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7th July 2023
GEMS, Department of Climate Change, Energy, the Environment and Water
Dear Sir/Madam,
CESA comments on the Regulation Impact Statement for
consultation on the energy efficiency of electronic displays.
Televisions, computer monitors and digital signage displays.
2023
The Consumer Electronics Suppliers Association (CESA) welcomes the opportunity to make a submission on the above regulation impact statement.
CESA is the premier national, industry body in Australia representing suppliers of consumer electrical and electronic appliances and equipment. Members of CESA include major global suppliers of products such as televisions, home entertainment products, computers, computer monitors, whitegoods, cooking appliances, gas appliances, small appliances, accessories, and air conditioning equipment.
General Comment
CESA supports the Departments intension to increase MEPS levels for Television and
Computer Monitors and the introduction of MEPS for Digital Signage Displays.
CESA supports the move to align with the EU regulations and prefers a single step to the EU
2023 regulations.
CESA does not support the use of IEC 623078 Part 2 and 3 2023 until they are referenced in
EU regulations.
CESA PO Box 250 Avoca Beach NSW 2251 Tel: 0411 627 270
ABN: 34 065 208 531 www.cesa.asn.au
Page 2 of 7
To Answer the Specific Questions
Televisions and Computer Monitors
1) Do you support the proposal to increase the stringency of MEPS for televisions and
computer monitors and harmonise efficiency requirements with the European electronic
display regulations?
Yes, Australia and New Zealand have fallen behind mandatory international energy
efficiency levels.
2) One option is to introduce the EU 2023 requirements 1 to 2 years after introduction in
Europe (Options A) and B)). The other option is a staged approach where the EU 2021
levels are introduced in 2024, followed by the EU 2023 levels in 2026 (Option C)).
Which of the options do you prefer and why?
Our preference would be Adopt EU MEPS 2023 2 years after Europe. Harmonise the scope
of Australian and New Zealand regulation of televisions and computer monitors with the
EU. Option 2 (B).
A 2-step approach would require suppliers to re-register products a 2nd time with GEMS
needing to go through a deemed to comply process to identify compliant products to the
2023 MEPS level. It would be simpler and less confusing if Australia and New Zealand
undertook a single step to catch up to the current EU 2023 levels.
3) Do you have a view on when any new requirements should be introduced or what transition
arrangements should be considered in introducing new regulations? How much time would
your company need to adjust to any change?
Our members have indicated that a minimum of 24 months from the Determination signing
to enforcement for the 1-step arrangement to EU MEPS 2023. Each year televisions
suppliers tend to introduce their new models in the 1st half of the new year. The
Determination in force date should be 1st July which would provide a transitional period of
somewhere between 24 and 36 months.
4) Are there any issues that need to be considered if the scope of the efficiency regulations
for televisions and computer monitors is harmonised with the EU scope?
Australia and New Zealand should consider a less aggressive Max EEI for displays with 8K
and higher pixel count. The EU 2023 Max EEI of 0.90 is too difficult for manufacturers to
meet with current screen technology. To achieve Max EEI of 0.90 the image brightness is
insufficient.
Australia and New Zealand should consider a Max EEI of 1.10 (EU 2021 4K) initially.
If this approach was implemented the Energy Star Rating algorithm would depart from the
EU grading proposed in the CRIS.
CESA PO Box 250 Avoca Beach NSW 2251 Tel: 0411 627 270
ABN: 34 065 208 531 www.cesa.asn.au
Page 3 of 7
5) What issues need to be considered if the 2023 EU MEPS levels were adopted for televisions
and computer monitors?
Televisions: The EU label has 2 energy efficiency class ratings and 2 energy consumption
figures. This approach will confuse consumers. We need the label to reflect actual usage
in Australia/New Zealand. Usage is moving towards streaming with an increasing
percentage of Australian household viewing streamed content which is increasingly HDR.
Consideration should be given to the ERL displaying an energy consumption figure which
is the average of the SDR and HDR power consumption. If adopted the Energy Star Rating
algorithm would be the average of the SDR and HDR EEI.
A different ERL design will be required as Grandfathering will allow products registered to
both determinations to be in store at the same time. Suggest seriously looking at
implementing the swimming pool pump style label design which includes the star rating
numeral under a single 1 to 10 star arch.
A retailer fact sheet should be considered to explain the dramatic star level change under
the new Determination.
Computer monitors: large screen and high-performance models (which have not
previously been regulated) will require a longer transitional period allowing manufacturers
to develop compliant models. The determination should include a 2-year transitional period
from the date of publication.
6) What issues need to be considered if a staged approach (EU 2021 followed by EU 2023 in
Option C) was adopted?
This is not our preferred approach, due to additional complications with the possibly of 2
grandfather periods in effect and the additional registration requirement.
7) Do you agree with the assumptions and methodology described in Chapter 5 and the CRIS
Technical Appendices for the cost benefit analysis?
We see no reason to disagree.
8) Do you agree with the assumptions about the number of hours that televisions and
Computer monitors are used per day? Should the number of assumed hours of usage be
changed from 10 hours per day for Energy labelling to reflect more typical viewer habits?
Our preference would be to retain the 10 hr per day rating. This is a comparative figure
and not representative of individual usage habits. 10 hr is an easy number for customers
to make individual assessments against.
CESA PO Box 250 Avoca Beach NSW 2251 Tel: 0411 627 270
ABN: 34 065 208 531 www.cesa.asn.au
Page 4 of 7
9) What level of MEPS would be appropriate for 8k televisions? Are there any issues in
including 8k televisions in a new efficiency regulation?
As discussed in 4) above, Australia and New Zealand should consider a less aggressive Max
EEI for displays with 8K and higher pixel count. We propose a Max EEI of 1.10 (EU 2021
4K) should be considered initially.
The energy efficiency class (star rating) label will require a different scale commencing
from EEI 1.1.
10) Do you have any data or information about the expected future market for 8k televisions
that you can provide? Any such information will be treated confidentially by the
Department.
8K televisions are expensive to manufacture, sales have been low since their introduction
several years ago which has led to less models on offer presently. If history is any
indication, 8K, like UHD 4K, will find its place and sales will increase as the price of large
screen TVs, 100” and above comes down. This may be a few years off. The EU 2023
regulations may set back the development of 8K televisions using current screen
technology.
11) What issues need to be considered if the 10% reduction in measured energy consumption
is adopted for digital screens with active automatic brightness control (ABC)?
There should be consideration given to identifying ABC models with a tick box on the ERL.
These models will use considerably less energy in darker environments.
12) Are there any issues if the latest IEC62087 Part 2 and 3 (2023) standards are adopted as
the test method standard for new efficiency regulations? The newly published IEC 2023
test method standard is equivalent to the current EU test method.
We do not support the use of IEC 623078 Part 2 and 3 2023 until they are called up in
European regulations. There are several differences between the IEC 2015 and IEC 2023
standards which could alter the testing outcome. Manufacturers complying with EU 2023
MEPS are testing products to the IEC 2015 standards and EU 2023 regulations. If Australia
and New Zealand were to require compliance based on the IEC 2023 standards, additional
testing will be required to show compliance to the IEC 2023 standards in the supporting
test report.
13) Do you have a view on the proposal to base new star ratings on the European label
grades? Are there any other star rating issues that need to be considered?
This seems like a sensible approach; the EU label provides scope for higher efficient
products in the future. This will result in the loss of ½ stars.
CESA PO Box 250 Avoca Beach NSW 2251 Tel: 0411 627 270
ABN: 34 065 208 531 www.cesa.asn.au
Page 5 of 7
14) How should labels be displayed in show rooms and shops? Would there be any issues with
allowing suppliers and retailers to use a digital label displayed on screen instead of a printed
label? Should other label options be considered, such as affixing the label to packaging?
A variety of labelling options should be allowed. Due to the slim screen boarder of modern
digital displays the physical label option should allow a tag type which is attached to the
upper rear part of the cabinet with the printed side of the label to fall over the front of the
screen. Models/brands that are predominantly sold in the carton should be permitted to
have the label printed on the packaging surface. The option to include the physical label in
the accessory pack should also be permitted.
Models capable of displaying a digital form of the ERL in Retail Mode should also be
permitted. A process will be required so that manufacturers can in-house design the digital
ERL.
Digital Signage Displays
1) Do you support the proposal to introduce mandatory energy labelling for digital signage
displays and harmonise efficiency requirements with the European electronic display
regulations?
Industry supports MEPS for digital signage displays however does not support mandatory
energy labelling. Digital signage monitors are not viewed by the purchaser and therefore
the energy consumption and Star rating information only needs to be available on the
GEMS public search database.
We support harmonising efficiency requirements with the European electronic display
regulations 2 years after EU regulation.
2) What opportunities or difficulties could mandatory labelling and energy requirements create
for your company? Sufficient time to develop compliant models. Would your company be
able to adjust to any change, if given sufficient time? Alignment with European
requirements could be achieved. How much time would your company need to adjust to a
change?
Regulation of digital signage displays will be regulated for the first time and therefore a
minimum of 2 years transition period is required from the publication of the Determination.
Digital signage displays have a longer new product life cycle that Televisions.
EU 2023 regulations have complicated inclusions and exclusions for digital signage displays,
a detailed fact sheet will be required to help manufacturers correctly apply the
determination.
CESA PO Box 250 Avoca Beach NSW 2251 Tel: 0411 627 270
ABN: 34 065 208 531 www.cesa.asn.au
Page 6 of 7
3) Do you have a view on when any new requirements should be introduced or what transition
arrangements should be considered in introducing new regulations?
Ideally 24 months transitional period from Determination sign off due to the fact that these
products are not currently regulated. Recognition that these are commercial products that
may be included in sales contracts signed several years before supply. Products included
in sales contracts when the Determination comes into force need to be exempt from
compliance.
The design life cycle is longer for this product segment which must be considered.
4) Are there any issues that need to be considered if the scope of the efficiency regulations
for televisions and computer monitors is harmonised with the EU scope?
Follow the EU lead however do not mandate ERL for digital signage displays.
5) Do you agree with the assumptions and methodology described in Chapter 5 and the CRIS
Technical Appendices for the cost benefit analysis?
We have no comment.
6) Do you agree with the assumptions about the number of hours that digital signage displays
are used per day?
We agree if aligned with EU.
7) Are there any issues if the latest IEC62087 Part 2 (2023) standards are adopted as the test
method standard for new efficiency regulations?
We do not support the use of IEC 623078 Part 2 and 3 2023 until they are called up in
European regulations.
If Australia and New Zealand were to require compliance to the IEC 2023 standards,
additional testing will be required to show compliance to the IEC 2023 standards in the
supporting test report as EU test reports would state IEC 623078 2015 compliance.
8) Do you have a view on the proposal to base new star ratings on the European label grades?
Are there any other star rating issues that need to be considered?
This sounds like a logical approach in conjunction with the European energy requirements.
The electronic label that appears on the GEMS registration site could follow the design of
the swimming pool pump ERL where the star rating numeral appears in the star rating
arch. Using the EU label grades will only provide full star rating, no ½ stars.
CESA PO Box 250 Avoca Beach NSW 2251 Tel: 0411 627 270
ABN: 34 065 208 531 www.cesa.asn.au
Page 7 of 7
9) How should labels be displayed in show rooms and shops? Would there be any issues with
allowing suppliers and retailers to use a digital label displayed on screen instead of a printed
label? Should other label options be considered, such as affixing the label to packaging?
These are commercial products generally not shown at retail level, we do not see the need
or benefit in mandating an ERL. If an ERL was mandated the preference would be for a
digital label. An option to the digital label would be the allowance of a physical label
included with the product’s accessories bag.
10) How should digital signage displays be defined for registration and labelling purposes?
Follow the EU methodology for definitions. Labelling as discussed previously is not required
as the product is rarely on display at the point of purchase. The GEMS registration site can
include a replica of the ERL.
Yours sincerely,
Stuart Parker
General Manager
Consumer Electronics Suppliers Association stuart.parker@cesa.asn.au
CESA PO Box 250 Avoca Beach NSW 2251 Tel: 0411 627 270
ABN: 34 065 208 531 www.cesa.asn.au
