# Energy Conservation Program: Test Procedure for Battery Chargers

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/fr%3A2021-24367

## Record

- **Collection:** Federal Register
- **Document type:** Proposed Rule
- **Published:** November 23, 2021
- **Citation:** 86 FR 66878

## Text

DEPARTMENT OF ENERGY
10 CFR Parts 429 and 430
[EERE-2020-BT-TP-0012]
RIN 1904-AE49
Energy Conservation Program: Test Procedure for Battery Chargers

AGENCY:

Office of Energy Efficiency and Renewable Energy, Department of Energy.

ACTION:

Notice of proposed rulemaking and request for comment.

SUMMARY:

The U.S. Department of Energy (“DOE”) proposes to amend the test procedures for battery chargers to improve test procedure representativeness. The proposal would: Establish a new appendix Y1 that would expand coverage of inductive wireless battery chargers and establish associated definitions and test provisions; establish a new test procedure approach that relies on separate metrics for active mode, stand-by, and off-mode (consequently removing the battery charger usage profiles and unit energy consumption calculation); and update the wall adapter selection criteria. DOE also proposes changes to appendix Y to reorganize two subsections, to clarify symbology and references, to correct an incorrect cross reference and section title, to update the list of battery chemistries, and to terminate an existing test procedure waiver because the covered subject models have been discontinued. DOE further proposes to mirror these changes in the newly proposed appendix Y1. DOE is seeking comment from interested parties on the proposals.

DATES:

DOE will accept comments, data, and information regarding this proposal no later than January 24, 2022. See section V, “Public Participation,” for details. DOE will hold a webinar on Wednesday, December 15, 2021, from 12:30 p.m. to 4:00 p.m. See section V, “Public Participation,” for webinar registration information, participant instructions, and information about the capabilities available to webinar participants. If no participants register for the webinar, it will be cancelled.

ADDRESSES:

Interested persons are encouraged to submit comments using the Federal eRulemaking Portal at
www.regulations.gov.
Alternatively, interested persons may submit comments, identified by docket number EERE-2020-BT-TP-0012, by any of the following methods:

(1)
Federal eRulemaking Portal: www.regulations.gov. Follow the instructions for submitting comments.

(2)
Email: BatteryChargers2020TP0012@ee.doe.gov. Include the docket number EERE-2020-BT-TP-0012 or regulatory information number (“RIN”) 1904-AE49 in the subject line of the message.

No telefacsimiles (“faxes”) will be accepted. For detailed instructions on submitting comments and additional information on the rulemaking process, see section V “Public Participation,” of this document.

Although DOE has routinely accepted public comment submissions through a variety of mechanisms, including postal mail or hand delivery/courier, the Department has found it necessary to make temporary modifications to the comment submission process in light of the ongoing COVID-19 pandemic. DOE is currently suspending receipt of public comments via postal mail and hand delivery/courier. If a commenter finds that this change poses an undue hardship, please contact Appliance Standards Program staff at (202) 586-1445 to discuss the need for alternative arrangements. Once the COVID-19 pandemic health emergency is resolved, DOE anticipates resuming all of its regular options for public comment submission, including postal mail and hand delivery/courier.

Docket:
The docket, which includes
Federal Register
notices, public meeting attendee lists and transcripts (if a public meeting is held), comments, and other supporting documents/materials, is available for review at
www.regulations.gov.
All documents in the docket are listed in the
www.regulations.gov
index. However, some documents listed in the index, such as those containing information that is exempt from public disclosure, may not be publicly available.

The docket web page can be found at
www.regulations.gov/docket?D=EERE-2020-BT-TP-0012.
The docket web page contains instructions on how to access all documents, including public comments, in the docket. See section V, “Public Participation,” for information on how to submit comments through
www.regulations.gov.

FOR FURTHER INFORMATION CONTACT:

Mr. Jeremy Dommu, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Office, EE-5B, 1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone: (202) 586-9870. Email
ApplianceStandardsQuestions@ee.doe.gov.

Mr. Michael Kido, U.S. Department of Energy, Office of the General Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone: (202) 586-8145. Email:
michael.kido@hq.doe.gov.

For further information on how to submit a comment, review other public comments and the docket, or participate in a public meeting (if one is held), contact the Appliance and Equipment Standards Program staff at (202) 287-1445 or by email:
ApplianceStandardsQuestions@ee.doe.gov.

SUPPLEMENTARY INFORMATION:

DOE proposes to maintain the previously incorporated by reference standards and to incorporate by reference the following industry standards into part 430:

IEC 62301, (“IEC 62301”), “Household electrical appliances—Measurement of standby power, (Edition 2.0, 2011-01).”

Copies IEC 62301 can be obtained from the International Electrotechnical Commission at 446 Main Street, Sixteenth Floor, Worcester, MA 01608, or by going to
www.iec.ch.

See section IV.M. for a discussion of this standard.

Table of Contents

I. Authority and Background

A. Authority

B. Background

II. Synopsis of the Notice of Proposed Rulemaking

III. Discussion

A. Scope of Applicability

1. Battery Chargers

2. Inductive Wireless Battery Chargers

B. Test Procedure

1. External Power Supply Selection

2. Battery Chemistry and End-of-Discharge Voltages

3. Battery Selection

4. Battery Charger Usage Profile and Unit Energy Consumption

5. Battery Charger Modes of Operation

6. Test Procedure Waivers Regarding Non-Battery-Charging Related Functions

C. Corrections and Non-Substantive Changes

1. Certification Flow Charts

2. Testing and Certification Clarifications

3. Cross-Reference Corrections

4. Sub-Section Corrections

D. Test Procedure Costs and Harmonization

1. Test Procedure Costs and Impact

2. Harmonization With Industry Standards

E. Compliance Date and Waivers

IV. Procedural Issues and Regulatory Review

A. Review Under Executive Order 12866

B. Review Under the Regulatory Flexibility Act

1. Description of Reasons Why Action Is Being Considered

2. Objective of, and Legal Basis for, Rule

3. Description and Estimate of Small Entities Regulated

4. Description and Estimate of Compliance Requirements

5. Duplication, Overlap, and Conflict With Other Rules and Regulations

6. Significant Alternatives to the Rule

C. Review Under the Paperwork Reduction Act of 1995

D. Review Under the National Environmental Policy Act of 1969

E. Review Under Executive Order 13132

F. Review Under Executive Order 12988

G. Review Under the Unfunded Mandates Reform Act of 1995

H. Review Under the Treasury and General Government Appropriations Act, 1999

I. Review Under Executive Order 12630

J. Review Under Treasury and General Government Appropriations Act, 2001

K. Review Under Executive Order 13211

L. Review Under Section 32 of the Federal Energy Administration Act of 1974

M. Description of Materials Incorporated by Reference

V. Public Participation

A. Submission of Comments

B. Issues on Which DOE Seeks Comment

VI. Approval of the Office of the Secretary

I. Authority and Background

Battery chargers are included among the consumer products for which DOE is authorized to establish and amend energy conservation standards and test procedures. (42 U.S.C. 6295(u)) DOE's energy conservation standards and test procedures for battery chargers are currently prescribed at title 10 CFR 430.32(z), and 10 CFR part 430, subpart B, appendix Y (“Appendix Y”), respectively. The following sections discuss DOE's authority to establish test procedures for battery chargers and relevant background information regarding DOE's consideration of test procedures for this product.

A. Authority

The Energy Policy and Conservation Act, as amended (“EPCA”),
1

authorizes DOE to regulate the energy efficiency of a number of consumer products and certain industrial equipment. (42 U.S.C. 6291-6317) Title III, Part B
2

of EPCA established the Energy Conservation Program for Consumer Products Other Than Automobiles, which sets forth a variety of provisions designed to improve energy efficiency. This NOPR covers battery chargers, which are included under EPCA. (42 U.S.C. 6291(32); 42 U.S.C 6295(u))

1
All references to EPCA in this document refer to the statute as amended through the Energy Act of 2020, Public Law 116-260 (Dec. 27, 2020).

2
For editorial reasons, upon codification in the U.S. Code, Part B was re-designated Part A.

The energy conservation program under EPCA consists essentially of four parts: (1) Testing, (2) labeling, (3) Federal energy conservation standards, and (4) certification and enforcement procedures. Relevant provisions of EPCA specifically include definitions (42 U.S.C. 6291), test procedures (42 U.S.C. 6293), labeling provisions (42 U.S.C. 6294), energy conservation standards (42 U.S.C. 6295), and the authority to require information and reports from manufacturers (42 U.S.C. 6296).

The Federal testing requirements consist of test procedures that manufacturers of covered products must use as the basis for: (1) Certifying to DOE that their products comply with the applicable energy conservation standards adopted pursuant to EPCA (42 U.S.C. 6295(s)), and (2) making representations about the efficiency of those consumer products (42 U.S.C. 6293(c)). Similarly, DOE must use these test procedures to determine whether the products comply with relevant standards promulgated under EPCA. (42 U.S.C. 6295(s))

Federal energy efficiency requirements for covered products established under EPCA generally supersede State laws and regulations concerning energy conservation testing, labeling, and standards. (42 U.S.C. 6297) DOE may, however, grant waivers of Federal preemption for particular State laws or regulations, in accordance with the procedures and other provisions of EPCA. (42 U.S.C. 6297(d))

Under 42 U.S.C. 6293, EPCA sets forth the criteria and procedures DOE must follow when prescribing or amending test procedures for covered products. EPCA requires that any test procedures prescribed or amended under this section be reasonably designed to produce test results which measure energy efficiency, energy use or estimated annual operating cost of a covered product during a representative average use cycle or period of use, and not be unduly burdensome to conduct. (42 U.S.C. 6293(b)(3))

In addition, EPCA requires that DOE amend its test procedures for all covered products to integrate measures of standby mode and off mode energy consumption. (42 U.S.C. 6295(gg)(2)(A);
see also
42 U.S.C. 6295(u)(1)(B)(i)) Standby mode and off mode energy consumption must be incorporated into the overall energy efficiency, energy consumption, or other energy descriptor for each covered product unless the current test procedures already account for and incorporate standby and off mode energy consumption or unless such integration is technically infeasible. If an integrated test procedure is technically infeasible, DOE must prescribe a separate standby mode and off mode energy use test procedure for the covered product, if such test procedures are technically feasible. (42 U.S.C. 6295(gg)(2)(A)(ii)) Any such amendment must consider the most current versions of the International Electrotechnical Commission (“IEC”) Standard 62301
3

and IEC Standard 62087
4

as applicable. (42 U.S.C. 6295(gg)(2)(A))

3
IEC 62301,
Household electrical appliances—Measurement of standby power
(Edition 2.0, 2011-01).

4
IEC 62087,
Methods of measurement for the power consumption of audio, video, and related equipment
(Edition 3.0, 2011-04).

If DOE determines that a test procedure amendment is warranted, it must publish proposed test procedures and offer the public an opportunity to present oral and written data, views, and arguments with respect to such procedures. (42 U.S.C. 6293(b)(2)) EPCA also requires that DOE evaluate test procedures for each type of covered product at least once every 7 years to determine whether amended test procedures would more accurately or fully comply with the requirements for the test procedures to not be unduly burdensome to conduct and be reasonably designed to produce test results that reflect energy efficiency, energy use, and estimated operating costs during a representative average use cycle or period of use. (42 U.S.C. 6293(b)(1)(A)) If the Secretary determines, on her own behalf or in response to a petition by any interested person, that a test procedure should be prescribed or amended, the Secretary shall promptly publish in the
Federal Register
proposed test procedures and afford interested persons an opportunity to present oral and written data, views, and arguments with respect to such procedures. (42 U.S.C. 6293(b)(2) The comment period on a proposed rule to amend a test procedure shall be at least 60 days and may not exceed 270 days.
Id.
In prescribing or amending a test procedure, the Secretary shall take into account such information as the Secretary determines relevant to such procedure, including technological developments relating to energy use or energy efficiency of the type (or class) of covered products involved.
Id.
If DOE determines that test procedure revisions are not appropriate, DOE must publish its determination not to amend the test procedures. (42 U.S.C. 6293(b)(1)(A)(ii)) DOE is publishing this NOPR in satisfaction of the 7-year review requirement specified in EPCA. (42 U.S.C. 6293(b)(1)(A))

B. Background

On May 4, 2020, DOE published a request for information (“May 2020 RFI”) seeking stakeholder comments and data on whether, since the last test procedure update, there have been changes in battery charger testing methodology or new products

introduced to the market that may necessitate amending the test procedure for battery chargers. 85 FR 26369. DOE specifically solicited feedback on possible approaches to testing inductive wireless battery chargers not designed for use in a wet environment, and whether any industry test procedures have been developed or were being developed to specifically address such products. 85 FR 26369, 26371. DOE requested data on how inductive wireless chargers were used in the field, particularly with regard to the placement of the wireless charging receiver found in end use products on the transmitting surface of the charger.
Id.
For battery charger products that require a wall adapter but do not come prepackaged with one, DOE requested comment on the characteristics of the wall adapters typically used by manufacturers for testing and certification purposes and, if different, the characteristics of the wall adapters used by consumers in real-world settings. DOE also requested comment on whether using a reference wall adapter for testing would be appropriate in such a situation.
Id.
DOE similarly requested comment on the appropriateness of testing a battery charger using a reference battery load. 85 FR 26369, 26372. DOE further requested comment on whether other parts of the battery charger test procedure need to be updated such as end-of-discharge voltages, prescribed battery chemistries, consumer usage profiles, battery selection criteria, and the battery charger waiver process. 85 FR 26369, 26372-26373.

DOE received comments in response to the May 2020 RFI from the interested parties listed in Table I.1.

Table I.1—Written Comments Received in Response to May 2020 RFI

Commenter(s)
Reference in this NOPR
Commenter type

Association of Home Appliance Manufacturers
AHAM
Trade Association.

Association of Home Appliance Manufacturers, Power Tool Institute, Inc
Joint Commenters
Trade Association.

California Investor Owned Utilities (Pacific Gas and Electric Company, San Diego Gas and Electric, Southern California Edison)
CA IOUs
Utility Association.

Delta-Q Technologies Corp
Delta-Q
Manufacturer.

Information Technology Industry Council
ITI
Trade Association.

Northwest Energy Efficiency Alliance
NEEA
Efficiency Organization.

Techtronic Cordless GP
TTI
Manufacturer.

Wireless Power Consortium
WPC
Efficiency Organization.

A parenthetical reference at the end of a comment quotation or paraphrase provides the location of the item in the public record.
5

5
The parenthetical reference provides a reference for information located in the docket of DOE's rulemaking to develop energy conservation standards for pool heaters. (Docket No. EERE-2020-BT-TP-0012, which is maintained at
www.regulations.gov/#!docketDetail;D=EERE-2020-BT-TP-0012
). The references are arranged as follows: (Commenter name, comment docket ID number, page of that document).

II. Synopsis of the Notice of Proposed Rulemaking

In this notice of proposed rulemaking (“NOPR”), DOE proposes to update appendix Y to reflect updates in battery chemistry and user profiles, to provide more explicit direction, correct cross-reference errors, and to improve organization of the test procedure, as follows:

(1) Update terms used in the battery chemistry table;

(2) Provide further direction regarding the application for a battery charger test procedure waiver when battery energy cannot be directly measured;

(3) Provide more descriptive terms for battery energy and battery voltage values used for determining product class and calculating unit energy; and

(4) Correct a cross-reference and a table title, further clarify certain references, and reorganize certain subsections for improved readability.

DOE is also proposing to establish an amended test procedure for all covered battery chargers in a new appendix Y1, which would generally require that testing be conducted as provided in the proposed amendments to appendix Y, but with the following additional changes:

(1) Establish definitions associated with inductive wireless power transfer, and differentiate between those that incorporate a physical receiver locating feature (
e.g.,
a peg, cradle, dock, locking mechanism, magnet, etc.) for aligning or orienting the position of the receiver (“fixed-location” wireless chargers) with respect to the transmitter and those that do not (“open-placement” wireless chargers);

(2) Include within the scope of the test procedure fixed-location inductive wireless battery chargers, and add a separate no-battery mode test for open-placement wireless chargers;

(3) Remove the unit energy consumption (“UEC”)
6

calculations and usage profiles and instead rely on separate metrics for active mode, standby mode, and off mode using E
a
, P
sb
, and P
off
, respectively, as measured by the newly established appendix Y1; and

6
The UEC represents the annualized amount of the non-useful energy consumed by a battery charger among all tested modes of operation. Non-useful energy is the energy consumed by a battery charger that is not transferred and stored in a battery as a result of charging,
i.e.,
the losses.

(4) Specify wall adapter selection priority and amend selection requirements for battery chargers that do not ship with a wall adapter and for which one is not recommended by the manufacturer.

If the proposed amendments for appendix Y are finalized, manufacturers testing and reporting battery charger's energy use will have to do so based on the DOE test procedure as amended beginning 180 days following the final rule. Furthermore, as proposed, manufacturers would not be required to test according to proposed appendix Y1 until such time as compliance is required with amended energy conservation standards, should such standards be amended.

Additionally, DOE is not proposing amendments to address an existing test procedure waiver and extension of waiver (Case Nos. BC-001 and 2018-012), having initially determined that the basic models subject to the waiver are no longer available on the market.

DOE's proposed actions are summarized in Table II.1 compared to the current test procedure as well as the reason for the proposed change.

Table II.1—Summary of Changes to the Current Test Procedure and the New Proposed Test Procedure Relative to Current Test Procedure

Current DOE test procedure
Proposed test procedure
Applicable test procedure
Attribution

Only those wireless chargers that operate in “wet environments” and have a battery energy of less than or equal to 5 watt-hours (Wh) are in scope of the battery charger test procedure
Proposes to increase the 5 Wh limit to 100Wh and to replace the “wet environment” designation with “fixed-location wireless chargers”, such that wireless chargers meant for dry as well as wet environments would be in scope
Appendix Y1
To reflect changes in the market.

Does not differentiate between types of wireless chargers
Addresses open-placement wireless chargers and fixed-location wireless chargers, and proposes definitions for both
Appendix Y1
To reflect changes in the market.

Does not provide a test method for open-placement wireless chargers
Adds a no-battery mode test method for open-placement wireless chargers in a newly created section of the appendix
Appendix Y1
To reflect changes in the market and to improve representativeness.

Does not provide wall adapter selection priority for chargers that do have associated wall adapters. For those that do not, current test procedure requires DC battery chargers be tested with 5.0 V DC for USB port powered devices, or the midpoint of the rated input voltage range for others
Adds wall adapter selection order priority and removes the 5.0V DC input criteria. For battery chargers that do not ship with a wall adapter and do not have a recommended adapter, proposes that the charger be tested using a wall adapter that is minimally compliant with the applicable energy conservation standard and supplies the rated input voltage and current
Appendix Y1
To reflect changes in technology and to improve representativeness and comparability of results.

Battery chemistries specified in Table 3.3.2 do not reflect the latest industry naming convention
Updates “Lithium Polymer” to “Lithium-ion Polymer,” and changes “Nanophosphate Lithium-ion” to “Lithium Iron Phosphate”
Appendix Y and Appendix Y1
To reflect changes in the market.

UEC calculation relies on usage profiles to determine the length of time spent in each mode of operation

Removes battery charger usage profiles and the UEC calculation; adopts separate metrics, E
a
, P
sb
and P
off
, for the energy performance of a battery charger in each of the following three modes of operation respectively: Active mode, standby mode and off mode

Appendix Y1
To improve representativeness.

Total test duration might not capture the true maintenance mode power of certain battery chargers
Prolongs the test duration until maintenance mode power has been captured representatively, if needed
Appendix Y1
To improve representativeness.

Manufacturer can report the battery discharge energy and the charging and maintenance mode energy as “Not Applicable” if the measurements cannot be made
Provides specific direction to apply for a test procedure waiver if the battery energies cannot be directly measured
Appendix Y and Appendix Y1
To improve representativeness.

Uses the designation “E
batt
” for both experimentally measured battery energy and representative battery energy

Changes the denotations to “Measured E
batt
” for experimentally measured battery energy, and “Representative E
batt
” for representative battery energy, with further clarification in the footnotes

Appendix Y
To improve readability.

Section 3.3.4 incorrectly references section 3.3.2 for instructions on how to discharge batteries
Corrects the cross-section reference to Table 3.3.2
Appendix Y and Appendix Y1
To improve readability.

Table 3.3.2 is located after Section 3.3.10 (Determining the 24-hour Energy Consumption) but is required for use in section 3.3.8 (Battery Discharge Energy Test)
Moves Table 3.3.2 to Section 3.3.8
Appendix Y and Appendix Y1
To improve readability.

Certain sections use terms such as “above” or “below” for references
Further clarifies the referenced sections
Appendix Y and Appendix Y1
To improve readability.

Battery charger standby mode and off mode can be inappropriately tested if manufacturer does not follow the test procedure in order
Reorganizes sections 3.3.11 and 3.3.12 so battery charger standby and off modes can be tested correctly even if the test procedure order is not followed
Appendix Y and Appendix Y1
To improve readability.

Column title in Table 3.3.3 states “Special characteristic or rated battery voltage”
Corrects the title to read “Special characteristic or highest rated battery voltage” to clarify that for multi-voltage chargers, the highest battery voltage must be used to determine product class
Appendix Y and Appendix Y1
To improve readability.

DOE has tentatively determined that, of the proposed amendments described in section III of this NOPR, the proposals in appendix Y1 to require testing with a minimally compliant wall adapter, increase the scope of wireless chargers, and to remove the usage profiles and UEC calculation would result in a value for measured energy use that is different from that measured using the current test procedure. However, as proposed, testing in accordance with these specific proposed changes would not be required until such time as compliance is required with new and amended energy conservation standards. DOE further clarifies that if the proposed

amendments for appendix Y were made final manufacturers testing and reporting a battery charger's energy use will have to do so based on the DOE test procedure at appendix Y as amended beginning 180 days following the final rule. DOE has also determined that the test procedure will not be unduly burdensome to conduct. Discussion of DOE's proposed actions are addressed in detail in section III of this NOPR.

III. Discussion

As stated, EPCA requires DOE to periodically review the test procedure for battery chargers and determine whether amendments to the test procedure would more accurately or fully comply with the requirements regarding representativeness and test burden. (42 U.S.C. 6293(b)(1)(A)) In the following sections, DOE discusses in detail relevant test procedure issues, proposes changes to the current DOE test procedure for battery chargers, and responds to relevant comments received in response to the May 2020 RFI. The Joint Commenters and AHAM stated in response to the May 2020 RFI that there are no product or testing changes that would warrant a significant update to DOE's current battery charger test procedure, recommended only minor revisions, and urged DOE to prioritize other issues. (Joint Commenters, No. 6 at pp. 1-2, AHAM, No. 5 at p. 2) DOE is undertaking this rulemaking pursuant to the periodic review as required by EPCA. As discussed in the following sections, DOE has initially determined that amending the current test procedure (and adding a new appendix) as proposed would more fully comply with the requirements in EPCA regarding representativeness and test burden. (42 U.S.C. 6293(b)(3))

A. Scope of Applicability

1. Battery Chargers

This rulemaking applies to battery chargers, which are devices that charge batteries for consumer products, including battery chargers embedded in other consumer products. 10 CFR 430.2. (
See also
42 U.S.C. 6291(32)) Functionally, a battery charger is a power conversion device used to transform input voltage to a suitable voltage for charging batteries used to power consumer products. (
See
42 U.S.C. 6291(32)) A battery charger may be wholly embedded in another consumer product, partially embedded in another consumer product, or wholly separate from another consumer product.
Id.

DOE's current battery charger test procedure applies to battery chargers that operate at either direct current (“DC”) or United States alternating current (“AC”) line voltage (115 Volts at 60 Hertz), as well as to uninterruptible power supplies that have an AC output and utilize the standardized National Electrical Manufacturer Association (“NEMA”) plug, 1-15P or 5-15P, as specified in American National Standards Institute “ANSI”/NEMA WD 6-2016.

Appendix Y differentiates among different types of battery chargers, including batch chargers, multi-port chargers, and multi-voltage chargers, as well as various battery chemistries. For each type of battery charger, appendix Y specifies test setup requirements and test battery selection, such as battery preparation steps, battery end-of-discharge voltages, and battery charger usage profiles
7

based on the respective product classes. These different specifications ensure that each battery charger is tested to produce results that measure energy use during a representative average use cycle or period of use.

7
In section III.B.4, DOE discusses a proposal to remove the UEC metric and the associated usage profile in favor of a multi-metric approach that would measure the energy performance of battery chargers in each mode of operation (active, standby and off modes) independently. If such a proposal were to be finalized, usage profiles would no longer be unnecessary.

2. Inductive Wireless Battery Chargers

DOE's current energy conversation standards for battery chargers were published on June 13, 2016 (“June 2016 Final Rule”). The standards cover inductive wireless battery charger products (also referred to as “wireless power devices”) only to the extent that such products are designed and manufactured to operate in a wet environment (
i.e.,
Product Class 1). 81 FR 38266, 38282; 10 CFR 430.32(z)(1). DOE established standards for these wet-environment inductive wireless battery chargers (
e.g.,
battery chargers found in wireless toothbrushes and electric shavers) after finding that the technology used in those products was mature.
Id.
DOE did not establish standards for other types of inductive wireless battery chargers to avoid restricting the development of newer, less mature inductively charged products.
Id.
Similarly, DOE did not generate usage profiles for other types of inductive wireless chargers at the time because of their nascent state of development and their lack of widespread availability in the marketplace.
Id.
Without usage profiles, a corresponding unit energy consumption value cannot be calculated.
Id.

In the May 2020 RFI, DOE requested comment on whether DOE should further clarify the term “wet environment,” whether any industry test procedures have been developed (or are being developed) to specifically address inductive wireless chargers other than those used in a wet environment, and data on how inductive wireless chargers are used in the field. 85 FR 26369, 26371.

In response, CA IOUs and NEEA recommended that DOE create and define categories of wireless chargers based on whether they are dedicated wireless chargers, interoperable single device wireless chargers, and interoperable multiple device wireless chargers, and that DOE expand the scope to include all dedicated wireless chargers rather than just those that are under 5Wh or designed to work in wet environments. (CA IOUs, No. 9 at pp. 2-4, NEEA, No. 8 at p. 11) NEEA stated that wireless charging is expected to continue to be integrated into new consumer products and cited research suggesting that wireless charging could nearly double national energy use of battery chargers by 2030. (NEEA, No. 8 at p. 1) NEEA noted that DOE's current test procedure already covers wired chargers associated with the same end uses as dedicated wireless charging systems. (NEEA, No. 8 at pp. 1-2). CA IOUs recommended that DOE eliminate the wet environment distinction, but that if DOE maintains the wet environment distinction that an ingress protection (“IP”) rating of IPX7 or IPX8
8

would be suitable to identify wet rated products. (CA IOUs, No. 9 at p. 5) Similarly, the Joint Commenters suggested that DOE re-define Product Class 1 as pertaining to inductive chargers that use a locating feature rather than “inductive chargers for wet environments” to avoid confusion. (Joint Commenters, No. 6 at p. 2) ITI stated that the term “wet environments” would benefit from further clarification, and requested that DOE provide more examples of products within this category. (ITI, No. 7 at p. 3) Delta-Q commented that the distinction of use in a wet environment does not sufficiently define the scope of covered wireless charger products. (Delta-Q, No. 10 at p. 1) Delta-Q claimed that, although Product Class 1 is intended for low-power personal hygiene products, other chargers such as those for outdoor lawn mowers and drones may also be covered

by the wet environment characterization.
Id.
Delta-Q recommended that DOE continue to exclude non-hygiene products, asserting that they represent a rapidly-changing emerging market and that regulating their efficiency at this time could stifle innovation. (Delta-Q, No. 10 at p. 1)

8
IPX7 and IPX8 are both ingress protection levels as defined by IEC 60529, “Degrees of Protection Provide by Enclosures (IP Code)”.

As stated previously, inductive wireless battery chargers are subject to the DOE test procedures and energy conservation standards only to the extent that such battery chargers have an inductive connection and are designed for use in a wet environment. (
See
Table 3.3.3 of appendix Y, footnote to Product Class 1) This scope of coverage includes those wireless charging products for which DOE determined in the June 2016 Final Rule had sufficiently mature designs such that regulation would not impede innovation,
e.g.,
electric toothbrushes and shavers. 81 FR 38266, 38283. While DOE refers to these as “wet environment” products, this term refers to products found in wet environment applications, not the level of waterproofing. But, as discussed further in this section, DOE is proposing to remove the “wet environment” distinction altogether.

The wet environment products covered in scope require sealing to prevent moisture ingress, and typically use a locating feature, such as a peg, cradle or a dock, to confine the physical engagement of the receiver (
i.e.
, consumer product) and the transmitter (
i.e.
, charger). 85 FR 26369, 26371. This feature provides relatively consistent placement of the receiver during testing.
Id.
The consistent physical alignment of the receiver to the transmitter enables the battery charger's energy performance to be measured repeatably using DOE test procedure. But DOE tentatively finds that approaches providing consistent receiver-transmitter alignment are now being used in non-wet environments.

Therefore, by adding a new appendix Y1 and eliminating the “wet-environment” limitation on inductive wireless battery chargers currently contained in appendix Y, DOE would be subjecting inductive wireless battery chargers as a whole to testing in appendix Y1testingY1. DOE further proposes to define the term “fixed-location” wireless charger in appendix Y1 to refer to inductive wireless battery chargers that incorporate a physical receiver locating feature (
e.g.,
a peg, cradle, dock, locking mechanism, magnet, etc.) to repeatably align or orient the position of the receiver with respect to the transmitter, and to require that battery chargers meeting such a definition be subject to the DOE test procedure regardless of whether it is for a wet-environment. This proposed amendment to include fixed-location inductive wireless chargers would cover products such as inductive chargers for electronic watches, fitness bands, smartphones, wireless earbuds, and wireless speakers, if the basic model prioritizes wireless charging of a battery and has a physical receiver locating feature.

DOE also proposes to increase the rated battery energy limit of fixed-location wireless chargers in appendix Y1 from ≤5 Wh to <100 Wh in order to address the broader scope of battery chargers that currently employ inductive wireless connections and to accommodate potential future product designs that may have larger battery energies. For battery chargers, the UEC metric represents an annualized amount of non-useful energy consumed by a battery charger in all modes of operation by combining the energy or power consumption in each mode with specified usage profiles (
i.e.
the time spent in that mode) and subtracting from it the discharged energy of a fully charged battery. Table 3.3.3 of appendix Y established such usage profiles for different classes of battery chargers, including inductive wireless chargers, defined by ranges of battery energy and voltage. At the time of the June 2016 Final Rule, inductive wireless chargers designed for use in wet environments were all found to have a battery energy under 5Wh. 81 FR 38266, 38283. As such, Table 3.3.3 of appendix Y specifies a rated battery energy of ≤5 Wh for Product Class 1. But, since the June 2016 Finale Rule, products on the market that rely on such inductive wireless charger designs have grown to include electronic wearable devices such as watches, fitness trackers, wireless earbuds, and even some smartphones. DOE has conducted initial research and found that although most of the fixed-location inductive wireless chargers were designed for batteries with lower energy ratings, typically within 20Wh, there are some fixed-location inductive wireless chargers that can charge products with higher battery energy levels of around 80Wh, namely inductively charged power tool products. DOE is not able to find fixed-location inductive chargers designed for products with battery energy of more than 100Wh. Therefore, DOE tentatively concludes that a rated battery energy limit of <100 Wh would appropriately cover the range of products that would be newly included in scope as a result of DOE's proposal to remove the wet environment designation.

As noted, in section III.B.4, DOE discusses the proposal to remove the UEC metric and the associated usage profile in favor of a multi-metric approach that provides the energy performance of battery chargers in each mode of operation (active, standby, and off modes) independently. If such a proposal were finalized, usage profiles based on battery energy limits would be unnecessary altogether.

DOE seeks comment on its proposal to define fixed-location wireless chargers in appendix Y1 and whether this definition accurately captures all the types of wireless chargers with locating features that are on the market; its proposal to remove the “wet environment” designation for wireless chargers; its proposal to revise the scope of Product Class 1 to include all fixed-location wireless chargers in appendix Y1; and its proposal to increase the rated battery energy limit for fixed-location wireless chargers from ≤5 Wh to <100 Wh in appendix Y1 to accommodate the range of inductive wireless battery chargers on the market and potential future product designs that may have larger battery energies. DOE also requests information on which types of inductive wireless battery chargers would be subject to DOE regulations due to the proposed change in scope, including any corresponding usage data, if available.

DOE also proposes to define the term “open-placement” wireless chargers in appendix Y1 to address wireless charging products that do not have a physical locating feature (
e.g.,
charging mats). CA IOUs, NEEA, and ITI stated in response to the May 2020 RFI that there are difficulties in testing open-placement wireless chargers, but encouraged DOE to continue working with stakeholders to establish either its own uniform wireless charger test method or adopt one being developed by the industry, such as ANSI/Consumer Technology Association (“CTA”) 2042.3
9

(“ANSI/CTA 2042.3”), the WPC protocol,
10

or the IEC 63288 test procedure.
11

(CA IOUs, No. 9 at pp.

1-2, ITI, No. 7 at pp. 1, 3-4, NEEA, No. 8 at p. 6) CA IOUs suggested that wireless chargers are no longer a nascent technology; however, NEEA claimed that wireless chargers are still relatively nascent when compared to other charging technologies. (CA IOUs, No. 9 at p. 2, NEEA, No. 8 at p. 5) CA IOUs and NEEA commented that wireless chargers are rapidly growing in popularity, and that because of the wide variation in efficiency, wireless chargers present significant opportunities for energy savings. (CA IOUs, No. 9 at pp. 1-2, NEEA, No. 8 at pp. 1-3, ITI, No. 7 at pp. 3-4) WPC further commented that wireless chargers still need to be tested uniquely to account for the wide charging area, unique standby, and end of charge behavior, irrespective of whether the system is treated as a battery charger or as an external power supply (“EPS”). (WPC, No. 4 at p. 2) NEEA suggested that interoperable (
i.e.,
open-placement) wireless chargers are similar to EPSs, in which standby power and active mode efficiency are regulated separately. (NEEA, No. 8 at pp. 4-5 and 7-9) WPC also asserted that the term “wireless battery chargers” may be misleading and cause overly burdensome testing for wireless power sources, and that wireless chargers are better classified as EPSs because of their lack of battery charging circuitry and their AC-to-DC power conversion nature. (WPC, No. 4 at p. 2) Similarly, for open-placement wireless power transfer devices, CA IOUs and NEEA suggested that DOE implement a standby power measurement in the interim while an active mode test method continues to be developed. (CA IOUs, No. 9 at p. 2, NEEA, No. 8 at pp. 9-10).

9
American National Standards Institute/Consumer Technology Association Standard 2042.3, “Methods of Measurement for Power Transfer Efficiency and Standby Power of Wireless Power Systems”.

10
Wireless Power Consortium, ENERGY STAR Test Method for Wireless Power Transmitters, test procedure development in progress.

11
International Electrotechnical Commission IEC 63288, “Wireless Power Transfer—Measuring method for wireless power transfer efficiency and standby power—mobile phone”. For more information on the development of IEC 63288,

including access to drafts of the test procedure, visit
www.iec.ch/dyn/www/f?p=103:7:516407272337837::::SP_ORG_ID,FSP_LANG_ID:10039,25.

DOE recognizes the increasing usage of open-placement inductive wireless chargers designed to work with a range of products by supporting multiple wireless charging protocols and having physical form factors that do not restrict engagement or alignment to one specific end use device. DOE also recognizes that, as indicated by commenters, a number of challenges remain with establishing a representative test procedure for these interoperable open-placement inductive wireless products. First, efficiency of wireless power transfer varies greatly depending on the alignment of the receiver with respect to the transmitter. A test procedure designed to capture the representative energy performance of such a device would need to repeatably measure the average power transfer efficiency across the full range of possible placement positions on the transmitter. Second, representative test load(s) would need to account for all charging scenarios because these open-placement wireless chargers are designed to work with various third-party products. Third, these devices also typically incorporate other non-battery-charging related features inherent to implementing an open-placement design, such as foreign object detection circuits, that may affect charging efficiency.

DOE acknowledges the industry's progress in developing test methods for open-placement wireless chargers, such as ANSI/CTA 2042.3, the WPC protocol, and the IEC 63288 test procedure. These test methods specify the use of either one reference receiver at multiple charging positions on the transmitter or require using multiple receivers at an optimal receiver placement point. DOE has reviewed these industry test standards, and tentatively finds that they do not sufficiently address the challenges with respect to repeatability of placement and ensuring use of a representative third-party receiver. DOE, working in conjunction with industry organizations such as the WPC, has found that mitigating these challenges is difficult. To-date, that work has yielded test methods that either lack repeatability or result in significant test burden. In addition, evaluating whether a particular test procedure measures the energy performance of open-placement wireless chargers during a representative average use cycle, specifically during active mode operation, requires data on consumer usage at the various modes of operation. DOE lacks, and is unaware of, such data.

Because data are lacking to develop a test procedure that would provide representative measurements of such a technology during active mode operation, DOE is not proposing a test procedure for measuring the active mode energy performance of open-placement wireless chargers in this NOPR. DOE will continue its efforts, working with industry bodies, such as WPC, IEC, and ANSI/CTA, to develop an active mode test procedure for open-placement wireless chargers that appropriately addresses the impact of receiver placement on charging efficiency, and will continue to gather relevant consumer usage data.

DOE finds, however, that measuring the no-battery mode energy performance of an open-placement wireless charger would not be affected by the same issues discussed above for active-mode testing, and is more straightforward than measuring active-mode energy. Therefore, DOE proposes to create a new section 5 of appendix Y1 titled, “Testing requirements for all open-placement wireless chargers,” which would include instructions for testing open-placement wireless chargers in no-battery mode according to IEC 62301 Ed. 2.0. DOE proposes that, after observing a period of stability, the AC input power of the open-placement wireless charger would be measured without any foreign objects (
i.e.,
without any load) placed on the charging surface. DOE also proposes that if the open-placement wireless charger has power supplied by an EPS but does not come pre-packaged with such an EPS, then testing must be conducted with any compatible and commercially-available EPS that is minimally compliant with DOE's energy conservation standards for EPSs as prescribed in 10 CFR 430.32(w). DOE notes that open-placement wireless chargers are not currently subject to energy conservation standards and are not subject to requirements regarding standby energy use. Were the proposed standby test procedure provisions to be adopted, open-placement wireless chargers would not be required to be tested according to such provisions until such time as compliance is required with any energy conservation standards that DOE may establish for these chargers. If the proposed amendments were made final, manufacturers voluntarily testing and reporting the energy usage of any open-placement wireless chargers would have to be based on the DOE test procedure as amended beginning 180 days following the final rule.

DOE seeks comment on its proposal to define open-placement wireless chargers in appendix Y1 and whether this definition accurately captures all the types of wireless chargers without physical locating features that are on the market. DOE also requests comment on its proposal to require testing of the no-battery mode power consumption of these open-placement wireless chargers.

B. Test Procedure

1. External Power Supply Selection

Most battery chargers require the use of a power adapter to convert 120 volt (“V”) AC line voltage into a low-voltage DC or AC output suitable for powering the battery charger. DOE's battery charger test procedure specifies that the battery charger be tested with the power adapter packaged with the charger, or the power adapter that is sold or recommended by the manufacturer. If a power adapter is not packaged with the charger, or if the manufacturer does not

sell or recommend a power adapter, then the battery charger is tested using a 5.0V DC input for products that draw power from a computer USB port, or using the midpoint of the rated input voltage range for all other products. Appendix Y, sections 3.1.4.(b) and 3.1.4.(c). However, the 5.0 V DC specification for products drawing power from a computer USB port may not be representative for battery chargers designed for operation only on DC input voltage and for which the manufacturer does not package the charger with a wall adapter or sell or recommend a wall adapter. The current generation USB specification can support up to 20 V, per the voltage and current provisions of the most recent version of the International Electrotechnical Commission's (“IEC”) “Universal serial bus interfaces for data and power—Part 1-2: Common components—USB Power Delivery” (“IEC 62680-1-2”) specification.

In the May 2020 RFI, DOE requested information on the characteristics and technical specifications of the wall adapters typically used when testing battery chargers shipped without a wall adapter and for which a wall adapter is not recommended by the manufacturer. 85 FR 26369, 26371. DOE also sought detailed technical information and data on the characteristics of the wall adapters typically used in the real world with such battery chargers including, but not limited to, input and output voltages, output wattage, power supply topologies, output connector type, and the impact of these on average efficiencies.
Id.
Additionally, DOE sought comment on whether testing such battery chargers using a reference wall adapter would be appropriate, and if so, how a reference wall adapter should be defined.

Both CA IOUs and ITI supported providing additional direction on the AC adapter used to test chargers that do not come with one. (CA IOUs, No. 9 at p. 4; ITI, No. 7 at p. 5) CA IOUs and ITI recommended that DOE provide minimum technical characteristics that must be met when testing battery chargers with external power supplies without an AC adapter pre-packaged, sold, or recommended by the manufacturer.
Id.
ITI further commented that the cable used can also affect power consumption, and that a reference wall adapter would work only if DOE designs one for universal connection types. (ITI, No. 7 at p. 5) The Joint Commenters stated that the test procedure already addresses USB chargers and therefore amendments are not necessary regarding the wall adapter provisions. (Joint Commenters, No. 6 at p. 2)

Considering the current market and these comments, DOE proposes to require in appendix Y1 that when wall adapter is not pre-packaged with a battery charger (and the charger manufacturer does not sell or recommend a compatible charger), testing would be performed using any commercially-available EPS that is both minimally compliant with DOE's energy conservation standards for external power supplies (“EPS”) found in 10 CFR 430.32(w) and satisfies the EPS output criteria specified by the battery charger manufacturer. DOE recognizes that these battery chargers are always operated with an EPS by the consumer, and that testing them without one is unrepresentative of their actual use. Because the battery charger energy consumption is measured at the input, under the proposed appendix Y1 requirement to test these battery chargers with a minimally compliant EPS, the energy consumption of the minimally compliant EPS will be included when calculating the battery charger product's unit energy consumption, similar to the testing condition in which an EPS is supplied with the charger. DOE has tentatively concluded that this proposal would not result in additional test burden; the current battery charger test procedure already requires input power to be captured, and this proposal does not lead to additional test steps. Furthermore, this proposed EPS selection criterion would not be required until DOE amends the energy conservation standards to account for the updated EPS selection criteria, if adopted. However, manufacturers are still required to continue testing their battery charger products following the amended appendix Y, if made final, during the meantime. If the proposed appendix Y1 amendments were made final, manufacturers can voluntarily test and report any such representations based on the appendix Y1 test procedure as amended beginning 180 days following the test procedure final rule.

When performing compliance or enforcement testing on such a battery charger basic model, DOE proposes that if the certified EPS is no longer available in the market, DOE would test the battery charger with any compatible minimally compliant EPS that meets the performance criteria. The intent of the proposal to test with a minimally compliant power supply is to allow manufacturers a wider selection of EPSs that are readily available, while ensuring that the battery charger is tested in a configuration representative of actual use. This proposal would also only apply to appendix Y1.

Additionally, DOE is proposing to specify in section 3.1.4(b) of appendix Y the order of preference for the test configuration when a wall adapter is provided or recommended. DOE is proposing that a battery charger would be tested using the pre-packaged wall adapter; if the battery charger does not include a pre-packaged wall adapter, then the battery charger would be tested with a wall adapter sold and recommended by the manufacturer; if the manufacturer does not recommend a wall adapter that it sells, then the battery charger is to be tested with a wall adapter recommended by the manufacturer.

ITI commented that input or output cables can affect a battery charger's power consumption but stopped short of quantifying their impact. (ITI, No. 7 at p. 5) DOE's analysis suggests that only output cables have the potential to notably impact power consumption, but that battery chargers are rarely shipped without an output cable. DOE, therefore, continues to require that battery chargers be tested with the output cable that is supplied with the device.

DOE requests comment on the proposal to specify the priority of wall adapter selection in appendix Y1. DOE also requests comment on the proposal in appendix Y1 to replace the 5 V DC input requirement for those chargers that do not ship with an adapter, and one is not recommended, with the requirement that these chargers be tested with any compatible and commercially-available EPS that is minimally compliant with DOE's energy conservation standards for EPSs. DOE also requests comments on whether these proposals would result in increased test burden.

2. Battery Chemistry and End-of-Discharge Voltages

The battery charger test procedure requires that, as part of the battery discharge energy test, the battery must be discharged at a specified discharge rate until it reaches the specified end-of-discharge voltage stipulated in Table 3.3.2 of appendix Y. Appendix Y, section 3.3.8(c)(2). Table 3.3.3 defines different end-of-discharge voltages for different battery chemistries. A footnote to Table 3.3.2 provides that if the presence of protective circuitry prevents the battery cells from being discharged to the end-of-discharge voltage specified, then the battery cells must be discharged to the lowest possible voltage permitted by the protective circuitry.
Id.

In the May 2020 RFI, DOE requested information on whether there have been any new battery chemistries that are not covered by the categories listed in Table 3.3.2 of appendix Y. 85 FR 26369, 26372. DOE also requested information on whether any of the end-of-discharge voltages listed for the battery chemistries under Table 3.3.2 of appendix Y need to be updated.
Id.

ITI and the Joint Commenters stated that they were not aware of any new battery technologies or changes to existing chemistries that would warrant an update to Table 3.3.2 of appendix Y. (ITI, No. 7 at p. 6; Joint Commenters, No. 6 at pp. 1-2) The Joint Commenters stated that the footnote to Table 3.3.2 addresses the end-of-discharge voltage of battery chemistries not explicitly included in Table 3.3.2. (Joint Commenters, No. 6 at p. 2)

Delta-Q commented that, normally, the battery management system would terminate discharge before reaching the appendix Y specified end-of-discharge voltage, which is consistent with the Table 3.3.2 footnote. (Delta-Q, No. 10 at p. 1) Delta-Q stated that because of this, DOE should keep the protective circuitry guidelines in the test procedure, as it is representative of the charger's energy use.
Id.
Delta-Q also commented that the term “Lithium Polymer” listed in Table 3.3.2 is not clear because the term can refer to either an existing, but commercially unsuccessful, battery technology with cells that rely on a polymer electrolyte instead of a liquid electrolyte; or the term may refer to non-rigid laminated pouch packing, as is found in small consumer products.
Id.
Delta-Q also asserted that the term is altogether unnecessary in Table 3.3.2 since “Lithium-Ion” captures all lithium battery sub-types.
Id.
Delta-Q suggested that DOE remove the term “Lithium Polymer” from the table.
Id.
Delta-Q also commented that “Nanophosphate Lithium-ion,” which is included in Table 3.3.2, is a registered trademark and should be re-designated as “Lithium Iron Phosphate,” a common battery chemistry, to avoid unintentional referral to a proprietary product.
Id.

CA IOUs encouraged DOE to incorporate emerging battery chemistries but did not suggest any specific new battery chemistries. (CA IOUs, No. 9 at p. 5)

DOE is proposing to replace the term “Lithium Polymer” in Table 3.3.2 of appendix Y with “Lithium-ion Polymer.” Lithium-ion polymer batteries are structurally different from lithium-ion batteries in that lithium-ion polymer batteries incorporate a polymer separator to reduce safety hazards. Although having the same end-of-discharge voltage as lithium-ion batteries, DOE proposes a separate listing for lithium-ion polymer batteries to reflect the structural differences of these batteries. DOE also proposes to update the term “nanophosphate lithium-ion” to refer to the non-proprietary version of this battery chemistry,
i.e.,
“lithium iron phosphate.” DOE is proposing to incorporate these changes in the proposed appendix Y1, as well.

Although the presence of protective circuitries allows some batteries to discharge to end-of-discharge voltages that are different from the voltages prescribed in Table 3.3.2 of appendix Y, such circuits are not universal, and accurate values for end-of-discharge voltages are required to ensure batteries are safely and representatively discharged when such circuits are not present. Therefore, no changes are proposed for the footnote regarding protective circuitries.

DOE requests comment on the proposal to update the term “Lithium Polymer” to “Lithium-ion Polymer”. DOE also requests comment on the proposal to rename the term “Nanophosphate Lithium” to the non-proprietary term “Lithium Iron Phosphate”.

3. Battery Selection

Table 3.2.1 of appendix Y specifies battery selection criteria based on the type of charger being tested; specifically, whether the charger is multi-voltage, multi-port, and/or multi-capacity. For multi-capacity chargers, Table 3.2.1 specifies using a battery with the highest charge capacity. Similarly, for multi-voltage chargers, Table 3.2.1 specifies using the highest voltage battery. Section 3.2.3(b)(2) of appendix Y specifies that if the battery selection criteria specified in Table 3.2.1 results in two or more batteries or configurations of batteries with same voltage and capacity ratings, but made of different chemistries, the battery or configuration of batteries that results in the highest maintenance mode power must be used for testing.

As indicated, some battery chargers (
e.g.,
lead-acid battery chargers) can charge numerous combinations of batteries from third-party vendors, and these battery chargers generally do not have a maximum battery capacity limit because, theoretically, multiple batteries can be connected in parallel to a single charger. For these devices, finding the most consumptive combination of charger and battery could require a number of trials.

In the May 2020 RFI, DOE requested comment on how manufacturers are certifying battery chargers that can charge third-party batteries from different manufacturers but do not ship with batteries themselves. 85 FR 26369, 26372. To address this scenario, DOE also requested feedback on possible alternate approaches to testing battery chargers, such as by replacing the batteries with a reference load during testing.
Id.

CA IOUs supported both the current battery selection criteria, and the concept of replacing the test batteries with a representative resistive load. (CA IOUs, No. 9 at p. 5) CA IOUs stated that this latter approach would require comprehensive study of multiple batteries with different chemistries from multiple manufacturers at various states to be accurate.
Id.
CA IOUs suggested that DOE analyze any developed dataset and validate it against actual battery values.
Id.
CA IOUs recommended that while a representative resistive load is being developed, DOE collect a set of reference measurements for a test laboratory to use in choosing batteries that meet the specified attributes and tolerances—and if multiple batteries meet the same criteria, the batteries shall be selected according to Table 3.2.1 of appendix Y. (CA IOUs, No. 9 at pp. 5-6)

Delta-Q commented that for its multi-capacity chargers sold without a dedicated battery pack, it would choose commercially-available batteries with a maximum charge capacity based on the individual charger, following Table 3.2.1 of appendix Y. (Delta-Q, No. 10 at p. 2) Delta-Q further stated that it would choose a flooded lead acid battery to test with chargers that support multiple battery chemistries, asserting that flooded lead acid batteries have the lowest efficiency.
Id.
Delta-Q discouraged an approach that would test battery chargers with a reference load that simulates the characteristics of a battery.
Id.
Delta-Q stated that although using a reference load could improve test repeatability, it would be almost impossible to simulate the non-linear response of many common battery chemistries in a way that would be representative of real-world energy consumption.
Id.
Delta-Q further stated that if DOE were to take this approach, it would propose testing a charger's power conversion efficiency at several steady-state operating points and calculating a weighted average.
Id.

As suggested by commenters, deriving a representative reference load that accurately models the performance of a battery would require a considerable amount of testing and development; in

addition, the rapid pace of evolution in battery design would require frequent updates that would likely outpace DOE's regulatory processes. Therefore, DOE is not proposing the use of reference test loads.

Furthermore, none of the comments received indicated any particular difficulty testing battery chargers that can charge numerous combinations of batteries from third-party vendors. Therefore, DOE is not proposing any changes to the current battery selection criteria in Table 3.2.1 of appendix Y, or the proposed new appendix Y1.

4. Battery Charger Usage Profile and Unit Energy Consumption

The UEC equation in section 3.3.13 of appendix Y combines various performance parameters, including 24-hour energy, measured battery energy, maintenance mode power, standby mode power, off mode power, charge test duration, and usage profiles. Table 3.3.3 specifies values for time spent (in hours per day) in active and maintenance mode, standby mode, off mode; number of charges per day; and threshold charge time (in hours). The usage profiles are based on data for a variety of applications and that primarily consisted of user surveys, metering studies, and stakeholder input that DOE considered during the rulemaking culminating in the June 2016 Final Rule. 81 FR 38266, 38287.

In the May 2020 RFI, DOE requested feedback on whether the usage profiles listed in Table 3.3.3 of appendix Y required updating, with a particular interest in data specific to end-use device type and battery voltage. 85 FR 26369, 26372.

Delta-Q and NEEA stated that they were not aware of any usage profile changes for both wired and wireless battery chargers. (Delta-Q, No. 10 at p. 2; NEEA, No. 8 at p. 10) NEEA recommended that DOE study and update the usage profiles to help develop a test procedure for dedicated and interoperable wireless chargers. (NEEA, No. 8 at p. 10) The Joint Commenters stated that the current usage profiles are sufficient and that there is no need to change them since manufacturers have already familiarized themselves with the current profile. (Joint Commenters, No. 6 at p. 3) CA IOUs commented that wireless chargers can have different user profiles that result in a longer maintenance charging period, but that most overnight charging profiles remain the same as wired chargers. (CA IOUs, No. 9 at pp. 5-6) CA IOUs recommended that DOE conduct additional research to develop a comprehensive set of usage profiles. (CA IOUs, No. 9 at p. 6)

Currently, the energy use of a battery charger is captured by a single metric, UEC. UEC integrates active mode, stand-by mode, and off mode energy use in order to estimate the amount of non-useful energy (
i.e.
energy not transferred to the battery) consumed by the battery charger over the course of a year. UEC requires the use of usage profiles to appropriately reflect the period of time a product spends in each mode. DOE's product class-specific usage profiles were initially developed using the shipment weighted average usage hours of all the applications of battery chargers whose battery voltage and energy met the criteria for each product class. The intended result is for each usage profile to be appropriately representative of the usage of the product class as a whole. As the battery charger market continues to evolve, DOE has observed that the relative share of shipments among different types of products within a product class has changed; the types of products within a given product class as well as the usage patterns of the products within a product class have become more varied. For example, the current Product Class 2 includes both smartphones and home power tools—two products with widely different usage patterns and annual shipments. A more recent market review shows that the shipments for certain applications, such as smartphones, cordless phones, wireless headsets etc. have changed significantly since the usage profiles in appendix Y were originally established. Additionally, the market and shipments of battery chargers has shown to change over short periods of time as new products that rely on battery chargers emerge and are adopted by the market, and as consumer use of products that rely on battery chargers changes. As an example, note that the shipments for Digital Audio Players and Digital Cameras have declined significantly with the advent of smart phones that have similar built-in capabilities.

As discussed, EPCA requires DOE to amend its test procedures for all covered products to include standby mode and off mode energy consumption, with such energy consumption integrated into the overall energy efficiency, energy consumption, or other energy descriptor for each covered product, unless the Secretary determines that (i) the current test procedures for a covered product already fully account for and incorporate the standby mode and off mode energy consumption of the covered product; or (ii) such an integrated test procedure is technically infeasible for a particular covered product, in which case the Secretary shall prescribe a separate standby mode and off mode energy use test procedure for the covered product, if technically feasible. (42 U.S.C. 6295(gg)(2)(A)) DOE is also required to establish test procedures that are reasonably designed to produce test results which measure energy efficiency and/or energy use of a covered product during a representative average use cycle or period of use, as determined by the Secretary, and such test procedures must not be unduly burdensome to conduct. (42 U.S.C. 6293(b)(3)) Therefore, when considering the feasibility of a test procedure that provides for a metric that integrates active mode, standby mode, and off mode energy use DOE must also consider the representativeness and burden of the test procedure.

The current test procedure approach specifies an integrated metric relying on usage profiles, but changes in consumer use of a limited number of products within a product class and the emergence of new products can both impact the representativeness of that usage profile. As the market and usage of battery chargers continues to evolve, the current test procedure approach risks becoming less representative, absent additional and continuously-revised usage profiles. Because the test procedure metric requires integrating active mode, standby mode, and off mode energy use, the need for new or amended usage profiles would potentially result in the need to repeatedly amend test procedures, which in turn potentially would require manufacturers to update representations, increasing manufacturer burden.

In an effort to maintain the representativeness of the test procedure for battery chargers while minimizing the potential need for future amendments, DOE is proposing an approach that does not rely on the UEC equation or usage profiles. Specifically, DOE is proposing in appendix Y1 to establish an approach that relies on a separate metric for each of the following modes of operation: Active mode, standby mode and off mode. This proposal is discussed in further detail in section III.B.5 of this NOPR.

DOE notes that if it were to adopt the proposed multi-metric approach, compliance with the test procedure in appendix Y1 would not be required until such time as DOE were to amend the energy conservation standards for battery chargers based on the revised test procedure in compliance with EPCA. (42 U.S.C. 6295(o) and 42 U.S.C. 6295(gg)(3)(A)-(B))

DOE requests feedback on the proposal to remove the specification of usage profiles and the associated UEC calculation in appendix Y1, to be replaced with an approach that relies on separate metrics for active mode, standby mode, and off mode. For further consideration of the existing approach, DOE requests, for all applications in each product class, data such as the percentage of time spent in each mode of operation along with data sources for consideration in updating the usage profiles for battery chargers.

5. Battery Charger Modes of Operation

a. Active Mode

Battery charger active mode is the state in which the battery charger system is connected to the main electricity supply and is actively delivering power to bring the battery to a fully charged state, as defined in section 2.1 of appendix Y. Appendix Y currently tests the active mode power consumption along with battery maintenance mode power
12

to produce a consolidated 24-hour energy consumption value, or E
24
, which is then used in the UEC calculation. As previously discussed, DOE is proposing to replace the UEC metric system with a discrete multi-metric approach that determines the energy efficiency and energy use of the active mode, standby mode, and off mode power consumption separately.

12
Maintenance mode is the operation of a battery charger to maintain a battery at full charge while a battery remains in the charger after fully charged. Under the current test procedure the characterization of maintenance mode as active mode or standby mode is less critical because the current test procedure metric integrates the modes. As discussed in the following section, DOE has tentatively characterized maintenance mode as part of standby mode.

In the newly proposed appendix Y1, DOE proposes to use a charge test in which the test period would begin upon insertion of a depleted battery and would end when the battery is fully charged. The active mode energy, E
a
would represent the accumulated input energy, meaning the average input power integrated over this test period.

Similar to the procedure currently in section 3.3.2 of appendix Y (
Determining the Duration of the Charge and Maintenance Mode Test
), if a battery charger has an indicator to show that the battery is fully charged, that indicator would be used to terminate the active mode test. If no indicator besides the manufacturer's instructions indicates how long it should take to charge the test battery, the active mode test would be conducted for the longest estimated charge time as provided in the manufacturer's materials. If the battery charger does not have such an indicator and a manufacturer does not provide such a time estimate, the length of the active mode test would be 1.4 multiplied by the rated charge capacity of the battery divided by the maximum charge current. DOE also proposes to arrange sections of appendix Y1 such that the battery discharge test is performed immediately after this active mode test is completed and prior to continuing to the 24-hour charge and maintenance mode test that would then be used to determine maintenance mode power.

In DOE's experience, it may be possible to analyze the resulting data from the 24-hour charge and maintenance mode energy consumption test and divide it into its constituents;
i.e.,
the active mode energy and maintenance mode power. Under this alternative approach, active mode energy consumption, E
a
, would be the time series integral of the power consumed from the point when the battery was first inserted (or plugged in for chargers with integrated batteries) until the measured data indicate a drop in power associated with the transition from active charging to maintenance mode. Under this approach, a single test period would provide the necessary measurements for the active mode energy, E
a
, from the 24-hour charge and maintenance mode test data.

DOE is proposing a separate test for active mode to allow the battery discharge test to be conducted immediately afterwards and prior to the maintenance mode test. This would ensure that the energy put into the battery can be directly compared to the energy extracted from it without any contribution from other modes of operation such as maintenance mode. However, DOE may also consider the discussed alternate approach in the development of the final rule.

DOE requests comment on the proposed approach to determining active mode energy, as well as the suggested alternate method. In particular, under the alternate method, DOE requests comment on how to define the drop in power associated with the transition from active charging to maintenance mode, such that this method would provide repeatable and reproducible results.

b. Standby Mode and Battery Maintenance Mode

Standby mode is the condition in which an energy-using product is:

(1) Connected to a mains power source; and

(2) Offers 1 or more of the following user-oriented or protective functions:

(aa) To facilitate the activation or deactivation of other functions (including active mode) by remote switch (including remote control), internal sensor, or timer.

(bb) Continuous functions, including information or status displays (including clocks) or sensor-based functions.

(42 U.S.C. 6295(gg)(1)(A)(iii))

Appendix Y defines standby mode for battery chargers as the condition in which a battery charger is connected to mains electricity supply, the battery is not connected to the charger—and for battery chargers with manual on-off switches, all switches are turned on. Appendix Y also includes a definition for maintenance mode in section 2.8 to mean the mode of operation in which the battery charger is connected to the main electricity supply and the battery is fully charged but still connected to the charger. In maintenance mode, a battery charger continuously monitors the voltage of the fully charged battery and periodically supplies charge current to maintain the battery at the fully-charged state.

As mentioned previously, because the current test procedure relies on a metric that integrates active mode, standby mode, and off mode, it is less critical as to whether maintenance mode is characterized as standby mode as compared to the proposed multi-metric approach. The current “standby mode” definition in appendix Y only captures what can be referred to as “no-battery mode,”
i.e.,
the condition where a battery charger is connected to a mains power source but a battery itself has not yet been inserted. In the context of the proposed multi-metric approach, DOE has tentatively determined that maintenance mode is also appropriately characterized as a standby power mode. In maintenance mode, a battery charger provides continuous monitoring of the battery charge. While a battery charger provides some limited charging in maintenance mode in order to maintain the battery at full charge, it is not charging a depleted battery. Unlike active mode, maintenance mode can persist indefinitely. As an example, power tool chargers in residential environments routinely spend an indefinite amount of time maintaining batteries that are not regularly used but are required to be fully charged. In addition to balancing and mitigating self-discharge of the cells, these chargers also typically provide a status display indicating that the battery is in the fully charged state and ready for use. As previously mentioned, DOE has tentatively determined that these continuous functions in maintenance

mode satisfies both EPCA's and IEC 62301's definition of standby.

To better account for these conditions, DOE proposes to rename what is currently defined in appendix Y as standby mode to “no-battery mode” in appendix Y1 (and reference this term, as appropriate, throughout appendix Y1). DOE also proposes to define in appendix Y1 the term “standby mode” to capture both no-battery mode and maintenance mode. Specifically, DOE proposes that in appendix Y1, standby mode power of a battery charger (P
sb
), would be calculated as the sum of the no-battery mode power (P
nb
), and maintenance mode power (P
m
).

DOE requests feedback on its proposed definition of standby mode in newly proposed appendix Y1 to capture both no-battery mode as well as maintenance mode. DOE also requests feedback on its proposal to define standby power, or P
sb
, to mean the summation of the no-battery mode (P
nb
) and maintenance mode (P
m
).

In proposing to replace the UEC metric with mode-specific metrics, DOE considered utilizing the existing E
24
metric instead of the proposed active mode energy E
a
. E
24
captures the energy performance of a battery charger in active mode as well as some time spent in maintenance mode. However, in doing so maintenance mode would have been captured twice—once as part of E
24
and again as part of the proposed definition of standby mode. DOE believes that regulating maintenance mode and no-battery mode in terms of their power consumption (
i.e.,
in watts), rather than as an energy consumption metric over a certain period of time (
i.e.,
in watt-hours), is more appropriate and representative because of the indefinite amount of time a battery charger may spend in either of these modes, as described above. As such, DOE is proposing that maintenance mode be accounted for as part of standby mode instead of within the E
24
metric in conjunction with active mode.

Per section 3.3.9 of appendix Y, maintenance mode power is currently measured by examining the power-versus-time data from the charge and maintenance test, and computing the average power that spans a whole number of cycles, and includes, at least, the last 4 hours of the test data. DOE considered an alternative test method in which maintenance mode power would be calculated as the highest rolling average over at least a 4-hour continuous time period during the charge and maintenance mode test, starting from when active mode charging ends. DOE, however, did not propose this alternate test method in this NOPR due to lack of sufficient data needed to determine if such a method would be appropriate for all battery chargers.

DOE requests feedback on its proposed approach to rely on E
a
, P
sb
and P
off
instead of E
24
, P
nb
and P
off
to determine the energy performance of a battery charger, and whether a different approach exists that may provide test results that are more representative of the energy performance and energy use of battery chargers. DOE also requests comment on the described alternate approach to capturing maintenance mode power and whether such an approach would be representative of actual use for all battery chargers.

6. Test Procedure Waivers Regarding Non-Battery-Charging Related Functions

DOE granted Dyson, Inc. (“Dyson”) a waiver from the current battery charger test procedure for a specified battery charger model (used in a robotic vacuum cleaner) and provided an alternate means for disabling non-battery-charging functions during testing.
13

82 FR 16580 (Apr. 5, 2017). As described in the petition for waiver, the battery charger basic models subject to the waiver have a number of settings and remote management features not associated with the battery charging function, but are instead associated with the vacuum cleaner end product that must remain on at all times. 82 FR 16580, 16581. Dyson explained that it would be inappropriate to make these functions user controllable, as they are integral to the function of the robot.
Id.
The DOE test procedure for battery chargers requires that any function controlled by the user and not associated with the battery charging process must be switched off; or, for functions not possible to switch off, be set to the lowest power consuming mode. Section 3.2.4.b of appendix Y. DOE determined that the current test procedure at appendix Y would evaluate the battery charger basic models specified in the Orders granting the waiver and (related waiver extension) in a manner so unrepresentative of its true energy consumption characteristics as to provide materially inaccurate comparatively data. 82 FR 16580, 16581 and 84 FR 12240, 12241. Pursuant to the approved test procedure waiver, the specified basic models must be tested and rated such that power to functions not associated with the battery charging process are disabled by isolating a terminal of the battery pack using isolating tape.
Id.
In the May 2020 RFI, DOE requested comment on whether the waiver approach is generally appropriate for testing basic models with similar features. 85 FR 26369, 26372-26373.

13
Decision and Order Granting a Waiver to Dyson, Inc. From the Department of Energy Battery Charger Test Procedure (Case No. BC-001). Subsequently, DOE issued an Extension of Waiver to Dyson, Inc. to cover an additional basic model (Case No. 2018- 012). 84 FR 12240 (Apr. 1, 2019).

Delta-Q supported incorporating the waiver language into the test procedure to make available the same testing method available for other chargers with integrated non-charging features, such as DC-DC converters, communication, diagnostics, and datalogging, that increase user value and reduce cost and complexity. (Delta-Q, No. 10 at p. 2) The Joint Commenters and ITI also supported physically disabling non-charging-related features, stating that the inclusion of these features during the charge and maintenance mode test would produce results that are not representative of a battery charger's actual use. (Joint Commenters, No. 6 at p. 3, ITI, No. 7 at p. 1, 8) The Joint Commenters suggested that DOE add a column to the certification report for manufacturers to indicate when special modifications were made to an end-use product for testing and certification purposes. (Joint Commenters, No. 6 at p. 3) The Joint Commenters recommended that DOE add additional anti-circumvention language that makes the intent of the approach to disable non-battery-charging functions clear.
Id.
ITI further commented that smart devices must be connected to a network and that DOE should update the test method to recognize the constant connectivity needs of these devices, including during charging. (ITI, No. 7 at p. 9) As an alternative, ITI suggested that DOE could also prescribe “adders” for different functions instead of allowing them to be disabled. (ITI, No. 7 at pp. 8-9)

CA IOUs recommended that DOE continue to rely on the use of waivers and review them on a case-by-case basis, granting them only when publicly available solutions to make the product compliant with DOE's standards are unavailable. (CA IOUs, No. 9 at pp. 4-5) Furthermore, CA IOUs recommended that DOE only prescribe waivers to those products with core components that cannot be disabled without risk of damaging the product.
Id.

NEEA suggested that the robotic vacuum cleaner waivers should be discontinued, asserting that other manufacturers of similar products have been able to redesign their products to be successfully tested without a waiver in response to enforcement action taken

by the California Energy Commission (“CEC”). (NEEA, No. 8 at p. 10)

Based on DOE's review of the market indicating that products subject to the waivers granted to Dyson are no longer available, DOE is not proposing to amend the test procedure to include instructions regarding disabling power to functions not associated with the battery charging process that are not consumer controllable. If made final, this proposal would terminate the existing Dyson waivers consistent with 10 CFR 430.27(h)(3) and 10 CFR 430.27(l).

DOE is also not proposing to include different power consumption adders for non-battery-charging related functions. As stated, the DOE test procedure applies to battery chargers as that term is defined by EPCA and in the DOE regulations. Inclusion of power consumption adders for non-battery charging-related functions would result in a UEC or active energy consumption value unrepresentative of the energy use by the battery charger.

C. Corrections and Non-Substantive Changes

Since the publication of DOE's current battery charger test procedure and energy conservation standards, DOE has received numerous stakeholder inquiries regarding various topics involving battery charger testing and certification. Based on these inquiries, DOE identified the need for certain minor corrections. These corrections are addressed in the following sections. Additionally, in the interest of improving overall clarity, DOE will include a flowchart in the docket outlining the required testing and certification process upon publication of a final rule.

1. Certification Flow Charts

Upon publication of a final rule, DOE will include flowcharts in the docket, shown in Figure III.C.1 and Figure III.C.2,
14

to help manufacturers better understand the battery charger testing and certification process. In particular, the flow charts would provide an overview of the testing and certification process including an overview of the basic model definition; the scope of DOE's battery charger test procedure; the required sample size; difference between a rated value, a represented value, and a certified rating; and the statistical criteria for determining compliance with energy conservation standards. The flow charts are not intended to address all aspects of the testing and certification requirements, but instead provide a general-level guide to the process. As such, manufacturers should not rely solely on the flow charts for testing and compliance. Manufacturers of battery chargers are required to comply with the applicable provisions under 10 CFR parts 429 and 430.

14
Figures III.C.1 and III.C.2 are included to clarify the process in this rulemaking only. Manufacturers should not rely solely on the flow charts as substantive guides for testing and compliance, should changes proposed in this NOPR be finalized.

BILLING CODE 6450-01-P

EP23NO21.192

EP23NO21.193

BILLING CODE 6450-01-C
DOE requests stakeholder feedback on whether such flow charts will assist manufacturers through the certification testing and certification process. DOE also requests comment on whether the flow charts would benefit from the inclusion of any additional information.

2. Testing and Certification Clarifications

DOE's current battery charger UEC calculation is prescribed in section 3.3.13 of appendix Y, with product

specific certification requirements prescribed in 10 CFR 429.39. In response to the May 2020 RFI, stakeholders submitted comments suggesting areas regarding the testing and certification requirements that may benefit from additional detail or re-organization.

a. Multiple Battery Combinations

ITI suggested that DOE add the term “representative testing” to make it clear that testing is not required for every combination of battery pack and EPS if the battery packs and EPSs are identical in electrical ratings. (ITI, No. 7 at pp. 1-2) ITI commented that testing every combination would be time-consuming, costly, and requires excessive test samples, which produces nearly identical test results between combinations. (ITI, No. 7 at p. 2) ITI also suggested that the sample size should be reduced for products that pass DOE's energy conservation standards by more than a certain margin. (ITI, No. 7 at pp. 1-2)

Manufacturers are required to test and certify basic models of battery chargers, as defined in 10 CFR 430.2. For battery chargers, the term “basic model” means all units of a given battery charger class manufactured by one manufacturer; having the same primary energy source; and, which have essentially identical electrical, physical, and functional characteristics that affect energy consumption and energy efficiency. 10 CFR 430.2. Individual units within a basic model may be distributed under different brand names but must be made by the same manufacturer. If the battery selection criteria specified in Table 3.2.1 of appendix Y results in two or more batteries or configurations of batteries of different chemistries, but with equal voltage and capacity ratings, the battery or configuration of batteries with the highest maintenance mode power, as determined in section 3.3.9 of appendix Y, should be selected for testing. This would result in a single battery or a single configuration of batteries for conducting the test.

In cases where the battery charger basic model's UEC passes DOE's energy conservation standards and shows consistent energy consumption, manufacturers have the potential to certify the product with only 2 units tested so long as they follow the test procedure and the certification requirement. Otherwise, more samples would need to be tested until the sampling requirements of 10 CFR 429.39 are met.

b. Measured vs. Rated Battery Energy

The product class distinctions provided in Table 3.3.3 of appendix Y are based in part on rated battery energy as determined in 10 CFR 429.39(a), which in turn references the represented value of battery discharge energy. 10 CFR 429.29(a)(1). The calculation of UEC in section 3.3.13 of appendix Y is based in part on the tested (
i.e.,
measured) battery energy.

TTI commented that there is inconsistency when determining the battery charger product class between appendix Y and DOE's battery charger standard at 10 CFR 430.32(z). Under appendix Y, the term “E
batt
” refers to the measured battery energy while under the standard (10 CFR 430.32(z), the term “E
batt
” refers to the rated battery energy determined in 10 CFR 429.39(a). (TTI, No. 3 at p. 1) TTI commented that because of this, different labs are using different battery energy values to determine battery charger product class and energy conservation standards, resulting in possibly inaccurate certifications.
Id.

As described, UEC calculation in section 3.3.13 of appendix Y incorporates the measured battery energy as determined in section 3.3.8 of appendix Y. In contrast, determining the appropriate product class determination for purposes of standards compliance is based on the “rated” battery energy (
i.e.,
the represented value of the battery energy). To better distinguish between measured battery energy and rated (
i.e.,
represented) battery energy, DOE proposes updating the nomenclature in appendix Y by modifying the “E
batt
” term used in the UEC calculation and usage profile selection in Table 3.3.3 to “Measured E
batt
”. DOE notes, however, that if the proposal to remove the UEC equation and usage profiles, as described in III.B.4 are finalized, all remaining instructions within appendix Y1 will rely on measured E
batt
, such that distinguishing between measured and rated E
batt
would not be required.

DOE requests comments on whether manufacturers and test laboratories are currently using “measured” battery energy or “rated”/“represented” battery energy values to determine battery charger product class. DOE requests comment on its proposal to update the nomenclature in appendix Y to refer to “Measured E
batt
” and “Represented E
batt
” to better distinguish between the two values.

c. Alternate Test Method for Small Electronic Devices

ITI recommended that DOE simplify the test procedure for small electronic devices by relying on the battery capacity as marked on the battery pack/cell instead of direct measurements. (ITI, No. 7 at p. 2) ITI claimed that this approach would simplify sample preparation for certain samples, avoid the need for obtaining special samples from the factory with unsealed enclosures, and avoid the difficulty of soldering test leads to a very small battery terminals in mobile products.
Id.

DOE has observed several occasions where the measured battery energy was lower than the capacity as marked on the battery pack/cell (
i.e.,
nameplate) battery energy. In such cases, a test procedure reliant on the nameplate battery energy, rather than measured battery energy, could result in an unrepresentative value of UEC or active energy consumption. Accordingly, DOE is not proposing to amend the requirement to rely on the measured battery energy value for the purpose of the testing and certification.

d. Inability To Directly Measure Battery Energy

Section 3.2.5.(f) of appendix Y states that when the battery discharge energy and the charging and maintenance mode energy cannot be measured directly due to any of the following conditions: (1) Inability to access the battery terminals; (2) access to the battery terminals destroys charger functionality; or (3) inability to draw current from the test battery, the battery discharge energy and the charging and maintenance mode energy shall be reported as “Not Applicable.” In such cases, the test procedure does not provide instruction on how to proceed with the remainder of the test, and an alternate test method must be used to measure battery discharge energy and the charging and maintenance mode energy. DOE therefore proposes to update section 3.2.5(f) of appendix Y to explicitly state that if any of the aforementioned conditions are applicable, preventing the measurement of the battery discharge energy and the charging and maintenance mode energy, a manufacturer must submit a petition for a test procedure waiver in accordance with 10 CFR 430.27. The same provision would also be included as part of the new appendix Y1.

e. Determining Battery Voltage

The product class distinctions provided in Table 3.3.3 of appendix Y are based in part on “battery voltage” in addition to rated battery energy or special charging characteristics, as described previously. Section 3.3.1 of appendix Y specifies recording the nameplate battery voltage of the test

battery. Section 2.21 of appendix Y defines “nameplate battery voltage” as specified by the battery manufacturer and typically printed on the label of the battery itself. If there are multiple batteries that are connected in a series, the nameplate battery voltage of the batteries is the total voltage of the series configuration—that is, the nameplate voltage of each battery multiplied by the number of batteries connected in series. Connecting multiple batteries in parallel does not affect the nameplate battery voltage. Section 2.21 of appendix Y.

Additionally, for a multi-voltage charger, the battery with the highest battery voltage must be selected for testing, as prescribed by Table 3.2.1 of appendix Y. Consequently, the highest supported battery voltage should also be used to determine product class, which is not reflected by the current term “battery voltage” in Table 3.3.3. Updating the language in Table 3.3.3 would avoid the potential for future confusion with regard to multi-voltage products.

TTI asked DOE to provide a method to determine battery voltage for certification purposes. (TTI, No. 3 at p. 1)

DOE proposes to amend Table 3.3.3 of appendix Y by replacing the term “battery voltage” with “highest nameplate battery voltage” to provide clearer direction that the battery voltage used to determine product class is based on its nameplate battery voltage, and that for multi-voltage products, the highest voltage is used. This proposed change would also be reflected in the proposed appendix Y1.

DOE is not aware of any multi-voltage battery chargers that are currently incorrectly certified. Updating the language in appendix Y would further avoid the potential for future confusion with regard to multi-voltage products. DOE requests comments on its proposal to amend Table 3.3.3 of appendix Y, and the corresponding language in the proposed appendix Y1, with the term “highest nameplate battery voltage.”

3. Cross-Reference Corrections

Section 3.3.4 of appendix Y, “Preparing the Battery for Charge Testing,” specifies that the test battery shall be fully discharged for the duration specified in section 3.3.2 of appendix Y, or longer using a battery analyzer. However, DOE's intention was to instruct the user to discharge a test battery not for a set duration but until it reaches the end of discharge voltages listed in Table 3.3.2 of appendix Y. While a battery would be fully discharged with either set of instructions, current instructions would lead to a battery preparation step that is significantly longer. Additionally, there are several instances in appendix Y of which DOE used generic terms such as “specified above” or “noted below”. While these generic reference terms are referring to the test procedure sections immediately preceding or following, identifying the specific referenced sections would improve the test procedure clarity. Therefore, DOE proposes to further clarify these cross-references in appendix Y, and incorporate this same change into proposed appendix Y1, to reduce test burden and avoid potential confusion. To further streamline the readability of appendix Y, DOE also proposes to move the end-of-discharge Table 3.3.2 so that it immediately follows the battery discharge energy test at section 3.3.8.

4. Sub-Section Corrections

Sections 3.3.11(b) and 3.3.12(b) of appendix Y provide instructions for testing the standby and off mode power consumption, respectively, of a battery charger with integral batteries. Section 2.6 of appendix Y describes an integral battery as a battery that is contained within the consumer product and is not removed from the consumer product for charging purposes. Sections 3.3.11(c), 3.3.11(d), 3.3.12(c), and 3.3.12(d) provide instructions applicable to products containing “integrated power conversion and charging circuitry,” which is intended to refer to products with integral batteries for which the circuitry is integrated within the battery charger, in contrast to being integrated within a cradle or an external adapter (as referred to in sections 3.3.11(b) and 3.3.12(b)). To improve the readability of the test procedure and avoid potential confusion as to the applicability of sections 3.3.11(c), 3.3.11(d), 3.3.12(c), and 3.3.12(d) in relation to sections 3.3.11(b) and 3.3.12(b), DOE proposes to reorder these sections of appendix Y such that section 3.3.11(b) would include only the statement that standby mode may also apply to products with integral batteries. The remainder of current section 3.3.11(b), as well as 3.3.11(c) and 3.3.11(d) would be reorganized as subsections (1) through (3) subordinate to section 3.3.11(b), to provide clearer indication that these three subsections refer to three different types of products with integral batteries. The same structure would be applied in section 3.3.12(b) for off mode. This proposed change would also be mirrored in the proposed appendix Y1.

D. Test Procedure Costs and Harmonization

1. Test Procedure Costs and Impact

In this NOPR, DOE proposes to incorporate some editorial changes in the existing test procedure for battery chargers at appendix Y to: (1) Update battery chemistry table to improve representativeness; (2) explicitly refer manufacturers to the test procedure waiver provisions when battery energy cannot be measured; and (3) provide more descriptive designation of the different battery energy and battery voltage values used for determining product class and calculating unit energy consumption. The proposed changes to appendix Y also include minor cross reference corrections and test procedure organization improvements. DOE is also proposing to terminate the existing Dyson test procedure waiver.

Newly proposed appendix Y1 would include all the changes previously listed, as well as: (1) Remove the “wet environment” designation and expand the 5 Wh battery energy limit to 100 Wh for fixed-location wireless chargers; (2) add definitions for “fixed-location” and “open-placement” wireless chargers; (3) introduce a new no-battery mode only test for open-placement wireless chargers; (4) amend the wall adapter selection for chargers that do not come with one; and (5) establish an approach that relies on separate metrics for active mode, standby mode, and off mode, in place of the UEC calculation in appendix Y. DOE has tentatively determined that these proposed amendments would not be unduly burdensome for manufacturers to conduct.

Appendix Y Test Procedure Amendments

The proposals specific to appendix Y would not alter the scope of applicability or the measured energy use of basic models currently certified to DOE. DOE does not anticipate that the proposals specific to appendix Y would cause any manufacturer to re-test any currently covered battery chargers or incur any additional testing costs.

Appendix Y1 Test Procedure Proposal

All the proposals specific to appendix Y1 would not be required to be used until DOE amends energy conservation standards for battery chargers in a future rulemaking and requires battery charger manufacturers to rate their products using appendix Y1. DOE is aware that certain manufacturers may be voluntarily reporting under state programs the energy efficiency as

determined under appendix Y of a limited number of fixed-location wireless chargers that are not currently subject to the DOE test procedure. DOE is not aware of such representations being included in manufacturer literature. Given that such reporting appears limited to state programs and manufacturers are not otherwise making representations of the energy efficiency or energy use of such products, DOE is unable to estimate the extent of such reporting. If the proposed amendments were made final, beginning 180 days following the final rule, were manufacturers to continue such voluntary reporting, any such representations would have to be based on the DOE test procedure as amended. To the extent there is a limited number of models for which manufacturers are making voluntary representations, such models may require re-testing were the proposed amendments finalized. Further details regarding the cost impact of the proposed amendments for when battery charger manufacturers are required to test their products using appendix Y1 are presented in the following paragraphs.

Appendix Y1—Wireless Chargers

The proposal to remove the “wet environment” designation and increase the battery energy limit will increase the scope of the existing battery charger test procedure to include wireless battery chargers other than those with inductive connection and designed for use in a wet environment. DOE has estimated the testing cost associated to test these fixed-location and open-placement wireless chargers in accordance with the proposed test procedures, if finalized. DOE estimates that it would take approximately 48 hours to conduct the test for one fixed-location wireless charger unit and 2.2 hours to conduct the no-battery mode only test for one open-placement wireless charger unit. These tests do not require the wireless charger unit being tested to be constantly monitored by a lab technician. DOE estimates that a lab technician would spend approximately 4.2 hours to test a fixed-location wireless charger unit and one hour to test an open-placement wireless charger unit.

Based on data from the Bureau of Labor Statistics' (“BLS's”) Occupational Employment and Wage Statistics, the mean hourly wage for electrical and electronic engineering technologist and technician is $32.84.
15

DOE also used data from BLS's Employer Costs for Employee Compensation to estimate the percent that wages comprise the total compensation for an employee. DOE estimates that wages make up 70.4 percent of the total compensation for private industry employees.
16

Therefore, DOE estimates that the total hourly compensation (including all fringe benefits) of a technician performing these tests is approximately $46.65.
17

Using these labor rates and time estimates, DOE estimates that it would cost wireless charger manufacturers approximately $196 to conduct a single test on a fixed-location wireless charger unit and approximately $47 to conduct a single test on an open-placement wireless charger unit.
18

15
DOE used the mean hourly wage of the “17-3023 Electrical and Electronic Engineering Technologists and Technicians” from the most recent BLS Occupational Employment and Wage Statistics (May 2020) to estimate the hourly wage rate of a technician assumed to perform this testing.
See www.bls.gov/oes/current/oes173023.htm
. Last accessed on July 22, 2021.

16
DOE used the March 2021 “Employer Costs for Employee Compensation” to estimate that for “Private Industry Workers,” “Wages and Salaries” are 70.4 percent of the total employee compensation.
See www.bls.gov/news.release/archives/ecec_06172021.pdf
. Last accessed on July 22, 2021.

17
$32.84 ÷ 0.704 = $46.65.

18
Fixed-location wireless charger: $46.65 × 4.2 hours = $195.93 (rounded to $196)

Open-placement wireless charger: $46.65 × 1 hour = $46.65 (rounded to $47).

DOE requires that at least two units to be tested for each basic model prior to certifying a rating with DOE. Therefore, DOE estimates that manufacturers would incur testing costs of approximately $392 per fixed-location wireless charger basic model and approximately $94 per open-placement wireless charger basic model, when testing these wireless chargers. However, this proposal to remove the “wet environment” designation and increase the battery energy limit for wireless battery chargers, if finalized, would only be applicable for appendix Y1, and manufacturers would not be required to use appendix Y1 for wireless battery chargers that are not currently covered by appendix Y until DOE amends the energy conservation standards for battery chargers as part of a future rulemaking. DOE will further address the expected costs to industry if and when DOE establishes energy conservation standards for wireless chargers.

Appendix Y1—Wall Adapter Selection

The proposed update to require the use of a minimally compliant power supply selection criteria for battery chargers that are not sold with one ensures that these products are tested in a manner that is representative of actual use in accordance with EPCA. This proposal would not create additional cost or require additional time as compared to the current test procedure, as these battery chargers currently require a low voltage input; this proposal would only specify how the low voltage input must be provided and would not result in additional costs. DOE also anticipates this proposal to impact the measured energy consumption of battery chargers, but only for scenarios where the manufacturer previously certified the product using an EPS that is either not minimally compliant or used a bench power supply and failed to include its energy consumption as part of the battery charger system.

However, the proposed test procedure would only apply to the proposed new appendix Y1, meaning it would not be required for testing until DOE amends energy conservation standards and requires manufacturers to use appendix Y1. Based on DOE's market research, DOE estimates that most battery charger models do not remain on the market for more than four years because of frequent battery charger new model updates and retirement of old models. Therefore, DOE anticipates that most battery chargers required to use appendix Y1 will likely be introduced into the market after this test procedure amendment is finalized.
19

Because of this, DOE does not anticipate that battery charger manufacturers would have to re-test battery charger models that were introduced into the market prior to DOE finalizing this proposed test procedure. Should use of appendix Y1 be required due to amended energy conservation standards, battery chargers introduced prior to this test procedure's finalization would likely no longer be on the market. Battery charger manufacturers using the proposed selection criteria of a power supply would not incur any additional testing costs compared to the current battery charger testing costs. Therefore, battery chargers introduced into the market after DOE finalizes this proposed test procedure, is finalized, have the option to test those models using the proposed selection criteria of a power supply. Any manufacturer seeking to avoid any risk of retesting costs can choose to comply with the propose selection criteria of a power supply earlier. If a manufacturer chooses this option, they would incur the same testing costs when using the proposed selection criteria as they currently incur

and would not have to retest those battery chargers after appendix Y1 is required to comply with future energy conservation standards. DOE will examine the potential retesting costs of manufacturers continuing to test battery charger models that do not use the proposed selection criteria of a power supply in the future energy conservation standard.

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For this cost analysis DOE estimates that the battery charger test procedures will be finalized in 2022. Similarly, amended energy conservation standards, if justified, would be finalized in 2024 with an estimated 2026 compliance date.

Appendix Y1—Modes of Operation

DOE has also estimated the testing costs associated with battery charger testing under the proposed appendix Y1. Removing usage profiles and switching the UEC metric to an active, standby, and off modes separate multi-metric system in appendix Y1 will cause battery charger manufacturers to re-test their products when DOE amends energy conservation standards requiring manufacturers to test their products using appendix Y1. Under appendix Y1, if the manufacturer has (i) already tested and certified the battery charger basic model under the current appendix Y and (ii) still has the original testing data from the appendix Y testing available for standby power calculation, those battery charger basic models would only need to be retested with the active charge energy and discharge tests with additional standby power data analysis. For these battery charger basic models, DOE estimates an extra labor time of 1.5 hours would be needed to set up and analyze the test results.
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Using the previously calculated fully-burdened labor rate of $46.65 per hour for an employee conducting these tests, DOE estimates manufacturers would incur approximately $70 to analyze the test results for these battery chargers. DOE requires at least two units be tested per basic model. Therefore, DOE estimates manufacturers would incur approximately $140 per battery charger basic model for these battery chargers.

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The total additional testing time for conducting the extra active charge energy charge and discharge test can range from 8 hours to 21 hours. However, only 1.5 hours of the total extra testing time would require technician intervention.

Basic models that will either be newly covered under the expanded scope or that are missing the original test data from their appendix Y testing would need to be fully tested under appendix Y1. DOE estimates a total testing time ranging from 43 to 62 hours would be needed, with 4.2 hours of technician intervention required to test each additional battery charger unit. Using the previously calculated fully-burdened labor rate of $46.65 for an electrical technician to conduct these tests, manufacturers would incur approximately $196 per unit. DOE requires at least two units be tested per basic model. Therefore, DOE estimates manufacturers would incur approximately $392 per battery charger basic model to conduct the complete testing under appendix Y1.

All Other Test Procedure Amendments

The remainder of the proposal would add additional detail and instruction to improve the readability of the test procedure. The cross-reference corrections, sub-section corrections and reorganizations also help improve the test procedure readability and clarity without modifying or adding any steps to the test method. As such, these proposals, if finalized, will not result in increased test burden.

DOE requests comment on its understanding of the impact of the proposals presented in this document in relation to test burden, costs, and impact on the measured unit energy consumption of battery charger products. Specifically, DOE requests comment on the per basic model test costs associated with testing battery chargers and wireless chargers to the proposed appendix Y1. DOE also requests comment on DOE's initial assumption that manufacturers would not incur any additional testing burden associated with the proposed changes to appendix Y and the proposed changes regarding the power supply selection criteria in appendix Y1.

2. Harmonization With Industry Standards

DOE's established practice is to adopt relevant industry standards as DOE test procedures unless such methodology would be unduly burdensome to conduct or would not produce test results that reflect the energy efficiency, energy use, water use (as specified in EPCA) or estimated operating costs of that product during a representative average use cycle or period of use. Section 8(c) of appendix A, 10 CFR part 430 subpart C. But where the industry standard does not meet EPCA statutory criteria for test procedures, DOE will make modifications to the DOE test procedure via these standards through the rulemaking process.

The test procedures for battery chargers at 10 CFR part 430, subpart B, appendix Y currently incorporates by reference certain provisions of IEC 62301 (testing equipment and measuring device specifications), IEC 62040 (specifies testing conditions and measurement specifications for uninterruptible power supplies), and ANSI/NEMA WD 6-2016 for uninterruptible power supply plug standards. DOE is proposing to maintain the incorporation of these standards and incorporate these standards in the new appendix Y1.

Different organizations either have developed or are in the process of developing their own test procedures for measuring the wireless charging efficiency of interoperable chargers, including the ANSI/CTA 2042.3, WPC protocol, and the IEC TC 100 TA 15 test method. The WPC protocol provides a ranking of various wireless battery chargers by comparing their relative power transfer efficiencies when a reference receiver is placed on the most optimum charging location. The WPC protocol, however, does not provide an absolute value for a wireless charger's efficiency, and because it currently relies on a small number of reference receivers to represent the entire breadth of real-world loading conditions it may not be representative of actual use. Similarly, ANSI/CTA 2042.3 and IEC TC 100 TA 15 requires receivers to be placed at precise optimal charging locations.

DOE tentatively finds that these approaches are likely to lead to significant repeatability issues. Even a slight variation in alignment between the wireless transmitter and receiver can result in significantly different efficiency measurements. These approaches also require that the receiver be placed at the highest signal strength area, which may not be representative of real-world usage. Furthermore, IEC's test method utilizes 5 reference receivers with 4 different load ratings, requiring a total of 20 tests for a single wireless charger; this creates a total testing time considerably longer than the current DOE test procedure. Due to the potential issues with repeatability, non-representativeness of actual use, and test burden, DOE is not proposing to incorporate the aforementioned industry standards in its test procedure for battery chargers.

DOE recognizes that adopting industry standards with modifications may increase overall testing costs if the modifications needed to meet the conditions under EPCA require different testing equipment or facilities. DOE seeks comment on the degree to which the DOE test procedure should consider and be harmonized further with the most recent relevant industry standards for battery chargers, and whether there are any changes to the Federal test method that would provide additional benefits to the public. DOE also requests comment on the benefits and burdens of, or any other comments regarding adopting any industry/voluntary consensus-based or other appropriate test procedure, without modification.

E. Compliance Date and Waivers

EPCA prescribes that, if DOE amends a test procedure, all representations of energy efficiency and energy use, including those made on marketing materials and product labels, must be made in accordance with that amended test procedure, beginning 180 days after publication of such a test procedure final rule in the
Federal Register
. (42 U.S.C. 6293(c)(2)) To the extent the modified test procedure proposed in this document is required only for the evaluation and issuance of updated efficiency standards, use of the modified test procedure, if finalized, would not be required until the implementation date of updated standards.
See
10 CFR part 430, subpart C, appendix A, section 8(d). Manufacturers are still required to continue testing their battery charger products following the amended appendix Y, if made final, during the meantime. If the proposed appendix Y1 amendments are made final, manufacturers can voluntarily test and report any such representations based on the appendix Y1 test procedure beginning 180 days following the test procedure final rule.

If DOE were to amend the test procedure, EPCA provides an allowance for individual manufacturers to petition DOE for an extension of the 180-day period if the manufacturer may experience undue hardship in meeting the deadline. (42 U.S.C. 6293(c)(3)) To receive such an extension, petitions must be filed with DOE no later than 60 days before the end of the 180-day period and must detail how the manufacturer will experience undue hardship.
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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/fr%3A2021-24367. Public record. Not legal advice.