A few weeks ago we discussed the ErP or Ecodesign Directive for Europe. This week’s article will cover energy efficiency requirements in the United States of America.
The Department of Energy or DOE manages the United States energy policy and to date has published standards for over 50 different product types used regularly in our homes and businesses. Adhering to the minimum efficiency requirements as in the case of the Ecodesign Directive, greatly reduces the US energy demand and saves consumers money every year without reducing the service these products provide.
Products intended to be shipped or sold in the US must therefore consider the requirements outlined by the DOE, if a standard exists for that particular product type. Compliance with the DOE is a mandatory requirement if your product falls within the scope of standards. The DOE similar to the ErP Directive monitors products on the market via market surveillance. They may also request at random for a manufacturer to submit a sample for testing. Failure to meet minimum standard requirements can incur monetary fines, penalties and in some cases a product recall of the failing item.
Effective August 2013, the DOE adopted rules on products that fail to meet the minimum energy efficiency requirements. Under the new ruling, the US Customs and Border Protection (CBP) have authority to refuse entry to products that have failed to meet the applicable energy conservation and labeling standards pursuant to the Energy Policy and Conservation Act of 1975 (EPCA) and its implementing regulations. It doesn’t take a rocket scientist to tell you of the adverse effects this could have on a manufacturer trying to get a product to market in the US only to be held up at customs. Missed product launches and missed deadlines only equate to one thing- lost revenue!
The ruling does have some allowances, as the DOE and FTC (Federal Trade Commission) are encouraged to work with manufacturers who should find their products in such situations. The CBP may also conditionally release under bond to the importer failing products for the purpose of bringing the subject product into compliance. The conditional release period has been given as 30 days. Extensions to this date are also allowed at the discretion of the DOE or FTC.
So how do you ensure your product is not affected and is in compliance with the DOE rulings? Well there are 2 ways:
- As a manufacturer you can perform your own in-house tests and submit the results to the DOE for review.
- You can submit your product to a Third-party laboratory like UL for testing and preparation of the necessary documentation for submission to the DOE.
UL has been working to support the DOE in the development and testing processes adopted in the standards in existence today. Our in depth product knowledge and testing expertise is regularly sought by the committee for the DOE and perform regular verification testing on behalf of the DOE.
Next week we will be looking into specific State requirements in the U.S.