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 games consoles
Date: 2015-04-22
Institutions: European Commission
Subjects: computer equipment, energy consumption, energy efficiency, environmental impact, marketing standard, recording equipment, reduction of gas emissions, voluntary restraint agreement

EN 

   EN 

   EUROPEAN COMMISSION  Brussels, 22.4.2015  SWD(2015) 88 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 games consoles {COM(2015) 178 final} {SWD(2015) 89 final}  
 
 
Executive Summary 
“Sound  and  imaging  equipment",  has  been  identified  as  a  candidate  product  group  for 
possible  Ecodesign  measures,  comprising  game  consoles,  video  players/  recorders  and 
projectors.  The  Ecodesign  Directive  2009/125/EC  of  the  European  Parliament  and  of  the 
Council1 establishes a framework for the Commission to set ecodesign requirements through 
regulations, or for industry to make self-regulatory initiatives. The impacts of potential policy 
measures  are  assessed  in  line  with  the  requirements  of  the  Directive,  together  with  possible 
measures under the Energy Labelling Directive 2010/30/EC2.  

Compared to other Ecodesign Regulations the energy savings potential of this product group 
is  relatively  moderate.  For  sound  and  imaging  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  Ecodesign  Regulation  on  Computers.  The  analysis 
presented in the report is considered proportionate to the expected savings. 

This  impact  assessment  also  assesses  whether  an  industry  self-regulatory  initiative  can  be 
considered an alternative policy measure.  

1. 

PROBLEM DEFINITION 

The problem is that the environmental performance of sound and imaging equipment could be 
improved, and that the market penetration of energy-efficient products is lower than it could 
be. The consequences are that innovation is not sufficiently encouraged, and that energy costs 
for equipment users are higher than economically necessary.  

A check of available market data found that in 2012 roughly about 50 million video players 
and  recorders,  12  million  game  consoles  and  2  million  projectors  were  sold  in  the  EU. 
Altogether they consume around 8.5TWh electricity per year, and the consumption is forecast 
to increase to 13 TWh in 2020. The market forecast found that video players/ recorders and 
projectors  will  gradually  disappear  from  the  market.  The  sales  figures  for  video  players/ 
recorders and projectors are currently dropping by up to 10% per year, and this decrease will 
continue as other technologies increasingly replace these products.  

Figure 1: Business as Usual - EU Energy Consumption for all Products 

1 
2 

OJ L 285, 31.10.2009 
OJ L 153, 18.06.2010 

2 

 
 
 
                                                            
The key problem regarding game consoles is their increasing energy consumption, related to 
their quickly expanding functionalities and gaming performance. Their annual energy saving 
potential has been estimated at around 1.5 TWh per year, by the year 2020. The key question 
for this report is whether the current trends of growing energy consumption of game consoles 
could  be  significantly  reduced  by  a  voluntary  agreement,  or  whether  there  is  a  need  for 
introducing mandatory ecodesign or energy labelling measures. 

OBJECTIVES 

2. 
The  preparatory  study3  and  the  Impact  Assessment  (IA)  study  found  that  there  is  a  cost-
effective potential for reducing the energy consumption of sound and imaging equipment, and 
that  the  full  potential  is  currently  not  being  exploited.  The  objective  is  therefore  to  analyse 
whether ecodesign or  energy labelling measures, including  self-regulation, can  contribute to 
the 20/20/20 energy policy objectives. 

In  line  with  recitals  18  and  19  and  Article  15(6)  of  the  Ecodesign  Directive,  it  should  be 
explored  whether  self-regulation  could  be  the  preferred  option.  For  sound  and  imaging 
equipment products fulfilling the ecodesign criteria, the general objective is to correct market 
failures  and  to  reduce  energy  consumption  in  a  proportionate  and  cost-effective  manner, 
without affecting functionality.  

3. 

POLICY OPTIONS  

The following legislative and non-legislative measures have been considered: 

- 

- 

- 

- 

Option 1: No EU action (baseline) 

Option 2: Self-Regulation (Voluntary Agreement under the Ecodesign Directive) 

Option 3: Ecodesign Implementing Measures 

Option 4: Energy Labelling Measures 

Game consoles 

Option  1  is  included  in  the  analysis  not  only  for  comparison  purposes,  but  also  as  a  viable 
option in its own right. This option implies that barriers will persist for realising the potentials 
to  improve  the  energy  efficiency  of  game  consoles.  Although  consoles  become  relatively 
more  efficient,  energy  consumption  will  increase,  but  less  rapidly  than  the  gaming 
performance.  

Option  2:  In  2012,  three  game  console  manufacturers  (Microsoft,  Nintendo  and  Sony) 
presented to the Commission a comprehensive industry proposal for game consoles. With the 
exception of the required monitoring and reporting parts, it contained all essential elements, 
and is therefore regarded sufficient to evaluate this initiative as an alternative to a regulatory 
implementing measure.  

The proposal is based on a simplified approach, with requirements on two operational modes: 
‘media  playback/streaming’  and  ‘navigation’.  These  modes  are  also  simple  to  test.  The 
electricity consumption requirements in the operational modes are 90 W in 2013, and 70 W in 
2017. The industry proposal did not tackle the gaming mode for lack of performance metrics.  

Option 3 aims at improving the environmental impact of game consoles by setting mandatory 
maximum  levels  for their  power  consumption.  It is  based  upon  the technical  concept  of  the 
industry  proposal,  but  with  more  stringent  power  caps.  The  requirements  in  the  operational 
modes are 70 W in 2014 and 50 W in 2017. It proposes further “power supply” and “power 

3 

See http://www.ecomultimedia.org/ 

3 

 
 
                                                            
management” requirements. The modelling of this  option could not consider future possibly 
extended  performance  or  functionalities  of  next  generations  of  game  consoles,  as  they  are 
hard to predict.  

Option 4: A mandatory EU energy label approach aims at categorising products by efficiency 
class, applying an A to G categorisation by 2014. However, there are only three main product 
types/ models, one produced by each manufacturer, and the product architectures and 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 render labelling ineffective. 

The following table summarises the maximum energy consumption levels of all 4 options for 
games consoles:  

Policy Options 

1 No 
action 

2 Industry proposal  3 Ecodesign 

4 Energy Labelling 

Requirements 
in Watt (≤W) 

Tier 1 

Tier 2  

2013 

2017  

Tier 
2014  

1 

Tier  2 
2017  

Label 
Class 

Tier  1 
2014  

Tier  2 
2017  

Media 
Playback 
mode 

Navigation 
mode 

90 

70 

70 

50 

90 

70 

70 

50 

A 
B 

C 

D 
E 
F 
G 

30 
40 
50 

60 
70 
80 
90 

15 
25 
35 

45 
55 
60 
70 

Table 1: Summary - Game Consoles Options 

Video Players/ Recorders  

Option 1: The baseline 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 clients, removing the need for these products.  

Option 2 has been discarded, as no self-regulatory initiative has been proposed by industry.  

Option  3:  Policy  options  with  ecodesign  requirements  were  developed  in  the  preparatory 
study  in  2010,  and  re assessed  in  light  of  new  technical  information  and  industry  feedback. 
The revised and more stringent proposal is based on the operational modes like on-play, and 
has updated timelines starting in 2014.  

Option  4  has  been  discarded,  as  an  energy  labelling  for  video  player/recorder  has  not  been 
found pertinent, due to their relatively low energy consumption, and the limited improvement 
potential.  

Projectors 

Option 1: With no EU action, the baseline scenario is characterised by a clear downward sales 
trend, as applications are substituted by widescreen televisions.  

Option  2  has  been  discarded  for  projectors,  as  such  an  initiative  has  not  been  proposed  by 
industry. 

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Option  3  is based  on reassessed  and  updated  policy scenarios  of  the  preparatory  study.  The 
requirements  are  based  upon  an  assessment  of  available  technology,  and  propose  light 
efficiency requirements.  

Option 4: A label for projectors would be complex but feasible. The labelling option is based 
on  the  requirements  and  on  simplified  assumptions  suggested  in  the  preparatory  study.  It 
would result in improvements in efficiency from 2016 onwards. 

The Table below gives an overview of the options retained for in-depth analysis, for all three 
types of products within the overall group “image and sound equipment”. 

Game consoles 

Video players / recorders 

Projectors 

  Option 1 No EU action 

  Option 1 No EU action 

  Option 1 No EU action 

  Option 

2 

Proposal 
Regulation  

Industry 
Self 

- 

  Option 

3  Mandatory 

Ecodesign  

  Option 

4  Mandatory 

energy labelling 

  Option 

3  Mandatory 

  Option 

3  Mandatory 

Ecodesign  

Ecodesign  

  Option 

4  Mandatory 

energy labelling  

Table 2: Retained options: Game Consoles, Video Players/ Recorders and Projectors 

4. 

IMPACT ANALYSIS 

The overarching aim of this section is to assess the overall energy and carbon savings against 
other parameters, such as economic and social impacts. The assessment is implemented in line 
with  the  criteria  set  out  in  Article  15(5)  of the Ecodesign Directive, taking  into  account the 
impacts on manufacturers, including SMEs. The aim is to find a balance between achieving 
the appropriate level of ambition and associated benefits for the environment/ user on the one 
hand, and the potential burdens for manufacturers on the other.  

As  almost  all  mass-market  video  players/recorders  projectors  and  game  consoles  are 
assembled  in  China,  EU  manufacturers  will  not  be  affected,  practically.  Costs  related  to 
improved  technology  and  production,  and  re-design,  will  primarily  be  borne  by  non-EU 
manufacturers.  

Economic impact 

The most important economic impacts of the retained options are summarised below.  

Game consoles  

Option  2  (Industry  Proposal:  Self-Regulation)  would  not  incur  high  additional  costs,  as 
manufacturers themselves have already introduced the necessary changes in their production 
plans.  

Option  3  (Mandatory  Ecodesign  requirements)  require  changes  to  products,  which  may 
represent  a  significant  proportion  of  manufacturing  costs  per  unit,  but  the  required  changes 
will  very likely  add  little  to  the  final  price.  On  the  other  hand,  consumers  may  save  energy 
from  more  efficient  components.  Due  to  the  strong  competition  between  the  three  global 
players,  no  information  regarding  future  details  is  available.  Therefore  it  is  very  difficult  to 
estimate precisely the impacts on the buyers and the affordability of consoles.  

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Option  4  (Mandatory  Energy  Labelling)  would  incur  very  minor  additional  costs  to  display 
the energy classes on a label, but would not incur 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,  the  levels  suggested  for  a  regulation  would  not 
require  substantive  changes  to  mass  market  products,  since  there  is  little  scope  for 
improvement. Impacts will be minimal, and will be low/ no cost.  

Projectors 

Option 3 could result in an increase in manufacturing costs, reflected in the consumer increase 
in product price to cover improved efficiency power supplies, and improved light efficiencies. 
No  significant  design  changes  would  be  necessary  to  achieve  the  requirements.  The 
affordability  is  difficult  to  forecast,  both  with  regard  to  how  manufacturing  costs  could  be 
passed  through  to  consumers,  and  regarding  the  competition  of  more  expensive  projectors 
with screens.  

Option 4 would not be expected to incur significant supply chain costs. 

Environmental Impacts 

The  electricity  consumption  for  all  product  groups  was  analysed  and  estimated  through  a 
modelling exercise, with model development advised by technical experts within the product 
groups.  

Figure 2: Evolution of Annual Energy Consumption - Game Consoles 

The annual electricity consumption of game consoles 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  2  shows  that  the  energy  consumption  increases  uniformly  for  all  options.  By 
2020, the saving potential of all intervention options is similar, with a very small advantage 
for the ecodesign option. By 2025, the two mandatory regulation options achieve 16% energy 

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savings,  i.e.,  roughly  double  the  savings  of  the  industry  proposal,  which  achieves  energy 
savings of 8%. 

Video players / recorders 

The electricity consumption of the “business as usual” option for video players and recorders 
are displayed previously, in Figure 1. The electricity consumption 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 provide for a stronger decrease already by 2015 and 2016, but would 
regress towards the baseline curve in the longer term.  

Projectors 

According  to  modelling  predictions,  the  electricity  consumption  of  projectors  decreases 
similarly  to  video  players/  recorders.  Regulatory  options  would  have  no  significant  effects, 
and would not add to the constant decrease in energy use. 

Social Impacts  

For  all  policy  options  assessed,  the  risk  of  job  losses  is  expected  to  be  very  low.  For 
regulatory  measures,  the  staged  approach  and  timings  will  allow  manufacturers  to  adapt  to 
Ecodesign requirements in a timely manner.  

Within the EU, there are only a small number of SMEs indirectly involved, for example, to 
develop game software, for some “high end” video players/recorders, or for import and retail, 
and they will not be noticeably affected.  

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. 

Other impacts 

The full Impact Assessment Report assesses in more detail further economic costs and social 
impacts. In summary, these impacts are expected to be marginal within the EU.  

5. 

COMPARISON OF THE POLICY OPTIONS 

The  following  table  summarises  the  estimated  electricity  and  carbon  savings  attributable  to 
the preferred policy options compared to the business as usual scenario. 

Table – Annual Electricity and Carbon (Mt CO2) Savings vs. BaU: 
2020 

2025 

Electricity 
Savings 
(GWh/a) 

Carbon 
Savings (Mt 
CO2 eq/a)4 

Electricity 
Savings 
(GWh/a) 

Carbon 
Savings (Mt 
CO2 eq/a) 

Game consoles 

1,020 

0.408 

1,122 

0.449 

1,461 

0.584 

2,395 

0.958 

1,115 

0.446 

2,124 

0.849 

Policy option 2 - Industry 
Proposal  
Policy option 3 - 
Mandatory Ecodesign 
Requirements (Regulation) 
Policy option 4 - 
Mandatory Energy 
Labelling 

Video players/ recorders 

4 

Assumption: 0.4 kg CO2/kWh following MEErP  
7 

 
 
 
 
                                                            
Policy option 3 - 
Mandatory Eco design 
Requirements (Regulation) 

360 

0.145 

50 

0.020 

Policy option 2 - 
Mandatory Eco design 
Requirements (Regulation) 
Policy option 3 - 
Mandatory Energy 
Labelling 

6 

62 

Projectors 
0.002 

0.025 

2 

23 

0.001 

0.009 

Table 3: Summary of quantified annual impacts - 2020 and 2025 

Table 3 shows that the saving potential of games consoles is much more significant than for 
the two other product groups.  

5.1. 

Game Consoles 

The regulatory option with ecodesign measures (Option 3) leads in the long term - by 2025 - 
to  most  savings  (2.4  TWh  per  year),  and  provides  therefore  the  highest  environmental 
benefits,  but  has  also  the  highest  economic  and  social  impacts.  The  energy  labelling  option 
(Option  4)  has  similar  effects  to  the  ecodesign  option,  but  will  be  slightly  less  effective 
concerning environmental impacts and savings (2.1 TWh per year). The self-regulation option 
(Option 2) has the lowest economic and social impacts, but leads in the long term to savings 
of only 1.1 TWh per year, lying in the middle between “no-action” and the regulatory options.  

However,  Option  2  has  the  advantage  that  it  is  already  effective  in  the  short-  and  medium-
terms.  The  Option  2  annual  electricity  savings  of  1  TWh  can  be  translated  into  around  200 
Million  Euros  of  cost  savings  on  electricity  for  consumers.  The  fact  that  technology 
developments and market changes for such electronic equipment are very rapid suggests that 
referring  to  the  medium-term  forecast  rather  than  to  the  long-term  forecast  might  be  more 
reliable.  

5.2. 

Video Players/ Recorders  

A mandatory ecodesign option would achieve some additional savings in comparison to the 
“business as usual” option, but the overall saving potential is very low. The preferred option 
for this product group is therefore Option 1, "No action".  

5.3. 

Projectors 

The analysis 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  baseline 
scenario. The preferred option is therefore Option 1, "No action". 

6. 

CONCLUSIONS 

For game consoles, the self-regulation Option 2 is the preferred choice. It provides the most 
advantages,  has  the  best  cost-benefit  ratio,  and  provides  the  best  energy  efficiency 
improvements. It contributes to solving the continuity problem with the current positive trend 
towards  energy  efficiency.  In  this  dynamic  sector,  Option  2  generates  almost  comparable 
savings  to  the  alternative  of  mandatory  ecodesign  or  energy  labelling  requirements,  it 
provides  flexibility,  and  it  enables  quicker  updating  of  target  levels,  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. 

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The  self-regulatory  initiative  proposed  by  the  games  consoles  manufacturers  was  finally 
revised in November 2014 to the satisfaction of all Commission services. It is suggested that 
the proposal, and especially the monitoring system, be reviewed by the end of 2017.  

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