Updating standards for standby, networked standby and off mode power consumption: consultation (HTML)

Question 1

Introduction

Accepted Answer

Ecodesign legislation enables the government to set minimum energy performance standards (MEPS) to remove the very worst performing products from the market, ensuring consumers are not exposed to the most expensive‑to‑run products and incentivising manufacturers to produce higher‑efficiency products. These policies have overall contributed significantly to our energy security, reducing electricity demand by an estimated 245 TWh over the last decade. They have delivered 59 MtCO₂e carbon savings since 2010 and are one of the most cost-effective ways to reduce emissions and bills, with low impact on consumers and businesses.

However, GB’s current minimum standards for standby, off mode and networked standby have not kept pace with technological progress – meaning new types of products and more complex features often fall outside our rules or exploit outdated definitions, leading to avoidable energy waste.

This consultation seeks views on proposals to update and strengthen Great Britain’s Ecodesign requirements for products in standby, off mode and networked standby, drawing on recent improvements made in the EU framework.

We are therefore proposing to repeal and replace the 2 current GB regulations covering standby, off mode, networked standby and simple set-top boxes — Commission Regulation (EC) No 1275/2008 and Commission Regulation (EC) No 107/2009 — with a single new Ecodesign regulation.

Specifically, we are consulting on proposals to:

repeal the current assimilated regulations: Commission Regulation (EC) No 1275/2008, which establishes ecodesign requirements for standby, off mode and networked standby electric power consumption for electrical and electronic household and office equipment; and Commission Regulation (EC) No 107/2009, which establishes ecodesign requirements for simple set-top boxes
align Great Britain’s requirements as soon as possible with the updated EU Regulation (EU) 2023/826 and introduce new Ecodesign requirements through a statutory instrument (SI), as set out in this document

Unlike many other regulations relating to energy-related products, which contain the entirety of the Ecodesign requirements for a particular product type, this is a ‘horizontal’ regulation that relates solely to standby, off mode and networked standby. If implemented, the proposals would introduce updated energy performance requirements for standby, off mode and networked standby, which require manufacturers to ensure products placed on the GB market meet revised design and power-consumption thresholds. The range of products proposed to be within scope is set out in Annex C.

The proposals are expected to affect manufacturers, importers, distributors and retailers of energy-related products placed on the GB market, as well as consumers who purchase and use these products. Through this consultation, the government is seeking views on the proposed approach, including alignment with EU requirements and the likely effects on businesses and consumers. For businesses, the predicted effects of this proposal would be that:

manufacturers would not need to comply with different GB and EU ecodesign requirements, reducing compliance complexity
a more streamlined regulatory framework could lower administrative costs for industry; and
improved market access could support the smoother movement of products across GB, Northern Ireland and the EU, helping to avoid internal market friction

Updating the GB Ecodesign rules for standby/off mode equipment would likely produce small net costs for some products and net benefits for others. The overall impact on a typical household’s bills is expected to be broadly neutral – it depends on the mix of products in use, and any small upfront costs are expected to be offset by subsequent electricity savings.

By 2050, the stronger standby standards could save around 11.5 TWh of electricity and 234 ktCO₂e, a significant contribution to net zero, Clean Power 2030 and UK energy security goals. These estimates depend on the products included in scope and modelled, baseline standby, off mode and networked standby energy use, product sales, stock, lifetimes and replacement rates, usage patterns and growth in smart and networked products.

A draft SI of the proposed Regulations is published alongside this consultation and should be read in conjunction with this document. Throughout the consultation, we refer to specific provisions and drafting approaches contained within the draft. We therefore encourage respondents to review the draft SI when considering and responding to the consultation questions.

Respondents are encouraged to provide evidence on costs, benefits, proportionality, unintended impacts and any alternative options.

The government is notifying the World Trade Organisation (WTO) of the proposed update to product standards and is completing the associated 60‑day standstill period alongside this consultation. Separate WTO notifications are also being made for proposed updates to Ecodesign product standards for Local Space Heating and Industrial Fans, which are the subject of separate consultations.

Question 2

General information

Accepted Answer

Why we are consulting

Improving product standards can save consumers money by reducing their bills, while cutting carbon emissions and increasing energy security. Product regulations, such as those set out in Ecodesign and energy labelling legislation are therefore a key lever to help reduce greenhouse gas emissions to net zero by 2050; reduce the administrative burden on manufacturers of having different requirements from the EU making the market more accessible to consumers and reversing divergence between GB and NI.

We welcome views and evidence on the proposals set out in this consultation document and accompanying draft statutory instrument (SI), as well as the options assessment.

Consultation details

Issued:

16 October 2026

Respond by:

24 December 11:59pm

Enquiries to:

Energy-Related Products Team
Department for Energy Security and Net Zero
3-8 Whitehall Place
London
SW1A 2EG

Email: efficientproducts@energysecurity.gov.uk

Consultation reference:

Updating standards for standby, networked standby and off mode power consumption

Audiences:

Manufacturers or their authorised representatives, importers, retailers, trade bodies, consumer groups, environmental organisations and other civil society organisations with an interest in products and equipment covered by standby, off mode and networked standby requirements.

Territorial extent:

The proposed updates to the ecodesign requirements for off mode, standby and networked standby set out in this consultation would apply in Great Britain only. Regulation (EU) 2023/826, as amended, automatically applies in Northern Ireland from 9 May 2025 in accordance with the Windsor Framework. Northern Ireland businesses would continue to have unfettered access to the GB market, in line with existing arrangements.

The proposals set out in this consultation are intended to help facilitate trade between Great Britain and Northern Ireland.

How to respond

We strongly encourage responses via the online survey. Using the online survey greatly assists our analysis of the responses, enabling more efficient and effective consideration of the issues raised. If it is not possible for you to use the online survey, you can respond through email or a written response.

Respond online

or

Email to:

efficientproducts@energysecurity.gov.uk

Write to:

Energy-Related Products Team
Department for Energy Security and Net Zero
3-8 Whitehall Place
London
SW1A 2EG

When responding, please state whether you are responding as an individual or representing the views of an organisation.

Your response will be most useful if it is framed in direct response to the questions posed, though further comments and evidence are also welcome.

Confidentiality and data protection

Information you provide in response to this consultation, including personal information, may be disclosed in accordance with UK legislation (the Freedom of Information Act 2000, the Data Protection Act 2018 and the Environmental Information Regulations 2004).

If you want the information that you provide to be treated as confidential please tell us, but be aware that we cannot guarantee confidentiality in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not be regarded by us as a confidentiality request.

We will process your personal data in accordance with all applicable data protection laws. See our privacy policy.

We will summarise all responses and publish this summary on GOV.UK. The summary will include a list of names or organisations that responded, but not people’s personal names, addresses or other contact details.

Quality assurance

This consultation has been carried out in accordance with the government’s consultation principles.

If you have any complaints about the way this consultation has been conducted, please email: bru@energysecurity.gov.uk.

Question 3

The proposals

Accepted Answer

The UK and EU set horizontal Ecodesign limits for off mode, standby mode and networked standby power consumption, and require automatic power management that returns equipment to a low-power state when it is not performing its main function.

In this consultation, we are seeking views on proposals to improve product standards by updating Ecodesign legislation for off mode, standby mode and networked standby. The policy intent is to align with the updated EU Ecodesign Regulation (EU) 2023/826, which started applying on 9 May 2025 and has resulted in divergence between Great Britain and Northern Ireland. We believe an aligned regulatory environment would reduce the administrative burden for manufacturers by avoiding the need to comply with different EU and GB ecodesign requirements, and improve product access for consumers.

This consultation includes 2 main proposals:

Modernising standards:
- Updating Regulations to reflect technological advancement
- Increasing the scope of the regulation
Improving product performance and compliance:
- Enhancing energy consumption efficiency
- Improving compliance including preventing circumvention

Modernising standards

Updating Regulations to reflect technological advancement

This proposal seeks to reflect technological advancement by updating standby, off mode and networked standby requirements. It also seeks to improve regulatory clarity so that today’s diverse device functions, such as remote activation, status displays and smart connectivity, are properly defined and regulated. The revised regulations are designed to deliver ongoing benefits by reducing the power consumed by products in off mode, standby mode and networked standby. Such measures ensure that newer standards are applied to a wider range of devices, addressing both technological advancements and the increased energy demands of modern equipment.

The intention is to modernise Great Britain’s current rules, which were originally implemented over 2 decades ago. Updating these regulations enables the inclusion of technological advances that did not exist at the time the current regulations were made. As a result, products such as air fryers, coffee makers, smart plugs and robot vacuums will now be covered, ensuring the regulatory system remains current and effective.

Increasing the scope of regulation

Products and equipment that were previously exempt under Regulation (EC) 1275/2008 are now acknowledged as having rapidly evolved in both functionality and energy usage. The inclusion of these items within the regulatory scope is expected to promote further energy savings and help ensure a fair and consistent approach for manufacturers across the sector.

The proposal seeks to update the rules governing standby energy consumption to better reflect the way contemporary products operate. Whereas older regulations concentrated on a limited range of household and office equipment, many devices today are smart, connected, or perpetually online. This initiative would broaden the scope to cover more of these products, establishing clear requirements for various forms of standby operation.

By bringing additional technologies within the scope and addressing different types of standby use, the proposals would ensure that new devices minimise electricity consumption when not actively in use. This approach reduces wasted energy across a wider array of products and closes gaps in the existing regulatory framework.

Improving product performance and compliance

Enhancing energy consumption efficiency

The proposed measures are centred on improving the energy consumption efficiency of electrical and electronic household and office equipment. By reducing energy use, these measures aim to lower carbon emissions and operational costs, thereby supporting both environmental and economic objectives. Over time, this proposed approach is expected to lead to a tangible reduction in the energy footprint of household and office devices across Great Britain. As the market continues to innovate, this proposed regulation would serve as an effective mechanism to phase out outdated technology, ensuring that only more efficient products remain available. The proposals outlined in this consultation address both expansion of regulated products and enhanced standards for efficiency.

Improving compliance

Strengthening the effectiveness and credibility of the regulatory framework is essential to ensure that products deliver genuine energy savings in real world use, not just under test conditions. This helps protect consumers, support fair competition and maintain confidence in the rules.

The proposed updated requirements on standby, off mode and networked standby energy use aim to reduce the risk of products being designed to perform better during official testing than in everyday use. Circumvention occurs when products are engineered to achieve favourable test results without delivering equivalent performance once placed on the market. Addressing this risk helps ensure that products perform as they are tested, and that expected energy savings are realised in practice.

Alongside new energy limits and an expanded product scope, the proposed Regulation would introduce measures to improve compliance across the market. These measures would clarify testing and verification requirements, strengthen the technical information needed to demonstrate compliance, and reduce opportunities for test only performance. Together, they are intended to make the rules clearer and more consistent to apply, while supporting effective enforcement.

Question 4

Consultation impact

Accepted Answer

We welcome your feedback on the proposals in this consultation document, the accompanying draft statutory instrument (SI) and options assessment. We will aim to publish a government response after the closing date for responses to this consultation has passed, and after the feedback received has been considered.

Consultation questions layout

The table below indicates the main audience for each group of consultation questions. Views from all respondents are welcome for all questions, but the table seeks to help respondents identify the questions of most relevance to them.

Respondent type	Description	Questions
All respondents	Relevant to all respondents, including members of the public, consumer groups, manufacturers, authorised representatives, importers, retailers, trade bodies and civil society organisations.	10, 12-13, 26, 36, 38, 39, 41
All respondents, especially consumers, consumer groups and retailers	Particularly relevant to consumers, consumer groups and civil society organisations, though views from all respondents are welcome.	23, 24, 37, 40, 41
Mainly manufacturers, importers, retailers and trade bodies	Primarily aimed at respondents with knowledge of product scope, market impacts, costs or implementation issues.	6-13, 19-25, 34, 36, 39, 40
Mainly manufacturers, trade bodies and technical specialists	Primarily aimed at respondents with technical knowledge of product design, functionality, testing or energy performance.	1-5, 7, 8, 14-25, 30-33, 37
Mainly manufacturers, importers, retailers, trade bodies and enforcement bodies	Primarily aimed at respondents with knowledge of compliance, enforcement, technical documentation or anti-circumvention issues.	26–35

A glossary of terms can be found in Annex A.

The full list of the questions asked in this consultation is included in Annex B.

Question 5

1. Modernising standards

Accepted Answer

Technological advancements which have occurred since the existing regulations (Regulation (EC) No 1275/2008) and (EC) 107/2009 were introduced have led to changes in the way standby power modes are considered. With the advancement of smart products, there is significantly greater scope for products to interact with each other, allowing features such as pricing, user demand and energy efficiency to adjust dynamically. Alongside this, manufacturers have continued to produce more efficient products, which has increased the efficiency of existing power modes.

The policy proposals in this section aim to address these changes, with updated definitions and an increase in product scope, which will better reflect the way in which products behave in modern households when not in use. These measures aim to deliver energy savings, strengthen consumer protection, support manufacturers with clear rules, and maintain consistency across the UK internal market. Alignment with EU Regulation 2023/826 is proposed as a means to achieve these objectives.

1.1 Updating regulations to reflect technological advancement

When not in active use, modern products have a series of alternative states, or modes, which consume less power than when in active use. Traditionally, products have had simple functionality, such as an off/on switch, which has enabled consumers to opt for a fully on, or fully off product. With advances in technology, this has allowed additional modes, such as standby where a product is not off but can be reactivated using an external control, such as a remote control. Existing GB regulations define standby, off mode and networked standby modes. However, advances in network connectivity have enabled more sophisticated functionalities and control of these modes.

Whilst some definitions of more basic modes remain appropriate, we assess that existing GB regulation will not appropriately differentiate products with advanced standby function from basic products. To address this, we are proposing to define new standby modes, to allow consumers and manufacturers to distinguish increased functionality of products. In this section, we are outlining proposals for new definitions for standby requirements, which will be compatible and align with EU regulation 2023/826.

Scope definition

We propose to retain the existing definitions from Regulation (EC) No 1275/2008 for the following power modes, which are well understood and established in existing standby policy: off mode, standby mode and networked standby.

1. Do you agree with the proposal to retain the existing definitions of ‘off mode’, ‘standby mode’ and ‘networked standby’?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

Standby mode with information or status display:

Some products, while in standby mode, provide ongoing information to users via a display (for example, showing time, charge status or system information). These displays may offer consumer benefits but typically consume more energy than simple indicator lights. To distinguish these products from those with minimal standby functionality (such as a single LED indicator), we propose a specific definition for standby mode that includes the description “information or status display”, as set out in the draft SI.

2. Do you agree with the proposed definition of ‘standby mode’ that includes “information or status display”?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

Standby mode with reactivation function:

Some products in standby mode retain the ability to be reactivated by a user through a remote control, internal sensor or timer. This functionality can increase convenience and affect standby energy consumption. To ensure consistent treatment of such products, we propose a clarified definition of standby mode that includes the description “a reactivation function”.

3. Do you agree with the proposed definition of ‘standby mode’ that includes a ‘reactivation function’?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

Networked standby mode (non high network availability):

Networked standby differs from other standby modes in that the product is able to resume functionality in response to a remotely initiated trigger via a network connection (for example, a wired or wireless local network). Products without high network availability typically require fewer network related functions to remain active during standby.

4. Do you agree with the proposed definition of ‘networked standby’ for products without high network availability?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

High network availability (HiNA) equipment:

Certain networked products, such as routers, network switches and wireless access points, are designed to remain continuously available on a network. To support this, they require additional functionality while operating in networked standby mode.

Commission Regulation (EU) 2023/826 contains 4 related definitions covering networked equipment, network availability, HiNA equipment and equipment with HiNA functionality. In our view, these definitions work together to identify the products that are subject to the relevant standby requirements.

In preparing the draft SI, we have sought to preserve the effect of these definitions while presenting them in a simpler way, in line with UK drafting practice. We have accordingly omitted the alternative terms ‘networked equipment with high network availability’ and ‘networked equipment with high network availability functionality’ from our draft SI, on the understanding that the former has the same meaning as ‘HiNA equipment’ (which we have retained) and the latter has the same meaning as ‘equipment with HiNA functionality’ (which we have also retained), noting that ‘HiNA equipment’ and ‘equipment with HiNA functionality’, unlike those 2 omitted terms, are used in other parts of the regulations. In addition, we retained the separate definition of ‘networked equipment’ and have referred to it within these definitions of ‘HiNA equipment’ and ‘equipment with HiNA functionality’ in our draft SI, on the understanding that that term applies to both terms as well as being used elsewhere in the draft SI. In contrast, we have omitted the separate definition “network availability” and instead simply incorporated the text defining that term within the definition of ‘HiNA equipment’ and ‘equipment with HiNA functionality’, as those are the only 2 terms which use that defined term in Commission Regulation (EU) 2023/826.

5. Do you agree that the government’s interpretation of the definitions of networked equipment, network availability, HiNA equipment, and equipment with HiNA functionality from points 6–9 of Annex I to Commission Regulation (EU) 2023/826, as described above and set out in our draft SI, accurately reflects the intent and effect of those EU provisions?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

1.2 Increasing the scope of regulation

The current GB rules on standby and networked standby were developed when products were simpler, with fewer features and limited connectivity. Since then, technology has moved on quickly, with a wider range of smart and interconnected products now common in homes and workplaces. This has exposed gaps in the existing framework and created uncertainty about which products are covered. Expanding the scope of the regulation would update it to reflect today’s market, provide greater clarity for businesses, and help ensure it continues to deliver energy savings and consumer benefits as technologies evolve.

Expanding scope to include previously exempt and excluded products

By expanding the scope of products under the regulation and including previously exempt products, we aim to ensure that the standby, off mode and networked standby framework continues to meet its original objectives of reducing energy consumption when products are idle, lowering consumers’ energy bills and supporting net zero and energy security objectives.

A clearer, broader scope removes ambiguities and improves effectiveness of the regulation. It also ensures we are working at pace with changing technologies.

Motor-operated adjustable furniture and building elements:

Motor-operated adjustable furniture operated by electric means and motor-operated building elements spend extensive amounts of time in off mode, standby mode, and networked standby and so offer significant potential for improved energy consumption while in those modes.

6. Do you agree that motor-operated adjustable furniture operated by electric means, such as adjustable desks or motorised beds, should be included within the scope of this regulation?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

7. Do you agree that motor-operated building elements operated by electric means, such as motorised blinds or electric shutters, should be included within the scope of this regulation?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

Low-voltage external power supplies:

Products equipped with low-voltage external power supplies, such as smart speakers and smart thermostats, were exempted from the scope of Regulation (EC) No 1275/2008 by Commission Regulation (EC) No 278/2009. These products are rapidly evolving in terms of their functionalities and are being placed on the market in increasing numbers.

8. Do you agree that devices powered by low-voltage external power supplies, such as charging bases, docking stations or similar products, should be regulated under this regulation?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

Portable battery-operated products:

Portable battery-operated products with a recharging circuit that have to be plugged in to recharge should be covered by Ecodesign regulation, because they depend on energy input from the mains.

9. Do you agree that portable battery-operated products with recharging circuits, which must be plugged in to recharge, and products that consume power in off mode or standby mode when the battery is not being charged, such as cordless electric toothbrushes, should be included within the scope of this regulation?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

Simple set-top boxes:

Simple set-top boxes covered by Commission Regulation (EC) No 107/2009 are no longer expected to form a significant part of the market, and their remaining standby, off mode and networked standby power consumption should be covered by this Regulation. Regulation (EC) No 107/2009 should therefore be repealed.

10. Do you agree that there is a decline in the sales and usage of simple set-top boxes?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

11. Do you support including simple set-top boxes within the scope of this regulation, following the repeal of the EU vertical regulation for simple set-top boxes?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

Product-specific and horizontal approaches:

Our proposed regulation reflects the policy approach that product-specific low-power operating modes, such as those used in information technology equipment, are not addressed through the horizontal standby framework. Instead, where appropriate, such modes are regulated through targeted, product-specific Ecodesign measures, with the horizontal regulation remaining focused on simple, broadly applicable standby, off mode and networked standby conditions.

12. Do you agree that the GB standby, off mode and networked standby framework should reflect the EU’s revised horizontal approach, while continuing to address product-specific low-power operating modes, such as those used in smartphones, through separate product-specific Ecodesign measures where appropriate?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

13. Do you consider the current GB approach, where certain products are excluded from the horizontal regulation because they are covered by separate vertical measures, to be clear and effective, or would greater clarity or restructuring of scope be beneficial?

Please explain your answer and provide examples where possible.

14. Are there any other products that you believe should be included in, or excluded from, the scope of this regulation because of technological developments?

Yes / No / Don’t know. Please provide details and supporting evidence or reasoning.

Question 6

2. Improving product performance and compliance

Accepted Answer

Increased performance requirements would contribute electricity savings of 11,517 GWh from 2027 to 2050, reducing unnecessary standby power consumption and ensuring that the poorest performing products are removed from the GB market. This would give consumers confidence that they are purchasing efficient products.

We propose to tighten the permitted standby and off mode power levels and improve the energy performance of covered products in GB. This will cut wasted energy and reduce carbon emissions by enforcing more stringent power caps and automatic power-down requirements on devices in their low-power states. Modern products increasingly incorporate digital and networked features that can increase residual electricity use, particularly where products remain partially active or connected while in low-power modes. Improving product performance, such as through effective automatic power management, appropriate default configurations and efficient management of background functions, can help ensure energy savings are delivered by design, without relying on repeated consumer action.

Many electronic products currently draw 0.5–1 W or more in standby, which, scaled across millions of units, is a substantial energy drain. This policy proposal would ensure a level playing field – one efficiency benchmark for all.

We also propose measures to close loopholes and ensure effective compliance, so that the intended energy savings are delivered in practice. The updated EU regulation introduces an anti-circumvention clause for standby – meaning manufacturers must not design products to behave differently in test conditions vs real use. We would incorporate this to deter any strategies (e.g. special firmware settings) that mask true energy use under testing. This ensures fair competition and that advertised energy performance matches reality.

2.1 Enhancing energy consumption efficiency

To address the technological advances which have allowed for reduced power consumption of products in standby modes, we are proposing to introduce new power consumption limits for products in standby modes. These proposals represent an effective method to cut household power consumption, ensuring that households reduce running costs of products on standby.

Aligning with updated EU requirements will also benefit manufacturers by creating aligned standards that reduce regulatory burden, ensuring that products sold in Great Britain meet modern efficiency standards, support our net zero goals, and protect consumers from unnecessary energy costs.

Power consumption limits

Commission Regulation (EU) 2023/826, with which we are proposing to align, strengthens Ecodesign requirements for the energy consumption of electrical and electronic household and office equipment in off mode, standby mode and networked standby. Table 2 below shows the current and proposed power consumption thresholds.

Table 2: Power consumption thresholds in existing regulation compared to proposed new thresholds, in Watts (W)

Mode	Existing GB thresholds (W)	Proposed thresholds (W)
Off mode	0.5	0.3
Standby mode with reactivation function	0.5	0.5
Standby mode with information or status display	1.0	0.8
Networked standby with high network availability	n/a	7.0
Networked standby other than high network availability	n/a	2.0

Overall, the proposals would tighten the off mode limit from 0.5 W to 0.3 W and the standby limit for products with a display from 1.0 W to 0.8 W, while keeping the reactivation standby limit at 0.5 W. They would also introduce new networked standby limits of 7.0 W for products with high network availability and 2.0 W for other networked products. The effect is likely to vary by product type, depending on design, display and connectivity features, and we welcome evidence on which products are most affected and whether the proposed limits are proportionate.

15. Do you agree with the proposed maximum power consumption of 0.3 W for products in off mode?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

16. Do you agree with the proposed maximum power consumption of 0.5 W for products in standby mode with a reactivation function?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

17. Do you agree with the proposed maximum power consumption of 0.8 W for products in standby mode with an information or status display?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

18. Do you agree with the proposed maximum power consumption of 7 W for products in networked standby mode with high network availability?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

19. Do you agree with the proposed maximum power consumption of 2 W for products in networked standby mode other than high network availability?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

20. Are there any products within scope of this regulation, as listed in Annex C, which you believe will not be able to meet these proposed thresholds?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

21. We assume that updating minimum energy performance standards will incur a cost. To what extent will this cost vary between different types of products?

Please explain your answer and provide evidence, where available, or reasoning to support your answer.

22. For manufacturers, what product do you manufacture and how much would you expect this cost to be per product?

Please explain your answer and provide evidence, where available, or reasoning to support your answer.

23. Are there factors, for example product size or price, that will affect the outcome between different product types?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

Automatic power-down and other functional requirements

We are proposing that all equipment must include an automatic power-down (APD) function that, after a period of no user interaction or network activity, switches the product into standby mode, off mode or networked standby. There are some exceptions, for example where it is inappropriate or unsafe for the product to turn itself off, such as medical devices, emergency equipment or some IT server products. These exceptions will be carried over. Table 3 below shows the maximum inactivity period before automatic transition.

Table 3: Maximum inactivity period before automatic transition

Equipment	Maximum inactivity period before automatic transition
Drip Filter household coffee machines storing coffee in an insulated jug	5mins
for drip filter household coffee machines storing the coffee in a non-insulated jug	40mins
for household coffee machines other than drip filter household coffee machines	30mins
Other equipment other than networked equipment	20mins
Networked equipment, such as smart TVs and games consoles	20mins

In summary, the proposal would require most equipment, including networked equipment, to switch automatically to a low power mode after 20 minutes of inactivity, while different time limits would apply for certain coffee machines: 5 minutes for drip filter machines with an insulated jug, 40 minutes for drip filter machines with a non-insulated jug, and 30 minutes for other household coffee machines; this is expected to reduce avoidable energy use during idle periods, with the greatest practical impact on products that are often left on between uses.

24. Do you agree with the requirement for equipment to automatically switch into an appropriate low power mode after a period of inactivity, as set out above?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

25. What impacts, if any, do you anticipate from these requirements, including transitional costs, redesign needs or impacts on product functionality? Do you consider the requirements proportionate to the expected energy savings?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

26. Are there any products that you believe should be exempted from the automatic power management requirement that are not already explicitly exempt in the EU 2023/826 update?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

2.2 Improving compliance

We are proposing to strengthen the requirements for ensuring that standby, off mode and networked standby energy requirements are met in practice. Alongside updated energy limits and an expanded product scope, the proposed regulation would introduce a set of supporting measures to improve compliance across the market and give manufacturers clearer expectations about how products will be assessed.

These proposed measures would operate in 3 related ways. First, they would clarify measurement conditions, definitions and calculation methods so that products are tested on a more consistent basis and results can be reproduced by both manufacturers and market surveillance authorities. In practice, this should make it clearer how low power performance must be measured and reduce the scope for ambiguity at the point of conformity assessment (see article 5 of the draft Regulations).

Second, they would strengthen the technical information and documentation that manufacturers must keep to show compliance, such as the information needed to explain how relevant standby functions, displays or network features operate. This should help authorities verify compliance more efficiently, but may also require manufacturers to review product files, declarations and internal processes to ensure the necessary evidence is available (see article 6 and schedule 4 of the draft regulations).

Third, the proposed regulation includes anti-circumvention provisions to address products that are designed to perform differently under test conditions than in normal use. In practice, this means manufacturers should not use software, firmware or other design features that detect or respond to testing in a way that improves measured results without delivering the same performance in everyday operation (see article 7 of the draft regulations).

Taken together, these proposed measures are intended to support robust, real-world compliance rather than introduce a wholly new testing regime. For many manufacturers, the main practical effect may be the need to check that product design, software behaviour and technical documentation all align with the legal requirements and with how the product performs once placed on the market. The proposed measures therefore aim both to improve enforceability and to provide a clearer basis for compliance planning, product development and post-market changes such as software updates.

This section seeks views on whether these proposed measures are an appropriate and proportionate way to improve compliance with standby, off mode and networked standby requirements, how clearly they set out what manufacturers need to do in practice, and whether any additional guidance or transitional arrangements would be helpful to support effective implementation and market surveillance.

Preventing circumvention

27. Do you agree with the proposed approach to preventing circumvention, so that products must comply in everyday use and not only under test conditions?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available.

28. Do you have views on the proposed provision banning the use of circumvention measures, such as firmware or software updates, as set out in article 7 of the draft SI?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

29. Are there any practical issues that enforcement authorities or manufacturers should be aware of when applying this provision in practice?

Yes / No / Don’t know. Please provide details and evidence, where available.

30. What practical impacts, if any, do you expect this anti-circumvention provision to have on product design, software updates or product maintenance?

Please provide details and evidence, where available.

Product and technical information

Providing clear technical information helps show that products meet low power energy requirements and allows results to be checked. This supports consistent assessment and effective enforcement, helping ensure products perform as claimed once on the market.

31. Do the proposed requirements for technical information and documentation under Schedule 2, Part 4, paragraph 11 of the draft SI seem reasonable to demonstrate compliance with low power energy limits?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasons to support your answer.

32. Are there any risks that these proposed information requirements could create an unnecessary burden, especially for smaller manufacturers?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasons to support your answer.

Annex III of Commission Regulation (EU) 2023/826 contains a number of information requirements that refer to a manufacturer, importer or authorised representative. Our interpretation is that these requirements are intended to apply to any of these economic operators involved in placing a product on the market, rather than requiring all 3 categories of economic operator to comply in every case. The draft Regulations have therefore been prepared on the basis of this interpretation.

We are seeking views on whether this interpretation reflects stakeholders’ understanding of the equivalent provisions in Commission Regulation (EU) 2023/826.

33. Do you agree with the government’s interpretation that the information requirements in Annex III of Commission Regulation (EU) 2023/826 apply to any one or more of the manufacturer, importer or authorised representative involved in placing a product on the market, rather than requiring each of those categories of economic operator to comply in every case?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasons to support your answer.

Implementation of standards

Standards help ensure products are tested and measured in a consistent way. This makes it clearer how compliance is demonstrated and supports effective and fair enforcement.

34. Are there any transitional or lead-in periods you believe should be considered to support industry readiness for the updated standards in addition to the transitional period of 6 months we are already proposing to provide in line with our WTO commitments?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasons to support your answer.

35. Do you have any concerns about enforcement of the new requirements?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasons to support your answer.

Question 7

3. General questions

Accepted Answer

Standards on standby and off mode energy use are intended to reduce unnecessary energy consumption while remaining proportionate and applicable across a wide range of products.

Regulation (EU) 2023/826 introduces more stringent standby and off-mode requirements in 2 tiers, with the first tier applying from 9 May 2025 and the second, more stringent stage applying from 9 May 2027.

The government is considering a different approach for Great Britain. Rather than introducing the requirements in 2 tiers, we are proposing to implement the full set of new requirements in a single step from Q2 2027. This would avoid introducing an interim set of requirements before the final standards take effect and would simplify the regulatory framework for manufacturers and market surveillance authorities.

We are interested in understanding the potential impacts of this approach, including whether moving directly to the final requirements in 2027 would provide sufficient lead-in time for industry, and whether it would present any practical or economic challenges compared with a phased implementation.

The questions below ask for views on the overall approach, timing and objectives of the policy, rather than on detailed technical requirements for individual products.

36. To what extent do you expect standby and off mode efficiency to improve in line with EU standards in the absence of UK legislation?

Please explain your answer and provide evidence, where available, or reasoning to support your answer.

37. Do you agree that 3D printers should remain excluded, or is there evidence for their inclusion in future?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

38. Do you have any further views on the proposals detailed in this consultation that are not already captured in your responses to the previous consultation questions?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, to support your answer.

39. Do you agree with the proposal to introduce the full new standby and off-mode requirements in Great Britain from Q2 2027, rather than adopting the EU’s two-stage implementation approach?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

40. How do you expect usage patterns for products within scope of this regulation to differ between domestic and commercial settings?

Please provide examples or evidence, where available.

3.1 Equality Act 2010

Under the Public Sector Equality Duty (PSED), the government is required to have due regard to the need to eliminate discrimination, harassment, victimisation and other conduct prohibited by the Equality Act 2010; advance equality of opportunity between people who share a protected characteristic and those who do not; and foster good relations between people who share a protected characteristic and those who do not. Relevant protected characteristics include age, disability, race and sex.

Ensuring that equipment automatically enters standby mode, off mode or networked standby can help reduce unnecessary energy use and lower electricity bills. This is particularly relevant for vulnerable households, who may be more exposed to rising energy costs and less able to absorb higher bills. Automatic low-power modes reduce reliance on users manually switching products off and help prevent energy being used when equipment is not actively needed.

By reducing wasted electricity, these features can support more predictable and affordable energy use and help reduce the risk of fuel poverty. They may also benefit individuals who have limited ability to monitor or manage energy consumption regularly, ensuring that energy savings are delivered automatically and consistently.

In line with the PSED, we have undertaken an impact assessment to consider the potential effects of the policies proposed in this consultation. Our analysis showed that households with only core appliances are likely to experience a small net benefit in terms of bill savings due to this policy. Adding more products to the households will likely decrease that benefit and could lead to small net costs. From this it could be inferred that lower income groups are more likely to experience a net benefit than higher income groups who are more likely to experience a net cost. Overall, the net effect is expected to be neutral for households, fluctuating depending on the specific combination and quantity of products owned.

We recognise that any upfront increase in the price of household equipment could have a greater relative impact on lower income households, and that household income can be correlated with certain protected characteristics, such as disability and race. While modest upfront price increases are expected (for example, between £1.48 and £5.55 per product compared to pre policy prices), we expect all consumers to benefit from improved energy efficiency over time, resulting in energy cost savings, greater consumer choice, and a broadly similar payback period across households. Over the longer term, these measures are expected to deliver net financial benefits through reduced energy use, alongside wider environmental benefits from lower carbon emissions.

41. Do you have views on whether, and to what extent, the policy proposals might disproportionately affect certain types of consumers, with a particular focus on groups with protected characteristics?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, to support your answer.

3.2 Post Implementation Review

Should the proposals in the consultation be implemented, we will ensure that their impact is reviewed. This would include assessment of the benefits and impact to industry across the UK, and whether the scope of products included should be modified. We would also assess whether the standards remain suitable for the GB market, with reference to technological developments. To allow sufficient time for policy impact review, we are proposing to publish a Post‑implementation review no later than 5 years after the regulations come into force.

42. Do you have views on the proposed date for review of our proposed standby, off mode and networked standby regulations?

Yes / No / Don’t know. Please provide evidence or reasoning to support your answer.

Question 8

Annex A: Glossary

Accepted Answer

This annex defines technical references and key terms used throughout this public consultation document.

Term	Description
Assimilated EU law	EU-derived legislation that was retained, and then assimilated, as part of UK law after the UK left the European Union.
Automatic power-down (APD)	A function that automatically switches a product into off mode, standby mode or networked standby after a period of inactivity, so that it does not keep using more electricity than necessary. This consultation also refers to this as automatic power management.
Circumvention	When a product is designed to perform differently during testing than it does in normal use, so that it appears more compliant or more efficient than it really is.
Ecodesign	The legislative framework used to set minimum energy performance requirements for products, so that the least efficient products are improved or removed from the market.
High network availability (HiNA)	Equipment that needs to maintain a high level of network availability while in networked standby, so that it can respond quickly or continue providing network services.
Horizontal regulation	A regulation that applies across many types of products, rather than to just one product category. In this consultation, the horizontal regulation covers standby, off mode and networked standby requirements across different products.
Information or status display	A display that shows information such as time, charging status, settings or system information while the product is not carrying out its main function.
Market surveillance authority	A public authority responsible for checking whether products placed on the market comply with legal requirements, and for taking enforcement action where they do not.
Networked standby	A condition in which a product is not carrying out its main function but remains connected to a network so it can respond to signals or maintain connectivity.
Off mode	A condition in which the product is connected to the mains electricity supply but is not providing any function or is only indicating that it is off.
Public Sector Equality Duty (PSED)	The duty on public authorities, under the Equality Act 2010, to have due regard to the need to eliminate discrimination, harassment, victimisation and other prohibited conduct; advance equality of opportunity between people who share a protected characteristic and those who do not; and foster good relations between people who share a protected characteristic and those who do not.
Standby mode	A condition in which the product is connected to the mains electricity supply and is only providing limited functions, such as reactivation or an information or status display, while not carrying out its main function.
Statutory instrument (SI)	A type of secondary legislation used to make detailed legal rules under powers given by an Act of Parliament or another statutory instrument.
Technical information	The documents and data a manufacturer must prepare and keep to show how a product meets the legal requirements, including relevant measurements, calculations and product characteristics.
Verification requirements	The rules used by enforcement authorities to check whether a product complies with the legal requirements, including how results are assessed during market surveillance.
Windsor Framework	The agreement between the UK and the EU concerning how the Northern Ireland arrangements work after EU exit, including rules affecting the movement of goods and the continued application of certain EU goods rules in Northern Ireland, such as Ecodesign.
World Trade Organization (WTO) notification	A formal notice to the World Trade Organization about proposed technical regulations, allowing other members time to review and comment before the rules are finalised.
60-day standstill period	The period after a WTO notification during which the proposed regulation is generally not finalised, so that comments from other WTO members can be considered.

Question 9

Annex B: List of consultation questions

Accepted Answer

This public consultation contains 42 questions, which will help government assess the viability of the proposed SI. The questions contained in this public consultation are as follows:

1. Do you agree with the proposal to retain the existing definitions of “off mode”, “standby mode” and “networked standby”?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

2. Do you agree with the proposed definition of “standby mode” that includes “information or status display”?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

3. Do you agree with the proposed definition of “standby mode” that includes a “reactivation function”?

Yes / No / Don’t know. Please explain your answer and provide evidence, where available, or reasoning to support your answer.

4. Do you agree with the proposed definition of “networked standby” for products without high network availability?