CEA Sees New ‘Burdens’ in Changes Proposed to Energy Star Verification

Given the CE industry’s “excellent track record” of compliance, the EPA should exempt CE products from proposed changes to Energy Star’s qualification testing and verification requirements, CEA said in comments. The EPA has found 100 percent compliance by CE, the association said. A proposal by the agency for testing by independent third-party labs “ignores this marketplace success as well as industry’s underlying system of self-certification,” said Douglas Johnson, CEA’s vice president of technology policy.

Under an agreement with the Department of Energy, EPA proposed that qualification testing for Energy Star be conducted by third-party labs or in-house accredited labs. It also wants “verification” testing, to ensure compliance with Energy Star specifications, to be done by third-party companies. The agency decided to accelerate the changes after the GAO found that Energy Star was prone to fraud and abuse because investigators got certification for 15 bogus products (CED March 29 p3).

Requiring that testing for qualifying products be done by third party or accredited in-house labs would mean “new costs and burdens for many consumer electronics manufacturers,” said Johnson. For the CE industry, “there are intense time-to-market pressures and relatively short product cycles,” he said. “A blanket requirement for qualification testing by either in-house accredited labs or external third-party labs could both increase product development costs and delay time-to-market for many electronics products."

For CE, the EPA should maintain the improved Energy Star product registration system, with enhanced self-certification requirements such as submission of lab testing reports, Johnson said. “These recent improvements to product registration, combined with an enhanced Energy Star market verification program, will produce sufficient controls and safeguards to address the concerns that have been raised regarding the Energy Star qualification and verification system.” Without evidence of “significant issues” with Energy Star qualification and testing in CE, a new requirement for third-party testing or testing by accredited in-house labs is “unnecessary and unjustified,” he said.

If the agency intends to move ahead with accredited lab testing, it should limit requirements to “verifying that the lab personnel are qualified, the lab equipment is calibrated and the test facilities are adequate,” Johnson said. It should not require labs to meet standards such as ISO 19001 or ISO/IEC 17025, he said. The EPA also should ensure that test procedures adopted for Energy Star are based on standards from “accredited, consensus-based” industry standards organizations, he said.

CEA sought “clear guidelines” for the companies that the agency hires to verify Energy Star compliance. “Such guidelines should specifically address how products will be obtained, handled and disposed, including avoidance of situations where tested products are returned to retailers, which increases product return costs,” Johnson said. CEA also urged the agency to set “appropriate cost controls” for CE makers as it develops verification testing procedures. “Based on the outline of EPA’s current proposal, there does not appear to be any limit on the costs involved in verification testing that would be borne by the manufacturer.”