What this means is that affected items (see below) will need to undergo a compliance and regsitration process (see below ) in order to be sold. This has huge ramifications on the IT industry (IMHO)
The process being implemented ( See below) is binding on all manufacturers of computers, be it someone who manufactures 10000 pcs or someone who manufactures 1.
SUMMARY:
This legislation really concerns me because:
- It adds huge compliance costs to those who build one off computers,
- It looks like it was written by someone non-technial and has huge holes in it,
- It is forcing builders of computers to pay for receiving compliance standards (>$200)
- Builders have to register all computer models on foreign government web sites
- Increases the cost of building 1 off computers by over $900 per unit. It will force small business who build computers out of business.
Computers Affected:*
All computers that are imported or manufactured in New Zealand for sale or hire, including:
- desktop computers
- notebooks
- small scale servers
The following computers do not need to comply with MEPS:*
- Personal digital assistants (PDAs).
- Palmtop computers and smartphones.
- Games consoles.
- Blade, slate or thin client computers.
- Workstations.
- Computers that are not connected to mains voltage or by external power supply.
So who is a manufacturer?
According to the information I can gather it is anyone who manufactures, imports a computer. If you build a computer from components you are a manufacturer.
So whats the problem?
EECA are requring ALL computer manufacturers to register ALL models of manufactured Pc with them. The registration process is as follows:*
"What do I need to do to comply with the law?"
As an importer or manufacturer of computers, you are required to:
- Step 1. Ensure each computer model has been tested to the AS/NZS 5813.1
- Step 2. Ensure each computer model has efficiencies that meet or exceed the minimum energy performance levels specified in AS/NZS 5813.2.
- Step 3. Register each computer model through the energy rating website.
- Step 4. Provide product sales, import and export data each year to EECA.
Here is where it starts to bite:
- Step 1 - Compliance testing requires you to test power efficiency on all models of computer. To test whether a computer is 85% efficient at 100% power load you will need to have a device that sits between the power supply and the computer and is capable of running the computer to 100% power usage. I personally dont have that type of equipment and I'm sure it wont come cheap. what is more the standards you have to comply with have to be PURCHASED - you need to pay for the information required on how to be compliant. This is a rort.
- Step 2 - Computers need to be fixed at the hardware level to automatically go into power idle / shutdown mode after 30 minutes of inactivity. Kiss goodbye to video watching, backups, anti virus runs, screen savers, presentations etc. unless you, the end user are able to figure out how to set the hardware settings back to something that doesnt auto turn off when you are not fiddling with the keyboard. Servers with hardware power savings modes? I've yet to see a system that effectivly handles power savings for AV, downloads, backups or server work.
- Step 3 - Register - all models need to be registered on an AUSTRALIAN govenrment website. Since when did we become a vassal state of Australia? We, NZ citizens, are now required to REGSITER on a foreign states web site - You must be joking.
- Step 4 Paper work, compliance and cost.
EECA put out a Consultation draft% for stakeholder comment issued pursuant to S36 (2) of the Energy Efficiency & Conservation Act 2000% in Sept 2011. The list of those consulted is below^ As you will see it was mostly Australians with a couple of NZ larger firms thrown in.
They further state it will only affect about 58 businesses in NZ but yet all manufacturers of Pcs are affected. Small businesses like mine are going to get bitten and have been forgotten.
Finally:
The total maximum beneft to NZ is calculated to be $264m of cumulative benefit by 2025. This compliance will save NZ an average of $2.3m per year - I hate to think what the cost of Govt oversight of this shambles will be.
Compliance for a new model will cost you (from EECA document)%
- Product registration (in Australia only) A$150 – A$280 Depending on registering authority used (No NZ figure but we have to reigster using gov.au site so assume same as for aussies)
- Standards A$200 - Typical cost of a 2 part standard (must be purchased )
- Testing costs (computers) A$500 – A$1,000 Typical cost of test at NATA27 accredited lab. In house test reports are acceptable for product registration
- Testing costs (monitors) A$800 Typical cost of test at NATA28 accredited lab. In house test reports
- What constitutes a new model of computer? Different CPU? Different case? different graphics card?
- When does a rebuild of an old computer constitute a new PC? Therefore requiring registration? if I take a new PC and put in one old component is that a rebuild or a new model?
- Desktops need to be registered, work stations dont? what is the difference? Even using official types of definition of work station I cant divide between the two. http://www.webopedia.com/TERM/W/workstation.html
- When does a small server become a large server?
- Gaming PCs - you design them to chew through power. Efficiency? Is it good to have an 85% efficient 2kw monster and bad to have an 80% efficient 0.1kw baby PC? (think the raspberry pi)
Conclusion:
I am an NZ citizen. I should not be forced to register my work product on foreign government web sites. This is a sovereign state, legislation and compliance should stay inside NZ jurisdiction.
Forcing me to add over $1000 to the cost of building one off computers is insane
This to me looks like a process and legislation written by non-technical people who have made a hash of it. The materials I have seen a loose and unenforcable.
Consultation was for the big guys and Aussies only. This is not fair on thousands of small businesses around NZ
*MEPS pdf produced by EECa and distributed to those manufacturing or imprting computers.
% proposed-standards-computers-oct-2011.pdf - EECA
^ firms consulted.
Table 7: Timetable of open consultation meetings
Date Location Notes
Nov 2007 Auckland EECA met with Westpac, Renaissance (Apple suppliers),
ICT, IBM, HP, Lenovo, Sharp, ASA, NZ Retail Association,
Noel Leaming, Farmers, Panasonic, Genii, Ricoh, Ministry
for the Environment (MfE), The Warehouse, CEANZ,
Phillips
19 Dec 2007 Melbourne Les Winton consumer survey group
8 Feb 2008 Grand Stamford North Ryde E3 open meeting – CESA, Choice, Aust Computer
Society,
8 Feb 2008 HP head office North Ryde AIIA sustainability group
20 Feb 2008 Seville Apartments., Canberra AIIA, HP, Dell, Apple and Lenovo
22 May 2008 Medina Grand, Sydney AIIA, CESA, Apple, BenQ, Hewlett-Packard, IBM, Intel,
Lenovo, Panasonic, Samsung Electronics, Sharp, Sony
July 2008 Computers Off Australia launch,
Hilton Sydney
Presentation to attendees on overview of proposed MEPS
29 July 2008 Menzies Hotel, Sydney Acer, Apple, Asus, BenQ, Cisco, Dell, HP, IBM, Intel, Ipex,
Lenovo, Panasonic, Philips, Samsung, Sony, Viewsonic,
AIIA, CESA
24 September
2008
Mercure, Sydney AIIA, Distance, HP, IBM, Intel, Lenovo, NEC, Philips,
Samsung, Sony
30 October
2008
Federation Square, Melbourne Gershon Report presentation/ meeting with AIIA
23 April 2009 Menzies Hotel, Sydney AIIA, HP, Apple, Samsung, Dell, Intel, Sony, Viewsonics,
Panasonic, CESA, Sharp
Various Various One-on-one meeting with manufacturers over two years,
predating the open meetings.
Various Telecomference Consultations with overseas offices of manufacturers over
two years.
October 2010 Sydney E3 open meeting – CESA, AIIA, industry representatives,
Trusted
