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Frequently Asked Questions

This page presents the U.S. Department of Energy's (DOE) answers to frequently asked questions about certification and enforcement related to external power supplies (EPSs).

The DOE rule takes effect on April 27, 2009, but when do we have to start reporting data on EPSs to DOE? In section 2D, the rule mentions that manufacturers are not required to certify compliance to DOE until sampling requirements are finalized. When is that going to happen?
After the sampling requirements are finalized, how long will we have to supply our data to DOE?
Once the deadline for supplying data is established, will we have to supply data to DOE only on new models or will we have to supply data on all models we have in production?
According to the final rule, it does not seem that DOE changed at all the definition of a single-output Class A EPS vs. a BC in EISA 2007. Is this true?
Will DOE publish a separate test procedure document for EPSs that manufacturers can share with their suppliers? If so, when would that happen? Reading the final rule and trying to pick out only the items and issues relevant to testing is very difficult.
Does the effective date of April 27, 2009, apply to date of manufacture?
Who should submit the required information to DOE–manufacturers or the private brand/supplier? What if the private brand/supplier does not label the product with its name?
What method(s) will be available for submission of data, and what is the process for each method?
Our EPS models for Energy Star compliance are simply AC-AC adapters. This is simply the voltage transformer used to convert AC 120V input to AC 6.5/7.3/8.0V ready for the built-in rectifier and filter circuit within the base unit and external charge cradles:

Question: The DOE rule takes effect on April 27, 2009, but when do we have to start reporting data on EPSs to DOE? In section 2D, the rule mentions that manufacturers are not required to certify compliance to DOE until sampling requirements are finalized. When is that going to happen?

Answer: The sampling plan requirements will be finalized by the end of the year through a DOE Final Rule for Certification, Compliance and Enforcement Requirements for EPACT 2005 Consumer Products.

Question: After the sampling requirements are finalized, how long will we have to supply our data to DOE?

Answer: Once DOE publishes its Final Rule for Certification, Compliance and Enforcement Requirements for EPACT 2005 Consumer Products it will become effective 30 days after publication. Therefore, the External Power Supply (EPS) Certification Requirements announced in our March 27, 2009, Final Rule will become effective 30 days after publication of the DOE Final Rule for Certification, Compliance and Enforcement Requirements for EPACT 2005 Consumer Products. However, we will give manufacturers of EPSs additional time to file the Certification Reports for all products that they manufacture. It has not been decided what additional time will be allowed at this point, but this will be communicated to our stakeholders during or before the DOE Final Rule for Certification, Compliance and Enforcement Requirements for EPACT 2005 Consumer Products is published.

Question: Once the deadline for supplying data is established, will we have to supply data to DOE only on new models or will we have to supply data on all models we have in production?

Answer: DOE will require data to be submitted for all EPS models that are manufactured or imported after the effective date of the DOE Final Rule for Certification, Compliance and Enforcement Requirements for EPACT 2005 Consumer Products.

Question: According to the final rule, it does not seem that DOE changed at all the definition of a single-output Class A EPS vs. a BC in EISA 2007. Is this true?

Answer: DOE has retained in the final rule the definitions for "Class A" EPS and battery chargers that were established in EISA 2007. See EISA 2007, Pub. L. No. 110-140, Sec. 301(a) (Dec. 19, 2007). DOE has provided its interpretations of these definitions for stakeholder comment in a Framework Document for potential standards for EPS and BCs. This Framework Document is available on our Web site: www.eere.energy.gov/buildings/appliance_standards/residential/battery_external_std_2008.html.

Question: Will DOE publish a separate test procedure document for EPSs that manufacturers can share with their suppliers? If so, when would that happen? Reading the final rule and trying to pick out only the items and issues relevant to testing is very difficult.

Answer: No. The United States Government Printing Office publishes annually an official codification of Federal Regulations and this will be published on 1/1/2010. Codifications of Federal Regulations are also available on-line at www.gpoaccess.gov/cfr/index.html.

Question: Does the effective date of April 27, 2009, apply to date of manufacture?

Answer: The EPS energy efficiency standard was established by Congress under EISA 2007 and became effective on July 1, 2008. This date applies to the required compliance of all "Class A" EPSs that were manufactured or imported for sale in commerce in the United States. Although DOE has not yet established formal reporting requirements for EPSs, this fact does not relieve manufacturers of their legal obligations to ensure that their products meet the requirements under the law. A manufacturer who chooses to violate these requirements could be subject to civil penalties and other appropriate action. See 42 U.S.C. §§ 6302-6305.

Question: Who should submit the required information to DOE–manufacturers or the private brand/supplier? What if the private brand/supplier does not label the product with its name?

Answer: Your question on "manufacturers or private brand suppliers" of the EPS can generally be answered by which party is the first to distribute the EPS into commerce in the United States. If the EPS is made overseas and imported into the country by the EPS manufacturer for sale to an end-use consumer product manufacturer in the United States for sale with his product (e.g. laptop computer), or to an EPS distributor, the EPS manufacturer would be responsible for ensuring and reporting that the EPS complies with the energy conservation standards when it arrives at the port of entry.

If the EPS is manufactured overseas for an end-use consumer product that is also manufactured overseas (e.g. laptop computer) and the importer was the end-use consumer product manufacturer, then the end-use consumer product manufacturer would be the responsible party for ensuring and reporting that the EPS complies with the energy conservation standards when it arrives at the port of entry. However, nothing prevents the end-use product manufacturer from ensuring that the EPS has already been certified by the EPS manufacturer, so that it eliminates the end-use product manufacturer responsibility to certify.

Also, an end-use product manufacturer who supplies imported EPSs for sale with their end-use product is considered a "manufacturer" of the EPS under the legislative definition, if the end-use product is manufactured and distributed in commerce in the United States. Therefore, the end-use product manufacturer would also be the responsible party for ensuring and reporting that the EPS complies with the energy conservation standards prior to distribution in commerce (unless the end-use product is manufactured solely for export). Again, nothing precludes this end-use product manufacturer from ensuring that the EPS has already been certified by the overseas EPS manufacturer to eliminate the end-use product manufacturer responsibility for ensuring and reporting compliance.

Question: What method(s) will be available for submission of data, and what is the process for each method?

Answer: At this point the only method allowable for submission of data is hard copy. DOE is evaluating the possibility of providing an option to permit the electronic submission of data. DOE plans to issue in the future a Federal Register Notice regarding reporting methods.

Question: Our EPS models for Energy Star compliance are simply AC-AC adapters. This is simply the voltage transformer used to convert AC 120V input to AC 6.5/7.3/8.0V ready for the built-in rectifier and filter circuit within the base unit and external charge cradles:

a. How do the DOE's requirements for EPSs intersect with the requirements for Energy Star, including data reporting, selection of certified test labs, and product and packaging labeling for compliance (Energy Star and DOE)?

Answer: The ENERGY STAR Program is a voluntary program while the DOE Appliance Standards Program is a mandatory program. Consequently, there will be differences between these programs. DOE and the ENERGY STAR Program use the same test procedure for measuring the energy efficiency of the EPS, but may have different sampling requirements. The DOE sampling requirements with respect to EPSs have not yet been finalized by DOE. DOE and the ENERGY STAR Programs both allow manufacturers to certify results for only the lowest and highest voltage models within a design family. Manufacturers are not required to use independent certified labs to test EPSs. EISA 2007 requires that all "Class A" EPS that are required to meet the EISA 2007 standard for EPS and be clearly and permanently marked in accordance with the EPS International Efficiency Marking Protocol. ENERGY STAR is now requiring a level V marking. DOE believes that any EPS with at least a level IV marking is in compliance with the EISA requirement.

b. Are there any "grandfathering" provisions or exceptions?

Answer: No grandfathering provisions were included in EISA. EISA 2007 did include some "Exclusions" from "Class A" EPS definition. DOE has provided its interpretations of the definitions and exclusions under EISA 2007 for stakeholder comment in a Framework Document for battery charger and external power supply standards. EISA 2007 also exempts a "Class A" EPS from the standards if the EPS was manufactured from July 1, 2008 through June 30, 2015 and the EPS was made available by the manufacturer as a service part or a spare part for an end-use product that: 1) constitutes the primary load; and 2) was manufactured before July 1, 2008.

c. Will the DOE's certification and data reporting process be similar to the approach used by FCC, which is a model familiar to many companies in the electronics sector? What will be the requirements for paperwork?

Answer: DOE's certification and data reporting will be similar to that of other products that are covered under the Appliance Standards Program.

d. Is the DOE standard and certification applicable only to the EPS or to the EPS and host device together?

Answer: The EISA 2007 standards only apply to the EPSs that meet the Class A definition. See EISA 2007, at Sec. 301(c).