As part of the better regulation agenda, the EU has launched a public consultation on draft legislation, such as the draft Ecodesign implementing measure on electronic displays.
In a nutshell, FEM requests the full exclusion of all displays integrated and to be integrated into equipment and industrial machines. FEM highlights the need to exclude displays to be integrated into other equipment, to avoid market distortions between machines assembled in the EU and imported machines already including displays.
As far as resource efficiency requirements are concerned, FEM raises concerns about uncertainties regarding responsibilities to implement requirements for integrated displays and the too prescriptive approach to assembly of display components.
Finally, FEM also raises concerns about the lack of impact assessment for the whole range of affected equipment and the inappropriate consultation of stakeholders, although these are required under the framework Ecodesign Directive.
All comments provided to the European Commission, including the FEM input, are available on the EU website: https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2016-7108187/feedback_en.