Position: 
The electronics industry supports voluntary, market-oriented programs and initiatives, including industry-led standards, which highlight and sustain energy efficiency in the electronics industry. The electronics industry will continue to work cooperatively with governments in the development of energy efficiency initiatives that complement and support voluntary approaches and continued innovation, expanded consumer choice,
and enhanced product functionality.  The electronics industry opposes government-imposed approaches that stifle innovation, reduce consumer choice, and limit product features and services. 

Background: 
Technical innovation, supported by voluntary programs and initiatives, is the primary driver of energy efficiency in the electronics industry. The industry designs, produces and markets products and services that enable people to stay connected, informed and entertained. By their very design, electronics must use electricity efficiently and effectively. This is important with respect to physical issues such as heat generation and economic considerations such as component selection and design. Beyond design, there also are major industry trends which naturally drive, support and sustain the energy efficiency of electronics. These trends include convergence, miniaturization, and the transition from analog to digital technology. 

For many years, the electronics industry has worked cooperatively with government agencies in pursuit of successful voluntary, market-oriented programs and initiatives, such as Energy Star, which highlight and support energy efficient product design and purchasing. The electronics industry also is deeply involved in voluntary, industry-led standards setting activities at the national, regional and international levels on a variety of subjects, including energy efficiency. These voluntary initiatives have transformed the market and delivered more energy efficient products to consumers and businesses over time. 

The use of electronics helps to save energy, reduce greenhouse gas emissions, and protect the environment. In many ways, electronics are part of an energy savings solution. Many home networking products help to save energy by providing increased control over home heating, cooling and lighting systems. Information technology and telecommunications products allow teleworking and remote access to information and entertainment, both of which save fuel and reduce smokestack emissions. In addition,  electronics are key enabling technologies that drive energy efficiency in various sectors such as automobiles and manufacturing. 

Demand for energy, including electricity, continues to be a major topic around the world. As governments consider programs and policies that support the efficient use of energy, the electronics industry must guard against ill-conceived regulations and mandatory standards imposed by governments that could stifle innovation and have adverse impacts for consumers and manufacturers. Governments must recognize and support innovation and the pursuit of voluntary initiatives which are the keys to energy efficiency progress in the electronics industry. Realistic solutions and initiatives for energy efficiency in the electronics industry can best be reached through a government-industry partnership that thoroughly analyzes the facts to determine what is best for energy conservation, innovation, consumers and high tech manufacturers. Since voluntary standards contain aspirational elements they should not be used to regulate products. With these considerations in mind, several principles are crucial for governments focusing on energy efficiency policies related to electronics: 

SUPPORT VOLUNTARY INITIATIVES: Governments and industry groups around the world have developed, and will continue to develop, voluntary initiatives focused on energy efficiency and eco-design.  Future government initiatives should complement and build on these existing voluntary efforts to the maximum degree possible.

HARMONIZATION: With a global supply network and customer distribution, it is critically important to synchronize international requirements. Multiple requirements across different regions create design, manufacturing, and supply chain chaos, increasing the cost of final products for consumers. Mandatory product labeling should be avoided or at least harmonized to existing standards. 

FLEXIBILITY: Requirements should not hinder innovation nor impede customer-demanded performance features, consumer use or behavior. Requirements should be performance-based, holistic and flexible rather than prescriptive. Product safety and other factors should be taken into account. 

COST-EFFECTIVENESS: The cost to implement efficiency requirements should be offset by energy savings within the life span of the product. The interval between promulgation and implementation must take into account product development cycles and supply chain capability. 

MEASURABILITY: Requirements should be quantifiable and verification should be based on clear and reasonable testing procedures. 

PRODUCT DIFFERENTIATION: Consideration should be made for market segmentation and performance variations. Requirements must not favor proprietary technologies. 

PROCESS TRANSPARENCY: All affected stakeholders should have a meaningful opportunity to engage in the development of the requirements. 

COMPLIANCE: Compliance verification should be handled via self-certification, such as 1-1-SDoC, etc. Pre-market testing or other requirements that hinder free trade should be avoided. Administrative burdens should be kept to a minimum.