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Sony Europe Limited

Sony Europe Limited houses our European Corporate and Business Support functions, the Sports Entertainment Business Unit, Sony Semiconductor Solutions Europe and our R&D centres.

Lobbying Activity

Response to Energy labelling for electronic displays

7 Nov 2018

Sony is a manufacturer of consumer and professional displays, as such, we appreciate the opportunity to provide comments to the European Commission’s draft act on energy labelling rules for electronic displays (TVs, monitors, signage), amending (EU) No 1062/2010. For improvement of the current draft, Sony suggests that a reference to High Dynamic Range (HDR) is not included among energy labelling information. This due to the following reasons: - HDR is not a term with which users are often familiar. This term could be easily confused, leading to misinterpretation of the energy labelling information. - A single weighted value between SDR and HDR energy consumption would lead to misleading information, as the current or future uptake of HDR is not possible to be estimated without high levels of uncertainty. - Finally, there is no HDR measurement standard available today that can be used to measure consumption using HDR signal, and the availability of such standard by the entry into force of the new label is questionable.
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Response to Ecodesign requirements for electronic displays and televisions

7 Nov 2018

Sony is a manufacturer of consumer and professional displays, as such, we appreciate the opportunity to provide comments to the European Commission’s draft act on ecodesign rules for electronic displays (TVs, monitors, signage), amending (EC) No 642/2009. We have evaluated the current proposal and observed positive evolution for this revision process, which started in 2012. Nevertheless, we remain strongly concerned about a number of requirements in the areas of energy and material efficiency, including: 1) The overly strict on-mode power consumption limits, which fail to recognize the reality of current display technology, and will result in an overwhelming number of displays restricted from the EU market, excluding not the least energy efficient displays, but particularly affecting feature-rich displays and new panel technologies. 2) The inadequate low power mode requirements applied horizontally for all types of signage displays, which will prevent certain type of signage from market access. 3) The automatic power down requirements that contravenes the functionalities requested from broadcast displays. 4)The repair and re-use information requirements making manufacturers to share very detailed information, potentially leading to intellectual property losses, and end-of-life information that will generate significant administrative burden but cannot be substantially used by recyclers. The document attached summarizes Sony’s concerns, and provides explanations to justify the suggested improvement modifications to the act draft.
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Response to Ecodesign requirements for electronic displays

18 Jan 2017

A successful implementation of eco-design requirements can only be achieved when regulation 1) sets clear and sensible rules, and 2) allows sufficient time for the redesign of products. The proposed regulation does not satisfy either of the previous conditions. Instead, a very short timetable is set, and the implementation of several requirements can endanger the proper functioning of Sony technology. Scope - The horizontal scope involves a wide range of products, yet a proper assessment remains to be performed to fully understand the implications on all products covered. The conclusions of the study done exclusively on 2K & 4K TVs and monitors were extrapolated to other displays without considering technical specification or functionality. To reduce the risk of safety hazards, malfunctions, market disruption and double regulation, the scope should not cover: displays integrated into other products, displays operated by batteries, 8K technology, ICT products (still to be assessed under WP3), and all displays for which a thorough study has not yet been done. Definitions - Even when Recital 8 recognizes that the energy use of signage displays is different from that of other displays, the definition proposed is very narrow. Thus, a large share of signage displays will fall under inadequate energy limits. A new definition is needed. Energy requirements On mode - Such strict requirements should be introduced gradually providing sufficient time for redesign. Since this is not currently the case, the regulation poses a serious threat to about half of TV models (from all manufacturers) as soon as 2018. At a minimum, limits should be eased by 20-30 percent and all enforcement dates postponed by one year. Standby mode - a limit of 0.3W threatens the compliance of over a half of displays on the market. A Fast/Quick start enabled function with this limit is not achievable. It needs to be increased to 0.8W. Moreover, EMC Class A products, such as professional and broadcast displays, exempted from reg. 1275/2008, should be exempted from this requirement, as for technical reasons is near to impossible to comply, or an adequate period for redesign given, starting from 0.5W/1.0W limit. Standby definition should align with reg. 1275/2008. Current definition is unclear and faulty. Network standby mode - In order to consider design previsions and avoid unpredictability in regulation, the limits should align with reg. 801/2013. Peak luminance ratio - A fixed ratio of 65% can result in unnecessary high luminance at standard home mode. The suggestion is to align with Energy Star V7.0 requirement. Software/firmware update - The large majority of updates are done to correct malfunctions. If the user decides to reject the update, the malfunction will interfere with the user experience, which may result in a large number of displays disposed prematurely. A study remains to be done to understand the environmental and commercial consequences of users rejecting the updates. Resource requirements Dismantling - An exemption should apply when gluing/welding is technically or legally required, needed for safety or to ensure quality. This is particularly true when implementing a horizontal scope. I.e. some medical displays require gluing of PMMA board or glass to the LCD panel to avoid contamination. Marking of plastics - The feasibility of marking of flame retardants can only be assured if the exemptions for marking of polymer type are also applicable to marking of flame retardants. Information requirements Repair & EoL - On providing information for repair, this is a threat to confidentially, and the actual profit for experienced repair technicians is questionable. On providing information for recycling, it is unfeasible to estimate exact amount of substances given the complexity of supply chains, and the benefit for recyclers is yet to be proven. At a minimum enforcement dates for repair and EoL should be postponed to Jan 2020.
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