EU CoC Tier 2, Expanded Analysis

An Understanding and Brief History of the European CoC Tier 2 Regulation, for External Power Supplies (Lot 7) , Explanation and Status Report

May 1, 2018

The European Commission JRC (Joint Research Centre) Renewable Energy Unit, produces memorandums of understanding for manufacturers of energy consuming products, with the purpose of encouraging manufacturers to design/produce products which are of low environmental impact.

Manufacturer participation is voluntary. However membership by a manufacturer may help increase the general positive view of the company by the general public. At present membership is relatively small only 4 companies, for the external power supply category.

A key part of the mission/strategy of the JRC is to produce enhanced energy performance standards. The member companies are then required to produce 90% of their products in compliance with the enhanced energy performance standards.

(2013-10-29) https://e3p.jrc.ec.europa.eu/sites/default/files/documents/publications/code_of_conduct_for_eps_version_5_-_final.pdf

As these standards are voluntary and not required by EU law, any company may claim individual product compliance to these standards, providing good technical data which supports their claim is available. As part of the Code of Conduct on Energy Efficiency of External Power Supplies, Version 5, the JRC added provisional dates of mandatory compliance, which would require approval by EU law. However at the present point in time, the original JRC recommendations for Tier 1 and Tier 2 provisional dates legislative enactment, have been preempted (superceded) by the EcoDesign April 2015 Draft Working Document for the EPS/BC document 278/2009.

The Ecodesign, April 2015 Draft Working Document for EU legislation (has not been enacted, still “draft”) for EL6 Compliance on January 2017, and Tier 2 Compliance on January 2018: https://www.energimyndigheten.se/globalassets/energieffektivisering/produkter-med-krav/externa-nataggregat/draft-up-dated-working-document-eps-for-written-comments_278-2009.pdf It is necessary to understand, that unless a document is enacted by legislation, the recommended compliance dates are meaningless.

Note, when/if legislation is approved, a transition plan with a 2 year future date would typically be specified/required in the legislation. Therefore it seems unlikely that the Tier 2 limit requirements would be mandated before 2020. Additionally, please note, the 10% load efficiency criterion is dropped to harmonize energy performance metric internationally, as suggested by Jan Viegand and the Digital Europe trade group.

Meeting of the Consultation Forum on 2013-04-18: http://www.eup-network.de/fileadmin/user_upload/2015/Explanatory_Note_Up-Date_ReviewExternal_Power_Supplies__16042015.pdf

Report on March, 2014 by Viegand/Maagoe subcontracted company by the European Commission -Directorate - General for Energy http://www.eup-network.de/fileadmin/user_upload/2015/EPS_Review_Additional_Assessment_up-dated_Final_Report.pdf

Despite, the probable long delay before a Tier 2 implementing legislative measure, it is still a possibility. Therefore it is a good exercise to imagine what such a measure would entail. As I see it, if a Tier 2 requirement was to be mandated by law, then it is logical to presume that it would be harmonized with the International marking protocol for EPS, thus it will be given the moniker Efficiency Level VII, which we might refer to internally as EL7.

One of the dilemma’s with this presumed EL7 average efficiency target is the problem of 115Vac 4PAE (4 point average efficiency) in comparison with 230Vac 4PAE. We typically measure roughly a 0.6% to 1.0% higher 4PAE at 230vac compared to 115Vac model, when a PFC front end is used. This is a natural result of the efficiency delta, for the diode bridge at low AC voltage compared with high AC voltage.

Therefore, implementation of an EL7 parameter at both 115V and 230V will ratchet higher the metaphorical technical wall for power supply design even higher. Let us look at it another way:

If a 100W rated power supply is passing the CoC Tier 2 4PAE requirement of 89% at 230vac, perhaps with a 89.7% value, and then tested at 115Vac, there is a likely 88.9% (0.8% delta) 4PAE value, which is a pass for EL6, but a fail for the hypothetical EL7 category, however all the data analysis and crunching for determining the 89% CoC Tier 2 value, was undoubtedly done for 230Vac, as a cost/time simplification. Therefore, the 89% CoC Tier 2 limit for a 230V product, (keep in mid the EU is only 230Vac) is essentially the same as a 88% EL6 limit in 115V America. So although statistically relevant to require 89% for the EU based upon economics of production and cost of materials, when the same CoC Tier 2 limit is applied internationally including 115V countries, it looks like a cost imperative.

One of the common themes in the development of compliance engineering standards, is the concept of globalization of standard, properly referred to as “harmonization” of requirements. The original formation of the international marking protocol for EPS, used the term Efficiency Level, followed by a roman numeral to denote, the energy use performance metric. While the original conference was international in scope, and the EL1, EL2, EL3, and EL4 levels were defined for the EPS category, subsequent actions by the EU for EL5, and the USA DoE for EL6 were unilateral. Industry trade associations such as Digital Europe recognize the need to have universal, international, simultaneous action on this type of regulation, often referred to as Harmonization. The present recommendation from high level compliance engineers in the EU to simply adopt the EL6 energy performance metrics from the DoE in the USA, seems like a well-reasoned and logical course of action.

In any event, ultimately there is a bit of the tiger chasing it’s tail aspect to the continual pursuit of the perfect power supply, when the overall power consumption of the end-use product is fundamentally driven not by the power supply energy consumption, but rather by the end-product’s own energy consumption. In other words, the most energy use benefit, is obtained when one concentrates on reducing energy usage of the actual end-product design, and not the power supply design.

Based upon previous time interval lapse between EL5 and EL6 compliance regulations, a probable delay of 5 or 6 years between an EL6 and a new EL7 level is conceivable. This could result in a possible regulatory proposal date after 2020 for the EU, should this ErP component be considered in future EU legislation. Typical of regulatory document protocol, a 2 to 3 year period would then be added to allow manufacturers time to use up old stock and design new products.

Link to the EcoDesign Requirements for EPS, original website: http://www.eup-network.de/updates/general-news/news-detail/review-of-regulation-278-2009-eps-updated-working-document-published/

Link to the EcoDesign Requirements for EPS, new recommended website: English: http://www.eceee.org/ecodesign/products/battery-chargers/ http://www.eceee.org/ecodesign/
German: https://netzwerke.bam.de/Netzwerke/Navigation/DE/Evpg/evpg.html

Link to the Digital Europe, Revision of Lot 7 External power Supplies Regulation http://www.digitaleurope.org/DesktopModules/Bring2mind/DMX/Download.aspx?Command=Core_Download&EntryId=984&language=en-US&PortalId=0&TabId=353