseline....................................................................... 19 4.3.2. Option 2: Self-regulation via voluntary agreement.................................................... 19 4.3.3. Option 3: Mandatory Ecodesign requirements .......................................................... 19 
 
EN 2   EN 4.3.4. Option 4: Mandatory energy labelling ....................................................................... 20 
4.3.5. Summary of the Projectors Policy Options................................................................ 20 5. IMPACT ANALYSIS................................................................................................ 20 5.1. Economic impact........................................................................................................ 21 5.1.1. Impact on Industry in general .................................................................................... 21 5.1.2. Costs related to assessment of conformity/ compliance costs ................................... 22 5.1.3. Administrative costs for Member States.................................................................... 23 
5.1.4. Impacts on trade a nd competitiveness ....................................................................... 23 
5.1.5. Impacts on innovation................................................................................................ 24 5.1.6. Costs for SMEs .......................................................................................................... 24 
5.2. Reporting and verification ......................................................................................... 25 5.3. Social Impacts ............................................................................................................ 25 
5.3.1. Impacts on jobs ......................................................................................................... . 25 
5.3.2. Affordability of equipment ........................................................................................ 25 5.3.3. Impact on the functionality of equipment .................................................................. 25 5.4. Environmental Impacts .............................................................................................. 25 5.4.1. Annual energy consumption ...................................................................................... 25 5.4.2. Annual CO2 emission savings ................................................................................... 29 5.4.3. Accumulated electric ity cost savings......................................................................... 30 
5.4.4. Non Energy-in-use Impacts........................................................................................ 32 6. COMPARISON OF THE POLICY OPTIONS ......................................................... 32 6.1. Summary of quantified impacts ................................................................................. 32 6.2. Multi-criteria analysis ................................................................................................ 33 6.3. Comparison of game consoles options....................................................................... 35 7. CONCLUSIONS........................................................................................................ 36 8. MONITORING AND EVALUATION ..................................................................... 37 
9. Annexes..................................................................................................................... . 39 
9.1. Annex I - Summary Public Consultation ................................................................... 39 9.2. Annex II - Minutes Consultation Forum.................................................................... 41 9.3. Annex III – Product scope description....................................................................... 50 9.4. Annex IV - Market Situation for Sound and Imaging Group .................................... 51 9.5. Annex V – Stock developments of the 3 individual products groups........................ 53 
9.6. Annex VI - Assumptions............................................................................................ 55 9.7. Annex VII – Improvement Potential.......................................................................... 57 
 
EN 3   EN  
Executive Summary Sheet  
Impact assessment on Sound and Imaging Equipment including a voluntary ecodesign scheme for game 
consoles  
A. Need for action  
Why? What is the problem being addressed?  
 “Sound and imaging equipment" has been identified as a candidate product group for possible Ecodesign 
measures in the Ecodesign Working Plan 2008-2011. The main problem is that game consoles, video players/ 
recorders and projectors can improve their environmental performance, but that  the market penetration of energy 
efficient products is lower than it could be.  
The manufacturers of games consoles have proposed a self-regulatory initiative. The key question for this 
impact assessment is whether the current trends of increasi ng energy efficiency in this product group need to be 
backed up by a voluntary agreement as an alternative to  a regulatory intervention. The question of whether 
introducing mandatory ecodesign and/or energy labelli ng measures are merited is posed for all products 
considered.  
 
What is this initiative expected to achieve?  
 
The initiative should contribute to the achievement of the EU 20/20/20 targets, and specifically to reduce the 
EU’s energy consumption. Regulatory and/or self-regul atory measures under the Ecodesign regime must 
improve the environmental performance of products with  regard to their whole lif e cycle. Sound and imaging 
equipment are energy-using products, which currently co nsume around 8.5TWh electricity per year. The most 
appropriate options on how to improve environmental performance and to reduce energy consumption have 
been explored. 
 
What is the value added of action at the EU level?   
In the absence of harmonised requirements at EU level,  regulations at national level would create regulatory 
obstacles to the free movement of such goods within the internal market. The objective of measures under the 
Ecodesign Directive is to ensure the functioning of t he internal market by requiring products to reach an 
adequate level of environmental perfor mance, which cannot be sufficiently achieved by the Member States 
acting individually. Therefore measures for sound and audio equipment could be adopted. 
 
B. Solutions  
What legislative and non-legislative policy options have been considered?  Is there a preferred 
choice or not? Why?  
The following legislative and non-legi slative measures have been considered: 
- No EU action - Self-Regulation (Voluntary Agreem ent under the Ecodesign Directive) 
- Ecodesign Implementing Measures 
- Energy Labelling Measures 
For game consoles, the impact assessment identified self -regulation as a preferred opt ion, provided that some 
mitigating measures to minimise risks are considered. Se lf-regulation should be given priority where such action 
is likely to deliver the policy objectives faster, or in a le ss costly manner, especially  in markets that are changing 
rapidly. Where the conditions for a self-regulation are not met, or where the level of ambition proposed by the 
signatories is not adhered to, or if the process is unju stifiably delayed, the second preferred options would be 
joint mandatory energy labelling/ecodesign measures.  
For video-players/ recorders and projectors, the market analysis has shown that the market for product groups 
will gradually decline.. Their electricity consumption is decreasing steadily. The analys is shows that there are 
little environmental benefits from any of the policy options , which gives little weight to the argument of pursuing 
anything other than the BAU scenario. The preferred option is therefore no action. 
 
Who supports which option?  
A public consultation took place during the preparatory st udy phase, and recently on the self-regulatory initiative 
 
EN 4   EN plus other regulatory options, including a public survey  in autumn 2012, and the Ecodesign Consultation Forum 
on 9 November 2012.  
Many stakeholders suppor ted the initiative by the console industry. The overall opinion from Member States was 
rather reserved as to whether it would be worthwhile  to endorse a voluntary agreement, and Member States 
overall concluded that the proposed level of ambition should be raised. Environmental and Consumer NGOs 
supported regulation, rather than a voluntary agreement solution.  
Concerning video recorders/players and projectors, most stakeholders preferred 'no ac tion', provided that market 
data would support it. 
 
 
 
C. Impacts of the preferred option  
What are the benefits  of the preferred option (if any, otherwise main ones)?   
 
The preferred option will provide annu al energy savings of 1 TWh already by 2020, increasing to 1.1 TWh by 
2025. Consumers will profit from reduced electricity cons umption. The annual electricity savings will be around 
200 Million Euros. Environment and the climate will also benefit, as the resulting CO2 savings will be 0.45 
Mt/year.  
Within a self-regulatory initiative, manufacturers themselv es are the drivers and will also benefit. Other benefits 
or costs are considered to be negligible.   
What are the costs of the preferred option (if any, otherwise main ones)?   
 
The preferred option will not incur high additional costs as manufacturers themselves have already factored in 
the changes needed in their production plans, minimi sing the detrimental impacts and downtime costs.  
As none of the manufacturers is based in the EU, no signi ficant direct negative impa cts in economic, social or 
environmental areas are expected. 
  
How will businesses, SMEs and mi cro-enterprises be affected?  
SMEs and micro-enterprises will not be affected. The pr oducts in scope are not manufactured in the EU.  
Will there be significant impacts  on national budgets and administrations?   
No. 
 
Will there be other significant impacts?   
No other significant impacts are expe cted. The endorsement of a voluntary agreement in the EU may encourage 
similar self-regulatory processes in other jurisdictions (US, Australia) 
 
D. Follow up  
When will the policy be reviewed?  
A review by the end of 2017 is built-in the voluntary ag reement on games consoles. The Commission will closely 
monitor the implementation of the voluntary agreement.  
 
 
 
 
EN 5   EN  
Report from the Commission to the European Parliament and the Council on the 
voluntray ecodesign scheme for games consoles 
 
EN 6   EN 1. PROCEDURAL  ISSUES  AND  CONSULTATION   
1.1. Introduction 
The Directive 2009/125/EC of the European Pa rliament and of the Council establishing a 
framework for the Commission to set ecodesi gn requirements for energy-related products 
([ErP], hereafter referred to as the Ecodesign Directive)1 is to be implemented by the 
European Commission through regulations or self-regulati ons for the product groups 
identified in the relevant Ecodesign Working Pl ans. A product, or a group of products, shall 
be covered by ecodesign implementing measures or  by self-regulation (viz. criteria in Article 
19, Ecodesign Directive), if the ErP represents indicatively significant sales volumes, while 
having a significant environmental impact a nd significant improvement potential (Article 15, 
Ecodesign Directive). The impacts of potential po licy measures are assessed in line with the 
requirements of the Ecodesign Directive, toge ther with possible measures under the Energy 
Labelling Directive 2010/30/EC2.  
Compared to other Ecodesign Re gulations the energy savings pot ential of this product group 
is relatively moderate. .For sound and imag ing equipment energy savings amount to around 
2.5 TWh per year; this compares  to 215 TWh per year for the Ecodesign Regulation on Space 
Heaters, and 16 TWh per year for the Ecode sign Regulation on Comput ers.. The analysis 
presented in the report is c onsidered proportionate to these anticipated impact magnitudes. 
A special feature of this impact assessment is that it also assesses whether an industry 
proposal for self-regulation can  be considered as an al ternative policy measure.  
1.2. Organisation and timing 
The Ecodesign Working Plan for 2009-2011 iden tified "sound and imaging equipment" as 
one of the ten priority product groups. The Commission carried out a technical, environmental 
and economic analysis in preparation for these poten tial initiatives, hereafter referred to as the 
preparatory study3. Stakeholder consultation meetings were organised in the Commission's 
premises in Brussels on 2 April 2009, 18 December 2009 and 14 June 2010 to discuss the 
preliminary results of the preparatory st udy. The study identified three product subgroups: 
video players and recorders, projectors, and ga me consoles, and concluded in 2010 that these 
products met the criteria of Article 15 of th e Ecodesign Directive. The product groups present 
a significant volume of sales on the market, they have a significant environmental impact and 
energy consumption, and present a signi ficant potential for improvements. 
An Impact Assessment study for “sound and imag ing equipment” was carried out from March 
2012 to March 2013, providing the European Co mmission with technical and economic 
background.  
After several meetings between the Commi ssion and the manufacturers of game consoles4, the 
manufacturers presented in August 2012 a draft self-regulation measure,  i.e., an industry 
proposal for a voluntary course of action.  
From early October 2012 the Commission held a public consultation exercise, and the official 
Ecodesign Consultation process, concerning possible regulations, includi ng the proposed self-
regulation. Comments were received up to and including February 2013. The full text of the 
industry proposal and the public surv ey documents are available on: 
http://ec.europa.eu/enterprise/polic ies/sustainable-business/ ecodesign/product-groups/sound-imaging/index_en.htm .  
                                                 
1 OJ L 285, 31.10.2009 
2 OJ L 153, 18.06.2010 
3 See http://www.ecomultimedia.org/ 
4 The last meeting took place on 19 June 2012 in Brussels between the Commission and Microsoft, 
Nintendo, and Sony.  
 
EN 7   EN A draft Impact Assessment was submitted to the Impact Assessment Board on 29 April 2013. 
The present document takes into account th e recommendations by the Board, mainly 
regarding the presentation and co mparison of the options. In particular, a revised version of 
the Voluntary Agreement was submitted by i ndustry in November 2014 which has been 
considered acceptable by the different Commission services, as reflected in the associated 
inter-service consultation5.  
1.3. Consultation process 
Stakeholder insights on sound and imaging pr oducts were previously gathered via the 
preparatory study, which included a dedicated  website, taking into account input from 
relevant stakeholders including manufacturers and their associations, environmental NGOs, 
consumer organizations, EU Member State e xperts, experts from third countries and 
international organizations for e.g. th e International Energy Agency (IEA).  
As part of a further Impact Assessment (IA ) study providing techni cal assistance from 
external consultants6, a specific public Stakeholder Consultation exercise on the actual draft 
self-regulation for game consoles was carried out in autumn 2012. Stakeholders were invited 
to comment on individual product surveys and draft findings of th e IA, including policy 
options for the three 'sound and imaging' product groups.  
The Ecodesign Consultation Forum  met on 9 November 2012. It is the key consultation tool 
for all considered Ecodesign implementing measures ; it is foreseen in Art. 18 of the Directive 
and provides for a procedure of recognition of candidates for particip ation that ensures a 
balanced representation of inte rests. Comments from Member States and stakeholders were 
received up to and including February 2013.  
In summary, the Member States  welcomed the initiative by c onsoles manufacturers, but its 
opinion was rather reserved whether it would be worthwhile to endorse the proposal as 
voluntary agreement under the Ecodesign Directive, on account of the energy saving potential at 1 TWh/y, which was found to be insufficient. NGOs indicated that in general regulation is 
preferable over self-regulat ion. An influential report by th e US based National Resources 
Defense Council on the energy c onsumption of games consoles
7 was discussed with 
manufacturers and led to some changes in their self-regulatory inititiave. Industry  was, 
naturally, supportive of the industr y proposed approach and levels. On video players/recorders 
and projectors, there was general agreement in the consultation of a do wnward trend in the 
video recorder/player market overall, and that  respondents preferred th e policy route of no 
action.  
The results of the public consultation are su mmarised in Annex I. The minutes of the 
Consultation Forum, the discussion document, and a short summary of the written comments 
received can be found in Annex II. 
Internal consultation: All relevant Commi ssion services (ENER, ENTR, ENV, CNECT, 
SANCO, CLIMA, COMP, SG, and TRADE) were  consulted on drafts and relevant 
documents. Impact Assessment Steering Group Meetings concerning this product group took 
place on 23 February 2012, 7 November 2012, and 22 February 2013. At the last meeting, the 
Impact Assessment Steering Group was cons ulted on a final draft of this IA.  
                                                 
5 See consultation Ares(2014)2108118 de la DG GROW 
6 Ricardo-AEA with RPA, PE International, Intertek 
7 http://www.nrdc.org/energy /game-consoles/files/video-game-consoles-IP.pdf 
 
EN 8   EN 2. PROBLEM  DEFINITION 
2.1. Introduction 
The underlying problem, determined by the pr eparatory and the IA studies, can be 
summarised in the following way: cost-effective and ener gy efficient technologies for 
efficient equipment and technical solutions exist within the sound  and imaging product 
market, but their market penetration is lowe r than it could be. The dominant aspect for 
improving the environmental performance of sound and imaging equipment is the energy 
consumption, and therefore the ecodesign propos als within this assessment focus on this 
aspect. 
2.2. Product scope 
The product scope was well defined in th e preparatory study, covering three product 
subgroups: video players and record ers, projectors, and game cons oles. A short description of 
the three individual product groups , including trends, can be found in Annex III. As for other 
electronic equipment, such products are and will  be subject to quick technology developments 
and market changes, i.e. due to chan ges in data storage and transmission. 
The key question for this report is whether the current trends of increasing energy efficiency 
considering the increasing performance of c onsoles should be backed up by a voluntary 
agreement, or whether there is a need for introducing mandatory ecodesign or energy labelling measures.  
2.3. Market failures 
Barriers to the market uptake of more efficien t sound and imaging products are largely due to 
the following market failures: 
PROBLEM DRIVER 
Market prices for 
electricity do not reflect the real costs and benefits to society ('externalities') Not all environmental costs are in cluded in electricity prices – 
therefore consumer (and producer) c hoices that are made on the basis 
of lower electricity prices do not reflect the environmental costs to society, meaning less than optimal social welfare may result.  
Information failure - incomplete information on running costs/ cost savings  Information on running costs/cost sa vings can be obtained only with 
difficulty. Power demands of co mputing components are closely 
correlated to levels of computi ng performance. The higher power 
demanding products provide signifi cantly more processing power 
and therefore require more power to deliver the higher level of 
gaming functionality. Generally, ther e is little awareness of the 
energy consumption and the associated costs.  
Efficient products carry a substantial additional price, which is not enforceable on the market Energy consumption is not a decisive factor for purchasing 
decisions. For projectors, whilst more efficient lamp systems exist or are in development ( e.g. LED/Laser ) that could result in a step change in product energy efficien cy, these most efficient lamp 
systems would require an increa se in product price that is 
disproportionate to the cost of ener gy that would be  saved during the 
lifetime of the product. Typically a modulated mercury vapour lamp 
system will be three times as expensive to buy as the metal halide or halogen discharge lamps they repl ace (e.g. 330Euros as opposed to 
 
EN 9   EN 108 Euros for a schools or office conference room projector). For 
games consoles the key purchase dr iver is functionality (gaming 
experience) rather than environmen tal performance. Therefore, there 
are insufficient drivers to support such a step change in energy efficiency, and insufficient incentives exist for manufacturers to optimise the environmental perf ormance of sound and imaging 
equipment.  
Table 1: Market failures 
The consequences of these problems are that innovation is not sufficiently encouraged, and 
that energy costs are higher th an economically necessary. In conclusion, there is an untapped 
potential for this product group to contribu te to achieve the Europe 2020 targets.  
2.4. Related initiatives at European  Union and Member State levels 
EU-level initiatives aiming to improve the environmental impact of products include 
legislation on standby/off-mode power cons umption (Commission Regulation (EC) No 
1275/2008), and on the power consumption of  external power supplies (Commission 
Regulation (EC) No 278/2009), furthermore on waste ("WEEE")8, or on hazardous substances 
("RoHS")9.  
Regulation EC 1275/2008 requires th at products covered within  its scope, which include 
sound and imaging equipment, have to comply with a maximum power limit of 0.5 Watts in 
January 2013 (with some additional allowances available for extra functionalities) when operating in standby or off mode. A revision to  address network sta ndby is currently in 
progress (Committee vote on 21 Ma rch 2013), and is considered in  the baseline scenario.  
Initiatives in related prod uct areas involving the same  industrial sector include: 
• Voluntary agreement for complex set top boxes, accepted by Commission Report 
COM(2012) 684 final
10 
• Voluntary agreement for imaging equipmen t (printers), accepted by Commission 
Report COM(2013) 23 final11  
The experience of these recently accepted Vo luntary Agreements, including their impact 
assessments12 for more complex products with more signatories, can be partly used as a 
reference model.  
In related product areas, there are also the following initiatives to consider: 
• Draft Ecodesign Regulation for computer s (Committee vote on 28 February 2013)  
• Simple Set Top Box regulation (EC No 107/ 2009) 
• EU ENERGY STAR label addressing th e energy efficiency of computers 
In addition, there are also some requirements in national ecolabels such as  the Blue Angel, or 
the Nordic Ecolabel addressing products such as video player /recor ders and projectors. 
                                                 
8 Waste Electrical and Electronic Equipment Directive, 2012/19/EU 
9 Restriction of Hazardous Subs tances Directiv e, 2011/65/EU 
10 http://eur-lex.europa.eu/LexUriServ/LexU riServ.do?uri=COM:2012:0684:FIN:EN:PDF  
11 http://eur-lex.europa.eu/LexUriServ/LexU riServ.do?uri=COM:2013:0023:FIN:EN:PDF  
12 SWD(2012)391 and 392 final; SWD(2013) 14 and 15 final) 
 
EN 10   EN 2.5. Legal basis for EU action 
Article 16 of the Ecodesign Dir ective provides the legal basis for the Commission to adopt an 
implementing measure for this product cat egory. Recitals 16, 17, and 18, Article 17 and 
Annex VIII provide for the recognition, under cert ain conditions, of voluntary agreements as a 
valid alternative to EC regulation. 
With regard to subsidiarity, regulatory interv ention at the national le vel would hinder the free 
circulation of goods in the internal market , and would impose a much higher burden on 
producers. The market failures outlined above are not specific to one individual country in the 
EU and are pan-European in scope; therefore it is  proportionate to interven e at the EU level in 
this instance. 
2.6. Who is affected by ecodesign requirements and how? 
Manufacturers, suppliers and importers of ener gy-related products have to take account of 
environmental aspects in the design and develo pment stages. When products are covered by 
implementing or self-regulation measures, manufacturers and suppliers will also have to achieve minimum energy efficiency standard s for products placed on the European Union 
market. There would be a further need to provi de documentary proof of compliance entailing 
product testing. Market Surveillance Authorites have to check compliance. Finally consumers 
would be affected by any price increase associated with rede signed products – although they 
may realise a benefit from improved energy effici ency over the life time of the product’s use.  
2.7. Market Situation for Sound and Imaging Equipment 
There are no EU manufacturers of game consoles, projectors or mass-market video players/ 
recorders. Almost all mass-market video play ers/recorders (DVD/Blu- Ray), projectors and 
game consoles are assembled in China. Only  very few (below 5,000 units per year), high-
quality video player/ recorder products are made  in Europe by a very small number of SMEs 
for niche markets. This means that EU ma nufacturers are practically not affected, and 
importers and retailers which are unaffected by modifications to products will also not be 
concerned. Annex IV provides more specifi cs about this part icular product group.  
2.8. Baseline scenario 
For the purposes of conducting the impact an alysis, a baseline scenario, also commonly 
known as “No New Policy Action” or “Business As Usual – BAU” has been estimated for 
each product area within the Sound and Imaging Group.  
A check of available market  data by the IA study found th at in 2012 roughly around 50 
million video players and recorders, 12 million ga me consoles and 2 million projectors were 
sold in the EU. The video play er/ recorder products which are predominant on the market 
already have low energy consumption, and projecto rs have a low market size. However, game 
consoles have a relatively high energy cons umption and an important market size. The 
combined electricity consumption of sound and imaging equipment is estimated to have been approximately 8.5 TWh in 2010 in the EU -27 (comprising of 4 TWh for video 
players/recorders and projector s, and 4.5 TWh for games consol es). By 2020 the electricity 
consumption for the three product groups is forecast to increase to 13 TWh in EU27 (comprising of 2 TWh for video players/reco rders and projectors, and 11 TWh for games 
consoles). The BAU scenario for the three produ ct groups is presented in the figure below.  
 
EN 11   EN 
 
Figure 1: Business as Usual - EU Energy Consumption for all Products 
An important factor for modelling scenarios is the forecast of the market situation. This 
forecast shows that the markets are changing very rapidly, and explains the surprising 
decrease of energy consumption for some products. 
 - 10 20 30 40 50 60 70 80
2011
20122013
2014
20152016
2017
2018
2019
20202021
2022
20232024
2025million unitsSales of video players/recorders and game consoles 
in EU-27 (million units)
Game consoles
Video players and
recorders
 
Figure 2: Sales of products EU-27 (million units) 
Figure 2 shows a significant decrease for video players/ recorders. The forecast in the IA 
study found that video players/ recorders will e ffectively disappear from the market. Please 
note that this diagram excludes sales of projector s, as no future sales figures for projectors are 
available from industry experts; however, experts note that proj ectors are expected to follow 
the same downward trend as video players/ reco rders. The sales figures are currently dropping 
by up to 10% per year, and this decrease will continue as other tech nologies increasingly 
substitute these products. The stakeholder co nsultation confirmed the trends, and industry 
associations representing the manufacturers at the Consultation Forum regretted by affirmed 
these trends. These important facts have to be taken into account in th is Impact Assessment. 
 
EN 12   EN Detailed figures for the three individual produ ct groups are included in Annex V. Further 
assumptions for the baseline scenario (i.e. sale s, lifetime, use, effi ciency) are included in 
Annex VI. 
2.9. Improvement Potential 
Sound and imaging equipment overall has a potentia l to reduce in use el ectricity consumption, 
i.e. by increased hardware, optimised chip sets , and changes in power management. However, 
this is subject to qualifications. The improvement  potential for game consoles is difficult to 
identify because of their multi-functionality an d their complex architecture. A potential to 
achieve additional improvements in the energy efficiency of game consoles exists through a better integration of hardware and software. It is  also difficult to define the saving potential in 
an objective way, as it depends on the gaming pe rformance. For new video players/ recorders, 
the improvement potential has been nearly exhausted. For projectors, improvements in 
efficiency from current levels are not possible within the constraints of a low lifecycle cost 
solution. More efficient projector bulbs cost ar ound three times more th an standard bulbs, but 
do not proportionately reduce electricity consum ption, cost-wise. An overview for all product 
groups is included in Annex VII.  
3. OBJECTIVES 
For sound and imaging equipment products fulf illing the ecodesign criteria, the general 
objective is to correct market failures and to reduce energy consumption in a proportionate 
and cost-effective manner, in line with the EUs environmental priorities,  and to contribute to 
the EU objective of saving 20% of the EU’s energy consumption by 2020, while safeguarding the free movement of goods. 
The specific objectives are:  
• to create incentives for manufacturer s to design energy efficient models,  
• to facilitate the removal of lowest performing products from the market,  
• to satisfy the provisions of the Ecodesign Directive, avoiding negative impacts on the 
functionality of the product; and  
• to generate cost savings for end-users.  
The operational objectives are, in  the case of game consoles:  
• to agree by 2013 on representative operat ional modes for energy performance, 
• to develop by 2014 appropriate test measures for energy performance,  
• to make sure by 2014 that buyers can acce ss appropriate performance information 
and so foster an effective market, driven  by competition on energy performance; and 
• that voluntary agreements or  regulations could achieve these objectives without 
having a significant negative impact on func tionality, safety, affordability of the 
product, industry's competitiveness, the fr ee movement of such products within the 
internal market, and the administrative burden imposed on the internal market, and 
Member States.  
 
EN 13   EN 4. POLICY  OPTIONS   
4.1. Game Console Policy Options 
Each policy option is discussed in detail below, including the reasoning behind selecting each 
specific power demand requirement. 
4.1.1. Option 1: No new EU action/ Baseline 
This option is included in the analysis not only for comparison purposes, but also as a viable 
option in its own right (see also baseline scenar io in section 2.7). This  option implies that 
barriers will persist for realising the potentials to improve the energy efficiency of game 
consoles. 
4.1.2. Option 2: Industry Proposal – Self-Regulation  
At the beginning of August 2012, three game console manufacturers presented to the 
Commission an already quite comprehensive “D raft Outline proposal to further improve the 
energy consumption of game cons oles”. This draft industry propos al is silent on its purpose, 
and is not considered by the Commission as  a 'Voluntary Agreement' ready for immediate 
recognition. However, except for the monitori ng and reporting part, it does contain all 
essential elements, and is therefore regarded as sufficient to commence the evaluation of the 
admissibility of this initiative as an alterna tive to an implementing measure. According to 
Annex VIII No. 6 monitoring must be establ ished in partnership with the Commission 
services. Therefore, monitoring procedure has no t yet been included within the initial industry 
proposal. The proposal can be f ound at the following web link: 
http://ec.europa.eu/enterprise /policies/sustainable-busines s/ecodesign/product-groups/sound-
imaging/files/console_maker_proposal_en.pdf  
The principles of the proposal  are a result of world-wide negotiations by the console 
manufacturers following globally po ssible regulatory initiatives. So far neither self-regulation 
nor mandatory requirements exist anywhere in the world. Similar discussions regarding self-
regulation recently took place in Australia and New Zealand, and the US Environmental 
Protection Agency is working on an ENERGY STAR specification for game consoles. After 
many years of unsuccessful attempts to addres s the consumption of the extremely varying 
game play modes, which depend strongly on the gaming performance, all global discussions were reduced in 2012 to a simplified approa ch, with requirements on the two operational 
modes ‘media playback/streami ng’ and ‘navigation’, which ar e also simple to test. The 
present industry proposal to the Commission is based on these modes. In its latest version, the 
Voluntary Agreement drafted by industry takes a commitment to look into possible metrics 
for the gaming mode, with a view to explor ing maximum energy consumption requirements 
for its revision in 2017. 
The rationale for addressing the environmenta l impact of game consoles through self-
regulation is underpinned by th e following characteristic s of this product group: 
• There are only three main console manufacturers.  
• The energy consumption of these devices is im pacted not only by thei r design but also by 
the way that software interacts with the devices.  
• The competition between the manufacturers is very strong. Therefore very little 
information regarding product attributes and energy performance openly available prior to 
launch of a new product generation, re leased every seven years or so.  
The requirements are specified as follows: 
 
EN 14   EN Industry proposal Tier 1 2013 Tier 2 2017 
Media Playback mode  90.0W 70.0W 
Navigation mode 90.0W 70.0W 
Additional functi onality allowance 
NUI=Natural User Interface 20.0W 15.0W 
Auto-power down to stan d-by mode after one 
hour of inactivity   
Table 2: Game consoles Option 2 Requirements  
The industry proposal includes a comprehensive approach to tackling the power demands of 
some of the power modes found in game consoles , but not their main function of 'game play', 
which could not be included at this stage, so  as not to restrict the gaming performance. 
Furthermore, the proposal considers existing an d future standby regulations. However, there 
are several aspects of the proposal which requir e additional investigation, i.e. that media 
playback is limited to some specific media formats.  
Assessment against Annex VIII of the Ecodesign Directive 
As a basic condition, voluntary agreements under the Ecodesign Directive need a high level of 
environmental ambition, and need to demonstrat e that they are likely to deliver the policy 
objectives faster, or in a less costly manner, th an mandatory requirements. In line with Article 
17 of the Ecodesign Directive, voluntary agreements or othe r self-regulation measures 
presented as alternatives to implementing measur es in the context of this Directive shall be 
assessed at least on the basis of Annex VIII. As  explained, the consoles  manufacturers, aware 
of the fact that the draft proposal is not fully  compliant with the Directive, expressed their 
commitment to amend the proposal in order to fu lfil the Annex VIII  criteria, i.e. its No. 6 on 
Monitoring and Reporting. 
4.1.3. Option 3: Mandatory ecodesign requirements 
This option aims at improving the environm ental impact of game consoles by setting 
mandatory maximum levels for their power consumption.  
Based upon the technical concept of the indus try proposal, but c onsidering also the 
preparatory study options, additional informati on, stakeholder comments and recent technical 
analysis including the draft EN ERGY STAR specifications, seve ral potential sub-options with 
varying thresholds for power demand/energy co nsumption and timings have been explored. 
The most robust sub-option, from a technical perspective, has been taken forward for 
assessment. It proposes more stringent limit valu es as the industry proposal in two tiers for 
2014 and 2017, and further “power  supply” and “power management” requirements. In the 
absence of any widely accepted energy perfor mance metrics for the gaming mode, it is 
currently not possible to propose requirements for this mode. 
Overview table with th e main requirements: 
Regulatory option  Tier 1 2014 Tier 2 2017 
Media Playback mode  70.0W 50.0W 
 
EN 15   EN Navigation mode 70.0W 50.0W 
Additional functionality 
allowance (NUI) 7.0W 5.0W 
Internal power supply 85% minimum efficiency at 
50% of rated output and 82% minimum efficiency at 20% and 100% of rated output, with Power Factor > 0.9 at 100% of rated output.  
Power management Power down to network 
standby after 1 hour of inactivity.  
Table 3: Game consoles Option 3 Requirements 
The Tier 1 power demand value of 70W for me dia playback and navigation mode has been 
suggested for use within a mandatory measure, as  at least one of the current game consoles 
can already meet this requirement, if applied as of today. On the other hand, it is very 
ambitious, as two current consoles would possi bly be banned. The Tier 2 limit of 50W for 
media playback and navigation mode was includ ed, as it was clear that other products on the 
market which offered similar functionalities su ch as notebook gaming PCs could already meet 
these requirements. 2017 was considered a reas onable time for game console manufacturers to 
include energy efficient architect ures into their products so th at media playback could be 
offered at 50W or less. The modelling of this op tion has, however, not considered the future 
possibly extended performance or functionalities of  subsequent generations of game consoles, 
as they are impossible to predict.  
4.1.4. Option 4: Mandatory energy labelling 
The mandatory EU Energy Label usually aims to categorise products by efficiency class, 
applying an A to G categorisation. Energy labelli ng has advantages in terms of transparency, 
consumer information and consistency with approaches for other products. A mandatory 
energy label may offer an effective means of encouraging the market toward more energy-
efficient game consoles: in a horizontal wa y, helping consumers by giving them a further 
purchasing criterion to choose between the different models, and in a vertical and 
chronological way by stimulating manufacturers to  improve their new consoles, to place them 
into the better labelling classes. 
However, there are only three main product m odels of games consoles, one produced by each 
manufacturer, and the product architectures a nd gaming performance vary widely between the 
three different products. This means that there are considerable differences in functionality 
and power consumption between the products of each manufacturer, which may make the 
application of an acro ss-the-board categorisat ion unrepresentative. 
The labelling thresholds for A-G levels for ga me consoles have been developed using the 
power demand requirements in media playback  and navigation mode of 90 W, 70 W and 50 
W. These thresholds correspond to  the labelling classes G, E and C respectively. The formula 
to calculate the label class would be as follows: 
Specific Energy Consumption Index (SEC) = ( 0.5 x (Media Playback (W) + Navigation 
(W))). 
 
EN 16   EN The following table shows the energy labelling option and its classes. The proposal includes a 
Tier 2, reducing the labelling th resholds by 15 W to 20 W after three years, to set a strong 
incentive that improvements are necessary even  to keep the same class for the product.  
Mandatory Energy Labelling 
Requirements Label 
Class SEC Tier 1 
(2014) < (W) SEC Tier 2 
(2017) < (W) 
A 30 15 
B 40 25 
C 50 35 
D 60 45 
E 70 55 
F 80 60 Media Playback mode combined with 
Navigation mode 
G 90 70 
Table 4: Game consoles Option 4 Requirements  
4.1.5. Further Discarded Options 
Considering the specific situati on that none of the manufacturers is based in Europe, and that 
other international negotiations are on-going, two further options have been considered for the 
EU, not to opt for regulation alone. These ot her options are not under the control of the 
Commission, and depend on other developments a nd stakeholders. These alternative options 
could be progressed in parallel to the other op tions outlined in this Impact Assessment, but 
cannot be analysed further here. 
Option 5: Internationally -Recognised Agreement  
The potential for an international agreement on ga me console energy efficiency was discussed 
in 2012 via the initiative of Australian aut horities, under the IEA ba nner within the “4E” 
Implementing Agreement. An international ag reement could involve - as a minimum, for 
example - the EC, the Australian DCEEE, and the Californian Energy Commission. One 
advantage of this approach would be less vari ation in requirements among countries, so that 
impacts on competitiveness of EU firms would be minimised. However, negotiations between 
Australia and industry and for Energy Star specif ications have slowed down, and no concrete 
plans are known. . As an interna tional Agreement is not considered as a viable option in the 
near future, no detailed modelling of this approach has been developed.  
Option 6: EU ENERGY STAR coverage The voluntary EU ENERGY STAR label usually ai ms to qualify the top performing 25% of 
the market at the time the specification beco mes active, but the specification for game 
consoles is still at the draft stage. In pr inciple ENERGY STAR is considered a worldwide 
well-recognised incentive, which is  often used as a criterion for public procurement; however, 
this public procurement element is not very rele vant for game consoles. The 25% approach is 
also problematic when there are solely three pr oducts on the market; the incentive for industry 
to manufacture qualifying products would be low, and the approach bears the risk that none of 
the products would qualify fo r the label. Furthermore, as the EU - ENERGY STAR 
agreement is currently in the process of bei ng re-negotiated, this opt ion is discarded from 
further analysis. 
Option 7: Combination of Options 3 (Ecode sign Regulation) and 4 (Energy Labelling 
Regulation) 
An option combining ecodesign with energy labe lling would represent the most extensive 
regulatory approach. However, as both options t ackle the efficiency of the same operational 
 
EN 17   EN modes, effects of both regulations may absorb  each other rather than adding on significant 
benefits, whilst requiring the administrative burde n of both. Therefore this  option is discarded 
from further analysis at this stage, without excluding it as a possible legislative way forward 
at a later stage.  
4.1.6. Summary and level of ambition of the game console options 
For game consoles, manufacturers have proposed  voluntary requirements. An important task 
of this impact assessment is to contrast the level of ambition of the industry proposal option 
with possible mandatory options. The following table summarises the levels:  
 Policy Options 
 1 No 
action 2 Industry 
proposal 3 Ecodesign 4 Energy Labelling 
Requirements 
in Watt (≤W) Tier 1 
2013  Tier 2 
2017  Tier 1 
2014 Tier 2 
2017 Label 
Class SEC 
Tier 1 2014 SEC 
Tier 2 2017 
A 30 15 
B 40 25 Media 
Playback mode  
90 70 70 50 
C 50 35 
D 60 45 
E 70 55 
F 80 60 Navigation 
mode  
90 70 70 50 
G 90 70 
Table 5: Summary Game consoles Requirements 
The table indicates that minimum efficiency leve ls for all options are structured in a similar 
way. The levels under Option 3 are 20 W stricter  than under Option 2, which is considered 
ambitious, but not extremely different. The timing of their entry into force is also similar; 
however the industry proposal would apply al ready by 2013. Industry se lf-requirements are 
therefore phased in faster than under Options  3 and 4. Option 4 reflects the same approach 
using the same power modes, but  the labelling classes are set in a challenging way, assigning 
many consoles currently on the market to the lo west energy classes, which means that the 
“pull” effect of such an opti on can be considered ambitious. 
Stakeholder views: Nearly three quarters of respondents of the publ ic survey stated that there 
was no need for policy action in Europe. Th e following preferred policy option was the 
industry proposal. Further, the stakeholder survey preferre d self-regulation over an 
international agreement. The consultation resu lts showed a strong disa greement (>90 %) with 
the proposed levels and found them too stringe nt. Member States supported self-regulation 
provided that the level of ambition is rais ed. NGO respondents suggested that regulation 
would deliver results more qui ckly and cost effectively.  
4.2. Video Players/ Recorders Policy Options 
4.2.1. Option 1: No new EU action/ Baseline In addition to the information provided in sect ion 2.7 baseline scenario , this option can be 
characterised by a clear downward trend in sales. The trend will continue due to technological 
shifts towards the separation of  the hard/optical drive from the product and toward streaming 
 
EN 18   EN clients, removing the need for these products. 93%  of the stakeholders agreed to the broad 
view of the market. More technical details can be found in Annex IV on the market situation.  
4.2.2. Option 2: Self-regulation via a voluntary agreement 
No self-regulation initiative ha s been taken forward by industry. Drastic decreases in sales do 
not militate in favour of self-regulation. Theref ore this option is discarded from further 
analysis. 
4.2.3. Option 3: Mandatory Ecodesign requirements  
Policy options with  ecodesign requirements were develope d in the preparat ory study in 2010, 
and were subject to stakeholder consultation. The IA study checked th e policy requirements 
for products currently on the mark et, and found that that the ma jority of products already met 
these requirements. Therefore, the requireme nts have been re-asse ssed in light of new 
technical information and industry feedback. Th e revised and more stri ngent proposals, with 
updated timelines, were subjected to the pub lic stakeholder survey, and subsequently 
considered for purposes of this assessment. Th e option is considered ambitious and feasible 
within a least life cycle cost (“LLCC”) approach. 
Operating mode Product Thresholds 2014 
Video player SD ≤ 8W 
HD ≤15W On play 
Video recorder ≤20W 
Live pause Video recorder ≤20W 
Fast start Video players 
and recorders ≤8W 
Off mode or standby  equivalent power 
condition Video players 
and recorders ≤0.5W with hard on switch 
≤0.3W without hard on 
switch 
Video player Disabled by default. Fast start enabling 
Video recorder Fast start mode restricted to 4 
hours or only when the TV is on 
Auto power down (APD) enabling Video players 
and recorders APD requirements enabled 
by default.  
Video players 0.5 h 
 Time to enter standby/ off/ equivalent from 
conditions not providing  on-mode functions 
after no user interaction Video 
recorders 3.0 h 
Table 6: Video Players/Reco rders Option 3 Requirements 
4.2.4. Option 4: Mandatory energy labelling 
The mandatory EU Energy Label usually aims to categorise products by efficiency class, 
applying an A to G categorisation. Energy labelli ng has advantages in terms of transparency, 
consumer information and consistency with approaches for other products.  
However, the already very low level power de mand of a few Watts in these products means 
that an energy efficiency label would display th e best label class for almost all of the mass 
market devices. As the differences in power consumption between products are often very 
small, it would be artificial to develop and apply labelling classe s in one-watt steps or similar. 
 
EN 19   EN The introduction of a labelling scheme would therefore not be in line with Article 11 of the 
Energy Labelling Directive, which stipulates that the steps of the energy classification should 
correspond to significant  energy and cost savings from  the end-user perspective. 
This option is therefore dis carded from further analysis. 
4.2.5. Option 5: EU ENERGY STAR coverage 
The US ENERGY STAR label currently incl udes a “Home Audio & DVD” specification; 
however it covers wider products than just th e sound and imaging products addressed in this 
impact assessment. In principle, this label may provide a low-cost mechanism to influence 
market transformation toward greater energy effi ciency in Europe. However, the strength of 
the current EU ENERGY STAR la bel is its use in public procurement, which is not a major 
driver for the video player/ recorder market, a nd therefore it is unlikel y that there would be 
sufficient incentive for industr y to manufacture products wh ich would qualify for the EU 
ENERGY STAR. In addition, as the differen ce between the worst and best performing 
products on the market may only be 2 W to 3 W, notable savings would not be expected in the 
event that a label did see a significant uptake in Europe. For these reasons, this policy option is not considered further. 
4.2.6. Summary of the Video Players/ Recorders Policy Options 
From the five policy options considered for video recorders/players, three have been 
reasonably discarded from further analysis, and two will be taken forward for investigation in 
more detail. In addition to the discard justifications given here, the market data and the low energy consumption of these products (the po wer demand to play a DVD is often already 
below 10 W), support limiting the analysis  to a smaller number of options.  
Stakeholder views: There was general agreemen t in the consultation of  a downward trend in 
the video recorder/player market overall and the majority of respondents preferred ‘no action’.  
4.3. Projector Policy Options 
4.3.1. Option 1: No new EU action/Baseline 
With no EU action, the baseline scenario is ch aracterised by a clear downward trend in sales, 
because projectors will be increasingly substitu ted by widescreen televisions. More technical 
details can be found in Annex IV on the market situation. 
4.3.2. Option 2: Self-regulation via voluntary agreement 
No self-regulation initiative has been taken fo rward by the projector industry. Decreases in 
sales do not militate in favour of self-regula tion. Therefore this option is discarded from 
further analysis.  
4.3.3. Option 3: Mandatory Ecodesign requirements  
This option is based on reassessed and updated policy scenarios from the preparatory study. 
The requirements proposed below are based upon an assessment of av ailable technologies. 
The option is considered ambitious and feasible.  
Operating mode (2014) 
Off/Standby/Networked Standby mode  0.5/1.0/1.0 W 
Total projected light output 
(lm) Efficiency requirement 
W/ lm On mode  
X13 < 1,500 0.150 
 
EN 20   EN Table 7: Projectors Option 3 Requirements 
Correction coefficients would apply to thos e efficiency limits de pending on the projector 
specifications (product categories,  lamp technology) as follows: 
Projector specifications Correction Coefficients 
Wide aspect 1.1 
Multi lamp and Xenon lamp 1.3 
Solid state light source 2.0 
Home theatre projectors 2.0 
Short throw projectors 1.3 
Table 8: Projectors Option 3 Correction Coefficients 
4.3.4. Option 4: Mandatory energy labelling  
A label for projectors would be complex but feas ible. It could assist in identifying low quality, 
poor performance products coming to the market . To date there have  been no detailed 
discussions regarding the details of such a la bel. The modelling of the labelling option is 
therefore based on the requirements and on simplified assumptions suggested in the preparatory study, i.e. that this label would result in a 5% per annum improvement in 
efficiency from 2016 onward. 
4.3.5. Summary of the Projectors Policy Options 
Three of four policy options cons idered for projectors will be taken forward for investigation 
in more detail. The market data support to limit the analysis.  
Stakeholder views: There was general agreemen t in the consultation of  a downward trend in 
the projector market, and the majority of respondents preferred ‘no action’.  
5. IMPACT
 ANALYSIS 
The overarching aim of this sect ion is to assess the overall en ergy and carbon savings against 
other parameters such as economic and social  impacts, thereby identif ying the possible trade-
offs. This helps to ensure that consideration of environmental, economic and social impacts 
are all factored in to  the options analysis. 
The Table below gives an overview of the options retained for in-depth analysis. 
Game consoles Video players / recorders Projectors 
• Option 1 No EU action 
• Option 2 Industry 
Proposal - Self 
Regulation  
• Option 3 Mandatory 
Ecodesign  
• Option 4 Mandatory • Option 1 No EU action 
• Option 3 Mandatory 
Ecodesign  • Option 1 No EU action 
• Option 3 Mandatory 
Ecodesign  
• Option 4 Mandatory 
energy labelling  
 1,500 ≤ X < 2,500 0.120 
2,500 ≤ X < 4,000 0.110 
4,000 ≤ X < 5,000 0.100 
5,000 ≤ X 0.090 
 
EN 21   EN energy labelling  
Table 9: Retained options: Game Consoles, Video Players/ Recorders and Projectors 
The assessment is implemented in line with th e criteria set out in Article 15(5) of the 
Ecodesign Directive, taking into  account the impacts on manuf acturers, including SMEs. The 
aim is to find a balance between achieving th e appropriate level of ambition and associated 
benefits for the environment/ user (due to re duction of life-cycle costs) on the one hand, and 
the potential burdens for manufacturers, etc, on the other. Throughout, it should be ensured 
that negative impacts to the user are avoided - in particular in relation to affordability and 
functionality. 
5.1. Economic impact 
5.1.1. Impact on Industry in general  As explained in section 2.6, EU manufacturers w ill not be affected, practically. Costs related 
to improved technology and pr oduction, and re-design, will accrue to non -EU manufacturers, 
although the scale will depend on each individual option, and th e product scope and the type 
of exemptions applied.  
The policy options assessed would have the fo llowing supply-chain related cost implications: 
Game consoles:  
It has not been possible to quantify the cost s to manufacturers. The IA study assumes that 
Option 2, the Industry Proposal for Self-Regulati on, would not incur high additional costs, as 
manufacturers themselves have undoubtedly cons idered the 2013 requireme nts in their current 
console design. For the 2017 requirements, an indus try will have time to adapt to the changes 
needed thus minimising the detrim ental impacts and downtime costs.  
Option 3 (Mandatory Ecodesign requirements) ma y require changes to products. The IA study 
estimates that the impact could represent a si gnificant proportion of ma nufacturing costs per 
unit, but that the required changes will add little  to the final price, to consumers. This is 
explained further below.  
Some of the game console manufacturers have claimed that the first tier requirements would 
necessitate significant product changes. To suita bly assess costs, additional information is 
required from manufacturer s regarding the power demand values for new generations of game 
consoles. The proposed second tier in 2017 may re quire slightly more efficient components. 
However, it is difficult to anticipate what cha nges would be needed in future game consoles 
as manufacturers have been una ble to supply any additional da ta. No information regarding 
future details is available, due to the strong co mpetition between the three global players. It is 
assumed that 60% of the market would require  changes (based on the fact that the new 
Nintendo Wii U console is expected to already meet most of the 2017 proposed 
requirements).  
To get a feeling for costs, the retail price fo r a console can be assumed to be approximately 
€360, as given in the preparatory study. Manufact urers have suggested that the costs of 
including separate efficient components to supp ort the media playback functionality could be 
up to approximately 40 € per product unit. Assu ming that the manufacturers can absorb part 
of the additional costs, the required changes shou ld represent an increase of less than 10% in 
the final price to consumers, and this may re duce with time, in line with greater market 
penetration of these more efficient component s into the game consoles sector. The higher 
energy efficiency ambitions of the mandato ry Ecodesign requirement s would become the 
“new norm” immediately after the adoption of the Regulation, which might even result in 
 
EN 22   EN lower price increases per product unit, owing to mutual competition between the 
manufacturers, and thei r respective suppliers.  
On the other hand, consumers should save ener gy from more efficient components, at the 
same time as benefiting from greater function ality. In terms of electricity savings, the IA 
study estimates the typical electricity savings  to an average consumer should amount to 
around 1.30 Euros per year, i.e. approximately 8 Euros over the product’s typi cal six-year 
lifetime. When discussing costs it has to be further considered that the retail price may be a strategic price which is  only a part of the calculations, as costs may be recuperated by the 
prices of the games for the specific consoles . The increase in manufacturing cost of around 
€40 roughly represents the price of one additional video game. Therefore it is impossible to estimate more precisely the impacts on the buyers and the affordability of consoles. 
Option 4 (Mandatory Energy Labelling) would in cur very minor additi onal costs to display 
the energy classes on a label, but would not incu r extra costs in production. Manufacturers are 
able to set the pace of any efficiency improvements they wish to implement. 
Video players / recorders: 
With Option 3 being implemented in 2014, negligible additional supply chain costs are 
assumed, as the levels suggested for a regula tion would not require substantive changes to 
mass market products, since there is little scope for improvement,  as previously discussed. 
The main improvement options identified are: a)  changing the architecture to make the hard 
disk drive external to the product, a trend that is already underway; and b) using energy-
optimised chip sets for new generations of prod ucts. Changes of this kind will be minimal, 
and will be low/no cost. If regulatory requirements were also applied to high-end products, there is a risk that the costs would be disproportionate, and that the limits would constrain 
innovation and quality. Therefore, in the regula tory scenario assessed, it has been assumed 
that high-end products are exempt. 
Projectors: 
Option 3 could result in an  increase in manufacturing costs, re flected in the consumer increase 
in product price to cover improved efficiency pow er supplies, and improved light efficiencies. 
At least 75% of the market would require su ch changes. However, no significant design 
changes would be necessary to achieve the requirem ents, so there is little associated cost for 
producers. The affordability is difficult to fore cast, both with regard to how manufacturing 
costs could be passed through to consumers, a nd regarding the competition of more expensive 
projectors with screens.  
Option 4 would not be expected to in cur significant supply chain costs. 
5.1.2. Costs related to assessment of  conformity/ compliance costs  
Option 2 for all product groups: Vo luntary agreements would impl y costs of certification, but 
industry would minimise the costs by adapti ng existing measurements or certification 
processes that are fit for purpose. Moreover, under a voluntary agreem ent industry would be 
expected to factor in change s to product design into the nor mal manufacturing cycle, so the 
need for re-assessment of conformity will be minimised.  
Option 3 for all product groups: Assessing the conformity with Ecodesign requirements, 
including product testing, implies costs for manufacturers. Costs estimates developed for the 
impact assessment from Ecodesign requireme nts for televisions ra nge from 500€ (self-
certification) to 1000€ (external laboratory) per sample product/ model. The costs of assessing 
conformity for set-top boxes have been es timated to be between 500€ and 2000€. For the 
purpose of the requirements considered unde r this IA, a range between 500€ and 800€ for 
 
EN 23   EN conformity assessment of the power consumpti on can be considered realistic. In comparison 
with the sales figures, the costs would be in  the area of on e-hundredth of one Eurocent per 
unit, i.e., negligible. 
Option 4 for all product groups: Concerning mandatory energy labelling, product testing 
would also have to be undertaken. Costs for at taching the energy label have been estimated to 
be of order of 0.1 € per product unit.  
Further remarks on compliance costs: There may be a need to reassess compliance with other applicable requirements ("Low 
Voltage Directive" and "EMC Di rective"). Therefore, altho ugh the costs may increase, the 
energy consumption test coul d be undertaken in conjunc tion with other compliance 
requirements, to minimize costs.  
It is not expected that the costs for game c onsoles and projectors woul d exceed the estimates 
produced for TVs and set-top boxes. Similarly, because consoles and projectors are produced 
in large batches to the same specifications, c onformity assessment costs are not expected to 
represent a significant proportion of  the total running costs.  
However, for high-end Video Pl ayers/Recorders equipment manufactured in small volumes, 
costs may be more significant. This is why th e test procedure provide s for the testing at 
product family level – a manufact urer/integrator may choose to test at a higher aggregated 
level of products, provided that he reports the values of the highest-consuming model within 
that product family. 
Administrative costs, defined as the cost of providing inform ation in order to meet legal 
obligations, are expected  to be negligible.  
5.1.3. Administrative costs for Member States 
A regulation is directly applicable in all Member States. This ensures that there are no costs 
for national administrations for transposition of the implementing legislation into national 
legislation. However, Member States carry the costs for carrying out the verification 
procedure for market surveillance purposes, including testing. The resulting costs are 
expected to be similar to t hose for other products covered by Ecodesign, i.e. for set-top boxes 
typical costs have been between €400 and €800 pe r product test. The costs for Member States 
under a mandatory energy labelling schemes are e xpected to be of a similar magnitude. For 
voluntary agreements, there will be no direct cost im plications for Member States, but some 
indirect costs for monitoring.  
5.1.4. Impacts on trade and competitiveness 
The manufacturers of the produc ts considered in this impact assessment are very much 
predominantly based outside of the EU. As the EU market is important (imported volume of 
products in the EU-27 in 2008: ap proximately 5.5 billion € of vi deo game consoles and video 
games; approximately 1.3 billion € of projectors), it is not expected that  a regulation will deter 
manufacturers from stoppi ng imports into Europe.  
Both ecodesign and energy labelling regulations w ill apply to all manufacturers equally, so in 
that sense there would be no expected impacts on their competitiveness. Furthermore, the regulatory options are not expect ed to lead to  a relocation of economic  activity, to impact 
investment decisions, or to have significant im pacts on trade and thus on importers. However, 
it needs to be acknowledged that there may be a delay in the introducti on of new products into 
the EU markets, so EU retailers may be affected  by “time to market” delays. There is further a 
small potential that importers into the EU could be disadvantaged if ecodesign requirements were set with excessive stringency so as to require the development of  different models of 
 
EN 24   EN games console for the EU market. Stringent requirements could further encourage “grey 
market” imports from other regions where no energy efficiency measures exist. 
The main risk with a voluntary agreement relate s to its successful uptake by industry. In other 
words, if 100% of industry subscribes to the ag reement, the impacts on trade will be minimal. 
If, on the other hand, one manufacturer reneges, then impacts on trade and their competitive position may be more likely. However, the consultation undertaken for this impact assessment revealed 100% support for the agreement. Thus , impacts on trade are not expected to be 
significant.  
5.1.5. Impacts on innovation 
Overly stringent ecodesign requirements may incu r excessive cost to manufacturers and could 
thus limit innovation. For high-end products, co sts could be disproportionate and the limits 
would constrain innovation and quality. However, as the level of stringency and the timing of 
Option 3 are in general not overambitious, ne gative impacts on innovation can be excluded.  
Requirements for games consoles are expected  to have a positive impact on games console 
innovation as manufacturers will be  required to consider energy e fficiency of their products in 
more detail. The added research on energy effi ciency could result in fewer resources being 
available for other research areas though. 
For video players/recorders and projectors, innovation will affect  these products in the sense 
that the product is being replaced by another pr oduct or a service – that  of screens or on-line 
streaming.  
5.1.6. Costs for SMEs 
There are currently no game console manufactur ers head quartered in the EU. There are a 
significant number of games developers and games publishers in the EU however. These 
game developers and game publishers could be impacted by the proposed power down requirements in that they will need to ensure that future games support auto-save. Impacts on 
these companies are expected to be small as the proposed requirements are only applicable to 
future games where programming can be more easily tailored to support auto-save.  
High-end, high-quality video player / recorder pr oducts are made in Europe by a very small 
number of SMEs for niche markets. Manufactur ing in Europe is below 5,000 units per year. 
Due to the small volumes, it is difficult for th ese SMEs to procure energy efficient chips 
(minimum order is 1 million pieces per lot), pl us there are issues regarding the quality of 
energy efficient single chips for the high-e nd market. Assumed that  strict ecodesign 
requirement without exemptions would be set, costs for these SMEs would rise.  
For projectors, there should be no competitive advantage to, or negative impact on, any of 
these players as a result of th e suggested requirements. Where SMEs are involve d in projector 
manufacturing, their market niche is the high er specification. In terms of installation for 
specialist applications, SMEs would not be impacted by th e shift from projectors to 
televisions, as they would simply shif t to installing the new product instead.  
5.2. Reporting and verification 
Under a regulatory approach, re quirements would need to be met by all products meeting the 
definition of being “placed on the market”. Verification would be performed by market 
surveillance authorities on the basis of an esta blished procedure. In the case of Option 2 
(Industry Self-Regulation), the monitoring of a Voluntary Agreement will be performed by 
the Commission (for more details see section 8). As the draft voluntary agreement for game 
consoles contains only three signatories, the verification of the self-regulatory measure is 
considered manageable. 
 
EN 25   EN 5.3. Social Impacts  
5.3.1. Impacts on jobs For the regulatory policy options assessed, the risk of job losses is expected to be very low, 
because the staged approach and timings allow manufacturers to adapt to Ecodesign 
requirements in a timely manner, and - more importantly - because there are only a small 
number of SMEs involved in the manufacturing of products under considera tion. Although 
price increases are not expected to be signifi cant, there may be some impacts on small-scale 
retailers, as these retailers may be less able to bear the costs if manufacturers increase their 
prices. However, high-volume retailers may be more able to support the price increases, such 
that consumers will not be affected.  
The main SME job impact would be in the area  of high-end video play ers/ recorders. From 
data in the IA study, the manuf acturing of such products in Europe is below 5,000 units per 
year. Whilst product prices are high, quality is also a very powerful dr iver in this market 
segment, and it may be a struggle to find a ba lance between energy e fficiency requirements 
and performance. This could place such compan ies at a disadvantage, compared to the mass-
market manufacturers. In additi on, if Blu-ray requirements are over ly stringent, th ere is a risk 
of loss of jobs in Europe, due to the closur e of existing Blu-ray manufacturing (potentially 
6,000 posts). 
5.3.2. Affordability of equipment  
In principle, significant price increases are not  expected, in order to achieve the assessed 
policy options. Prices are not expected to change to such an extent that affordability could be 
negatively affected, especially in declining markets such as projectors and video players.  
5.3.3. Impact on the functionality of equipment 
The implementation of any of the options consid ered here would not have a negative impact 
on the functionality of the products addressed. Th is aspect was also the reason why no option 
has been proposed for game consoles which w ould regulate the game play mode, which could 
be disadvantageous for the gaming performance.  As mentioned previously, the only products 
that could have difficulties in meeting regul atory requirements are high-end video players/ 
recorders used for prof essional applications.  
5.4. Environmental Impacts 
5.4.1. Annual energy consumption The electricity consumption for all product gr oups was analysed a nd estimated through a 
modelling exercise, with model development a dvised by technical expe rts within the product 
groups.  
Following this modelling, the combined electri city consumption of all sound and imaging 
equipment is estimated to have been appr oximately 8.5 TWh in 2010, in the EU-27. By 2020 
the electricity consumption for the three product  groups is estimated to increase to 12.8 TWh.  
Product groups individually are forecast as follows: 
 
EN 26   EN 
 
Figure 3: Evolution of Energy Consumption Game Consoles 
The annual electricity consumption of game consol es is estimated to have been approximately 
4.6 TWh in 2010 in the EU-27, and is estimated to increase to 11 TWh per year in 2020 
(BaU). Figure 3 shows that the energy consump tion increases uniformly for all options. None 
of the options achieves a signifi cant change of the energy c onsumption, or a turnaround. The 
reason for this trend for all options is that th e overall functionalities,  processing power, and 
gaming performance, which is the purpose of thes e products, will increase strongly. This 
increase in overall energy consumption is despite the fact that relatively little additional power is needed to ensure strongly im proved performance, and that th e consoles become relatively 
much more efficient. Not even the most amb itious option can reverse this trend. By 2020, the 
saving potential of all interventi on options is similar, with a very small advantage for the 
ecodesign option. By 2025, the two mandatory re gulation options achieve 16%/ 18% energy 
savings, i.e., roughly double the savings of the industry proposal, which achieves energy 
savings of 8%. 
 
EN 27   EN 
  
Figure 4a: Evolution of Energy  Consumption Video Players 
 
Figure 4b: Evolution of Energy  Consumption Video recorders 
The electricity consumption of video players an d video recorders are di splayed in figures 4a 
and 4b and table 5. The energy consumption in th e “business as usual” option is forecast to 
drop steadily, and falls towards zero by 2025. A mandatory ecodesign Option 3 would add to 
the decrease in energy use, and would provi de for a stronger decrease in 2015 and 2016, but 
would regress towards the BAU curve in the longer term. The total annual energy saving 
 
EN 28   EN estimated of around 0.25 TWh per year in 2020 is s ubstantially lower th an the 10 TWh per 
year estimated in the preparatory study, resultin g from the revised assumptions regarding the 
development of the market. Sensitivity analysis has shown that if the decrease in sales is 
assumed to be slower, the saving to be achie ved by the ecodesign requirements option would 
be below 0.5 TWh per year for video players in the next three to five  years. The assumption 
of a continuous decline as such  is considered robust, and has been confirmed during the 
consultation.  
 
Figure 5: Evolution of Energy Consumption Projectors 
According to modelling predictions, the electric ity consumption of projectors decreases from 
2.1 TWh per year in 2010 to around 1 TWh per year in 2020. Figure 5 shows that regulatory 
options would have no significan t effects, and would not add to the constant decrease of 
electricity consumption of projectors.  Sensitivity analysis has shown that if the decrease in 
sales is assumed to be slow er, the saving to be achieved by the ecodesign requirements 
options would not deviate for projectors. The as sumption of a continuous decline as such is 
considered robust, and has been confirmed during the consultation. 
The table below demonstrates the potential electricity savings, as estimated from the 
modelling exercise, for the years 2020 and 2025.  
The table below demonstrates the potential electricity savings, as estimated from the 
modelling exercise.  
Table – Annual Electrici ty Savings vs. BaU: 
 2020 2025 
Use Savings  Use Savings  
GWh/a GWh/a % GWh/a GWh/a % 
Game consoles 
BAU  11,016    13,662   
Policy option 2 -
Industry Proposal  9,997 1,020 9.3  12,540  1,122 8.2 
Policy option 3 - 9,555 1,461 13.3  11,267  2,395 17.5 
 
EN 29   EN Mandatory Ecodesign 
Requirements 
(Regulation) 
Policy option 3 -Mandatory Labelling 9,902 1,115 10.1 11,538 2,124 15.5 
Video players / recorders  
BAU  660   65   
Policy option 3 - 
Mandatory Eco design 
Requirements 
(Regulation) 298 360 54.5 15 50 76.9 
Projectors  
BAU with network 
standby 1142   423   
Policy option 3 - 
Mandatory Eco design 
Requirements (Regulation) 1137 6 0.5 421 2 0.5 
Policy option 4 - 
Mandatory energy 
labelling 1081 62 5.4 401 23 5.4 
Table 10: Annual Electricity Savings 2020 and 2025  
The above table demonstrates that the greates t potential for energy savings comes from the 
most ambitious options, i.e. ecodesign and labelling. 
The ecodesign Option 3 for games consoles has th e greatest saving potential, estimated to 
achieve 1.5 TWh savings per year by 2020 increasing to 2.4 TWh per year by2025. The 
voluntary agreement Option 2 saves 1.0 TWh per year by 2020 and 1.1 TWh per year in 2025. The relatively greatest potential for energy savi ngs (in % of the baseline) stems from video 
players/ recorders regulation, followed by the game consoles regulation. In proportionate 
terms there appears to be little benefit fr om moving towards regulation or labelling for 
projectors, as the marg ins are negligible.  
It is important to consider that for game c onsoles, all policy options (including the baseline) 
involve increased energy consumption over time. Th e increase is due to an expected increase 
in the power demand and usage of new game consol es. This is in stark contrast to the other 
two products whose total energy co nsumption is expected to decrease over time. This is an 
important point to consider wh en assessing policy options.  
5.4.2. Annual CO2 emission savings  
Electricity production causes substantial envi ronmental and human health damages and 
associated external costs, which vary widely  depending on how and wher e the electricity is 
generated. The external costs are based upon different components, associated with the 
production of electricity: climate change damage  costs associated with emissions of CO2, 
damage costs (such as impacts on health, crops et c.) associated with ot her air pollutants (NOx, 
SO2, PM, NH3), and other non-environmental social costs for non-fossil electricity-
generating technologies. In this assessment, th e most common indicator, CO2, is used. The 
table below demonstrates the potential CO2 savings for 2020 and 2025, as estimated from the 
modelling exercise. 
Table – Annual Carbon (Mt CO2) Savings vs. BaU: 
 
EN 30   EN Table 11: Annual CO2 Savings 2020 and 2025 
Proportionally, potential carbon savi ngs from policy intervention in these product groups are 
the same as the energy savings above, since the carbon savings are directly linked to energy 
savings.  
5.4.3. Accumulated electr icity cost savings 
The accumulated electricity cost savings, trigge red by the policy measures assessed, depend 
on the timing of implementation for the pr oducts placed on the market from 2010 to 2025.  
Electricity cost savings and carbon savings for all product groups were analysed and 
estimated through a modelling exercise, with m odel development advised by technical experts 
within the product groups. These models are based on best estimates and assumptions, and 
should therefore be assumed to be indicative of  the potential savings that can be achieved 
through the various policy scenarios. Changi ng these assumptions may affect the overall  2020 2025 
Use Savings  Use Savings  
CO2 eq/a CO2 eq/a % CO2 eq/a CO2 eq/a % 
Game consoles 
BAU  4.406    5.465   
Policy option 
2 -Industry 
Proposal  3.999 0.408 9.3  5.016  0.449 8.2 
Policy option 
3 -Mandatory 
Ecodesign 
Requirements (Regulation) 3.822 0.584 13.2  4.507  0.958 17.5 
Policy option 
3 -Mandatory 
Labelling 3.961 0.446 10.1 4.615 0.849 15.5 
Video players / recorders  
BAU  0.264   0.0260   
Policy option 
1 - 
Mandatory Eco design 
Requirements 
(Regulation) 0.119 0.145 54.9 0.006 0.020 76.9 
Projectors  
BAU with 
network 
standby 0.457   0.169   
Policy option 
1 - 
Mandatory Eco design 
Requirements 
(Regulation) 0.0.455 0.002 0.4 0.168 0.001 0.6 
Policy option 
2 - 
Mandatory 
energy 
labelling 0.0.432 0.025 5.5 0.160 0.009 5.3 
 
EN 31   EN absolute impact of the options, but the relative ranking  of the options is not expected to be 
significantly affected. Details about the mode lling assumptions can be found in the IA study. 
The table below gives an overview of the accu mulated electricity savings, related avoided 
CO2 emissions, and cost savings over  the period between 2010 and 2025: 
Accumulated: Electricity 
consumption (GWh) Electricity 
savings compared to BAU (GWh) Avoided 
CO2 
emissions
14 
compared 
to BAU (Mt) Price of 
Electricity 
savings
15  
(Million 
Euro)   Price of 
Avoided CO2 emissions (Million 
Euro)
16  
 Game consoles 
Policy option 1 - 
Business as usual (BAU) 150,280     
Policy option 2 – 
Industry Proposal 138,807 11,472 4.59 2,060 69 
Policy option 3 – 
Regulation 132,641 17,638 7.06 3,170 106 
Policy option 4 – 
Labelling 135,694 14,585 5.83 2,630 34 
 Video recorders/players 
Policy option 1 - 
Business as usual (BAU)  23,465     
Policy option 3 – 
Mandatory Ecodesign  19,314 4,151 1.66 750 25 
 Projectors 
Policy option 1 - 
Business as usual (BAU) 23,287    1 
Policy option 3 – 
Mandatory Ecodesign  23,190 97 0.039 20 4 
Policy option 4 – 
Mandatory labelling 22,684 603 0.214 110  
Table 12: Accumulated Electricity Savings 
Consumers will experience the benefits of these energy savings through usage of more 
efficient game consoles in terms of medium- to long-term reduced energy costs. However, this will come at the short-term upfront e xpense of purchasing the more energy-efficient 
consoles. The magnitude of these savings wi ll depend on individuals ’ console usage, and 
variation in energy prices, whic h are historically volatile.  
For game consoles, the above table indicates th at Options 2, 3, and 4 all have the potential to 
create electricity savings and carbon savings, compared to the baseline. The most ambitious 
scenario is the regulatory option, which creates the most savings.  
 
EN 32   EN For video recorders/ players, only the regulat ory scenario (Option 3) has been modelled, 
relative to the baseline, and both electricity and carbon sa ving are also observed.  
For projectors, Options 3 (regula tion) and 4 (labelling) are mode lled relative to the baseline. 
A regulation is not expected to  achieve substantial savings re lative to the baseline. The 
reasons for this limited impact are explained in section 4.3.3 and 4.3.4. 
5.4.4. Non Energy-in-use Impacts 
The most significant environmental impact of vi deo recorders, projectors and game consoles 
occur as a consequence of ener gy consumption in the use phase:  the related energy generation 
emissions, their impact on air and water qual ity, and the resulting depletion of energy 
resources. These impacts have been assessed using the indicators ‘ene rgy consumption’ and 
‘CO2 emissions’.  
There are a number of other environmental impa cts associated with the constituent materials 
of the products, predominantly at end of life and during the production of materials, i.e. 
hazardous waste generation/ incineration, persiste nt organic pollutant emissions, heavy metal 
emissions to air, and particulate matter and dust emissions. These aspects were discussed in 
the preparatory study, but have not been modelle d or analysed further within this impact 
assessment. The clearly observed miniaturisatio n and light-weighting tr ends for the products 
in the scope, coupled with the identified mark et trends, do not suggest  focusing on material 
issues which become less and less significant.  
6. COMPARISON  OF THE  POLICY  OPTIONS 
6.1. Summary of quantified impacts 
The following table summarises the estimated el ectricity and carbon savings attributable to 
the preferred policy options compared to the business as usual scenario. 
Table – Annual Electricity and Carb on (Mt CO2) Savings vs. BaU: 
 2020 2025 
 Electricity 
Savings 
(GWh/a) Carbon 
Savings 
(Mt CO2 
eq/a) Electricity 
Savings 
(GWh/a) Carbon 
Savings (Mt 
CO2 eq/a) 
Game consoles 
Policy option 2 -Industry Proposal  1,020 0.408 1,122 0.449 
Policy option 3 -Mandatory 
Ecodesign Requirements 
(Regulation) 1,461 0.584 2,395 0.958 
Policy option 4 -Mandatory 
Energy Labelling 1,115 0.446 2,124 0.849 
Video players / recorders  
Policy option 3 - Mandatory 
Eco design Requirements 
(Regulation) 360 0.145 50 0.020 
Projectors  
Policy option 2 - Mandatory 
Eco design Requirements 6 0.002 2 0.001 
 
EN 33   EN (Regulation) 
Policy option 3 - Mandatory 
Energy Labelling 62 0.025 23 0.009 
Table 13: Summary of quantified annual impacts 2020 and 2025 
Table 13 shows that the saving potential of games consoles is much more significant than for 
the two other product groups. The different op tions will be discussed per product group.  
6.2. Multi-criteria analysis 
The following table summarizes the potential impact s of the options, and assesses them on a 
relative scale from 1 (low) to 3 (high), with 0 indicating negligible im pact. Negative impacts 
(costs for industry, risk of job losses) score negative figures. 
Environmental 
impact (electricity 
/ CO2 / electricity cost savings) Comparison 
of impacts Economic 
compatibility 
(costs for industry)  
Medium 
term 
'2020'  Long 
term 
'2025' Social 
compatibility 
(risk for job losses in 
SMEs) Effectiveness  
to deliver 
objectives Efficiency Coherence 
Game consoles 
Policy option 
1 - BAU 0 0 0 0 0 0 0 
Policy option 
2 – Industry 
Proposal -1 2 1 0 1 2 1 
Policy option 
3 – 
Regulation -3 2 2 0 2 0 0 
Policy option 
4 – Labelling -1 2 2 0 1 1 0 
Video players / recorders 
Policy option 
1 - BAU 0 0 0 0 0 0 0 
Policy option 
3 – Regulation -1 2 1 -1 1 0 0 
Projectors 
Policy option 
1 - BAU 0 0 0 0 0 0 0 
Policy option 
3 – Regulation -1 0 0 0 0 0 0 
 
EN 34   EN Policy option 
4 - labelling 0 1 1 0 0 0 0 
For games consoles, the medium term enviro nmental impact of options 2, 3 and 4 is 
considered to be similar, as expected energy savings are in a similar range (1 TWh/a for option 1, 1,4 for option 2 and 1,1 for option 3). Th e cost for industry of option 2 is difficult to 
quantify, but it is assumed to be negligible as manufacturers have already factored-in the 
proposed requirements in their console designs. The cost for industry of option 4 is equally 
difficult to quantify. At a minimum it will consist of the cost of testing plus the cost of 
attaching the energy label, but it is c onsidered not to be very significant. 
 Table 14: Multi-Criteria Analysis The policy options have been compared in te rms of economic, environmental and social 
impacts, and of effectiveness, efficiency and coherence. The above table indicates that some 
options may be preferred, according to the Multi-Criteria Analysis. 
In terms of economic impacts, an ecodesign re gulation for game consoles would imply the 
highest costs for manufacturers; other regulat ory or self-regulatory options imply more 
moderate costs for manufacturers. 
The environmental impacts have been assessed for the “long-term”, i.e., by 2025, but also for 
the “mid-term”, i.e., by 2020, as the delivery time is an important factor for assessing self-
regulatory actions. The self-regulation option for ga me consoles comes into effect earlier, and 
thus already provides the same savings as the ot her options in the mid-term. However, it must 
be noted that the long-term re gulatory interventions which kick  in later would have more 
positive impacts.  
Social impacts, via measures for this pr oduct goup, are neglegible . For high-end video 
recorders/ players, Ecodesign measures bear a small risk of putting re lated SME producers out 
of the market. Therefore this ecodesi gn option scores sl ightly negative. 
In terms of effectiveness, all retained options  for game consoles and video players/recorders 
score well. The reason for this good performan ce is that they would all remove the least 
efficient products from the market, thereby sensibly reducing energy consumption, and 
creating savings for users. However, Options 3 a nd 4 for consoles are superior to Option 2, as 
they would double all savings (e nergy, CO2 and to users).  
With regard to efficiency, the self-regulati on Option 2 for game consoles would be more 
efficient than Options 3 and 4. This is beca use the costs imposed on manufacturers and 
authorities would be lower. On the other hand,  the less stringent voluntary approach would 
reduce energy savings more slowly , and it would benefit users less. The voluntary agreement, 
as yet not finalised, bears some risks that it s effectiveness could be lower, i.e. if the 
monitoring and reporting scheme could not be ag reed upon. However, this risk is considered 
low, and the overall efficiency of Option 2 can be deemed higher than e ither Options 3 or 4. 
The efficiency of all options is considered negligible for video players/ recorders and 
projectors, since these are products that are estimated to soon become extinct.  
In terms of coherence with other EU policie s, only the self-regulation Option 2 for game 
consoles scores positively. All other options have  a neutral score. The reason for this is that 
all products will be covered by the horizonta l standby regulation, which will achieve 
significant savings. Additional regulations present a risk  for possible overlaps.  
 
EN 35   EN 6.3. Comparison of game consoles options  
This sub-section discusses in more detail the key question of this Impact Assessment, namely 
whether the current trends and saving potential s of consoles need to be backed up by a 
voluntary agreement, or whether there is a merit in introducing mandatory ecodesign or 
energy labelling measures. 
As none of the options outlined previously achieves a turnaround in the energy consumption, 
all regarded options need to  be assessed thoroughly, and ev en the “no-action” Option 1 
remains of interest, and should be considered. The currently moderate energy consumption of 
around 6 TWh per year, and the identified low maximum improvement potential of less than 20% over 12 years, makes it questionable if c onsoles represent a significant potential for 
improvement in terms of thei r environmental impacts.  
The regulatory option with ecodesign measures leads in the long term - by 2025 - to most 
savings, and provides therefore th e highest environmental benef its, but has also the highest 
economic and social impacts. One risk with mandatory Ecodesign requirements is that they might not be proportionate. Overly stringen t requirements may incur excessive costs on 
manufacturers, and thereby i ndirectly on consumers, and ma y limit innovation. Furthermore, 
game console manufacturers could choose to sell de-featured game consoles to the EU market 
if legal requirements are too stringent. This may encourage “grey market” imports of fully functional game consoles from  other regions, where no energy efficiency measures exist. 
Finally, as the boundaries between products for gaming become more and more blurred, with 
many gaming facilities provided by mobile devi ces and computers, a relatively inflexible 
legal framework could shift gaming to devices outside the regulated scope. 
The energy labelling option has similar effects to the ecodesign option, but will be slightly 
less effective concerning environmental impact s and savings. This policy option provides the 
manufacturers with some flexibility. Well-desi gned labelling classes are considered a strong 
incentive for manufacturers to improve their produc ts, in order to obtain ratings in the best 
labelling classes. For consumers, a mandatory la belling scheme provides a clear structure, and 
increases consumer awareness of energy efficien cy in game consoles over the longer term. 
For users of game consoles, obviously the most  important issue is the gaming performance, 
plus all the different technical features and game play functiona lities that the consoles offer. 
Therefore, for users, the influence of an energy label should not be overestimated. The 
effectiveness of how any mandatory energy labe l can contribute to stimulate improved energy 
efficiency would depend on the way that the la bel was finally develope d and applied. One risk 
similar to the ecodesign option is that ne w products coming onto the market could escape 
from the labelling system, where these new pr oducts blur the boundari es between products.  
The self-regulation option has the lowest economic and social impacts, but leads in the long 
term only to savings lying in the middle between “no-action” and the regulatory options. However, it has the advantage that it is alrea dy as effective as the regulatory options in the 
short- and medium-terms. The fact that tech nology developments and market changes for 
such electronic equipment are very rapid sugge sts that referring to the medium-term forecast 
rather than to the long-term forecast might be  more reliable. Theref ore the environmental 
benefits of the self-regulatory option by 2020 can be considered comparable. To visualise that 
in 2020 the saving potential and the environmental impacts are equal to the regulatory options, a vertical line has been included in figure 3 (chapter 5.4.1). The assessment confirms 
that the industry proposal fulfils in principl e the condition of Recital 18 of the Ecodesign 
Directive, i.e., that self-regul ation should be given priority, where such action is likely to 
deliver the policy objectives in a faster, or in a less costly manner. The fact that there are only 
 
EN 36   EN three manufacturers potentially fac ilitates monitoring, and decreases the risk of 'free-riding' by 
a significant part of the sector. 
However, a self-regulatory option has also a nu mber of risks. In the absence of any legal 
obligation, there is a risk that the self-imposed requirements w ill not be met, and that it will 
not result in any change(s) in the market . Possible intended loop holes in a voluntary 
agreement, such as specific media formats, unanticipated additional functionality or other 
features not listed etc., could be  utilized fully. It would be more difficult to address other 
environmental aspects than is typically do ne via an ecodesign regulation. Further, 
manufacturers could choose to leave the agreem ent at any time. One manufacturer leaving or 
defaulting on the agreement would mean a failure rate of 1/3, with clear implications for the 
agreement’s credibility.  
7. CONCLUSIONS 
Game consoles: This impact assessment finds that the self-re gulation Option 2 provides the most advantages, 
has the best cost-benefit ratio, and provides the best energy efficiency improvements. In the 
multi-criteria analysis, Option 2 (self-regulation)  has an equal medium-term score to Option 4 
(energy labelling) over the long-term. Option 2 ge nerates almost comparable savings to the 
alternative of mandatory ecodesign or energy la belling requirements, it provides flexibility, 
and it enables quicker updating of target leve ls, and has a lower administrative burden. The 
self-regulation option comprises a contribution of 1 TWh per year energy savings to the 
20/20/20 target, with commensur ate greenhouse gases reductions  of 0.45 Mt CO2 eq/ per 
year, and saves consumers annually up to 200 Mill ion Euros, and has no significant impact on 
the competitiveness of industry or on employ ment. Considering Recita l 18 of the Ecodesign 
Directive, namely that priority should be give n actions that are likely to deliver the policy 
objectives faster and in a less co stly manner, it is suggested to  consider the industry proposal 
as the preferred option. Furthermore, a self-r egulation option does not  break new ground. The 
recently accepted two other Ecodesign Vol untary Agreements on Complex Set-Top Boxes 
and on Imaging Equipment support that ecodesi gn self-regulation is a viable way forward, 
and lessons can be learned from these.  
However, to minimise the outlined risks, some mitigating measures should be considered:  
• As a matter of course, the industry self-re gulatory proposal has to be amended as 
soon as possible to become a Voluntary Agreement complying with all provisions 
similar to legal ecodesign requirements, i.e. Annex VIII of the Ecodesign Directive 2009/125/EC. Such amendments must update  the industry proposal of August 2012, 
and must consider as far as possible info rmation on the next generations of games 
consoles. Potential loopholes  need to be closed.  
• To back up the added value, the level of ambition of the proposed thresholds should 
be reviewed and adapted to technical pr ogress. It must prove an energy savings 
potential equal or higher to that an alysed in this impact assessment.  
• Monitoring and reporting: Th e current industry proposal does not contain a well-
designed monitoring system. As the nature  of voluntary instruments inherently 
provides less ex-ante certai nty than mandatory instrume nts, the monitoring and the 
testing system needs to go beyond minimum monitoring conditions, and must display 
information similar to an Energy Labelling ap proach (see also ne xt bullet). It must 
consider all relevant power modes and a llowances, and also be consistent with 
ENERGY STAR and other inte rnational agreements. Good monitoring examples 
 
EN 37   EN from other Voluntary Agreements should be considered. Potentially there is a role for 
the newly-formed CEN/CENELEC TC 100X Committee to be involved in the definition of new measurement standards, which could form the basis of an international agreement. Furthermore, it is suggested that the pr oposal, and especially 
the monitoring system, should by reviewed  by the end of 2017. If the monitoring 
system is not sufficiently transparent, a nd if it does not ensure the display of 
information similar to an Energy Labelli ng approach, the Commission could consider 
applying mandatory energy labelling. This  approach would combine the quick 
savings from the industry self-regulatory pr oposal with the long-term savings of the 
labelling approach. 
Where the conditions for a self-regulation are not met, or where the level of ambition 
proposed by the signatories is no t kept, or if the process is un justifiably delayed, the second 
preferred option would be a mandatory energy labelling measure on game consoles, possibly 
also in combination with an ecodesign regulat ion, provided that both instruments would be 
fully complementary. A mandatory approach is lik ely to provide the greatest energy savings 
of all policy options. Updates of  product and market informati on should be considered before 
proposals are made. As most of the technical pr eparations and consultations are carried out, 
the adoption of an energy-labe lling or ecodesign measure shou ld be feasible within a 
relatively short time frame.  
Video-Players and Recorders: 
The market analysis indicates clearly that  this product group will die out over time. A 
mandatory ecodesign option would achieve additi onal savings in comparison to the “business 
as usual” option, which are significant when accumulated over the next decade, but at a potential cost to the economy. Moreover, a re gulation would disproporti onately affect SMEs 
manufacturing high end products. In conclusion, the preferred option for this product group is 
therefore Option 1, "No action".  
Projectors: 
The situation for Projectors is similar to that of Video-Players and Recorders. Projectors are a 
product group that is pred icted to become extinct. Electric ity consumption of projectors is 
decreasing steadily. The analysis shows that ther e are little environmental benefits from any 
of the policy options, which gives little weight to the argument of pursuing anything other than the “BAU” scenario. The prefe rred option is Option 1, "No action". 
8. MONITORING
 AND  EVALUATION 
It is important to consider the need for the monitoring and evaluation of any action, whether it 
is regulation (ecodesign or labelling) or followi ng an industry proposal.  
For any regulation, it is appropriate to revi ew the scope, definitions and limits after a 
reasonable period of time, also taking into ac count the speed of technological development, 
and input from stakeholders and Member Stat es. Compliance with the legal provisions will 
follow the usual process of the New Legisla tive Framework regulati ons. Compliance checks 
would mainly be implemented via market surveillance, carried out by Member State 
authorities, ensuring that the requirements ar e met. For the monitoring of the Voluntary 
Agreement, this situation is presently still undetermined, as discussed below. 
Firstly, it is not yet clear if the industry proposal  for a self-regulation in itiative will lead to a 
Voluntary Agreement.  
 
EN 38   EN Secondly, the detailed procedure for monitoring and reporting for game consoles is not yet 
ready, and would need to be added subsequen tly to the Agreement. The development of a 
monitoring and testing system is  included, with details as a condition for the self-regulation 
option to become the preferred option.  
Thirdly, for a 'global' non-EU group of products , 'international' monitoring solutions should 
be considered. As included in  the operational objectives, an (international) framework for 
gathering information regarding the energy effici ency of game consoles should be created if 
possible, including appropriate (i nternational) te st standards; 
Finally, the Commission’s genera l requirements on Voluntary Agr eements, and especially on 
their monitoring, are still at a discussion st age (draft guidance under discussion). These 
requirements will be considered as far as applicable.  
Therefore, it is not pos sible at this stage to include specific informa tion about the monitoring 
system in this Impact Assessment. The operational objectives included in this Impact Assessment will serve as indicators for the monitoring. The following draft minimum requirements from the Commission can be outlined:  
• a framework for gathering information about  energy efficiency of  consoles based on 
the representative operational modes for energy performance, 
• agreed testing and measurement methods  and appropriate test standards, 
• a Steering Committee to continuously fo llow the progress and results of the 
agreement, 
• independent inspection,  
• data collection and transmission, and  
• annual reporting.  
A possible key performance indicator could be the average energy consumption of consoles 
placed on the market, i.e. by a specific energy  consumption index based on the representative 
operational modes. 
The first reporting period should start in July 2013. The members of the Consultati on Forum will be consulted on an  annual basis to take stock 
and monitor the results of a Voluntary Agreem ent. Member States wishing to verify the 
reported information will be granted access on demand to the background data, and on that basis they will be able to perform checks/ tests on products.  
The Commission, assisted by the Committee on the Ecodesign of Energy-related Products, 
will, in the light of the reports submitted and input from the Consultation Forum, consider 
whether the objectives of the Voluntary Ag reement are being met. If the Commission 
considers that the Voluntary Agreement is faili ng to achieve its objectives, it will consider 
proposing a regulation instead. 
 
EN 39   EN 9. A NNEXES  
9.1. Annex I - Summary Public Consultation 
A public Stakeholder Consultation exercise, in viting the views of st akeholders on the Sound 
and Imaging Equipment Impact Assessment went  live on 5 October 2012 and lasted for four 
weeks. It was widely announced using all available stakeholder lists, i.e from the 
Ecomultimedia-project. The survey ducumen ts are available on the following webpage: 
http://ec.europa.eu/enterprise /policies/sustainable-busines s/ecodesign/product-groups/sound-
imaging/index_en.htm  
54 replies to the three questionnaires were received. Participation was well balanced with a 
slight majority from industry. 
Summary: Game consoles:  Nearly three quarters of  respondents stating there was no need for policy 
action in Europe. The preferred policy optio ns, supported by the consultation, were the 
industry proposal, an internat ional agreement, and mandatory ecodesign requirements 
(regulation). Industry respondents were, natu rally, supportive of the industry proposed 
approach and levels, whereas NGO respondents suggested that regulation would deliver 
results more quickly and cost effectively.  
Video players/recorders:  There was general agreement in the consultation of a downward 
trend in the video recorder/pla yer market overall. Over half of respondents preferred the 
policy route of no action, but to re-evaluate the market in 3 to 4 years. Just under half the 
respondents preferred a regulat ory route was pursued. The ex emption for high-end products 
was supported by the majority.  
Projectors: There was general agreement in a downw ard trend in the sales market for 
projectors. Respondents’ prefer red policy route, by a slight margin, was mandatory ecodesign 
requirements (regulation). The next preferre d route was the no acti on option. Labelling was 
not deemed appropriate.  
Some more details: 
For video recorders/players, approximately ha lf of respondents were manufacturers of main 
market video recorders and players, and from other industry representa tives. For projectors, 
approximately half of the respondents were projector manufacturers. For games consoles, 
over half the respondents were manufacturers and independent technical experts. Other 
respondents included environmental NGOs re presenting about 20% of responses.  
Games consoles The vast majority (over 75%) of respondents ag reed that certain policy options could be 
dismissed. The need for policy action in Europe was questioned, with nearly 75% of respondents stating there was no need. The preferred policy options, supported by the 
consultation, were the industry proposal, as a second preference the In ternational Agreement 
and thirdly the Mandatory Eco design Require ments (Regulation). I ndustry respondents were, 
naturally, supportive with th e industry proposed appro ach and levels, whereas NGO 
respondents suggested that regulati on would deliver results more quickly and cost effectively.  
Video recorders/players The vast majority (over 75% of  respondents) agreed  with the policy options assessed, and 
agreed with those policy options that were discarded from furthe r analysis. Just over half of 
respondents preferred the policy ro ute of no action (but to re-evaluate the market in 3 to 4 
 
EN 40   EN years). Just under half the respondents pr eferred a regulatory route was pursued. The 
exemption for high-end products was supported by the majority. There was general agreement 
in the consultation of a downward trend in the video recorder/player market overall.  
Projectors Nearly all respondents agreed that the policie s not developed further within the impact 
assessment were appropriate to dismiss. Overa ll, views on the need for policy action were 
mixed. The preferred policy route of respondent s, by a slight margin, was mandatory Eco 
design requirements (regulation). The next preferred route was the no action option. Labelling 
was not deemed appropriate as a policy option. There was general agreement in a downward 
trend in the sales mark et for projectors.  
 
EN 41   EN  
9.2. Annex II - Minutes Consultation Forum 
Draft Minutes/Summary Record of the Meeting  
Subject: Meeting of Consultation Forum under Article 18 of the Ecodesign 
Directive – Product Group Sound and Imaging Equipment 
Place and date: Brussels,  9 November 2012 
Chair: Kirsi Ekroth-Manssila 
Participants: See separate list of participants   
1. Welcome and Introduction  
The chair  opened the meeting. The occasion to c onvene this meeting was the submission of 
an industry proposal for the im portant product group 'game consoles' (agenda item 3). She 
thanked the console manufacturers Microsoft,  Nintendo and Sony (in the following: the 
manufacturers) for making this pr oposal available and for their willingness to explain it. She 
further explained that the Commission uses th is opportunity to update the Forum on the state 
of play concerning the entire product group 'sou nd and imaging equipment video player and 
recorder, projectors, and game consoles (age nda item 2). She referred to written comments 
received in advance of the meeting from th e Netherlands/Hans-Pau l Siderius and from 
Sweden, and distributed as paper copies. The agenda was adopted. 
2. Presentation and Discussion of the stat e of play of Sound and Imaging Equipment, 
focus on Video Players/Recorders and Projectors  
The Commission  gave a short introduction into the eco design priority principle for self-
regulation and its impact  assessment procedures, followed by  an introductory presentation of 
the state of play of the product group in gene ral. The Commission's consultant presented the 
preliminary findings of the Impact Assessment study with an emphasis on the recently closed 
public consultation. The consultation documents contain po licy options for the three product 
groups, and the consultation extends to the as sessment of the options put down there. The 
presentations and consultation documents are available on CIRCA.  
The manufacturers asked about the number of respondents of the consultation. They 
remarked that they had provided information and a model that should be reflected in the 
study, and asked to clarify the energy savings. ECOS  found the preliminary findings 
assuming a strong decrease of some products an d their disappearance by 2025 quite radical. 
ECOS assumed for example for video players only a 1% decrease pe r year but no steep 
decline, and asked to assess this aspect more carefully. The Commission  responded to review 
these aspects. ECOS underlined that these products woul d clearly be candidates for ecodesign 
requirements, and expressed their preference fo r a regulation. Furthermor e, ECOS asked if a 
decision has already been taken, or if another meeting would be convened before a decision. 
The Chair  answered that this meeting is the mome nt to consult stakeholders before any 
decision will be taken, and th at there are currently no plans for an additional meeting. 
DigitalEurope  regretted but confirmed the clear declin e in the market for video recorders and 
players. One reason for players is the increa sing availability of onl ine streaming, and for 
recorders that TVs sold today ofte n have an USB drive connection. High End Society 
confirmed the clear decline for physical  discs superseded by online streaming. DigitalEurope 
confirmed the same developments in the projecto rs market, specifically in Europe. Projectors 
including for example those in classrooms are being replaced by large screens, and the decline 
 
EN 42   EN will continue. ECOS  referred to the current economic crisis and remarked that it is hard to say 
whether this is the real reason for market decline.  
Sweden suggested  considering projectors in the ecode sign regulation for TVs to decrease 
administrative burden. 
The Commission  noted a very predominant agreement on the preliminary findings, and 
invited the Forum to provide further informati on particularly on market developments to be 
considered in the impact assessment. The Comm ission clarified that th e criteria to propose 
ecodesign measures are not ma rket developments, but envir onmental impacts. If there are 
clear indications of a decreasing market for vi deo players/recorders and projectors, likewise 
their impacts will go down. This must be taken into account in the impact assessment, and for 
the decision making if ecodesign m easures would make sense.  
The chair  concluded this agenda item and invited participants to send written comments by 
the end of November. 
3. Presentations and Discussion Game Consoles  
The Commission  gave an introductory presentation about that state of play of game consoles, 
and introduced the Draft Outline Proposal receiv ed from the game consoles manufacturers. 
The proposal and other policy options like mandato ry ecodesign or energy labelling have been 
issued via and subject to the public consultati on. The Commission explai ned that it is an 
explicit task of the Forum to contribute to assessing voluntary agreements and other self-
regulation measures. So far the industry proposal is not considered as a 'Voluntary Agreement' 
ready for immediate recognition,  but sufficient to commen ce the evaluation of the 
admissibility of this initiative as an a lternative to an implementing measure.  
The manufacturers  subsequently presented the proposal  in detail. The proposal and the 
slides are available on CIRCA. The Chair  opened the floor for discussion.  
ECOS commented on procedural and technical as pects. Questions were raised how the 
proposal will be implemented, how its targets will be reviewed and updated, how stakeholders 
will be involved and how transparency will be  ensured, how monitoring and reporting will be 
done, what sanctions will be imposed in cas e of non-compliance, and if arrangements are 
made if new products enter the market. Furthe rmore, ECOS stated that improvements on the 
levels and requirements of applica tions would be possible,  i.e. that the proposed thresholds for 
navigation and media play could be lower, th at requirements on auto  power down and power 
supply are missing, and very importantly that  non-energy requirements on recyclability, 
recoverability etc. are fully lacking.  
Sweden  welcomed the initiative from industry, the proposed definitions, a nd remarked that an 
intensive use should be assumed. Sweden compar ed the electricity consumption with large 
TVs which had been reduced to for example 43W, and found 90W pr oposed by industry too 
high, and suggested to introduce a dynamic appro ach with progressive limits as included in 
the Dutch proposal. Furthermore, Sweden raised questions about the format of the agreement, 
how requirements would be fulfilled, and how sanctions would be imposed. If these concerns cannot be allayed, Sweden suggest to introduce regulatory and progressive approach, and to 
start also considering recyclability issues. 
The UK echoed Sweden and welcomed the  draft proposal, but asked for a more ambitious 
proposal, and urged manufacturers to go beyond B AU. The UK remarked further that tier 1 
 
EN 43   EN would be too short and tier 2 too long, and identi fied a lack of details about future monitoring. 
The UK further suggested to reflect about softwa re issues and to invol ve games developers.  
ISFE – the Interactive Softw are Federation of Europe  responded to this issue and 
remarked that software developments are completely separated issues. Interactive software is published on a multitude of different hardware and virtual platforms and not just on consoles. It usually allows for online play between pl ayers from around the world. Focusing only on 
software produced for consoles would heavily distort these markets. ISFE highlighted the 
importance of global standards, and cautioned ag ainst EU standards only which would have a 
negative impact on the user e xperience and, consequently, on their revenue streams.  
Denmark  welcomed the proposal as an important first step and noted three challenges. 
Firstly, the relatively high energy consumption, secondly, that many units are not being 
switched off by users and that au to power down is missing, and th irdly, that game consoles 
are also used for other purposes (for screeni ng, DVDs etc.). Denmark suggested to refine the 
proposal and to set lower requirements already several years in advance.  
France found the proposal not ambitious enough a nd asked whether the voluntary agreement 
would meet all requirements of annex VIII. 
Representatives of the manufacturers  replied to the remarks. They explained that game 
consoles cannot be compared with TVs or with computers, or with media players, which work 
differently. Game consoles w ould be already relatively ener gy efficient and, its energy 
consumption within one generation always de creases significantly compared to the launch 
phase. The chip technology can reduce the consum ption, but not of the whole console system, 
and therefore of not more than 35%. System co mponents use less power t ogether than if used 
separately. The manufacturers und erlined their commitment to sa ve energy, but th at even with 
scaling architecture the system does not allow for more savings, and that its consumption 
cannot be as low as for a particular media pl ayer. Survey information would suggest that 
around 95% of the users switc h their products off.  
The manufacturers expressed con cerns that they coul d not afford further development costs. 
To cut energy consumption in half, a complete ly different system and different operation 
management would be necessary. The costs fo r such a product would be extremely higher 
leading to unrealistic long payback periods fo r consumers. Manufacturers stated that their 
products can barely meet the 90W power cap, that  the proposal is pretty ambitious, and that 
they don’t know how to get to more ambitious levels. Manufacturers further referred to the 
international dimension and their engagement fo r an agreement with Au stralia under the IEA 
mechanism. Manufacturers also expressed their commitment to update and refine its proposal, 
to consider the reasonable a lternatives suggested by the Ne therlands, and to add missing 
elements i.e. on a review process,  on noncompliance, or monitoring.  
In a second round of discussion, introduced by an additional presentation of the 
manufacturers, ECOS challenged the  information provided by the manufacturers, remarked 
that unfortunately only very little information is available how future generations of consoles 
will look like, and that it is not possible to ch eck the information. ECOS also called for a fair 
and comprehensive comparison with gaming PC s. ECOS, astonished about information 
provided by the manufacturers that the power  use of one console model can decrease 
significantly revision by revision, suggested to launch a console di rectly at a revision 3 or 4 
level, and called for ambitious targets of energy  efficiency to be achieved already very early 
 
EN 44   EN on in the product phase. ECOS assumed that  it would not be diffi cult and with limited 
additional costs for all manufacturers to impr ove the energy consumption of consoles.  
Germany  asked about consumer information and stat ed that it is important to have energy 
consumption provided on the product, and ca lled for a better reporting and monitoring.  
Denmark  noted that it is difficult to discuss futu re figures, but asked to better address the 
performance of the products. Denmark suggested  developing the requirements aiming at least 
life cycle costs.  
The chair , referring to information that the one console consumes only 40W, whereas the 
other high definition consoles consume 70-90W, challenged the proposed thresholds and asked whether there is perhaps room  for technological improvements.  
The manufacturers reacted to the comments. They expl ained that the primary function of 
consoles will remain gaming, and that the in creased gaming performance can result in higher 
power consumption. With more power for ga ming, 70-90W would be needed for functions 
with lower power use like medi a and navigation modes. The propos al is targeted  on a more 
efficient architecture a new console must use, which will ensure energy savings in all modes. Manufacturers explained that they provided as much  data as they can and that the proposal is 
more ambitious than business as usual, but that they are unable to say more about future levels 
for competition reasons.  
Referring to the lower consumption of one consol e, manufacturers explained that a different 
chip architecture accounts for their consumpti on. Other consoles would not be able to meet 
the 40W, and if such a requirement would be set,  architecture of their consoles would have to 
change completely. Manufacturers stated lower thresholds woul d be infeasible. They would 
not be able to recuperate the costs for developi ng such products, and they expressed that there 
is a risk that a whole gaming department woul d have to shut down. Ma nufacturers added that 
their proposal already considers the next W ii generation which coul d also require the 
proposed thresholds. Furthermore, a regulation in this regard woul d restrict innovation.  
Regarding other environmental issues beyond en ergy, the manufacturers explained that they 
use limited components. They would buy their components from a global market, and environmental aspects should be regulated rath er at industry wide level than for a product 
group. Concerning recyclability, plastic parts et c. manufacturers expressed preference for a 
more horizontal approach like in  the WEEE and RoHS Directives. 
4. Conclusion – next steps
 
The chair thanked the manufacturers for their cont ributions and asked whether they are 
willing to include more details into the proposal and to amend it. The manufacturers  
expressed their commitment to meet the ecodesign self-regulation criteria, and added that they 
are aiming for a global agreement, not just for Europe. The chair  acknowledged that for this 
product group consistent global standards coul d be more advantageous than European 
standards, and supported the work  towards a global agreement. ECOS remarked that an 
international agreement would not be a constr aint not to meet the ecodesign criteria for a 
voluntary agreement. The chair  made clear that a self-regulat ory initiative, which has under 
certain conditions a clear priority, must comp ly with the criteria of Annex VIII. The 
Commission will assess the proposal on this basis,  and the parties of the Consultation Forum 
shall contribute to assessing it.  
 
EN 45   EN Before concluding the meeting, the chair  thanked the participants for their important input, 
and invited the Forum to comment on the industr y proposal and specifica lly to reply to the 
following questions: Does the parties support this  self-regulatory initia tive, can the proposal 
be considered as voluntary agreement, and whic h amendments would be required? The chair, 
recalling agenda item 2, encouraged participants to send comments also on Video Players/Recorders and Projectors. The deadline for written comments is 30 November 2012  
to the functional mailbox ENTR-ECODESIGN@ec.europa.eu
.  
The Commission  asked to keep the deadline for al l comments related to the impact 
assessment process to allow the Commission to make swift progress with its impact 
assessment before the end of this year; important comments on the self-regulatory initiative will also be considered after. The chair  closed the meeting. 
Discussion Document of 4 October 2012
 
WORKING DOCUMENT FOR THE ECODESIGN CONSULTATION FORUM ON SOUND AND 
IMAGING EQUIPMENT (ENTR  LOT 3), 9 NOVEMBER 2012 
This Working Document is not a Draft Ec odesign Regulation for the product group "Sound 
and Imaging Equipment" (video players and reco rders, projectors, game consoles). Rather, it 
is a discussion note: (1) explaining the state of  play; and (2) introduci ng voluntary courses of 
action for games console by the industry sector. 
1. STATE OF PLAY Background: The Ecodesign Directive 2009/125/EC es tablishes the framework for the setting 
of ecodesign requirements for energy-related products. The first Working Plan of the 
Ecodesign Directive adopted on 21 October 2008 lis ts the product groups which have been 
considered as a priority fo r implementing measures in 200 9-2011. This list includes 'sound 
and imaging equipment'. A preparatory study for this product group wa s launched in January 
2009. The final report of the study was published in December 2010, on the dedicated Project 
Webpage: http://www.ecomultimedia.org/
. The study concluded that sound and imaging 
equipment meets the criteria of Article 15 of th e Ecodesign directive, i.e., that the product 
group presents a significant volume of sales on  the market, has a significant environmental 
impact and energy consumption, and presents a significant potential for improvements. The 
preparatory study identified at that time an estimated energy  saving potential of around 15 
TWh/year in 2020. 
Since the finalisation of the preparator y study, the Commission has followed the 
developments in the market for consumer electronics in general. The experience with other products like televisions has shown that both the technologi cal development and market 
developments and consumer behaviour have been  quite different from what was expected in 
preparatory studies. Technological developments are occurring ofte n at such a fast pace that 
many products from the leading producers would have met the projected energy efficiency 
levels even in the absence of Ecodesign requirements. 
Recently, the Commission has launched an Impact Assessment Study to support the 
preparation of its Impact Assessment, which is mandatory for all Commission proposals. One 
task of this study is also to reassess and update the forecasts of the preparatory study. The 
work is on-going, and includes a public stakehol der consultation. The first preliminary results 
of the Impact Assessment Study give the following picture:
 
 
EN 46   EN Video Players and Recorders: A re-assessmen t of the analysis of the preparatory study 
completed in 2010, which estimated a highest saving potential of up to 10.6 TWh/year in 2020, has concluded that the market for video play ers and recorders is in more rapid decline 
than previously thought. There is a shift from disc-based systems to internet-connected and 
other systems, from hard disk drive to USB-powered solutions, and also a shift toward media 
streaming, removing the need for a hard disk altogether. Already in the mid-term by 2025, it 
is forecast that there will be no new sales of  video recorder/player products, except for small 
volumes of niche, high-end products.  
Projectors: The market for projec tors with a saving potential of 0.6 TWh/year is also in more 
rapid decline than was previous ly thought. Indications are that projectors in many applications 
will continue to be replaced by widescreen televisions, which can now be as bright as projectors. It is considered likely that sales of projectors will continue to decrease until there 
are no new sales of projector pr oducts other than those require d for large auditoriums and e-
cinemas by 2025. The improvement potential fo r the main component, i.e., the lamp, is 
furthermore limited. Ultra high-pressure (UHP) discharge lamps have little scope for cost-
effective step changes in efficiency levels, an d the efficiency developments for solid state 
lamp (SSL) systems using light-emitting diodes (LED) are slower than predicted. 
Video game consoles: The energy saving potential  was estimated in the preparatory study as 
up to 3.7 TWh/year. Although recen tly a decrease in sales of th e current generation of game 
consoles has been observed, it has been concluded from present data that the market for game 
consoles is continuing to grow, with more products held  in stock, with increasing 
functionalities, such as motion- detecting peripheral devices, e xpanding the poten tial audience 
for game consoles. Game consoles were identifi ed as one of the largest category of energy use 
in households (besides the TV) in  the home entertainment area. Sa les of the next generation of 
consoles, anticipated to be on the market in around 2014, are expected to exhibit similar sales 
patterns and volumes as witnessed for the current generation of high definition game 
consoles.  
The Impact Assessment Study will refine the pr eliminary findings, and will include a public 
stakeholder consultation, star ting in October 2012. The questi onnaire will be available on 
CIRCA, and the DG ENTR website link to the online questionnaire will be: 
http://ec.europa.eu/enterprise /policies/sustainable-busines s/ecodesign/product-groups/sound-
imaging/index_en.htm . The study will run until the end of 2012, and will support the 
Commission's subsequent Impact Assessment. 
Subject to the result of this Impact Assessmen t, and further opinion exchange, the preliminary 
results suggest to pursue ecodesign parameters for game consoles only.  
Members of the Consultation Forum are invited to comment on the state of play for this 
product group. They are also invited to cont ribute to the Impact Assessment study.  
 
EN 47   EN 2. INTRODUCTION INDUSTRY PROPOSAL  
Background: The Ecodesign Directive gives priority to alternative courses of action, such as 
self-regulation, by the industry s ector(s) concerned (recital 18) . As a basic condition, such 
action needs a high level of environmental ambiti on, and needs to demonstrate that it is likely 
to deliver the policy objectives faster, or in a less costly manner, than mandatory 
requirements. Proposals for voluntary agreements (self-regulation) are recognised as a valid 
alternative to regulation if their assessment ag ainst the criteria of Annex VIII is deemed 
satisfactory (Article 17 ), taking into account the feedback  from the Consultation Forum. 
The product group 'game consoles' is unusual, in that none of the manufac turers is based in 
Europe, and that only three manufacturers repres ent this entire product sector. Therefore, the 
approach described in this paper is also unique. The manufacturer s of game consoles 
presented a draft proposal for a voluntary course of action in August 2012, and they 
confirmed that it could be circ ulated publicly forthwith, and coul d form part of the official 
consultation process. In a nutshell, the industr y proposal is detailed, and contains defined 
energy performance requirements, including test  procedures, measurements and verification 
test methods. The proposed main requirements ar e two tiers of power cap s for two operational 
modes, (a) the media playback and (b) the na vigation mode. The proposed thresholds for both 
modes are 90W for 2013 and 70 W for 2017. The proposal is enclosed with this note.  
In accordance with Article 18 of the Ecodesign Directive, it is a task of the Consultation 
Forum to assess voluntary agreements and othe r self-regulation measures. Members of the 
Consultation Forum are therefore invited to a ssess the 'Draft Outline proposal to further 
improve the energy consumption of Game consoles'. 
The Commission would like to make some additi onal remarks to be taken into account when 
assessing the initiative:  
General and procedural: 
 
(1) The Commission had several meetings with the three manufacturers in the industry 
sector concerned, namely Nintendo, Micr osoft, and Sony. The industry sector 
believes that an implementing ecodesign m easure is not justified, and considers a 
voluntary self-commitment to be the best way to achieve energy savings for game 
consoles. The latest version of the industry proposal is silent on its purpose as to whether or not it comprises a self-regulat ion, within the meaning of Article 17 and 
Annex VIII of the Ecodesign Directive.  
(2) At this stage, the industry proposal, with the heading "draft outline proposal", is not 
considered by the Commission as a 'Voluntary Agreement' ready for immediate recognition. However, the Commission c onsiders it as a draft  sufficient to 
commence the evaluation of the admissibility of this initiative as an alternative to an 
implementing measure, and has decided to submit it to the Consultation Forum.   
(3) All self-regulations must be assessed at least on the basis of the criteria in Annex 
VIII to the Directive. The part ies of the Consultation Forum n eed to contribute to this 
assessment using these criteria as their reference.   
(4) One contested question is if this product gr oup really meets all the criteria specified 
in Article 15 of the Ecodesign Directive, notably whether or not game consoles have 
a significant environmental impact, and improvement potential. Where a product 
 
EN 48   EN meets the criteria, it must be covered either by legislation or via self-regulation to the 
same extent, which therefore excludes a 'no action' option.    
(5) The Commission will consider  the industry proposal as an option in the already-
commenced Impact Assessment process, and has asked the external consultants to take it into account in the Impact Asse ssment study. The industry proposal is also 
included in the public stakeholder consultation. 
Technical: (1) The manufacturers disagreed with some  findings of the preparatory study. The 
manufacturers provided data comprising  a corrected analysis, and their own 
assumptions, including their estimation of an energy savings potential of some 30% 
less, at about 2.6 TWh/year (see also the Annex to the proposal: "Energy Savings"). 
(2) The manufacturers argue that the energy effi ciency of the main operating status of a 
console, i.e., the operational game play mode cannot be regu lated, due to the 
particular console architect ure. The manufacturers also  argue that approaches 
suitable for computers, such as 'TEC' (T otal Energy Consumption) allowances are 
also not applicable, and that energy consum ption restrictions of the game play mode 
would compromise the important high and pr ogressive user perfor mance. Instead, the 
manufacturers propose to regulate othe r modes than the game play mode, 
considering that game consoles are a multi-function media device.  
(3) The level of ambition of the proposed self-c ommitment has to be assessed. The main 
questions for this assessment are: (i) wh ether the overall energy performance of the 
product can be represented by the proposed operational modes; (i i) if the proposed 
power caps and its timing are adequate ; and (iii) whethe r other significant 
environmental aspects need to be considered.   
International: (1) No specific regulations on the performance of  game consoles in other countries or 
regions are known. The United States is  discussing a draft test method and 
performance requirements for EnergyStar,  and in Australia a possible voluntary 
agreement is being considered, with th e same industry representatives. All 
discussions came down in 2012 to the same approach with requirements on the two 
operational modes media playback/streami ng and the navigation mode, as proposed 
to the Commission. However, discussions re garding the power cap  levels for these 
two modes are on-going.  
(2) As none of the manufacturers are based in Europe, new ways could also be pioneered 
to trigger action duri ng the design phase. For example, mechanisms with improved 
transparency could be speci fied, which would allow th e monitoring of continuous 
improvements of products, i.e. by making pub licly available the power consumption 
of all models in the relevant modes. 
(3) The potential for an international agreemen t on game console energy efficiency is 
being explored, possibly broke red by the Australian Depart ment of Climate Change 
and Energy Efficiency (DCCEE) under th e International Energy Agency banner 
within the 4E - Efficient Electrical End-Use Equipment Implementing Agreement. An international agreement could involve as  a minimum, for example, the European 
Commission, the Australian DCEEE and th e Californian Energy Commission, which 
are currently involve d in the discussion. 
 
 
EN 49   EN Summary of written comments received after the meeting:  
The Commission has received comments from fi ve Member States (DE, FR, NL, DE, UK) 
and a joint comment from Environmental NGOs  (ECOS, EEB, Friends of the Earth Europe, 
WWF EPO, CAN Europe and INFORSE Europe). 
The written comments correspond to the oral  comments at the meeting. In summary, the 
Forum welcomed the initiative by consoles manuf acturers, but its opinion was rather reserved 
whether it would be worthwhile to endorse  the proposal as voluntary agreement under the 
Ecodesign Directive. The Members of the Forum predominantly found that  the proposed level 
of ambition should be raised, and remarked that  the initiative does not yet comply with some 
of the criteria of Annex VIII of the Directiv e, like monitoring and reporting. Concerning 
video recorders/players and projectors, the Forum predominately supported 'no action', 
provided that updated market data would support it. 
 
EN 50   EN  
9.3. Annex III – Product scope description 
Game consoles: A game console is a mains power ed stand-alone device which is marketed as 
a product providing video game playing as its pr imary function through an external screen. It 
includes the current generation consoles – X box360, PS2&3, Wii, and the next generation of 
game consoles. Nintendo has released a new game  console, the Wii U, to the EU market in 
late 2012 whilst Sony and Microsoft are not expected to  release new consoles until late 2013 
or early 2014. There has been a continued growth in the us age of game consoles for 
functionalities other than gaming, such as vide o streaming. In addition the availability of 
motion-detecting peripheral devices  (Kinect, Move etc.) is likely to have been responsible for 
expanding the potential audience for game cons oles. Remark: The large variation in power 
demand during active use amongst the current game consoles on the market is primarily due to the amount of processing power provid ed by each product. Power demand is closely 
correlated to computing performance of the GP U and CPU due to factors such as increasing 
transistor numbers and frequency of operatio n. Higher power demanding game consoles 
(PlayStation and X-Box) offer significantly more  processing capability and therefore require 
more power to deliver the higher level of gaming functionality. 
Video players / recorders: in cluding DVD players / recorder s, Blu-ray (BD) players / 
recorders and hard disc drive (HDD) based devices. A video play er/recorder is a standalone 
device whose primary function is to  decode videos to an output a udio/video signal. It is mains 
powered, has no tuner, and does no t have a display for viewing vi deo. In the future, the shift 
from disc-based systems to internet-connected systems will mean that a significant proportion 
of mains-powered devices are be ing replaced by battery-powered mobile devices.  In addition, 
HDD-based systems are shifting from internal to  external HDDs that could for example be 
USB powered, which are out of the scope of this impact analysis. 
Projectors: including school proj ectors, office projectors a nd home cinema projectors. A 
projector is a mains powered, optical device, fo r processing analogue or digital video image 
information, in any, broadcasting, storage or ne tworking format to modulate a light source 
and project the resulting image onto an external  screen. For projectors, more recent research 
has suggested that a large share of projector sales is now being repl aced by sales of more 
affordable and equally bright LED backlit TV s – addressed via the Ecodesign TV Regulation 
(EC) No 642/2009.  In a ddition, it is important to note th at the highest efficiency lamps 
(mercury vapour UHP) are being completely phas ed out, under pressure from eco-labelling 
schemes due to their mercury content – th is provides less opportun ity for efficiency 
improvements in the medium term.   
 
EN 51   EN  
9.4. Annex IV - Market Situation for Sound and Imaging Group 
Almost all mass-market video players/reco rders (DVD/Blu-Ray), pr ojectors and game 
consoles are assembled in China. Integrated  circuits and other components are produced 
mainly in South East Asia. Most components ar e manufactured in the following locations:  
 Video player / 
recorders Projectors Game consoles 
Component 
manufacture location • Myanmar and 
China (Lenses) 
• China and 
Korea (trays) 
• China and USA 
(chips) 
 • China • Canada, China, Singapore, South 
Korea, Taiwan, Thailand, USA (Microsoft Xbox 360) 
• Canada, China, Japan, Singapore, 
South Korea, Taiwan (Sony PlayStation 3) 
• Canada, China, Singapore, 
Taiwan (Nintendo Wii) 
 
Game Consoles:  The share of the EU market is as follows: 
Manufacturer 2012 sales 2012 stock 
Sony 40% 45% 
Microsoft 33% 22% 
Nintendo 27% 33% 
Almost all mass-market video players/recorders  (DVD/Blu-Ray), proj ectors and game 
consoles are assembled in China.  Video record er manufacture is declining. There is a shift 
toward separation of the hard/optical drive fr om the product – as has been observed in new 
generations of products releas ed recently (which would no l onger be classified as video 
recorders as a result). 
In addition to the information provided in ch apter 2.7 baseline scenar io and in chapter 4.2.1 
baseline option, the market situation for vi deo recorders can be described as follows: 
• It is highly likely that th e downward trend in sales will continue. By 2025 there will be 
no new sales of optical disc based video recorder  player products (except for small volumes of 
niche high end products / modul es for repair purposes. 
• A continued shift from disc based syst ems to internet connected TVs and other 
systems, resulting in a significant proportion of mains powered devices being replaced by 
battery powered mobile devices.  
• Hard disk drive (HDD) based systems continue  to shift from internal to external HDDs 
that could, for example, be USB powered, and toward streaming clients, removing the need 
for a hard disk altogether.  
• The developments towards technology im provements for a product that becomes 
extinct are limited. However, a main natural dr iver is the miniatur isation. More compact 
 
EN 52   EN designs create barriers to heat dissipation, and therefore manufacturers ar e likely to focus on 
higher energy efficiency to re duce undesirable heat.     
Projectors:  The main brands are Epson, Sony Toshib a, Dell, Canon and Hitachi. Design is 
carried out mainly in America and Europe, by Japanese owned companies.  Research and 
development into DLP light engines is headed by Texas Instruments, whilst LCD light engine 
development is led by Canon and Sony. 
In addition to the information provided in ch apter 2.7 baseline scenar io and in chapter 4.3.1 
baseline option, the market situation for projectors can be described as follows: 
• Many projectors will continue to be replaced by widescreen televisions  (which can now be 
as bright as projectors) in a pplications such as small to medium office conference rooms 
and schools. 
• Projector products using ultra high-pressure  (UHP) discharge lamps will continue to 
perform at the average efficiency levels predicted by the prepar atory study, with little 
scope for cost effective step changes in efficiency levels. 
• Solid State lamp (SSL) systems (LED/Laser) w ill continue to improve in efficiency at a 
slower rate than predicted in  the preparatory study, perfor ming in line with home cinema 
projectors. 
• Expected sales of projectors will continue to decrease un til there are no new sales of 
projector products other than those require d for large auditoria and E-Cinema by 2025. 
This latter category is expected to account  for less than 200,000 unit sales a year will 
therefore not qualify for possible ecodesign measures. 
Further remarks on a possible mandatory ecodesign option for projectors: The reassessment 
has shown that one key assumption about the projected light output efficiency in the 
preparatory study was too optimis tic. Therefore these efficien cy requirements have been 
modified accordingly. Furthermore, the requirements proposed below for this option are based upon an assessment of available technology. It appears that whils t improvements in efficiency 
from current levels are possibl e, they are not possible within  a least lifecycle cost solution. 
More efficient projector bulbs cost around thre e times more than standard bulbs, but do not 
save proportionately on consumption. Costs woul d have to be passed onto the consumer, and 
as energy savings would not be very large, it  is unexpected that consumers would be willing 
to pay the extra for a more efficient projector – especially when there are alternative, and more affordable products available. 
 
EN 53   EN  
9.5. Annex V – Stock developments of the 3 individual products groups 
 
Figure AV1: Stock of games consoles EU-27 (million units) 
 
 
Figure AV2: Stock of video players/recorders in EU-27 (million units) 
 
EN 54   EN 
 
Figure AV3: Stock of projectors EU-27 (million units) 
 
EN 55   EN 9.6. Annex VI - Assumptions 
The baseline scenario is based on the following assumptions: 
Sales: In 2010, game console  sales were estimated to be around 17.7million. By 2025 it is 
predicted that this figure will reduce to around 9.8 million. Sales of the current generation of 
game consoles are starting to de cline. However, this decline is  not as rapid as previously 
thought due to new innovations such as motion controllers and improved video on demand 
technologies continuing to captu re consumers’ interest. For video players/recorders  
predictions suggest that by 2025, th ere will be no new sales of Blu-ray players and recorders 
with 2 million Blu-ray players in stock. There are assumed to be no new sales of HDD or 
DVD players. Projector annual sales ar e expected to drop off to 1.62 million. 
Lifetime:  The average economic lifetime is assumed to be 6 years for video players and 
recorders, projectors and game consoles.  The main driver for replacement of game consoles 
is the release of a new generation of products  (although the original console may still be 
retained for some time subsequently). For low- cost projectors, the replacement driver can 
often be lamp failure, although higher value pr ojectors are often refurbished and have a 
secondary life of around 2 years (dictated by lamp life).  For video players / recorders the 
main driver for replacement include s fashion and new technology trends. 
Use:  Game consoles with power management se ttings in place are assumed to spend on 
average around 22.0 hours per day in standby (or networked standby), 1.4 hours per day in 
active use and 0.60 hours per day in idle/inactive states.  For non-power-managed consoles, 
an additional 0.4 hours in idle are assumed, w ith a corresponding reduc tion in time spent in 
standby.  DVD/Blu-ray video recorders assumed to spend 0.75 hours per day in a play mode, 
0.25 hours per day in a record mode, 18 hours in  standby, and the remaining time between on-
idle and fast start modes.  Projectors are assu med to spend different times in on- and standby- 
modes depending upon application (Home cine ma 0.5 hours on, 20 hours standby, Office 
(portable) 1.5 hours / 0.8 hours, School 3 hours on-play mode / 4-6 hours standby).   
Efficiency:  It is assumed that the unit efficiency of the products covered will be increasing 
due to the Eco-design regulation on standby/off mode and to a lesse r extent to external power 
supplies.  
Auto Power Down (APD):  This is a standard feature for projectors and video players and 
recorders and is included in the BAU usage profile.  For game consoles, there is some 
potential for improvement in APD in the policy scenarios considered w ith shorter periods of 
inactivity before power down envisaged. APD functi onality is expected to  be included in all 
new generations of consoles launched to the ma rket from 2012 onwards and is included in all 
current game consoles that suppor t high definition media play back. 
Standby and Network Standby requirements are included in the baseline: For games 
consoles, including Network Standby requirements in the baseline has the effect of lowering 
total energy consumption of the product group from 2016. This reduction ranges from 10% to 
15% compared to a future scenario that ex cludes network standby requirements. Including 
Network Standby requirements in the baseline is therefore reducing the overall energy 
consumption of the baseline, a nd is a noteworthy driver that  is reducing ba seline energy 
consumption. It is not however, having a highl y significant impact on its own, and further 
policy measures can achieve more. Network standby accounts for estimated savings of 2.2 GWh per annum by 2025. 
For projectors, the energy efficiency impr ovements created by Network Standby requirements 
would be expected to prevail in a baseline th at excludes the requirements, due to existing 
lamp technology and movement towards 1W st andby. Therefore, a baseline considering 
 
EN 56   EN Network Standby achieves little improvement to en ergy efficiency than would be expected to 
prevail without Network Standby.  
Further details on the assumptions and on the assumptions of the modelling of the policy 
options is available via the Impact Assessment Study.  
 
EN 57   EN  
9.7. Annex VII – Improvement Potential 
Game Consoles 
– Reducing the power demand - sta ndby, inactive or active use.  
– Increasing hardware flexibility to perfor m less computationally intensive tasks 
with some of the processing resources di sabled – e.g. media playback is often 
much higher in game consoles than  in standalone media devices. 
– Reducing the duration and freque ncy of auto-wake events.  
– Implementing and improving auto power dow n functionality, to enable the console 
to automatically enter a low power stat e (normally standby or networked standby) 
if there is no user input for a predefined time.  
Video Players / Recorders 
– Changing the architecture to make the ha rd disk drive (HDD) external to the 
product (attached by USB).  This reduc es power consumption and enables 
sourcing of efficient HDDs. 
– Using energy-optimised chip sets (ma ss market only – not high end, which have 
multi-chip configurations).  The highest integrated chip solutions (system on chip or similar) integrate all components of an el ectronic device into a single chip.  This 
assists with light-weighting but may result in some waste implications as repair of 
single chip solutions is not possible. 
– Offering energy efficient quick -start modes and quick-start  not enabled as default. 
Projectors 
– Offering eco mode as sta ndard available feature 
– Using more efficient lighting modules 
– Using optimised lens solutions 
– Using efficient light path beam splitting optics