ENERGY EFFICIENCY CERTIFICATION. Craig Davenport - Certification Manager Energy Efficiency & Special Programs June 20, 2018

Transcription

1 ENERGY EFFICIENCY CERTIFICATION Craig Davenport - Certification Manager Energy Efficiency & Special Programs June 20, 2018

2 TODAY S AGENDA 01 General Overview of Energy Efficiency North America 02 Regulators, Schemes & Covered Products 03 Similarities, Differences, Costs & Benefits 04 Example of Scheme Development Based on the Revisions to the US EPA ENERGY STAR Program 05 Intertek s Approach to Energy Efficiency Certifications 2

3 01 GENERAL OVERVIEW OF ENERGY EFFICIENCY IN NORTH AMERICA

4 GENERAL OVERVIEW There is no single scheme for North America (or even for the United States). Energy Efficiency Schemes are combination of voluntary and mandatory requirements. Mandatory schemes are typically driven by specific regulations. Enforcement is often tied to financial penalties for non-compliance Voluntary schemes are market-driven (market differentiation, utility rebates, retailer distribution) 4

5 GENERAL OVERVIEW US Department of Energy (DoE) determines test procedures and sets mandatory minimum energy efficiency requirements. These procedures serve as the basis for energy efficiency test methods in the United States US Federal Trade Commission (FTC) regulates Mandatory labeling for products sold in the US US Environmental Protection Agency (EPA) runs the voluntary ENERGY STAR Program. California Energy Commission (CEC) sets mandatory minimum energy efficiency requirements for California using, primarily, the DoE procedures for testing. Natural Resources Canada (NRCan) performs similar functions as the US DoE, US FTC & US EPA for the Canadian market. Many NRCan requirements and methods are harmonized with US Requirements. 5

6 02 REGULATORS, SCHEMES & COVERED PRODUCTS

7 REGULATORS, SCHEMES & COVERED PRODUCTS US Department of Energy (DoE) Mandatory national minimum limits which are based on industry standards and federal statutes. No mandatory mark 3rd party qualification testing optional. Surveillance done via consulting firms contracting with 3rd Party Laboratories. Budgetary limitations can effect the ability of DoE to conduct aggressive market surveillance. Enforcement by fines and prosecution Basic range of products regulated (primarily HVAC/R, Appliances, Lamps). 7

8 REGULATORS, SCHEMES & COVERED PRODUCTS Natural Resources Canada (NRCan) 3rd Party Certification is mandatory to sell products Canada. Requires an energy efficient certification mark and registration, along with bi-lingual labeling requirements Certification Bodies are required to be accredited to ISO/IEC Enforcement at the border and within provinces. Target audience are dealers (manufacturer, distributor, importer) Aligned with US DoE methods and EPA ENERGY STAR Program Products covered is essentially aligned with US DoE 8

9 REGULATORS, SCHEMES & COVERED PRODUCTS California Energy Commission (CEC) Mandatory program to sell products in the State of California. Requires registration of Products, Laboratories, and Certification Bodies. Data must be generated by a registered Laboratory (1st or 3rd party allowed) No mandatory mark. Difference between DOE & CEC can be challenging for major retailers. CEC tends to be more stringent than other requirements. Enforcement by CEC and monetary penalties apply. CEC covers the same products as DoE and includes some additional products 9

10 REGULATORS, SCHEMES & COVERED PRODUCTS US EPA ENERGY STAR Program Voluntary program driven by market differentiation. Local utilities involved via rebates. EPA-Controlled Mark. Enforcement by EPA. No specific penalties identified, however EPA actively protects the integrity of their mark. Mandatory 3 rd party testing and certification Annual surveillance performed by Certification Bodies with oversight by EPA. Range of DoE covered products are included as well as additional ones (Food Service, Room Air Cleaners, Electronics & recently Electric Vehicle Supply Equipment) 10

11 03 SIMILARITIES, DIFFERENCES, COSTS & BENEFITS

12 SIMILARITIES, DIFFERENCES, COSTS & BENEFITS Similarities Each Regulator publishes a list of compliant products (available on their respective websites) DoE, CEC & NRCan allow manufacturers to submit product data directly or allow 3 rd Parties to submit on their behalf. Regulatory focus seems to be aligned, however CEC, ENERGY STAR & and some Provincial Regulators in Canada seem to drive expansion 12

13 SIMILARITIES, DIFFERENCES, COSTS & BENEFITS Differences US & Canada have similar standards for products, however 3rd Party certification by an SCCaccredited Certification Body is mandatory in Canada. DOE allows manufacturers to self-test and report results (self-declaration, sometimes referred to as certification in DoE regulations). DOE conducts market surveillance to monitor compliance. NRCan leaves surveillance to the Certification Body, implementation of surveillance programs may differ between Certification Bodies. CEC requires manufacturers to perform testing at CEC-approved laboratories and report results. CEC will approve both manufacturer s and independent laboratories under their program. There are few mandatory labeling requirements, and no surveillance requirements. Both US & Canada have ENERGY STAR programs, In Canada, ENERGY STAR is managed as an extension of the NRCan certification process; In the US, manufacturers are required to use EPA-Recognized Laboratories for testing and EPA-Recognized Certification Bodies for certification before the manufacturer can apply the ENERGY STAR Mark to their product 13

14 SIMILARITIES, DIFFERENCES, COSTS & BENEFITS Costs Non-compliances to DoE & CEC could result in significant monetary penalties Benefits DoE & CEC programs are less costly to a manufacturer initially NRCan & EPA require 3rd Party Certification, which can be costly to the manufacturer 3 rd Party Certification provides additional assurance of compliance ENERGY STAR requires annual market surveillance of all certified products which adds cost to the manufacturers Annual Surveillance ensures compliance of product actually in the marketplace. 14

15 SIMILARITIES, DIFFERENCES, COSTS & BENEFITS Energy Requirement Regulator Jurisdiction Application Method Labeling 10 CFR Part 430 DOE US Mandatory Self-Declaration ENERGuide ENERGY STAR EPA US Voluntary EPA-R CB/EPA-R Lab ENERGY STAR Label California Appliance Energy Regulations CEC California Mandatory Self-Declaration based on results from a CEC Approved Laboratory None Canadian Energy Efficiency Act NRCan Canada Mandatory Self-Declaration based on results from an Approvd CB ETL-Verified / ENERGuide ENERGY STAR NRCan Canada Voluntary Self-Declaration based on results from an Approvd CB ENERGY STAR Label 15

16 04 ENERGY STAR CERTIFICATION SCHEME DEVELOPMENT

17 ENERGY STAR CERTIFICATION SCHEME DEVELOPMENT In the beginning, EPA & their stakeholders worked together to build the ENERGY STAR brand through a Self-Declaration Program Partners would test, evaluate and label, submit data directly to EPA to qualify products EPA reviewed test data and added products to a public directory. EPA would then verify the energy performance of select models. Participation in the program was at little or no cost to the manufacturers. In 2009, the Government Accountability Office (GAO), issued a report stating that the ENERGY STAR Program certification process was vulnerable to fraud and abuse. The findings are contained in GAO

18 ENERGY STAR CERTIFICATION SCHEME DEVELOPMENT Developing a 3 rd Party Certification Scheme During EPA developed Criteria to qualify Accreditation Bodies (ABs), Certification Bodies (CBs) and Testing Laboratories. Each entity within the program (including an EPA-Partner) was assigned an Organization Identification Number (OID). These numbers are referenced throughout the documentation process for traceability. EPA-Recognized (EPA-R)Testing Laboratories must be accredited to ISO/IEC for the product specification; EPA-R Certification Bodies must be accredited to ISO/IEC for the product type. Allowance for the use of qualified 1 st Party WMTL/SMTL Laboratories by the CBs was included in the rules and harmonized with IECEE CB Scheme Partners utilize EPA-R Labs prior to qualification and labeling to evaluate products; EPA-R CBs certify compliant products and submit certified data to EPA to qualify product EPA-R CBs conduct verification testing after qualification and evaluate retested products that have undergone significant post-qualification changes 18

19 ENERGY STAR CERTIFICATION SCHEME DEVELOPMENT Implementation & Maintenance (2011-present) 2010 EPA drafted requirements for Accreditation Bodies, Certification Bodies and Testing Laboratories. Throughout the next year, entities were qualified in each category Over the same period, the EPA worked with stakeholders to better define the ENERGY STAR methods and standards EPA required all ENERGY STAR Product Categories to be registered with an EPA-R Certification Body Certifications Bodies were to maintain the product lists and manually submit revisions to EPA on a semi-monthly schedule. As new specifications were developed and released, testing by an EPA-R Laboratory was mandatory prior to Certification. By 2013 EPA had migrated their certified products lists to an online database allowing the Certification Bodies to continuously submit product data electronically Over time, EPA has utilized consultants to provide additional technical support to stakeholders and to expand the number of products covered under the program. 19

20 ENERGY STAR CERTIFICATION SCHEME DEVELOPMENT Implementation & Maintenance (2011-present) cont d Annual surveillance sampling was initially defined as 10% of each product type, certified by each EPA- R Certification Body Over the course of 2-3 years, historical data was accumulated and used to refine sampling percentages based a relative compliance of the product category within the program. Electronics were found to be largely compliant, therefore, sampling percentage was reduced to 5% Compact Fluorescent Lamps were found to largely non-compliant, and percentages raised to 20% Other categories were left at the original 10% sampling The revisions to the program have improved initial product compliance, ensured that annual surveillance effectively confirms ongoing compliance in the marketplace, and provided confidence in the ENERGY STAR Certification Mark. 20

21 05 INTERTEK S APPROACH TO ENERGY EFFICIENCY CERTIFICATION

22 INTERTEK S APPROACH TO ENERGY EFFICIENCY CERTIFICATION If a Scheme for certification exists, use the Scheme If a Scheme lacks sufficient detail, work with the Scheme-Owner to develop further guidance Additional implementation details not specified by the Scheme would based on ISO/IEC 17020, ISO/IEC 17025, ISO/IEC 17065, ISO/IEC and institutional knowledge within Intertek. 22

23 INTERTEK S APPROACH TO ENERGY EFFICIENCY CERTIFICATION As a basis for any Certification Program (Scheme) the following standards should be considered: ISO/IEC Conformity Assessment - Requirements for Bodies Certifying Products, Processes and Services ISO/IEC General Requirements for the Competence of Testing and Calibration Laboratories ISO/IEC Conformity Assessment - Requirements for the Operation of Various Types of Bodies Performing Inspection ISO/IEC Conformity Assessment - Fundamentals of Product Certification and Guidelines for Product Certification Schemes These documents provide a solid foundation for a reliable Certification Scheme, but there are other details that are important to consider 23

24 INTERTEK S APPROACH TO ENERGY EFFICIENCY CERTIFICATION If creating a Certification Scheme Who is the Owner? Who Takes Responsibility for the Design, Administration and Maintenance of the Scheme? What Drives Compliance? Mandatory Regulations? 24

25 INTERTEK S APPROACH TO ENERGY EFFICIENCY CERTIFICATION Considerations for a Regulatory Body as a Scheme Owner Who makes the certification decision? The Regulator, or is the decision delegated to a 3 rd Party Certification Body? If a Certification Body is used for the decision, what qualifications are required by the Regulator? If a Mark is used to signify certification, is the Mark unique to the Regulator, or is the Mark unique to the Certification Body? Is a Directory or List of Certified Products published by the Regulator or the Certification Body 25

26 INTERTEK S APPROACH TO ENERGY EFFICIENCY CERTIFICATION Considerations for Designing a Certification Scheme What the purpose and scope of the scheme? What types of products are being certified? What is the potential risk associated with non-compliance of a product? Does the structure provide adequate mitigation of those risks Is ongoing surveillance of certified products warranted? Via manufacturing inspections, or open market selection and test? Which Type from ISO/IEC might be appropriate? 26

27 INTERTEK S APPROACH TO ENERGY EFFICIENCY CERTIFICATION Functions & Activities within Product Certification Schemes (based on ISO/IEC 17067:2013; Table 1) Selection (specified requirements, origin of sample(s), quantity) Determination of Characteristics (testing, inspecting, design review) In ISO/IEC 17065; Selection & Determination are combined and referred to as Evaluation. Review (review of characteristics against the specified requirements) Decision on Certification (granting, maintaining, extending, reducing, suspending & withdrawing certification) Attestation, Licensing (certificate or statement of conformity, granting use of a mark of conformity) Surveillance (testing and/or inspection of samples from the open market or manufacturing facility, assessment of production system) Table 1 of ISO/IEC provides a number of possible variations by modifying Functions & Activities to fit the purpose of the scheme. 27

28 INTERTEK S APPROACH TO ENERGY EFFICIENCY CERTIFICATION Best Practices / Lessons Learned The use of mandatory regulations provide the best driver for certification. Requiring accreditation of labs and certification bodies will help provide uniformity of implementation. However, adequately defining the rules of scheme is critical to stakeholder understanding the process. Requiring products to bear a Certification Mark, provides assurance to stakeholders and control over certified products. Market surveillance is the method to determine compliance, but it can be costly to the manufacturer. 28

29 THANK YOU Craig Davenport Certification Manager Energy Efficiency & Special Programs 29

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