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Test Rules At Issue

CE Groups Urge NRCan Caution Before Setting Energy Regulations

Natural Resources Canada’s proposed energy limits on electronics are based on “inadequate and obsolete” data, said the CE industry, which seeks a “thorough and current” analysis of consumer electronics power use before the agency moves ahead with the regulations. NRCan has proposed “minimum energy performance” levels for a host of CE products, including TVs, video products, compact audio products, external power supplies and DTV adapters.

NRCan’s standby power use data for electronics is based largely on in-store measurements of “apparent standby power consumption,” CEA and Canada’s Consumer Electronics Marketing Council said in joint comments. “There are several concerns about the validity and usefulness of such data based on the testing of products on store shelves, including variable test conditions and methodologies, product configurations at retail and accounting of energy-related product features,” they said. And NRCan’s data are obsolete because they're of 2006-2007 “vintage,” the groups said. A new study would help determine whether the regulations are justified and allow for “more reasonable estimates of any energy savings and greenhouse gas emissions reductions."

The groups said they “strongly oppose” third-party conformance testing. “This type of assessment adds an additional layer of testing which increases cost and introduces significant time delays into the development of products which is not necessary.” If each country adopts it own testing rules, “the delays and costs are magnified,” they said. The testing requirement also would result in “product rationalization in Canada and could encourage a non-compliant grey market,” the groups said, adding that self-testing and declaration would meet NRCan’s compliance goals. They urged NRCan to “further investigate a self declaration model for electronics products and allow this model to be used for energy efficiency."

The groups commended NRCan for allowing the use of current internationally recognized labeling systems such as Energy Star for external power supplies and asked that the same be permitted for other electronic products. Professional monitors, video players and recorders and power supplies should be excluded from the regulations, they said. The agency should recognize the industry standard ANSI/CEA-2037 as the test method for TV energy use, as Energy Star has, they said. But coordinating North American energy efficiency efforts shouldn’t be “interpreted to mean the harmonization of mandatory energy efficiency standards with voluntary program specifications,” the groups said. “NRCan should not be proposing mandatory limits based on the voluntary specifications in the Energy Star program.”