China has submitted comments in response to the EU’s WTO TBT posting of new ecodesign requirements for external power supplies (EPS) (November 2018 ECD Report). The Chinese comments request:

• To delete the requirement to provide information on 10% load efficiency
  • China’s argument is that other countries such as US, Canada, Australia do not require testing at 10% load
  • If the 10% load requirement is not deleted, China recommends exempting EPS with output power level ≤10W
• Clarification of the exclusion for spare parts for products that are place on the market by 1 April 2021. Given that the requirements come into effect in 2020 the allowance for products placed on the market before 2021 is unclear.
• Clarification of the meaning of “household and office equipment”
  • The definition in the proposed regulation is vague compared the definition in the existing EPS regulation.
  • China suggests clarifying that this refers to EMC class B products as set out in EN 55022:2006
• Extend the transition period until 1 April 2021 instead of 1 April 2020. China feels that a one-year transition period is too short
• Exclusion of two types of EPS:
  • Power frequency transformer
  • EPS with power line communication (PLC) function
• To revise the test procedure for multiple output EPS
  • EN 50563 does not include multiple voltage output power supplies within its scope
• That the regulation should specify power consumption using only two decimal places (as specified in IEC 62301-2011) instead of the current three decimal places proposed in Annex I(a). Three decimal places of accuracy will impose new requirements on test equipment and test methods for testing EPS.

Impact on EEE Manufacturers

The regulation will impact most product manufacturers that use external power supplies.  The outcome of China’s question on the definition of “household and office equipment” could have an impact on whether your EPS are in scope or not.