COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT Accompanying the document Report from the Commission to the European Parliament and the Council on the voluntary ecodesign scheme for complex set-top boxes
Date: 2012-11-22
Institutions: European Commission
Subjects: EU control, electronic device, energy saving, environmental impact, product design, self-regulation, technical standard

EUROPEAN 
COMMISSION 

Brussels, 22.11.2012  
SWD(2012) 392 final 

COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

Report from the Commission to the European Parliament and the Council 

on the voluntary ecodesign scheme for complex set-top boxes 

{COM(2012) 684 final} 
{SWD(2012) 391 final} 

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COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

Report from the Commission to the European Parliament and the Council 

on the voluntary ecodesign scheme for complex set-top boxes 

1. 

BACKGROUND 

The  Ecodesign  Directive  2009/125/EC  establishes  a  framework  for  the  setting  of  ecodesign 
requirements for energy-related products. An energy-related product (ErP), or a group of ErPs, shall be 
covered by ecodesign implementing measures, or by self-regulation, if the ErP represents significant 
sales volumes, while having a significant environmental impact and significant improvement potential 
(Article 15). 

These  criteria  are  fully  met  by  complex  set  top  boxes  (CSTBs),  which  are  receivers  for  pay  TV. 
Although the installed base of CSTBs is expected to stabilise in 2010 at around 82 million and start 
decreasing after 2015 to 41 million in 2020, their overall energy consumption will still be considerable 
as the market will be increasingly dominated by devices providing additional functionalities requiring 
increased power. 

2. 

APPROACH FOR SETTING ECODESIGN REQUIREMENTS OR ENDORSING SELF-REGULATION 

The  approach  for  developing  ecodesign  implementing  regulations  or  self-regulation  and  this  impact 
assessment was structured in four steps: 

Step 1: assessment of the criteria for ecodesign implementing measure/self-regulation as laid down in 
Article  15(2a)-15(2c)  of  the  Ecodesign  Directive,  taking  into  account  the  ecodesign  parameters 
identified in Annex I of the Ecodesign Directive; 

Step  2:  consideration  of  relevant  European  Union  initiatives,  market  forces  and  environmental 
performance disparities of the equipment on the market with equivalent functionality as laid down in 
Article 15(2) of the Ecodesign Directive; 

Step 3: establishing policy objectives including the desirable level of ambition, the policy options to 
achieve  them,  and  the  key  elements  of  an  ecodesign  implementing  regulation  as  required  by  Annex 
VII to the Ecodesign Directive and the key elements of self-regulation as required by Annex VIII to 
the Ecodesign Directive; 

Step  4:  environmental,  economic  and  social  assessment  of  the  impacts  on  environment,  consumers, 
with  a  view  to  the  criteria  on  implementing  measures  set  out  in  Article  15(5)  of  the  Ecodesign 
Directive. 

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3. 

SUMMARY OF THE RESULTS 

3.1. 

Step 1. Legal base for an implementing measure or self-regulation: compliance with the 
Ecodesign Directive, Article 15, Annex VIII 

In  order  to  assess  the  criteria  for  ecodesign  implementing  measures  or  self-regulation  as  laid  out  in 
Article 15(2) of the Ecodesign Directive, the Commission has carried out a technical, environmental 
and economic study for CSTBs ("preparatory study")1 following the provisions of Article 15(4a) and 
Annex II to the Ecodesign Directive. 

With  regard  to  the  criteria  established  by  Article  15(2)  of  the  Ecodesign  Directive,  the  preparatory 
study concludes that the most significant environmental impact is electricity consumption during the 
use-phase, and the following results were established for the EU: 

Article 15 (2a): 

Article 15 (2b): 

Annual sales volume in the 
European Union 

59 million in 2010  
20 million in 2015 
10 million in 2020 

Environmental impact, in 
particular use phase 
electricity consumption 

10 TWh in 2010  
21 TWh in 2015 
11 TWh in 2020 

Article 15 (2c): 

Improvement potential for 
power consumption 

Up to 60% 

The  volume  of  sales  of  approx  60  million  units  per  year  is  far  above  the  indicative  200000  units 
provided for in the Ecodesign Directive. 

The annual electricity consumption of CSTBs for EU-27 in 2010 approx. corresponds to the electricity 
consumption  of  Iceland.  Although  the  stock  of  CSTBs  will  decrease  by  2020,  their  energy 
consumption will remain stable due to new functionalities necessitating additional power. 

Assuming  that  the  average  typical  energy  consumption2  (hereafter  'TEC')  is  improved  by  50%,  the 
annual electricity consumption of CSTBs would be reduced by approx. 7 TWh annually in 2015 (when 
the aggregated electricity consumption of these devices will peak), which corresponds approx. to the 
annual  electricity  consumption  of  Luxembourg,  and  is  considered  to  be  significant.  A  further 
significant environmental impact is waste, which is targeted by waste policy3 ("WEEE"). 

The improvement potential leads to a reduction of life cycle costs (cost-effective) without significantly 
increasing  the  purchasing  price,  because  it  is  related  to  technical  solutions  which  do  not  involve 
significant additional costs. 

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2008, 

documentation 

EuP Preparatory study "Lot 18 - Complex set-top boxes", Bio Intelligence Service S.A.S, France, final report 
of  December 
ecodesign  website 
http://ec.europa.eu/energy/efficiency/studies/ecodesign_en.htm 
A  method  of  testing  and  comparing  the  energy  performance  of  computers,  which  focuses  on  the  typical 
electricity consumed by a product while in normal operation during a representative period of time. 
Directive 2002/96/EC of the European Parliament and of the Council of 27 January 2003 on waste electrical 
and electronic equipment, OJ L 37, 13.2.2003, p. 24. 

the  DG  ENER 

available 

on 

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3.2. 

Step 2. Existing initiatives and capacity of market forces to address the issue 

Further to Articles 15(2) and 15(4c) of the Ecodesign Directive, relevant European Union and national 
environmental legislation is considered. Related initiatives both on European Union and Member State 
levels are taken into account and barriers preventing for market take up of technologies with improved 
environmental performance are analysed. 

Several  market  failures  have  been  identified  to  explain  that  cost-effective  technologies  leading  to 
energy  efficiency  improvements  are  not  penetrating  the  market  to  a  satisfactory  extend  by  market 
forces  alone.  The  vast  majority  of  CSTBs  are  not  purchased  by  the  user  (who  ultimately  pays  the 
electricity  bill),  but  by  TV  service  providers,  and  are  provided  to  the  consumer  as  part  of  a  service 
(split  incentives).  Therefore  insufficient  incentives  exist  for  manufacturers  to  optimise  the 
environmental performance of CSTBs, in particular the energy consumption. 

Several  initiatives  at  European  Union  level  (Ecodesign  Regulation  1275/2008,  European  Code  of 
Conduct  for  Digital  TV  Services)  and  at  Member  State  level  aim  at  improving  the  environmental 
performance  these  products  but  their  impact  is  limited.  Therefore  additional  legislative  or  non-
legislative action pursuant to the Ecodesign Directive should be taken on EU level. 

Conclusion of Steps 1 and 2 

The analysis carried out in Steps 1 and 2 shows that: 

– 

– 

– 

– 

the volume of sales and trade of CSTBs in the European Union is significant; 

the environmental impact of CSTBs is significant, the main environmental aspect being the 
electricity consumption; 

significant cost-effective improvement potentials for the electricity consumption exist; 

initiatives  on  European  Union  and  Member  State  level,  and  market  forces  alone  do  not 
capture the improvement potential for power consumption to a satisfactory extent. 

It  is  concluded  that  the  criteria  established  in  Article  15(2)  of  the  Ecodesign  Directive  are  met,  and 
CSTBs  should  be  covered  by  an  ecodesign  implementing  measure  or  by  self-regulation  pursuant  to 
Article 15(1) of the Ecodesign Directive. 

3.3. 

Step 3. Policy objectives and levels of ambition 

Further to Annex II to the Ecodesign Directive, the level of ambition for improving the electricity 
consumption of CSTBs should be determined by analysis of the least life-cycle cost for the user. The 
results are reflected in the objectives that the considered policy options aim to achieve. 

Several  policy  options  for  achieving  a  market  transformation  realizing  the  appropriate  level  of 
ambition are considered, including the business as usual case, self-regulation, energy labelling and an 
ecodesign regulation on CSTBs. 

However  the  impact  analysis  is  focused  on  comparing  a  possible  ecodesign  regulation  with  the 
voluntary agreement to improve the energy efficiency of CSTBs (VA) that was tabled by the Digital 
Interoperability Forum. Voluntary agreements/self-regulation under the Ecodesign Directive requires a 
high level of environmental ambition and need to demonstrate that they are likely to deliver the policy 
objectives  faster  or  in  a  less  costly  manner  than  mandatory  requirements.  In  such  case,  they  are 
considered  a  preferred  option  (recital  18  to  the  Ecodesign  Directive).  Proposals  for  voluntary 
agreements  (self-regulation)  are  recognised  as  a  valid  alternative  to  regulation  if  their  assessment 
against  the  criteria  of  Annex  VIII  to  the  Ecodesign  Directive  is  deemed  satisfactory  (Article  17), 
taking into account the feedback from the Consultation Forum. 

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3.4. 

Step 4. Environmental, economic and social impact assessment 

An assessment and comparison of a possible regulation and the VA is carried out. The two options are 
analysed taking into account the criteria set out in Article 15(5) of the Ecodesign Directive, and the 
impacts on manufacturers including SMEs. The degree of intensity of the options varies regarding the 
stringency of the requirements, the timing, the market coverage, and the procedure for monitoring. In 
addition in line with the provisions of the Directive the proposed VA is assessed against the criteria of 
Annex VIII. 

– 

– 

Option 2: the Voluntary Agreement sets targets for the energy consumption of CSTBs in two 
tiers set for July 2010 and July 2013, the levels broadly correspond to the recommendation 
of the preparatory study. The targets will have to be met by 90% of the products placed on 
the market/put into service by the individual signatories of the VA; 

Option 3: mandatory ecodesign requirements become effective in three tiers- July 2011, July 
2012, and January 2014. 

The following accumulated electricity and cost savings, and avoided CO2 emissions for the products 
placed on the market from July 2010 through December 2020 are expected: 

Accumulated 
electricity 
consumption 

Accumulated 
electricity 
savings 

Accumulated 
electricity cost 
savings4 

Accumulated
avoided CO2 
emissions5 

(TWh) 

(TWh) 

(billion EURO) 

(Mt) 

No policy 
(Baseline 1) 

Option 2 

Option 3 

159 

115 

114 

- 

44 

45 

- 

6 

6.2 

- 

21 

21 

The above table indicates the difference between the impact of the voluntary and mandatory approach 
is negligible. 

The  following  table  summarizes  the  considerations  on  the  impacts  of  the  options  2  (VA)  and  3 
(regulatory) compared to the baseline scenario, and assesses them on a relative scale from 1 (low) to 4 
(high): 

Economic impact 
(costs) 

Environmental 
impact 
(electricity/CO2/ 
electricity cost 
savings) 

Social impact (risk 
for job losses in 
SMEs) 

Improvement 
potential in the mid 
and long term 

Option 2 (VA) 

Option 3 
(regulation) 

1 

2 

3 

3 

1 

1 

4 

2 

It is concluded that Option 2 has a somewhat smaller cost for Member States (as the burden linked to 
the  verification/monitoring  is  shifted  to  the  industry)  and  for  industry  (as  the  voluntary  agreement 
allows  it  not  to  redesign  products  across  the  board,  but  leaves  10%  of  the  fleet  uncovered  by  the 
requirements). Most importantly option 2 offers higher potential for further improvement. 

4 
5 

Assumption: 0.136€/kWh  
Assumption: 0.4 kg CO2/kWh 

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Conclusion on Step 3 and Step 4 

A comparison of those options and the assessment of Option 2 against the Annex VIII to the Directive 
show that the VA is the preferred option. 

The VA implies the following: 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

cost-effective  reduction  of  electricity  consumption  of  6,5  TWh  by  2016  compared  to  the 
baseline scenario, corresponding to electricity cost savings of 884 million EURO, and 2,6 Mt 
avoided CO2 emissions; 

the requirements of Directive 2009/125/EC, in particular Recital 18 and Annex VIII are met; 

requirements enter into force faster and are less costly than in the case of regulation; 

compatibility and complementarily with existing policy instruments; 

correction of market failures and improvement of the functioning of the internal market; 

no significant administrative burdens for manufacturers or retailers; 

increase  of 
insignificant, 
overcompensated by savings during the use-phase of the product; 

if  any, 

the  purchasing  cost,  which  would  be 

largely 

that the specific mandate of the Legislator is respected; 

no significant impacts on the competitiveness of industry and employment, and in particular 
in  the  SMEs  sector  due  to  the  small  absolute  costs  related  to  product  re-design  and  re-
assessment; 

policy objectives are achieved in a flexible way in line with the better regulation agenda; 

the  involvement  of  service  providers  presents  an  opportunity  to  significantly  decrease  the 
energy consumption of CSTBs in the mid- and long-term. 

4. 

MONITORING AND EVALUATION 

The procedure for monitoring and reporting will look as follows: 

– 

– 

– 

– 

– 

The Steering Committee follow progress and results of the VA and agree on practicalities, 
such as the selection of an independent third-party/inspector that will be collecting the data 
from the individual signatories, and transmitting the aggregated results to the Commission. 

Signatories will annually submit to the Commission a report via an independent third- party. 

The members of the Consultation Forum will be consulted on an annual basis to take stock 
and monitor the results of the VA. 

The  Commission,  assisted  by  the  Committee  on  the  Ecodesign  of  Energy-related  Products 
will consider whether the objectives of the VA are met. 

If  the  Commission  considers  that  the  VA  failed  to  achieve  its  objectives  it  will  consider 
proposing a Regulation instead. 

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