The Consumer Technology…

The Consumer Technology Association™ (CTA®) is pleased to participate in the public consultation on the government’s Proposal to amend O. Reg. 509/18 under the Electricity Act, 1998 (“Efficiency Regulation”). As a trade association which includes the leading television manufacturers, CTA welcomes and supports the government’s proposal to update requirements for the energy efficiency of televisions by keeping stand-by requirements and removing on-mode requirements.

CTA is the trade association representing the North American consumer technology industry. Our membership includes more than 2,000 companies, 80 percent of which are small businesses and start-ups, with others among the world’s best-known manufacturer and retail brands. CTA owns and produces CES® – the most influential tech event in the world. CTA’s membership spans the breadth of the consumer tech industry and includes component suppliers, device manufacturers, software companies, retailers, distributors, installers and service providers. All these players contribute to industry-wide efforts to improve energy efficiency and in turn help consumers save money on their electricity bills. Many of our members are partners in the ENERGY STAR program, and several have received awards for their achievements in the program.

Innovations in display technologies far outpace the ability of traditional regulations to adapt and evolve. We support the Government of Ontario’s proposal to amend the on-mode energy efficiency requirements for televisions. In 2019, the Government of Ontario exempted 8K TVs from energy efficiency requirements. Development of new display technology continues apace, and now new microLED TVs are coming to market in the near future. Such cutting-edge display technology would again face regulatory barriers in Ontario without these proposed changes.

In their self-emissive properties, microLED TVs are similar to the familiar “organic light-emitting diode” or OLED models currently on the market. However, instead of using organic light-emitting diodes, microLED displays use tiny, non-organic LEDs, with three per pixel. That means that each pixel can be turned on or off individually or can display a completely different colour to the one next to it, benefiting TV contrast and colour control. MicroLED is reported to be brighter and last considerably longer than OLED. While MicroLED displays can be produced in small sizes, current industry trends and price-to-size balance mean that the technology will mostly be available in larger displays that will exceed current on-power regulations in Ontario.

As our research has shown, today’s TVs are consuming less energy and saving consumers more money, even as screen size and resolution have increased. The industry has pursued continual improvements in energy efficiency, and through programs like ENERGY STAR, consumer market pressure has driven energy efficiency alongside innovation.

Instead of taking a piecemeal, restrictive approach to the regulation of innovative technology, Ontario’s proposal to remove its on-power mode requirements altogether and harmonize with requirements in other jurisdictions, including those from Natural Resources Canada (NRCan), is a good approach which reduces red tape and facilitates inter-provincial and international commerce, while enabling innovation. In recent years, both Quebec and British Columbia removed on-mode energy efficiency requirements from their statutes and moved to harmonize with other similar programs, while the industry has continued to demonstrate its commitment to energy efficiency in consumer technology products.

Regulatory alignment and innovation-friendly policy approaches for consumer technology products are critical steps to protect competition and consumer choice and facilitate economic growth in the province. CTA encourages the Government of Ontario to continue to simplify compliance requirements for businesses whenever possible.