COMMISSION STAFF WORKING DOCUMENT 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, high-definition television, product design, self-regulation, technical standard

EUROPEAN 
COMMISSION 

Brussels, 22.11.2012  
SWD(2012) 391 final 

COMMISSION STAFF WORKING DOCUMENT 

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) 392 final} 

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TABLE OF CONTENTS 

COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT 

Procedural issues and consultation .............................................................................. 4 

Organisation and timing............................................................................................... 4 

Transparency and outcome of the consultation process............................................... 4 

Problem definition........................................................................................................ 5 

Introduction.................................................................................................................. 5 

Product scope ............................................................................................................... 6 

Market failures ............................................................................................................. 6 

Related initiatives on European Union and Member State level ................................. 6 

Baseline Scenario......................................................................................................... 7 

Legal basis for voluntary agreements under the Ecodesign Directive......................... 8 

Improvement potential ................................................................................................. 8 

Objectives..................................................................................................................... 8 

Policy options............................................................................................................... 9 

Option 1: No new EU action........................................................................................ 9 

Option 2: Self regulation.............................................................................................. 9 

1. 

1.1 

1.2 

2. 

2.1 

2.2 

2.3 

2.4 

2.5 

2.6 

2.7 

3. 

4. 

4.1 

4.2 

4.2.1  Rationale and main elements ....................................................................................... 9 

4.2.2  Assessment against Annex VIII of the Directive....................................................... 10 

4.3 

4.4 

5. 

5.1 

Option 3: Ecodesign requirements ............................................................................. 11 

Option 4: Mandatory energy labelling for CSTBs under Directive 2010/30/EC....... 11 

Impacts analysis ......................................................................................................... 11 

Type and level of ambition of ecodesign requirements/targets ................................. 12 

5.1.1. 

Improvement options ................................................................................................. 12 

5.1.2.  Level of ambition and timing..................................................................................... 12 

5.2 

5.3 

Reporting/measurement/verification.......................................................................... 13 

Economic impacts ...................................................................................................... 13 

5.3.1  Costs related to improved technology and production, re-design and supply chain.. 14 

5.3.2  Costs related to reporting/measurement/verification ................................................. 14 

5.3.3  Administrative costs for Member States .................................................................... 15 

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5.4 

Social impacts ............................................................................................................ 15 

5.4.1  Affordability of equipment ........................................................................................ 15 

5.4.2 

Impact on the functionality of equipment .................................................................. 15 

5.5 

Annual and accumulated electricity, electricity cost and CO2 emission savings by 
2020............................................................................................................................ 15 

5.5.1 

Electricity savings (including cost)............................................................................ 15 

5.5.2  Accumulated electricity cost savings through the VA and ecodesign requirements . 17 

5.5.3 

Potential accumulated electricity cost savings through the implementation of power 
management options (APD and low-power standby) ................................................ 17 

5.5 

Comparison of the sub-options .................................................................................. 18 

6. 

7. 

Conclusion ................................................................................................................. 18 

Monitoring and evaluation ......................................................................................... 19 

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COMMISSION STAFF WORKING DOCUMENT 

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 

Lead DG: DG TREN 

Associated DG: DG ENTR 

Other  involved  services:  SG,  LS,  DG  ENV,  DG  COMP,  DG  ECFIN,  DG  INFSO,  DG 
MARKT, DG SANCO, DG TRADE, DG CLIMA 

1. 

PROCEDURAL ISSUES AND CONSULTATION  

1.1 

Organisation and timing 

The proposed Voluntary Agreement is based on the Directive 2009/125/EC of the European 
Parliament and of the Council establishing a framework for the Commission to set ecodesign 
requirements  for  energy-related  products1,  in  the  following  abbreviated  as  "Ecodesign 
Directive".  An  energy-related  product  (ErP),  or  a  group  of  ErPs,  shall  be  covered  by 
ecodesign implementing measures, or by self-regulation (cf. criteria in Article 19), if the ErP 
represents  significant  sales  volumes,  while  having  a  significant  environmental  impact  and 
significant improvement potential (Article 15).  

The  Commission  has  carried  out  a  technical,  environmental  and  economic  analysis  in 
preparation  of  these  initiatives,  in  the  following  called  "preparatory  study".  The  preparatory 
study was carried out by a consortium of external consultants2 on behalf of the Commission's 
Directorate General for Energy and Transport (DG TREN).  

On  12  October  2009  a  meeting  of  the  Ecodesign  Consultation  Forum  established  under 
Article 18 of the Ecodesign Directive was held (details are provided below).  

1.2 

Transparency and outcome of the consultation process 

External expertise on complex set-top boxes (hereafter 'CSTBs') was gathered mainly in the 
framework  of  the  preparatory  study.  The  preparatory  study  provided  a  dedicated  website3 

1 
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OJ L 285 of 31.10.2009, p. 10. 
EuP Preparatory study "Lot 18 – Complex set-top boxes", Bio Intelligence Service S.A.S, France, final 
the  DG  ENER  ecodesign  website 
report  of  December  2008  documentation  available  on 
http://ec.europa.eu/energy/efficiency/studies/ecodesign_en.htm 
http://www.ecocomplexstb.org/ 

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where  interim  results  and  further  relevant  materials  were  published  regularly  for  timely 
stakeholder consultation and input.  

During  the  meeting  of  the  Ecodesign  Consultation  Forum  on  12  October  2009  the  Digitial 
Interoperability  Forum  presented  a  proposal  for  a  Voluntary  Industry  Agreement  aiming  at 
limiting  the  power  consumption  of  CSTBs  (hereafter  'VA')  which  was  largely  based  on  the 
results of the preparatory study. The proposal together with explanatory notes by Commission 
staff were posted on DG TREN's  ecodesign website, and  stakeholder comments received in 
writing before and after the meeting are included in the Commission's CIRCA system.  

The  position  of  main  stakeholders  on  the  key  features  of  the  proposal  for  a  Voluntary 
Agreement presented in the meeting of the Consultation Forum meeting on 12 October 2009 
can be summarised as follows. 

The Member States support in principle the industry proposal but would welcome a further 
improvement of the level of ambition in the second tier. The industry was asked to provide 
further information/evidence on the level of market coverage of the Agreement; the target in 
this respect should be around 80-90% (of products placed on the market). The industry was 
asked to provide further clarification on the governance of the VA. 

NGOs  indicate  that  in  general  regulation  is  preferable  over  self-regulation.  NGOs 
acknowledge that the industry proposal on CTBs has certain merits (e.g. the involvement of 
manufacturers as well as service providers) however it needs to be improved in terms of the 
representativeness and targets for the second tier.  

The Industry pointed to the advantages of this initiative as compared to regulation, i.e. faster 
entry into force of the requirements, greater flexibility, availability of data, and possibility of 
all  market  actors  to  work  together  towards  greater  energy  efficiency  of  equipment.  The 
industry committed to providing the Consultation Forum with an independent assessment of 
the  market  coverage  of  the  VA.  Lastly,  the  industry  confirmed  that  it  will  be  willing  to 
reassess to level of commitment in the second tier.  

2. 

PROBLEM DEFINITION 

2.1 

Introduction 

The underlying problem can be summarised in the following way: cost-effective and energy 
efficient technologies for CSTBs do exist on the market but their market penetration is lower 
than it could be. Furthermore, 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.  The  energy  demand 
for functions provided today by CSTBs will not decrease but will migrate to other products 
that will be providing these functions in the future, e.g. TV sets and home media centres. 

As  requested  by  Article  15  of  the  Ecodesign  Directive,  the  preparatory  study  identified  the 
environmental aspects in relation to CSTBs. 

The study concludes that: 

–  they have a significant environmental impact within the European Union 

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–  they present significant potential for improvement without entailing excessive costs 

–  the following environmental aspects are relevant: 

–  energy  consumption  in  the  use  phase,  including  power  consumption  in  the 

different operating modes, and power management ; 

–  materials acquisition and waste; 

The  most  significant  aspect  for  improving  the  environmental  performance  of  CSTBs  is  the 
energy consumption the different operating modes, and power management.  

2.2 

Product scope 

Products analysed in this impact assessment are CSTBs defined as stand-alone devices using 
an integral or dedicated external power supply, for the reception of digital broadcasting and 
depending  on  Conditional  Access  to  perform  its  primary  function.  Translated  into  non-
technical language this means receivers for pay TV.  

2.3 

Market failures 

Major barriers for the market uptake of CSTBs with low energy consumption exist which are 
largely due to the following market failures: 

1.  Split  incentives.  The  vast  majority  of  CSTBs  are  purchased  by  the  providers  of  pay  TV 
which resell them or lease to the end-user as part of a service. Not bearing the usage cost of 
these devices, the service providers do not consider energy efficiency as one of the purchasing 
criterions.  

2.  Negative  externality  related  to  energy  use:  not  all  environmental  costs  are  included  in 
electricity  prices.  That  is  why  consumer  (and  producer)  choices  are  made  on  the  basis  of 
lower electricity price not reflecting environmental costs for the society.  

3. Incomplete information on running costs/cost savings: information on running costs/cost 
savings is not explicit and can be obtained only with difficulty.  

2.4 

Related initiatives on European Union and Member State level 

Regulation  1275/2008  sets  requirements  for  standby  and  off  mode  electric  power 
consumption of electrical and electronic household and office equipment. The impact of this 
Regulation can remain limited as CSTBs are rarely in the 'off' or 'standby' modes as they need 
to be constantly in on mode or networked standby to be able to operate. 

The  European  Code  of  Conduct  for  Digital  TV  Services  orchestrated  by  the  JRC  brings 
together service providers and manufacturers with the aim of improving the efficiency of set-
top  boxes.  Although  the  CoC  has  a  much  smaller  coverage  than  the  VA  it  aims  at  seeking 
innovative technology solutions, and not setting minimum requirements. These two initiatives 
are therefore complementary. 

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WEEE addresses the CSTBs environmental impact of waste. No particular difficulties for the 
implementation of WEEE for such devices are reported in the 2008 WEEE review4. 

2.5 

Baseline Scenario  

The electricity consumption of CSTBs will be approx. 10 TWh in 2010 in EU-27, it will peak 
in 2015 at 21 TWh, and go down to 10 TWh in 2020. This baseline scenario is based on the 
following predictions and assumptions. 

–  It  is  assumed  that  the  future  technical  improvements  of  the  complex  STBs  will  lead  to 
reduction  in  terms  of  power  requirements  in  different  operating  modes  but  that  these 
improvements  will  be  offset  by  an  increasing  number  of  functionalities  provided  by  the 
STBs. It is therefore assumed that these two trends will offset each other. 

–  It is assumed that the number of CSTBs will grow until 2015 due to the digitalisation of 
TV services in the EU (see graph 1 below) and an increasing number of subscribers for pay 
TV servies. 

–  It  is  assumed  that  after  2015  the  power  consumption  of  CSTBs  will  decrease  as  their 
functions  will  be  increasingly  performed  by  TV  sets,  PCs,  and  other  devices.  Therefore 
although  the  power  demand  for  services  provided  today  by  CSTBs  will  grow,  it  will  be 
used by other products.  

– 

Graph 1: Digital TV penetration scenario in Europe 

The  above  considerations  already  point  to  the  challenge  of  addressing  such  products  with 
regulatory  measures,  and  the  comparative  advantage  of  more  flexible  instruments,  such  as 
voluntary agreements. These assumptions lead to the baseline scenario showed below. 

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See 2008 Review of Directive 2002/96 on Waste Electrical and Electronic Equipment (WEEE), Final 
No: 
Bonn, 
Report, 
07010401/2006/442493/ETU/G4, 
2007, 
ENV.G.4/ETU/2006/0032, 
http://ec.europa.eu/environment/waste/weee/studies_weee_en.htm 

University, 

Germany 

Contract 

Nations 

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August 

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23,0

22,0

21,0

20,0

19,0

18,0

17,0

16,0

15,0

14,0

13,0

12,0

11,0

10,0

9,0

8,0

7,0

6,0

5,0

4,0

3,0

2,0

1,0

0,0

Business-as-usual

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

Graph 2: Baseline development of electricity consumption of CSTBs until 2020  

2.6 

Legal basis for voluntary agreements under the Ecodesign Directive 

The  Ecodesign  Directive  and,  more  specifically,  its  Recitals  16,  17,  and  18,  Article  17  and 
Annex VIII provide for the recognition, under certain conditions, of voluntary agreements as 
valid alternative to EC regulation.  

2.7 

Improvement potential 

The  preparatory  study  has  shown  that  existing  cost  effective  technical  solutions  allow  for 
improvement  of  the  energy  efficiency  of  CSTBs.  The  total  energy  consumption  of  a  CSTB 
can  be  reduced  by  up  to  50%.  Thanks  to  reduced  power  consumption  the  life-cycle  cost 
(therefore including the purchase price of the box) can be reduced from 375 euro to 307 euro 
allowing the consumer to save 68 euro. 

3. 

OBJECTIVES 

As  laid  out  in  Section  2,  the  preparatory  study  has  confirmed  that  a  large  cost-effective 
potential for reducing electricity consumption of CSTBs exists. This potential is not captured, 
as  outlined  above.  The  general  objective  is  to  develop  a  policy  which  corrects  the  market 
failures, and which: 

I) 

Reduces energy consumption and related CO2 and pollutant emissions due to CSTBs 
and  drives  following  Community  environmental  priorities,  such  as  those  set  out  in 
Decision  1600/2002/EC  or 
the  Commissions  European  Climate  Change 
Programme (ECCP); 

in 

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II) 

Promotes energy efficiency hence contributes to security of supply in the framework 
of  the  Community  objective  of  saving  20%  of  the  EU’s  energy  consumption  by 
2020. 

4. 

POLICY OPTIONS 

4.1 

Option 1: No new EU action 

This option would have the following implications: 

–  the barriers for realizing the potentials to improve the energy efficiency of CSTBs would 

persist.  

–  it  is  to  be  expected  that  Member  States  would  want  to  take  individual,  non-harmonized 
action.  This  would  hamper  the  functioning  of  the  internal  market  and  lead  to  high 
administrative  burdens  and  costs  for  manufacturers,  in  contradiction  to  the  goals  of  the 
Ecodesign Directive. 

–  the provisions of the Directive would not be respected. 

4.2 

Option 2: Self regulation 

As a basic condition, voluntary agreements under the Ecodesign Directive need 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).  Proposals  for  voluntary  agreements  (self-
regulation) are recognised as a valid alternative to regulation if their assessment against the 
criteria  of  Annex  VIII  is  deemed  satisfactory  (Article  17),  taking  into  account  the  feedback 
from the Consultation forum. 

4.2.1 Rationale and main elements 

The  rationale  for  addressing  the  environmental  impact  of  CSTBs  through  self-regulation  is 
underpinned by the following characteristics of this product group: 

–  The energy consumption of these devices is impacted not only by their design but also the 
way they are operated by the service providers. A significant improvement of the energy 
efficiency of CSTBs necessitates therefore a close cooperation of hardware, software and 
service providers and could not be achieved by setting product requirements only. In needs 
to  be  noted  that  the  overall  power  consumption  of  CSTBs  is  not  addressed  through 
mandatory requirements almost anywhere in the world. 

–  The  functions  of  these  devices  and  related  products  (e.g.  data  modems)  are  quickly 
evolving  and  often  merging  which  requires  a  flexible  approach  in  terms  of  defining  the 
addressed parameters and setting applicable requirements. 

–  Although the number of potential manufactures of CSTBs is enormous, the bulk of CSTBs 
specifications  are  drawn  up  by  restricted  number  of  service  providers/operators.  This 
potentially facilitates monitoring and decreases the risk of 'free-riding' by a significant part 
of the sector. 

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On the basis of these arguments and the applicable provisions of the Ecodesign Directive, the 
Digital  Interoperability  Forum  (hereafter  ‘DIF’)  presented  to  the  Consultation  Forum  a 
proposal  for  a  Voluntary  Industry  Agreement  aiming  at  limiting  the  power  consumption  of 
CSTBs.  DIF  brings  together  manufacturers  of  hardware  and  middleware,  software,  and 
service providers (see Annex I). 

The  industry  proposes  to  introduce  targets  for  the  typical  energy  consumption  (TEC5)  of 
CSTBs  in  two  stages,  with  the  first  reporting  period  from  July  2010  to  July  2011,  and  the 
second from July 2013 to July 2014. The target values will have to be met by 90% of CSTBs 
placed on the market or put into service by each signatory during the reporting periods. 

4.2.2 Assessment against Annex VIII of the Directive 

In line with Article 17 of the Ecodesign Directive “Voluntary agreements or other self-
regulation measures presented as alternatives to implementing measures in the context of this 
Directive shall be assessed at least on the basis of Annex VIII”. Therefore before proceeding 
to the comparison of the expected impacts of this option with the other viable option(s), this 
section will give an overview of how it responds to the criteria annexed to the directive. 

–  Openness  of  participation:  the  agreement  development  was  open  to  all  interested  parties. 
Its drafting followed a transparent process and timetable that was agreed with all members 
and consulted with the Commission services.  

–  Added  value:  the  draft  VA  aims  at  improving  the  energy  efficiency  of  CSTBs  beyond 
business  as  usual.  A  detailed  overview  of  its  expected  impact  and  comparison  with  the 
other viable option(s) is provided in section 5.  

–  Representativeness:  annex  VIII  of  the  Directive  stipulates  that  Industry  and  their 
associations  taking  part  in  a  self-regulatory  action  shall  represent  a  large  majority  of  the 
relevant economic  sector. A report commissioned by DIF6 indicated  that approx.  75% of 
CSTBs  on  the  EU  market  would  be  covered  by  the  Agreement.  This  number  could  be 
increased  with  the  adherence  of  additional  companies,  and  indeed  since  then  additional 
signatories have joined.  

–  Quantified  and  staged  objectives:  the  draft  VA  provides  quantified  objectives  to  be 

introduced in two stages (details are provided in Section 5). 

–  Involvement  of  civil  society:  the  draft  VA  stipulates  that  the  meetings  of  the  Steering 
Committee  will  be  opened  to  any  "person  who  wishes  to  attend  and  who  the  Steering 
Committee  believes  represents  a  legitimate  stakeholder".  The  annual  reports  that  will  be 
submitted  by  the  industry  to  the  Commission  will  be  each  time  discussed  by  the 
Consultation forum. 

–  Monitoring  and  reporting:  the  draft  VA  provides  the  modalities  for  monitoring  and 
reporting.  The  monitoring  will  be  performed  by  the  Steering  Committee  composed  of 
signatories  and  of  the  European  Commission  and  its  meetings  will  be  opened  for  the 
participation of Member States, EFTA, and any other person who wishes to attend and who 
the Steering Committee believes represents a legitimate stakeholder. This monitoring will 

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'Typical  Energy  Consumption  (TEC)'  means  the  electricity  consumed  by  the  device  while  in  various 
modes during a representative period of time  
Market Penetration: Voluntary Agreement on complex set-top boxes power consumption – a report for 
the Digital Interoperability Forum, Screen Digest, January 2010 

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be performed on the basis of annual reports submitted by an independent third-party based 
on data collected from the signatories.  

–  Cost-effectiveness  of  administering  a  self-regulatory  initiative:  it  is  expected  that  the 
administrative  burden  as  compared  to  other  available  policy  instruments  will  remain 
limited (details are provided in Section 5). 

–  Sustainability: The draft VA responds to the policy objectives of the Ecodesign Directive 

by aiming at reducing the environmental impact of CSTBs. 

–  Incentive  compatibility:  It  is  considered  that  the  VA  is  compatible  with  the  elements 

mentioned in section 2.4. 

4.3 

Option 3: Ecodesign requirements  

This  option  aims  at  improving  the  environmental  impact  CSTBs  by  setting  mandatory 
maximum levels for their power consumption.  

The preparatory study concluded that Ecodesign requirements formulated in TEC could be set 
in  3  stages  set  on  July  2011,  July  2012,  and  January  2014.  However  certain  requirements 
implemented  in  the  later  tiers  could  have  a  negative  impact  on  the  functionality  of  the 
equipment (details are provided in section 5). 

A comparison of the levels proposed in Option 2 and 3 is presented in Section 5. 

4.4 

Option 4: Mandatory energy labelling for CSTBs under Directive 2010/30/EC 

–  The  vast  majority  of  CSTBs  is  not  purchased  by  end-users,  but  by  service  providers,  a 
labelling scheme would not address the main applicable market failure (split incentives). 

–  The introduction and an A-G labelling scheme would not be in line with Article 11 of the 
Energy Labelling Directive which stipulates that the steps of the energy classification shall 
correspond to significant energy and cost savings from the end-user perspective.  

–  That is why this option is discarded from further analysis.  

5. 

IMPACTS ANALYSIS 

Given  that  option  4  has  been  discarded  from  further  analysis,  this  section  will  compare  the 
impacts of options 2 and 3 against the BAU. . 

The assessment is done in two stages. First options 2 and 3 are compared with respect to: 

–  the type and level of ambition of the requirements/targets, and the timing of their entry into 

force 

–  the modalities for reporting/measurement/verification  

In the second stage the two options are compared with a view to the criteria set out in Article 
15(5) of the Ecodesign Directive, and the impacts on manufacturers, including SMEs.  

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5.1 

Type and level of ambition of ecodesign requirements/targets  

The scope of options 2 and 3 in terms of the covered equipment is analogous therefore a first 
step in comparing the two options is a comparison of the type of elements addressed by them 
and their respective levels of ambition.  

5.1.1. Improvement options 

The preparatory study concluded that the main environmental impact associated with STBs, 
i.e.  the  energy  consumption  during  use  could  be  decreased  by  the  implementation  of  the 
several  options,  including  power  management,  decreased  power-consumption  in  'on'  and 
'active standby' modes, and efficient power supplies. The cost of these improvement options is 
negligible and ranges between 0 and 3 euros. The exception are solid state drives which can 
add a cost of 100 euros. 

All  of  these  options  lead  to  the  setting  of  minimum  efficiency  requirements  formulated  in 
TEC  (typical  energy  consumption)  which  leaves  manufacturers  the  flexibility  for  achieving 
the  desired  levels.  The  TEC  allowances  vary  according  the  platforms  that  are  used  by  the 
devices and to the additional functionalities provided by the devices. This approach is applied 
in both option 2 and 3. 

5.1.2. Level of ambition and timing 

According to the Ecodesign Directive the target levels for measures should be set at least life 
cycle cost (LLCC), which presumes that at some point the price of the product increases so 
much  with  extra  design  options to save energy that the life cycle costs (purchase price plus 
running costs) will start to rise again. The table below compares the levels identified by the 
preparatory  study  as  LLCC  (four  right-hand  columns),  with  the  levels  proposed  by  the 
industry (2nd and 3rd column) and the base-case/business-as-usual (1st column). 

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Table  1:  Comparison  of  Base-case  with  VA  targets  and  recommendations  from  preparatory 
study. 

Table 1 indicates that: 

–  Minimum  efficiency  levels  under  option  2  (VA)  and  3  (mandatory  requirements)  are 

structured in the same way.  

–  The Tier 1 levels under option 2 and 3 are similar. The timing of their entry into force is 
also  similar,  however  one  important  difference  has  to  be  noted:  whereas  under  option  3 
(mandatory requirements) all CSTBs placed on the market after July 2011 would have to 
meet  the  indicated  level,  the  levels  of  option  2  would  have  to  be  achieved  by  90%  of 
CSTBs  placed  on  the  market  by  each  signatory  of  the  VA  between  July  2010  and  July 
2011. Requirements are therefore phased-in faster under option 2. 

–  The levels recommended by the preparatory study for Tier 2 and 3 are more ambitious than 
the industry proposal. It has to be noted however that the levels indicated in Table 1 in the 
last two columns on the right assume the implementation of low-power standby across all 
CSTBs placed on the market. However this option couldn't be made mandatory as, with the 
current technology it would have a negative impact on the functionality of the equipment- 
a CSTB that would switch automatically to a very low-power mode could not ensure the 
performance  of  such  functions  as  software  updates,  security  of  the  network  etc.  Its 
implementation would require a close cooperation of hardware manufacturers and service 
providers  which  goes  beyond  design  requirements,  hence  beyond  what  can  be  required 
under  an  ecodesign  implementing  measure.  This  option  however  theoretically  could  be 
implemented  in  the  mid-term  under  a  voluntary  approach.  Its  potential  is  depicted  on 
Graph 3 (p. 16). 

5.2 Reporting/measurement/verification 

Under  a  regulatory  approach  (option  3)  requirements  would  have  to  be  met  by  all  products 
meeting the definition that would be placed on the market after the date of the entry into force 
of  the  requirements.  Manufacturers  would  have  to  test  their  equipment  in  line  with  the 
applicable test procedure and report the values in the technical documentation referred to in 
Annexes  IV  and  V  of  Directive  2009/125/EC.  Verification  would  be  preformed  by  market 
surveillance authorities on the basis of an established procedure. 

In the case of option 2 (VA) the monitoring will be performed by the Commission assisted by 
the Committee referred to in Article 19 of the Directive. This monitoring will be performed 
on  the  basis  of  reports  submitted  by  an  independent  third-party  that  will  be  collecting  and 
aggregating the data from the individual signatories in accordance with Annex G of the draft 
VA.  Member  State  market  surveillance  authorities  will  have  access  upon  request  to  the 
background data in order to verify their accuracy. 

5.3 

Economic impacts 

Complex STBs are usually provided by the service provider (e.g. broadcaster, cable company) 
who  often  rents  or  provides  the  appliance  to  the  consumer  free  of  charge,  or  at  an 
advantageous  price,  along  with  the  service  subscription.  The  consumer  (i.e.  end-user)  is 
therefore rarely the purchaser due to the currently existing business models. 

The main actors of the complex STB market are the manufacturers of the complex STBs (e.g. 
LG  Electronics,  Pace,  Motorola),  TV  service  providers  (e.g.  BSkyB,  Telenet,  Canal+), 

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providers of software for Conditional Access, providers of middleware to enable applications 
such as electronic programme guide to run on the STB (Osmosys), and silicon vendors who 
supply  the  micro-processor  technologies  at  the  heart  of  the  product  (e.g.  ADM,  Broadcom, 
Microsoft, NEC Electronics). 

These  5  segments  are  mainly  dominated  by  large  companies.  It  should  be  noted  that  the 
evolution  in  the  design  of  the  complex  STB  will  affect  and  involve  co-operation  of  all  the 
parties.  This  concerns  also  energy  efficiency,  where  improvements  would  require  hardware 
engineers  (STB  manufacturers)  to  consider  energy  efficiency  from  the  outset,  CA  suppliers 
and silicon vendors to consider if full active standby mode is required7, middleware designers 
to  be  aware  of  power  management  requirements,  and  service  providers  to  consider  the 
implementation of power management in the STB they deliver even through they are not the 
final  end-user  of  these  devices.  These  changes  cannot  therefore  be  influenced  only  at  the 
design level, hence the limitations of regulation.  

5.3.1  Costs related to improved technology and production, re-design and supply chain 

As  indicated  in  the  section  5.1.2  both  options  aim  at  addressing  similar  parameters  with 
similar allowances. They would therefore necessitate similar redesign solutions, also in terms 
of cost. The aspects differentiating them are therefore: 

–  the percentage of equipment covered 

–  the potential to drive further in the mid-term the energy efficiency of CSTBs  

–  the adjustability to future technological changes. 

The improvement in both options in the first and partly second tier is achieved with readily-
available technology involving minimum or no additional cost. No major additional costs for 
re-design are expected, because compliance can be achieved by a minor modification which 
can  be  accommodated  into  planned  re-design  cycles  for  CSTBs.  The  technical  options  for 
improving the energy efficiency of CSTBs are estimated to add between 0 and 5 euro to the 
price of the box, depending on the option chosen. These price adders are well within the limit 
of the least life-cycle cost. 

The  redesign  cost  is  expected  to  be  somewhat  smaller  in  the  case  of  option  2  as 
manufacturers/service providers signing up to the VA will be allowed to leave 10% of their 
fleet outside of the commitments. 

5.3.2  Costs related to reporting/measurement/verification  

In general assessing the conformity with mandatory ecodesign requirements implies costs for 
manufacturers.  The  same  holds  true  for  verifying  compliance  with  voluntary  commitments. 
Based on stakeholder feedback it is estimated that the cost for assessing the conformity with 
ecodesign  requirements  is  in  the  order  of  500€  to  1000€  per  sample  product/model.  The 
aggregate cost to manufacturers is expected to be somewhat smaller in the case of option 2 as 
manufacturers signing up to the VA will be allowed to leave 10% of their fleet outside of the 

7 

Active standby mode is defined as (Task 1) “The appliance is connected to a power source, does not 
fulfil a main function but can be switched into another mode with the remote control unit or an internal 
signal.  It  can  additionally  be  switched  into  another  mode  with  an  external  signal  or  it  is  receiving  a 
minimal level of data from an external source.” - see further details on “active standby” in later tasks 
3,4,5,6 and 7. 

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commitments and hence will not be required to test this equipment. The cost of reporting is 
considered to be negligible (in the order of 2-3 thousand EURO per year per signatory). 

5.3.3 

Administrative costs for Member States 

In  the  case  of  option  3  the  costs  for  carrying  out  the  verification  procedure  for  market 
surveillance purposes is expected to be in the order of several thousand EURO.  

In  the  case  of  option  2  the  monitoring  of  the  VA  would  be  performed  on  the  basis  of 
aggregated data provided by an independent third party. This third party would be financed by 
the industry hence the cost would be shifted away from Member States.  

5.4 

Social impacts 

5.4.1 

Affordability of equipment 

The price increases due to the implementation of either option 2 or option 3 are estimated to 
be  in  the  range  of  0  to  5  euro,  i.e.  less  than  2  %  of  the  purchase  price  of  a  CSTBs.  This 
increase  in  the  upfront  price  is  expected  to  be  largely  offset  by  use  cost  savings  ranging 
between  15  euro  in  the  case  of  a  'basic'  CSTB  to  95  euro,  in  the  case  of  a  CSTB  with 
additional functionalities. 

5.4.2 

Impact on the functionality of equipment 

The implementation of either of the two options considered here would not have a negative 
impact on the functionality of the equipment. As indicated earlier in the mid-term the biggest 
saving-potential  is  associated  with  the  implementation  of  APD  and  low-power  standby. 
Making these features (in particular the latter) mandatory at this stage could have a negative 
impact on the user. The implementation of these technical options will require changes to the 
infrastructure  support  systems  that  the  major  European  subscription  service  providers  run. 
The implementation of such solutions would be the main challenge of the revision process as 
part of both a VA and regulation. However in the case of a VA it can be assumed that this will 
be easier due to a greater flexibility of the decision-making process, but above all due to the 
participation of service providers. 

5.5 

Annual  and  accumulated  electricity,  electricity  cost  and  CO2  emission  savings 
by 2020 

–  The electricity cost savings triggered by ecodesign depend on the level of ambition of the 

commitments/requirements and the percentage of equipment complying with them.  

5.5.1 

Electricity savings (including cost) 

Graph 5 shows the development of the electricity consumption of CSTBs until 2020. 

The  electricity  cost  savings  triggered  by  ecodesign  depend  on  the  level  of  ambition  of  the 
commitments/requirements  and  the  percentage  of  equipment  complying  with  them.  The 
figures below were established on the basic of the following assumptions: 

–  In  the  case  of  mandatory  requirements  (option  3)  the  assumed  level  of  compliance  is 
100%. In the case of the VA (option 2), it is assumed that manufacturers subscribing to it 
will cover 80% of the market and, in line with the commitments in the draft VA 90% of the 

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fleet of each signatory would comply, hence the overall percentage of equipment meeting 
the targets would be 72%. 

–  Option 3 (mandatory ecodesign requirements) assumed the implementation of the LLCC 1 
scenario  from  the  preparatory  study,  therefore  the  improvement  of  the  efficiency  though 
efficient power supplies and other technical options, such as efficient hard disk drives, but 
not 
the 
implementation of these options across the board is not possible in the short-term.  

implementation  of  APD  and 

low-power  standby  since 

the  mandatory 

–  Although as indicated in Table 1 the total allowed energy consumption for an STB with all 
additional  features  will  be  218  kWh  in  the  case  of  the  VA  and  196  kWh  in  the  case  of 
regulation, the market share of STBs providing multi-decoding is expected to remain very 
limited. If you correct for this element then the allowance under the VA is 180 kWh, while 
in the case of regulation it remains at 196 kWh (as the preparatory study didn't foresee any 
additional allowance for this element). 

It has to be noted that in the case of such 'volatile' and quickly-evolving products as CSTBs 
and forecasts beyond a time horizon of 5 years bear a high degree of uncertainty. 

Options 2 and  3  achieve a  comparable  improvement compared  to BAU. Furthermore  as  the 
graph 'improvement potential' shows the possibility for an improvement beyond option 2 and 
3 is considerable. The electricity consumption of CSTBs will peak around 2016 and from then 
will start declining. This is due to the fact that the functions provided today by CSTBs will be 
increasingly shifted into other devices, be it TV sets, media centres, or other devices that are 
not  yet  on  the  market.  This  provides  yet  another  argument  for  engaging  with  the  service 
providers to drive down the power consumption provided by their services, irrespectively of 
the physical device through which it is provided. 

a
/
h
W
T

23,0

22,0

21,0

20,0

19,0

18,0

17,0

16,0

15,0

14,0

13,0

12,0

11,0

10,0

9,0

8,0

7,0

6,0

5,0

4,0

3,0

2,0

1,0

0,0

Business-as-usual

Ecodesign Regulation

Improvement potential

Industry proposed voluntary
agreement (90%*80%=72%)

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

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Graph 3: EU27 Electricity Scenarios 2007-2020 in TWh/a (electric) 

Table - Electricity Savings 2016 vs. BaU: 

Business-as-usual 
Option 2 (VA) 
Option 3 (regulatory) 
Improvement potential 

Use 

Savings 

TWh/a  TWh/a 
21 
14,5 
14 
10 

6,5 
7 
11 

% 

31% 
33% 
52% 

Table 2: development of electricity consumption of CSTBs for several scenarios until 2016. 

The  annual  electricity  savings  of  6,5  TWh  expected  by  2016  correspond  to  savings  of 
electricity costs of 884 million EURO. 

5.5.2 

Accumulated electricity cost savings through the VA and ecodesign requirements 

Table 3  gives  an  overview  of  the  accumulated  electricity  savings,  the  corresponding  cost 
savings and avoided CO2 emissions over a period between 2011 and 2020: 

Accumulated 
electricity 
consumption 

Accumulated 
electricity 
savings 

Accumulated 
electricity 
savings8 

cost 

Accumulated 
avoided 
emissions9 

CO2 

(TWh) 

(TWh) 

(billion EURO) 

(Mt) 

BAU  

Option 2 

Option 3 

159 

115 

114 

- 

44 

45 

- 

6 

6.2 

- 

21 

21 

Table 3: accumulated electricity and cost savings, and avoided CO2 emissions for the products 
placed on the market from October 2011 until 2020 for options 2 and 3.  

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

5.5.3 

Potential accumulated electricity cost savings through the implementation of power 
management options (APD and low-power standby) 

The preparatory study indicated that the biggest saving potential in the mid-term is linked to 
the implementation of power-management options, APD and in particular low-power standby 
mode.  These  options  are  described  in  section  5.1.1.  The  implementation  of  these  options 
would lead to accumulated electricity consumption by 2020 of 87 TWh, electricity savings of 
72 TWh translating into10.2 billion EURO saved.  

8 
9 

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

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5.5 

Comparison of the sub-options 

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 
(costs) 

impact 

Environmental 
impact 
(electricity/CO2/ele
cost 
ctricity 
savings) 

Social  impact  (risk 
for  Job  losses  in 
SMEs) 

Improvement 
potential in the mid 
and long term 

BAU 

Option 2 (VA) 

1 

1 

Option 
(regulation) 

3 

2 

1 

3 

3 

1 

1 

1 

1 

4 

2 

Table 4: summary and assessment of options 2 and 3 

It is concluded that option 2 and 3 have a similar impact on electricity savings. 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. 
However this will depend on the willingness of the industry to commit to new targets in later 
stages and on the ability of policy-makers to engage with the industry as part of the voluntary 
agreement. In order to ensure that ambitious targets are set in the subsequent stage synergies 
will be sought with the Code of Conduct orchestrated by the JRC. 

6. 

CONCLUSION 

Following the principle of proportionality in the analysis effort, policy options 1 and 4 were 
discarded at an earlier phase of the analysis. The analysis of options 2 and 3 shows that option 
2 optimally fulfils the objectives as set out in Section 3. As described in section 4.2.3 it also 
meets  the  criteria  of  Annex  VIII  of  the  Directive.  In  particular,  the  Voluntary  Agreement 
implies : 

–  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 
mln tons 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; 

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–  insignificant,  if  any,  increase  of  the  purchasing  cost,  which  would  be  largely 

overcompensated by savings during the use-phase of the product; 

–  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 

7. 

MONITORING AND EVALUATION 

The procedure for monitoring and reporting will look as follows: 

–  The Steering Committee will continuously 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.  The  Steering  Committee  will  include  the  signatories  of  the  VA  and 
will be opened to outside stakeholders (as observers).  

–  Signatories will annually submit to the Commission a report through the independent third-
party.  For  quantified  objectives  the  report  will  include  detailed  figures  based  on  agreed 
measurement  methods.  The  first  reporting  period  started  in  July  2010  and  ends  in  July 
2011. In line with the provisions of the draft VA, by the 31 August 2011 each signatory 
shall  provide  the  applicable  information  to  the  independent  third-party.  The  independent 
third-party  will  then  have  3  months  to  aggregate  the  results  and  present  them  to  the 
Commission and stakeholders. 

–  The members of the Consultation Forum will be consulted on an annual basis to take stock 
and  monitor  the  results  of  the  VA.  Member  States  wishing  to  verify  the  reported 
information will be granted access on demand to the background data and on that basis will 
be able perform products checks/tests. 

–  The Commission, assisted by the Committee on the Ecodesign of Energy-related Products 
(in  its  advisory  capacity),  will,  in  the  light  of  the  reports  submitted  and  input  from  the 
Consultation Forum 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 an EC regulation instead. 

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ANNEX I 
List of companies currently providing support to the VA 

Set top box 
manufacturers 

Chipset 
manufacturers 

Service 
Providers 

Middleware 
manufacturers 

Conditional 
access providers 

Mocrosoft 
Open TV 

Conax 
Irdeto 
Nagra 
NDS 

Broadcom 
Intel 
NXP 
ST 

ADB 
Amstrad 
Cisco 
Humax 
Kaon Media 
Motorola 
Netgem 
Pace 
Sagem 
Samsung 
Tatung 
TechniSat 
Thomson 

BT 
Canal+ 
Kabel BW 
Kabel 
Deutschland 
Liberty Global 
Ono 
Sky  
Ses Astra 
Sogecable 
Sky Deutschland 
Sky Italia 
Telenet 
Topup TV 
Viasat 
Virgin 
Welho 

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ANNEX II 
Minutes of the Consultation Forum meeting 

Ecodesign of EuPs Consultation Forum – Voluntary Agreement on 

Subject: 
Complex Set-top boxes 
Place: 
Chairman: 
EC Participants: Jacek TRUSZCZYNSKI (TREN/D3),  Martin EIFEL (ENTR/B1) 

Centre de Conférence Albert Borchette, Brussels 
André BRISAER (TREN/D3) 

Kerstin LICHTENVORT (ENTR/B1),  Paolo BERTOLDI (JRC/ISPRA) 

Voluntary Agreement on Complex Set-top boxes 
12 October 2009, 10:00 – 13:00 

1. Welcome and introduction 

The Chairman welcomed  the  participants  and briefly introduced the proposal  formulated by 
the  Digital  Interoperability  Forum  (DIF)  for  a  “voluntary  agreement  on  complex  set-top 
boxes” within the framework of Directive 2009/125/EC. 

2. Adoption of the agenda 

The agenda was adopted without changes. 

3. Voluntary Industry Agreement on Complex Set Top Boxes (for opinions) 

The  Commission  services  provided  background  information  on  the  specific  provisions  of 
to  voluntary  agreements.  The  Commission  services 
Directive  2009/125/EC  related 
emphasized both the benefits and potential issues inherent to voluntary agreements. 

DIF introduced the industry’s proposal for a “Voluntary Industry Agreement to improve the 
energy consumption of Complex Set Top Boxes”. The agreement, DIF explained, is not only 
supported by DIF, but has also been signed by companies from the greater market of CSTB 
manufacturers  and  related  service-providers.  Key  elements  of  the  presentation  included  the 
following: 

CSTB sometimes account for up to five different modes of use and different types of actual 
usage by consumers.  
The  process of signing the voluntary  agreement has not been finalized: talks are still taking 
place  with  representatives  from  further  companies  (the  example  of  Kabel  Deutschland  as 
having recently signed the agreement was mentioned). 
All “interested parties” are invited to sit in the Voluntary Agreement’s Steering Committee. It 
was explained that, for instance, all organizations sitting in the Consultation Forum would be 
accepted. 
Should a company not meet the targets it had agreed to, the Steering Committee would most 
likely expel the defaulting company, as well as publicize this fact. 

The presentation was followed by a discussion on the basis of certain Annex VIII criteria, and 
in particular: 

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Added-value of the Voluntary Agreement 

ANEC/BEUC would like to see a calculated comparison between a Voluntary Agreement and 
a regulation. ENV NGOs enquired about the extent to which the industry would be willing to 
amend the proposal. DIF explained that modifying the proposal at this stage would be all the 
more difficult as it would require approval of over thirty signatories. At the same time DIF is 
open to make changes related to future commitments once the initiative gets started. 

DK, UK, NL acknowledged the industry’s efforts, but would like the latter to propose even 
stricter levels, especially in the second tier. 

ENV NGOs regret that the VA is focused on energy and the other environmental aspects are 
not addressed. 
Openness and participation 

ENV NGOs pointed out consistency issues between the text version and the oral presentation 
of  the  Voluntary  Agreement  as  made  by  DIF:  e.g.  the  text  specifies  that  the  Steering 
Committee  would  select  its  members.  DIF  reassured  that  all  members  of  the  Consultation 
Forum  would  be  welcome  in  the  Steering  Committee;  and  that  it  would  be  politically 
disastrous for the Steering Committee not to accept NGOs. 

Representativeness 
Several members of the CF asked he industry to provide data (ideally provided through a third 
party)  on  the  market  coverage  of  the  VA.  The  industry  committed  to  submit  such  a  report 
within the shortest delays. 

ANEC/BEUC pointed out that some Member States might not be covered by this initiative. 
The industry confirmed that all countries were covered by at least one manufacturer and one 
service provider. 

The UK estimates that the coverage should reach 90% of the market in order to be considered 
as a viable alternative to regulation.  

Quantified and stated objective 
UK  indicated  that  it  expected  the  industry  to  make  stronger  commitments  as  part  of  tier  II. 
DIF reiterated that it will be opened to make changes when the process starts and pointed out 
that a voluntary approach allows for a flexible adjustment of targets. 
Monitoring and Reporting 
The Commission services stressed the importance of collecting data by an independent third-
party. 
The  UK  and  ENV  NGOs  indicated  that  industry  should  make  available  to  MS  authorities 
upon  request  background  data  to  allow  for  checks.  DIF  indicated  that  although  such  a 
provision is not included in the draft text of the agreement, these data will be made available. 
At the same time market share data has to remain confidential. 
ANEC/BEAUC suggested that the names of defaulting companies be made public. 

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ANNEX III 
Structure of the methodology used for establishing the technical, environmental and 
economic analysis 

Following  the  "Methodology  Study  Eco-design  of  Energy  Using  Products"  ("MEEuP"),  the 
tasks listed below are carried out for developing the technical, environmental and economic 
analysis referred to in Annex II of the Ecodesign Directive: 

Task 1: Product definition, existing standards and legislation 

Task 2: Economics and market analysis 

Task3: Analysis of consumer behaviour and local infrastructure 

Task 4: Technical analysis of existing products 

Task 5: Definition of base case ("average" model) and related environmental impact 

Task 6: Technical analysis of best available technology 

Task 7: Improvement potential 

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