The deadline is approaching for ENERGY STAR stakeholders to offer their comments regarding the ENERGY STAR Program enhancement proposal for ENERGY STAR products. This proposal was distributed to all stakeholders by the Department of Energy (DOE) and the Environmental Protection Agency (EPA) in early December, (CLICK HERE to view the proposal), and comments are due on January 8.
Points included in the 31-page document include the establishment of a Governing Council, enhancements in stakeholder outreach, establishment of a National Building Rating program, and enhancements to the ENERGY STAR products programs.
According to the document, revisions to ENERGY STAR specifications will be undertaken more frequently so the ENERGY STAR label continues to highlight top energy-efficient products while targeting products that are appealing from a consumer standpoint. “Increasing the level of performance will provide greater energy savings in the future and maintain the credibility of the ENERGY STAR label as technologies and markets evolve,” reads the proposal.
Specifications will be set to recognize products that are cost-effective from the purchaser standpoint; offer at least equivalent functionality and features as standard products; and are proven and broadly available, according to the proposal. Officials say cost-effectiveness in terms of payback periods will be defined on a case-by-case basis, taking into account both the expected useful life of the product and the general desirability of shorter payback periods, but will in general be three to five years.
To identify top performing products, ENERGY STAR specifications will be set to identify approximately the top 25 percent most efficient of models within a product class under the ENERGY STAR specification at the time that specification becomes effective, with consideration of expected improvements in product efficiency and market penetration trends of those products that will take place between establishing a specification and the specification becoming effective.
The proposal also outlines a few specifics regarding the collection of product shipment data. This will be collected for ENERGY STAR qualifying products from manufacturers and analyzed on an annual basis to determine which specifications warrant updating. EPA plans to collect shipment data across all ENERGY STAR product categories for calendar year 2010. To collect the data necessary to support this enhancement, EPA will continue to work with third-party entities that are able to provide shipment data on behalf of their members. EPA also expects to make use of other existing sources of aggregated product shipment data, according to the proposal.
The proposal also outlines some specifics regarding labeling, testing and qualification.
For nearly all ENERGY STAR product categories currently, manufacturers have up to one year to submit to the government data that supports their labeling of a product.
“This scenario could lead to consumer confusion, as products labeled on retail shelves are not listed on an ENERGY STAR qualified product list,” reads the proposal. “In addition, pre-qualification allows for earlier review of qualification data. Thus, EPA and DOE are proposing to pursue a requirement that before a partner claims a product is qualified and uses the ENERGY STAR label, the product must be tested in an accredited laboratory and the resulting data must be shared with the ENERGY STAR program. Manufacturers would be allowed to participate in an approved third-party certification program to satisfy this requirement. Manufacturers will continue to pay for the pre-qualification testing.”
The DOE and EPA also propose to pursue a requirement that testing for both qualification and verification take place in laboratories that are accredited. The government will consider ISO 17025 where appropriate recognizing that other accreditations may be appropriate for some products and that third-party certification programs can serve this function.
EPA/DOE anticipate that the testing approach will vary depending on the nature of the product category, following two basic designs. Under each of these, if an ENERGY STAR rated product fails verification testing, the resulting action may be its disqualification from the ENERGY STAR program.
Regarding third-party verification, products in this category would need to be verified to the appropriate product’s qualifying criteria by third-party organizations that administer ongoing verification testing in accredited laboratories meeting EPA/DOE criteria.
EPA/DOE anticipate requiring third-party verification windows/doors/skylights, according to the proposal.
Comments are due on January 8, 2010, and should be sent to berringer.bryan@epa.gov.