Energy Conservation Program: Test Procedure for Battery Chargers

Federal RegisterSep 8, 2022

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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:

Final rule.

SUMMARY:

In this final rule, the U.S. Department of Energy (“DOE”) amends the existing test procedures for battery chargers to reorganize certain subsections, clarify symbology and references, correct an incorrect cross reference and section title, update the list of battery chemistries, and terminate an existing test procedure waiver because the covered subject models have been discontinued. This final rule also establishes in new appendix Y1 a new a test procedure for battery chargers that expands coverage to include inductive wireless battery chargers and establishes associated definitions and test provisions; establishes a new test procedure approach that relies on separate metrics for active mode, standby mode, and off mode; and updates the EPS selection criteria. The new test procedure Y1 will be used for the evaluation and issuance of updated efficiency standards, as well as to determine compliance with the updated standards, should such standards be established.

DATES:

The effective date of this rule is October 11, 2022. The amendments to the current test procedure will be mandatory for product testing starting March 7, 2023. Manufacturers will be required to use the amended test procedure in appendix Y until the compliance date of any final rule establishing amended energy conservation standards based on the newly established test procedure in appendix Y1. At such time, manufacturers will be required to begin using the newly established test procedure in appendix Y1.

The incorporation by reference of certain materials listed in this rule is approved by the Director of the Federal Register on October 11, 2022.

ADDRESSES:

The docket, which includes

Federal Register

notices, public meeting attendee lists and transcripts, 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, not all documents listed in the index may be publicly available, such as those containing information that is exempt from public disclosure.

A link to the docket web page can be found at

www.regulations.gov/docket/EERE-2020-BT-TP-0012.

The docket web page contains instructions on how to access all documents, including public comments, in the docket.

For further information on how to review the docket contact the Appliance and Equipment Standards Program staff at (202) 287-1445 or by email:

ApplianceStandardsQuestions@ee.doe.gov.

FOR FURTHER INFORMATION CONTACT:

Mr. Jeremy Dommu, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Office, EE-2J, 1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone: (202) 586-9870. Email:

ApplianceStandardsQuestions@ee.doe.gov.

Mr. Nolan Brickwood, U.S. Department of Energy, Office of the General Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone: (202) 586-5709. Email:

Nolan.Brickwood@hq.doe.gov.

SUPPLEMENTARY INFORMATION:

DOE incorporates by reference the following industry standards into 10 CFR part 430:

ANSI/NEMA WD 6-2016, “Wiring Devices—Dimensional Specifications;”

IEC 62040-3 Ed. 2.0, “Uninterruptible power systems (UPS)—Part 3: Method of specifying the performance and test requirements, Edition 2.0, 2011-03;”

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

Copies of ANSI/NEMA WD 6-2016 can be obtained from the American National Standards Institute, 25 W 43rd Street, 4th Floor, New York, NY 10036, (212) 642-4900,

webstore.ansi.org.

Copies of IEC 62040-3 Ed.2.0 and 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.

, and is available from the American National Standards Institute, 25 W 43rd Street, 4th Floor, New York, NY 10036, (212) 642-4900, or go to

webstore.ansi.org

For a further discussion of these standards, see section IV.N. of this document.

Table of Contents

I. Authority and Background

A. Authority

B. Background

II. Synopsis of the Final Rule

III. Discussion

A. Scope of Applicability

1. Battery Chargers

2. Inductive Wireless Battery Chargers

B. Test Procedure

1. Wireless Charger Test Procedure

2. External Power Supply Selection

3. Battery Chemistry and End-of-Discharge Voltages

4. Battery Selection

5. Mode-Specific Metrics

6. Active Mode Test

7. Standby Mode Tests

8. Non-Battery-Charging Related Functions

C. Corrections and Non-Substantive Changes

1. Certification Flowcharts

2. Testing and Certification Clarifications

3. Cross-Reference Corrections

4. Sub-Section Corrections

D. Effective and Compliance Dates

E. Test Procedure Costs

IV. Procedural Issues and Regulatory Review

A. Review Under Executive Orders 12866 and 13563

B. Review Under the Regulatory Flexibility Act

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. Congressional Notification

N. Description of Materials Incorporated by Reference

V. Approval of the Office of the Secretary

I. Authority and Background

Battery chargers are included among the consumer products for which the U.S. Department of Energy (“DOE”) is authorized to establish and amend energy conservation standards and test procedures. (42 U.S.C. 6295(u)(1)) 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”),

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

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. Battery chargers, the subject of this final rule, are products included in the Energy Policy Conservation Program. (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), which reflect the last statutory amendments that impact Parts A and A-1 of EPCA.

For editorial reasons, upon codification in the U.S. Code, Part B was redesignated 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), the authority to require information and reports from manufacturers (42 U.S.C. 6296).

The 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 under EPCA (42 U.S.C. 6295(s)), and (2) making other representations about the efficiency of those products (42 U.S.C. 6293(c)). Similarly, DOE must use these test procedures to determine whether the products comply with any 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 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, as determined by the Secretary, and shall not be unduly burdensome to conduct. (42 U.S.C. 6293(b)(3))

EPCA also requires that DOE evaluate test procedures for each type of covered product, including battery chargers, 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 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 and to not be unduly burdensome to conduct. (42 U.S.C. 6293(b)(1)(A); 42 U.S.C. 6293(b)(3))

Additionally, EPCA requires DOE to amend its test procedures for all covered products to include standby mode and off mode energy consumption, with standby mode and off mode energy consumption integrated into the overall energy efficiency, energy consumption, or other energy descriptor unless the Secretary determines that (i) the current test procedures already fully account for and incorporate the standby mode and off mode energy consumption, or (ii) such an integrated test procedure is technically infeasible for a particular covered product. (42 U.S.C. 6295(gg)(2)(A);

see also

42 U.S.C. 6295(u)(1)(B)(i))) If an integrated test procedure is technically infeasible, DOE must prescribe separate standby mode and off mode energy use test procedures, if separate tests are technically feasible. (

Id.

) Any such amendment must consider the most current versions of the International Electrotechnical Commission (IEC) Standard 62301

and IEC Standard 62087

as applicable. (

Id.

)

IEC 62301,

Household electrical appliances—Measurement of standby power

(Edition 2.0, 2011-01).

IEC 62087,

Audio, video and related equipment—Methods of measurement for power consumption

(Edition 1.0, Parts 1-6: 2015, Part 7: 2018).

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.

Id.

DOE is publishing this final rule 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 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 since the last test procedure update that may necessitate amending the test procedure for battery chargers. 85 FR 26369, 26370. DOE specifically solicited feedback on possible approaches to testing inductive wireless battery chargers not designed for use in a wet environment. 85 FR 26369, 26371. DOE requested comment on the characteristics of the EPSs typically used by manufacturers for testing and certification purposes for battery charger products that require an EPS but do not come prepackaged with one, and the characteristics of the EPS used by consumers in real-world settings.

Id.

DOE also requested comment on whether using a reference EPS 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.

On November 23, 2021, DOE published a notice of proposed rulemaking (“November 2021 NOPR”), in which DOE responded to comments received in response to the May 2020 RFI and proposed amendments to the test procedures for battery chargers in appendix Y and in a new appendix Y1. 86 FR 66878. DOE's proposed amendments to appendix Y included reorganizing two subsections, clarifying symbology and references, correcting an incorrect cross reference and section title, updating the list of battery chemistries, and terminating an existing test procedure waiver because the

covered subject models have been discontinued. 86 FR 66878, 66881, 66885-66886, 66889-66894.

DOE also proposed to establish a new appendix Y1 that, in addition to the changes proposed for appendix Y, would expand the scope of the test procedure to include inductive wireless battery chargers beyond those designed and manufactured to operate in a wet environment (removing that distinction altogether), increase the rated battery energy limit of fixed location wireless chargers in appendix Y1 from ≤5 Wh to ≤100 Wh, establish associated definitions for fixed-location wireless chargers and open-placement wireless chargers and corresponding test provisions; establish a new test procedure approach that relies on separate metrics for active mode, standby mode, and off mode (consequently removing the battery charger usage profiles and single-metric unit energy consumption calculation); and update the EPS selection criteria. 86 FR 66878, 66881, 66883-66885, 66887-66889.

On January 7, 2022, DOE published an extension of the comment period in response to a joint request submitted by some stakeholders.

87 FR 890.

The joint request was submitted by the Association of Home Appliance Manufacturers, Consumer Technology Association, Information Technology Industry Council, National Electrical Manufacturers Association, Outdoor Power Equipment Institute, Plumbing Manufacturers Institute, and Power Tool Institute. Comment no. EERE-BT-2020-TP-0012-0017 (available at

www.regulations.gov/comment/EERE-2020-BT-TP-0012-0017

DOE received comments in response to the November 2021 NOPR from the interested parties listed in Table II.1.

Table II.1—List of Commenters With Written Submissions in Response to the November 2021 NOPR

Commenter(s)

Reference in

this final rule

Document No.

in docket

Commenter type

American Honda Motor Co., INC

Honda

Manufacturer.

Appliance Standards Awareness Project, American Council for an Energy-Efficient Economy, Consumer Federation of America, Natural Resources Defense Council

Joint Efficiency Advocates

Efficiency Organizations.

Association of Home Appliance Manufacturers, Outdoor Power Equipment Institute, Power Tool Institute, Inc

Joint Trade Associations

Trade Associations.

California Investor-Owned Utilities (Pacific Gas and Electric Company, San Diego Gas and Electric, Southern California Edison)

CA IOUs

Utilities.

CSA Group

CSA

Efficiency Organization.

Delta-Q Technologies

Delta-Q

Manufacturer.

Information Technology Industry Council

ITI

Trade Association.

Northwest Energy Efficiency Alliance

NEEA

Efficiency Organization.

Schumacher Electric Corporation

Schumacher

Manufacturer

STIHL

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.

The parenthetical reference provides a reference for information located in the docket of DOE's rulemaking to develop test procedures for battery chargers. (Docket No. EERE-2020-BT-TP-0012, which is maintained at

www.regulations.gov

). The references are arranged as follows: (commenter name, comment docket ID number, page of that document).

II. Synopsis of the Final Rule

In this final rule, DOE amends appendix Y by adopting the proposed test procedure changes as follows:

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

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

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

(4) Corrects a cross-reference and a table title, further clarifies certain references and terminologies, and reorganizes certain subsections for improved readability.

DOE is also adopting the proposed new appendix Y1, which would generally require that testing be conducted as provided in appendix Y as amended in this final rule, but with the following additional changes:

(1) Establishing definitions associated with inductive wireless power transfer, and differentiating between wireless chargers 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) to the transmitter and those that do not (“open-placement” wireless chargers);

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

(3) Removing the unit energy consumption (“UEC”)

calculations and usage profiles and instead relying on separate metrics for active mode, standby mode, and off mode using E

, P

, and P

off

, respectively, as measured by the newly established appendix Y1; and

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) Specifying EPS selection priority and amending selection requirements for battery chargers that do not ship with an EPS and for which one is not recommended by the manufacturer.

Manufacturers would not be required to test according to appendix Y1 until such time as compliance is required with any amended energy conservation standards for battery chargers established after September 8, 2022.

The adopted amendments are summarized in Table II.1 compared to the test procedure provision prior to the amendment, as well as the reason for the adopted change.

Table II.1—Summary of Changes in the Amended Test Procedure

Current DOE

test procedure

Amended

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

Increases the 5 Wh limit to 100Wh and replaces 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 adds 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 EPS selection priority for chargers that do have associated EPSs. 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 EPS selection order priority and removes the 5.0V DC input criteria. For battery chargers that do not ship with an EPS and do not have a recommended adapter, requires that the charger be tested using an EPS 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 conventions

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

, P

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 a representative measure of 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.

Uses the term “wall adapters” to refer to external power supplies, which is inconsistent with certification requirements and reporting templates

Changes the “wall adapter” terms to more technically correct term of “EPSs”

Appendix Y and Appendix Y1

To improve readability.

Definition of “C-Rate” does not provide a straightforward translation between charge or discharge rate and charge or discharge time

Adds clarification that a 0.2 C-Rate would translate to a charge or discharge period of 5 hours

Appendix Y and Appendix Y1

To improve readability.

DOE has determined that the amendments to appendix Y described in section III and adopted in this document will not alter the measured efficiency of battery chargers, or require retesting or recertification solely as a result of DOE's adoption of the amendments to the test procedure at appendix Y. Additionally, DOE has determined that the amendments will not increase the cost of testing under appendix Y.

DOE has determined that the newly established appendix Y1, which specifies testing with a minimally compliant EPS, increases scope of wireless chargers, and removes 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, testing in accordance with the newly established appendix Y1 would not be required until such time as compliance is required with new and amended energy conservation standards, should DOE establish such standards. Additionally, DOE has determined that testing under appendix Y1 would not increase the cost of testing as compared to testing under appendix Y. Discussion of DOE's actions are addressed in detail in section III of this document.

The effective date for the amended test procedures adopted in this final rule is 30 days after publication of this document in the

Federal Register

. Representations of energy use or energy efficiency must be based on testing in

accordance with the amended appendix Y test procedures beginning 180 days after the publication of this final rule. Manufacturers will be required to certify compliance using the new appendix Y1 test procedure beginning on the compliance date of any final rule published after the effective date of this final rule that establishes amended energy conservation standards for battery chargers.

III. Discussion

In this battery chargers test procedure final rule, DOE is amending appendix Y and establishing a new appendix Y1 as described throughout the following sections.

EPCA requires DOE to review the test procedure for battery chargers at least once every 7 years and to determine whether amendments to the test procedure would more accurately or fully comply with the requirements for test procedures to be reasonably designed to produce representative test results without undue burden. (42 U.S.C. 6293(b)(1)(A)) In response to the November 2021 NOPR, the Joint Trade Associations stated that DOE proposed several changes that improve the clarity but not representativeness of the test procedure and urged DOE to prioritize other rulemakings. (Joint Trade Associations, No. 24 at p. 1) DOE reiterates that it is undertaking this rulemaking pursuant to the periodic review required by EPCA. As discussed in the following sections, DOE has determined that appendix Y, as amended in this final rule, and appendix Y1 as established in this final rule, more accurately and fully comply with the requirements in EPCA for test procedures to be reasonably designed to produce representative test results without undue 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. (42 U.S.C. 6291(32); 10 CFR 430.2) 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.

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

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 (“V”) 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.

The CA IOUs stated in their comment responding to the November 2021 NOPR that new consumer products powered by batteries require more power, and therefore current battery chargers are more powerful than when DOE initially developed its battery charger standard and test procedure. (CA IOUs, No. 25 at p. 7) These more powerful battery chargers, they claimed, offer larger energy savings potential through energy efficiency standards.

Id.

CA IOUs therefore recommended that DOE clarify the scope of the test procedure, and expand it to cover battery chargers that can operate on either 115V or 230V AC voltage levels. (CA IOUs, No. 25 at p. 7) CA IOUs noted that US residences typically offer AC electricity at both 115V and 230V at 60Hz and that modern battery chargers may be designed for either voltage, and therefore DOE should expand the test procedure to include both voltage levels.

Id.

DOE notes that AC line voltage for common household electrical outlets in the United States is typically limited to 115V

at 60Hz for residential environments, with specialized 230V 60Hz AC line voltage outlets reserved for limited number of heavy-duty applications such as clothes washers, dryers, and electric cooking products. While battery chargers with universal inputs exist (

i.e.,

that support a range of 115V to 230V as input voltage), such products support 230V generally only to facilitate travel outside of the United States without the need for a travel adapter. These products, when used within the United States, operate at 115V and therefore should be tested as such. The scope of the test procedure includes any battery charger capable of operating at either DC or United States AC line voltage without regard to whether it is also capable of operating at other voltages.

DOE refers to AC line voltage here as 115V, recognizing that United States line voltage is also often referred to as 120V or 110V in some contexts.

The CA IOUs further requested that DOE clarify the extent of DOE's authority on automobile chargers and other products. (CA IOUs, No. 25 at p. 7) CA IOUs stated that DOE possessed the authority to regulate battery chargers embedded in consumer products, and therefore DOE could regulate chargers embedded in automobiles even if DOE cannot regulate the efficiency of electric vehicles themselves.

Id.

CA IOUs asked DOE to clarify its authority under EPCA to set standards for chargers embedded in automobiles, both those that charge other consumer products and those that charge the automobile's internal battery.

Id.

NEEA also encouraged DOE to cover electric vehicle (“EV”) chargers under the test procedure scope, stating that market data and policy trends illustrate the need for EV charger efficiency standards. (NEEA, No. 27 at p. 10) NEEA noted there are three types of energy losses associated with EV charging, and that consumers are paying for these energy losses as though the lost energy were gasoline leaking from the hose as a tank is filled. (NEEA, No. 27 at p. 10) NEEA further suggested that because public policy and market designs are not focusing on promoting higher efficiency charging, EV chargers focus on lower cost and lower weight, and that even small efficiency differences from standards could have large nationwide impacts. (NEEA, No. 27 at p. 11)

DOE notes, however, that due to the definition of battery chargers in EPCA, DOE's authority to regulate battery chargers extends only to battery chargers that charge batteries for consumer products. (42 U.S.C. 6291(32)) As defined by EPCA, “consumer products” statutorily excludes automobiles. (42 U.S.C. 6291(1)) Regardless, DOE further notes that its test procedure for battery chargers as established in appendix Y (and newly established appendix Y1) cannot be adapted to measure the energy performance of battery chargers designed to charge electric vehicles without significant modifications that were not proposed in the November 2021 NOPR. Therefore, in this final rule DOE clarifies that this battery charger test procedure does not provide a method for testing electric vehicle battery chargers, and they remain outside the test procedure's scope.

Finally, CA IOUs requested clarification regarding whether chargers used by (i) electric trucks, E-bikes, electric motorcycles, electric boats, and other consumer electric vehicles that are not automobiles; (ii) aerial drones and other battery-powered, remotely operated devices marketed to consumers; (iii) battery-powered electric riding lawn mowers and walk-behind lawnmowers sold to consumers; and (iv) battery chargers commonly referred to as “DC fast chargers” or “Level 3 chargers” (

e.g.,

Wallbox and SETEC) that are not embedded in electric automobiles but are designed to charge batteries in electric automobiles by bypassing the on-board battery charger. (CA IOUs, No. 25 at p. 7)

A manufacturer is best positioned to know the nuances of their model's characteristics and design, which impact how regulations apply. DOE however notes that most battery chargers intended for use with consumer electronics, including E-bikes, aerial drones and lawn mowers are in scope of the battery charger test procedure. While DOE cannot comment on the test procedure's applicability to all the battery chargers for a specific end-use product group, DOE suggests inquiring with the department directly for clarifications on a case-by-case basis.

2. Inductive Wireless Battery Chargers

DOE's current energy conversation standards for battery chargers were established in a final rule 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 under the test procedure in appendix Y.

Id.

In the November 2021 NOPR, DOE proposed to define fixed-location wireless chargers and open-placement wireless chargers in a new appendix Y1 to include these chargers within the scope; and to expand the scope of the proposed appendix Y1 test procedure to cover testing of fixed-location wireless chargers in all modes of operation, as well as testing of open-placement wireless charger in no-battery mode only. 86 FR 66878, 66882-66884. DOE proposed 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. DOE then proposed 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). DOE proposed to remove the “wet environment” products distinction for wireless chargers, as a result of these changes. 86 FR 66878, 66883.

ITI, the Joint Efficiency Advocates, the Joint Trade Associations, the CA IOUs, NEEA, and Delta-Q expressed general support for DOE's proposed approach to expand the scope in appendix Y1 to remove the wet environment definition and to classify and cover both fixed-location and open-placement wireless chargers. (ITI, No. 20 at p. 2; Joint Efficiency Advocates, No. 23 at pp. 1-2; Joint Trade Associations, No. 24 at p. 8; CA IOUs, No. 25 at pp. 2-3; NEEA, No. 27 at pp. 4-6; Delta-Q, No. 28 at p. 1) However, NEEA urged DOE to adopt technology-neutral definitions for wireless chargers rather than specifying only an inductive connection, to allow future products to be tested and considered under the test procedures regardless of specific product technology used (citing inductive, magnetic resonant, radio frequency as examples) and allow free competition to deliver wireless charging without restriction by technology specific test procedures. (NEEA, No. 27 at pp. 6-7) Instead, NEEA recommended a definition for wireless chargers that defines wireless chargers as those chargers that transmit energy without a wired connection to a receiving device. (NEEA, No. 27 at p. 7) DOE notes that other wireless charging methods beyond those addressed in appendix Y and new appendix Y1 are still nascent and lack widespread availability in the market. Defining such technologies and addressing them in the test procedure at this time could potentially restrict the development of these less mature technologies.

DOE proposed in the November 2021 NOPR to cover fixed-location wireless chargers, having tentatively determined that the physical receiver locating feature would allow accurate and repeatable relative receiver alignment or orientation. 86 FR 66878, 66883. NEEA noted that DOE's proposal for fixed-location wireless chargers addresses the technical challenges associated with physical displacement of the transmitter and receiver, and that wireless charger efficiency depends on the product's horizontal and vertical displacement from the transmitter but that fixed-location charger's magnetic or physical guides ensure proper and consistent positioning. (NEEA, No. 27 at 6). ITI suggested that DOE clarify in its definition that fixed-location wireless chargers should be able to align or orient the receiver position in both vertical and horizontal orientations through the receiver locating feature, whereas open-placement chargers do not incorporate a physical receiver locating feature. (ITI, No. 20 at pp. 1-2) ITI further inquired whether a wireless charger that relies on LED or another form of indication to indicate correct placement in lieu of physical locating features, would be considered as an open-placement one. (ITI, No. 20 at p. 2)

DOE concludes that the definition as proposed, specifying that the locating feature should “repeatably align or orient the position of the receiver with respect to the transmitter”, to be sufficiently specific without respect to whether such alignment is in the vertical or horizontal (or any other) position. DOE finds that this specification in the definition sufficiently minimizes test to test variation without prescribing additional design constraints. In cases where the charger only employs indication of correct placement, such as by visual indication or audio indication, but does not have physical locating features that ensures repeatable alignment or orientation, DOE notes that relative receiver placement can still vary ever so slightly for such chargers, which causes variation in active mode testing. Therefore, such wireless charger would still be considered as open-placement wireless charger because of the lack of locating feature that can “repeatably align or orient the position of the receiver with respect to the transmitter.”

NEEA stated that for future fixed-location wireless chargers able to charge a variety of products (interoperable fixed-location chargers), different

receiver-battery combinations could result in efficiency differences. (NEEA, No. 27 at p. 6) NEEA suggested that DOE either address these chargers with an active mode test procedure waiver, or further specify that these chargers must be tested with a manufacturer-specified range of receivers but not other products that use the same power transfer standard. (

Id.

) The CA IOUs referred DOE to WPC's comment that fixed-location wireless chargers risk efficiency variations for different receivers, which prevents WPC from releasing a receiver-independent active mode power transfer efficiency metric. (CA IOUs, No. 25 at p. 5) The CA IOUs encouraged DOE to continue to measure performance and regulate fixed-location wireless charging systems under the current approach, and suggested that DOE require combinations of new receiver devices used in conjunction with previous wireless charger models to meet the minimum efficiency requirement. (

Id.

) The CA IOUs further encouraged DOE to clarify that if a change in receiver were to reduce efficiency beyond a nominal threshold for a particular fixed-location wireless charger, then it should be regulated as a new basic model. (

Id.

)

DOE notes that the definitions of “fixed-location wireless charger” and “open-placement wireless charger” proposed in the November 2021 NOPR and adopted in this final rule indicate that the term “wireless battery charger” encompasses both the transmitter (

i.e.,

the charging mat, for example) and the receiver (

i.e.,

the end-use product containing the battery). Neither the transmitter nor the receiver on its own constitutes a “battery charger.” As such, each combination of transmitter and receiver

that has different electrical, physical, or functional characteristics that affect energy consumption would be considered a different basic model and would be required to be certified accordingly.

DOE further notes that applicable to transmitters that can accommodate multiple receivers or batteries, only the manufacturer recommended combinations are tested.

See

section 3.1.4(b) of appendix Y and appendix Y1 as finalized, which specifies testing battery chargers with an EPS recommended by the manufacturer.

ITI further suggested that although ITI is unaware of any type of wireless chargers other than fixed-location or open-placement wireless chargers, DOE should leave open the possibility that future wireless chargers may not fall into either fixed-location or open-placement wireless chargers. (ITI No. 20 at p. 2) DOE agrees with ITI that all current wireless chargers would fall in either fixed-location wireless charger or open-placement wireless charger category. As such, the adopted fixed-location and open-placement wireless charger definitions would capture the current wireless charger market accurately. DOE will make thorough reviews of the battery charger test procedure, should new charger types mature in the market.

The Joint Trade Associations, noting that they support maintaining the UEC approach, also suggested DOE add Table 3.3.3 to a UEC-compatible version of appendix Y1 so that Product Class 1 is preserved with lower battery energy limits, and a new Product Class 1A can be established for higher battery energy inductive chargers. (Joint Trade Associations, No. 24 at p. 8) The Joint Trade Associations stated that it would be appropriate to separate wireless chargers from wired chargers under this approach, and further suggested DOE would need to account for the expanded scope and create a new Product Class 1A for higher energy inductive chargers. (

Id.

) DOE notes that DOE is adopting the proposed multi-metric approach, and under the multi-metric approach, DOE does not need to further separate product classes, as the testing method and calculation steps for determining the tested values are the same for battery chargers in all product classes. To the extent that consideration of different product classes may be warranted, DOE would do so in a future energy conservation standards rulemaking.

ITI inquired as to the applicability of standards to a product that can take either wired or wireless charging; and the applicability of standards to a wireless charger shipped without an end use device. (ITI, No. 20 at p. 6) As stated earlier, different wired/wireless charger and end use product/battery combinations could result in different charging efficiencies. Therefore, they would constitute different battery charger models and would need to be tested and certified separately. DOE notes that manufacturers have already been certifying products in this way under the current test procedure. Furthermore, under the new appendix Y1 test procedure if a consumer product can accept charge either wired or wirelessly, each charging configuration would also need to be tested and certified separately.

The CA IOUs supported DOE expanding coverage to “combination products” with integrated wireless chargers such as bedside or desk lamps, clocks, and furniture that has built in wireless chargers. (CA IOUs, No. 25 at pp. 5-6) The CA IOUs suggested that these products are currently not covered under DOE's battery charger test procedure and are expected to significantly displace DOE-regulated battery chargers in some product classes.

Id.

The CA IOUs stated that they are analyzing combination products and recommended DOE establish clear definitions for combination products to clarify what combination products are not covered by DOE's test procedures and standards, so that they can be covered under other energy efficiency regulations or guidelines such as CEC Low Power Mode Roadmap.

(CA IOUs, No. 25 at pp. 5-6) The Joint Efficiency Advocates encouraged DOE to expand the no-battery mode only test coverage to include dual-purpose open-placement chargers such as alarm clocks and table lamps with embedded wireless chargers, because they are becoming increasingly common. (Joint Efficiency Advocates, No. 23 at p. 2)

CEC Low Power Road Map is available on

www.energy.ca.gov/rules-and-regulations/appliance-efficiency-regulations-title-20/appliance-efficiency-proceedings-6.

DOE's definition for battery charger includes battery chargers embedded in other consumer products. 10 CFR 430.2. For combination products that have multiple functions, if they do come with a battery charger, then the battery charging component of the combination product would still need to be tested under DOE's battery charger test procedure.

The Joint Trade Associations stated that there was some confusion in DOE's proposal for expanded wireless chargers in appendix Y1, as they noted the preamble proposed a change to Product Class 1 in appendix Y1 to include all fixed-location wireless chargers, but that this change was not present in the regulatory text, and the proposed regulatory text for Table 3.3.3 of appendix Y shows a measured battery energy of 20Wh, a value not discussed anywhere in the preamble. (Joint Trade Associations, No. 24 at p. 8) DOE notes that the reference to 20 Wh in the proposed regulatory text for appendix Y was an error and has been corrected to 5 Wh for this final rule.

In the November 2021 NOPR, DOE proposed to increase the rated battery energy limit of fixed-location wireless chargers in appendix Y1 from ≤5 Wh to 100 Wh. 86 FR 66878, 66883. At the time of the June 2016 Final Rule, all inductive wireless chargers designed for use in wet environments (the prior scope of coverage) had a battery energy under 5 Wh.

Id.

In discussion of the increased limit in the November 2021 NOPR and in light of the removal of the wet environment distinction, DOE stated that it had 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 80 Wh, namely inductively charged power tool products.

Id.

The expansion of the limit to 100 Wh was made to accommodate potential future product designs that may have larger battery energies.

Id.

In their response to the November 2021 NOPR, NEEA noted that wireless charging for consumer products is already commonplace and continued growth is expected, along with substantially increased energy use. (NEEA, No. 27 at p. 4) ITI and the Joint Trade Association supported the proposal to expand the scope to include those with battery energies up to 100Wh. (ITI, No. 20 at p. 2, Joint Trade Associations, No. 24 at p. 8)

WPC stated that wireless chargers (referred to as “wireless power transmitters” by WPC) should be categorized as external power supplies (“EPSs”) because they can power devices without batteries. (WPC, No. 22 at p. 1) WPC stated that although they believe wireless chargers should be tested as EPSs with appropriate resistive loads, the usage profile is very different from wired chargers, and they are more frequently used for “top-ups”. (WPC, No. 22 at pp. 1-2)

In the November 2019 NOPR, the department acknowledged that open-placement wireless chargers are sometimes designed to work with third party products, some of which may not be battery operated. DOE's research of the marketplace however shows that the vast majority of these third-party applications continue to be primarily reliant on battery power, with power received from an open-placement charger used to charge that battery. This conclusion is reasonable, considering the inherent limitation in the distance across which wireless power can be transmitted. As such, DOE maintains that the revised battery charger test procedure is appropriate for capturing the energy performance of open-placement wireless chargers in no-battery mode. With regards to WPC's comment that wireless chargers should be measured with resistive loads, DOE notes that testing with a load is only relevant for active mode testing, which DOE did not propose for the reasons stated in section III.B.1 of this final rule. For the reasons discussed in the preceding paragraphs and in the November 2021 NOPR, DOE is adopting the proposals made in the November 2021 NOPR to establish definitions for both fixed-location wireless chargers and open-placement wireless chargers, to increase the rated battery energy limit for fixed-location inductive chargers from <5 Wh to <100 Wh, and, as discussed below to expand the test procedure's scope to cover testing open-placement wireless chargers in no-battery mode only.

B. Test Procedure

1. Wireless Charger Test Procedure

In the November 2021 NOPR, DOE proposed to expand the scope of the proposed appendix Y1 test procedure to cover testing of fixed-location wireless chargers in all modes of operation, and to cover testing of open-placement wireless charger in no-battery mode only. 86 FR 66878, 66882-66884.

The CA IOUs further recommended that DOE collaborate with industry and standards organizations to develop a suitable method of measurement for active mode power for interoperable open placement chargers, such as the approach proposed by WPC that measures active mode power consumption at several key locations on the charging device. (CA IOUs, No. 25 at p. 3) The CA IOUs modeled the savings potential from applying potential standby and active mode power regulations to inductive battery chargers. (CA IOUs, No. 25 at pp. 3-4) The CA IOUs estimated the lifetime unit energy savings from regulating standby mode to be about 1.4 GWh for 5 years of shipments. (

Id.

) The CA IOUs estimated the lifetime unit energy savings from regulating active mode to be about 60 GWh for 5 years of shipments. (

Id.

)

NEEA supported the development of a standby test method for open-placement wireless chargers using International Electrotechnical Commission (IEC) 62301 in appendix Y1 and encouraged DOE to continue developing an active mode test procedure with industry. (NEEA, No. 27 at 6). NEEA further recommended that DOE in the interim retain a placeholder for future active mode or other low power mode testing of open-placement wireless chargers. (NEEA, No. 27 at pp. 6-7). WPC agreed that no appropriate active mode test can be prescribed for open-placement wireless chargers yet, because of varying receiver efficiency and the capability for one open placement charger to simultaneously charge multiple receivers. (WPC, No. 22 at p. 1) However, WPC noted that covering only fixed-location wireless chargers in the active mode test procedures can discourage manufacturers from choosing more efficient fixed-location wireless charger designs. (WPC, No. 22 at pp. 1-2) WPC recommended that DOE extend the no-battery only test to fixed-location chargers designed for receivers that can take open-placement chargers as well (for example, exclude certain wireless charging stands and specific in-car wireless chargers from the active charging test). (WPC, No. 22 at pp. 1-2)

DOE acknowledges the difficulty in establishing a repeatable and representative open-placement wireless charger (including interoperable open-placement wireless charger) test procedure for active mode. As stated in the November 2021 NOPR, 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. 86 FR 66884. 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.

Id.

Based on further evaluation and consideration of the comments received, DOE concludes that a representative and repeatable test procedure for measuring the active mode energy performance of open-placement wireless chargers cannot be prescribed at this time without undue burden. 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. WPC stated that fixed-placement does not necessarily mean battery charger, because the battery management and control circuitry are often placed in the wireless receiver. (WPC, No. 22 at p. 3) WPC agreed that the present “interoperable” wireless charger (regardless of open-placement or fixed-location) efficiency testing method is not representative of real-world performance and is likely not repeatable. WPC stated that to make such a test method repeatable would require a placement coordinate table that moves the receiver in 1mm increments within the charging area, developing accurate user placement models, and limiting the receiver to one specific product design. (

Id.

)

For fixed-location wireless battery chargers that can work with multiple end use products, each different wireless charger and end use product/battery combinations could result in different charging efficiencies, therefore, they would constitute as different battery charger models and would need to be tested and certified separately. DOE notes that manufacturers have already been certifying products in this way under the current test procedure. As for open-placement wireless chargers, DOE notes that for even a relatively small wireless charging coil of 30 by 30 square millimeters, to accurately and repeatably capture the overall active mode energy consumption by moving the relative receiver placement in 1mm increments, as described by WPC, would result in 900 iterations. Even if the technician were to measure the efficiency differences across 5mm or 10mm increments, it would still result in dozens of repeated active mode tests, which adds significant undue burden to the test procedure. Additionally, because of the open-placement wireless charger design, it would be virtually impossible to develop representative relative receiver placement models. Therefore, DOE reiterates that a representative and repeatable test procedure for measuring the active mode energy performance of open-placement wireless chargers cannot be prescribed at this time without undue burden.

WPC further suggested that the name for open-placement chargers “no-battery mode” test should be changed to “no receiver mode”. (WPC, No. 22 at p. 2) DOE notes that wirelessly charged devices usually have batteries and receiving circuitry built-in the device; therefore, batteries and receivers cannot be separated without tearing down the product. To maintain test mode language consistency, DOE is not changing the “no-battery mode” designation.

DOE appreciates the remainder of WPC's comments and notes that this final rule establishes only a test procedure and not energy conservation standards for fixed-location wireless chargers. DOE does not believe simply providing a method for testing the efficiency of these technologies without a corresponding energy conservation standard would impact manufacturer's design choices.

In this final rule, DOE is finalizing its proposal from the November 2021 NOPR to test fixed-location wireless chargers in all modes of operation, and to capture the no-battery mode energy performance of open-placement wireless chargers in the new appendix Y1. DOE is also adopting the proposal to leave a placeholder section in the new appendix Y1 to be reserved for a potential active mode test procedure for open-placement wireless chargers.

2. External Power Supply Selection

Most battery chargers require the use of an EPS to convert 115-volt (“V”) AC line voltage into a low-voltage DC or AC output suitable for powering the battery charger. DOE's current battery charger test procedure specifies that the battery charger be tested with the EPS packaged with the charger, or the EPS that is sold or recommended by the manufacturer. If an EPS is not packaged with the charger, or if the manufacturer does not sell or recommend an EPS, 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 an EPS or sell or recommend an EPS. 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.

To resolve this issue and improve test procedure representativeness and test results comparability, in the November 2021 NOPR DOE proposed to require in appendix Y1 that when an EPS 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 (i) minimally compliant with DOE's energy conservation standards for EPS found in 10 CFR 430.32(w) and (ii) satisfies the EPS output criteria specified by the battery charger manufacturer. 86 FR 66878, 66885. DOE further proposed that if the certified EPS is no longer available in the market, then for DOE's compliance and enforcement testing DOE would test the battery charger with any compatible minimally compliant EPS that meets the performance criteria.

Id.

Additionally, in appendix Y1, DOE proposed to clarify the EPS selection priority when one is provided or recommended, to maintain test procedure repeatability.

Id.

In response to these proposals regarding EPSs, DOE received several comments. Schumacher suggested DOE allow manufacturers describe the recommended EPSs in their user manuals for customers' reference and that such recommendations direct the use of an EPS when testing a battery charger that does not ship with one. (Schumacher, No. 21 at p. 5) ITI asked DOE to clarify whether the “minimally compliant EPS” language simply means any compliant EPS, currently level VI, and nothing more. (ITI, No. 20 at p. 2) Both the Joint Efficiency Advocates and NEEA suggested DOE further specify the efficiency range for these minimally compliant EPSs to improve reproducibility and maintain a level playing field. (Joint Efficiency Advocates, No. 23 at p. 2; NEEA, No. 27 at pp. 9-10) WPC and the CA IOUs recommended DOE prescribe a standardized EPS when none is recommended. (WPC, No. 22 at p. 2; CA IOUs, No. 25 at p. 6)

The CA IOUs also commented that there is a trend towards shipping chargers without an EPS, and that many consumers are reusing AC to DC EPSs whose efficiency under load contributes to an important part of the battery charger efficiency and should not be eliminated via an adjustment factor approach unless significant experimental validation confirms this model. (CA IOUs, No. 25 at p. 6) The CA IOUs further requested that DOE consider how new battery chargers will typically be powered by older EPSs if current trends continue. (

Id.

)

As an initial matter, DOE will also continue studying the trends of shipping battery chargers without an EPS and the effect of reusing old EPSs. The proposal to require testing with a minimally compliant EPS reflects the

wide selection of EPSs readily available and ensures that the battery charger is tested in a configuration representative of actual use, as most battery chargers require the use of an EPS to convert 115V AC line voltage into a low-voltage DC or AC output. By “minimally compliant EPS”, DOE is referring to EPSs that are minimally compliant with their respective EPS product class energy conservation standard, or in other words, EPSs with Compliance Certification Database (“CCD”) reported efficiencies as close to their respective minimum product class energy conservation standard as possible. Requiring the use of a minimally compliant EPS for testing will help improve test procedure reproducibility. Requiring the use of an EPS with an efficiency as close to the minimum as possible also ensures that manufacturers who do not package, sell, or recommend an EPS for testing with their battery chargers do not get an unfair advantage, by preventing the use of a very efficient third-party EPS for testing. DOE reiterates that the make and model of such minimally compliant EPS used for testing would also need to be reported to CCD, as prescribed by battery charger certification reporting requirements at 10 CFR 429.39. Specifying the use of a minimally compliant EPS results in battery chargers shipped without an EPS being tested with EPSs of comparable efficiency. As such, DOE is not prescribing specific EPSs, or the acceptable range of EPS efficiencies for testing with battery chargers.

The Joint Trade Associations opposed DOE's proposal to test battery chargers with a minimally compliant EPS, when applicable. The Joint Trade Associations claimed that manufacturers do not know which adapters are minimally compliant until after testing them. The Joint Trade Associations instead suggested DOE to continue allow 5V DC input option for conventional USB connections. For other connections, including for USB-PDs, the Joint Trade Associations proposed allowing any other commercially available EPS to be used. The Joint Trade Associations asserted that this would avoid possible circumvention through use of a specially designed adapter, but that DOE should study whether adapters vary enough in efficiency that this approach may cause an increase in unacceptable testing variations. (Joint Trade Associations, No. 24 at p. 9)

DOE clarifies that the “minimally compliant” qualification applies to the EPS and compliance with the applicable energy conservation standards applicable to EPSs. By adopting the proposal to test with a minimally compliant EPS for applicable battery chargers, it would further avoid accounting for adapter efficiency differences, leading to unacceptable testing variation. The efficiencies of DOE compliant EPSs can be found on DOE's publicly available CCD. As discussed in the November 2021 NOPR, testing with a 5V DC input is less representative than testing with an EPS. 86 FR 66878, 66885. Additionally, testing with a 5V DC input does not provide as comparable of results with battery chargers that are shipped and tested with an EPS. Therefore, in order to improve the representativeness and comparability of testing, DOE is adopting the provisions discussed in the preceding paragraphs to test with a “minimally compliant EPS,” as proposed in the November 2021 NOPR. These battery chargers are operated with an EPS by the consumer and testing the chargers without an EPS is not representative of actual use. DOE is also adopting the proposed enforcement testing change in appendix Y1 from the November 2021 NOPR to address instances in which the certified EPS relied on in testing is no longer available in the market. 86 FR 66878, 66885. In such an instance, DOE will test the battery charger with any compatible minimally compliant EPS that meets the performance criteria.

Regarding DOE's proposal in appendix Y1 to further specify the EPS selection priority when one is provided or recommended, DOE did not receive comments opposing such proposal, with both WPC and the Joint Efficiency Advocates expressing their support for this proposal. (WPC, No. 22 at p. 2; Joint Efficiency Advocates, No. 23 at p. 2) As such, DOE is adopting the proposal that a battery charger would first 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. DOE reiterates that only if when the manufacturer does not package, sell, or recommend an EPS to be used with the battery charger, then the battery charger should be tested with a minimally compliant EPS, or in other words, and EPS that is no more efficient than the corresponding baseline EPS standard.

For the reasons presented in the November 2021 NOPR and in the preceding paragraphs, DOE is adopting the proposals from the November 2021 NOPR to specify the EPS selection priority and require applicable battery chargers to test with a minimally compliant EPS in the new appendix Y1.

3. 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 3.3.2 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.

DOE stated in the November 2021 NOPR that 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. 86 FR 66878, 66886. Therefore, DOE proposed no changes for the footnote regarding protective circuitries.

Id.

However, DOE proposed to update the term used for battery chemistry in Table 3.3.2 from “Lithium Polymer” to “Lithium-Ion Polymer” and to change “Nanophosphate Lithium-Ion” to “Lithium Iron Phosphate” in order to reflect changes in the market. 86 FR 66878, 66886.

The Joint Trade Associations supported DOE's proposal to update the battery chemistry terms, and also supported not changing the foot note regarding end-of-discharge voltages. The Joint Trade Associations further stated that they are not aware of new cut off voltages and the new battery chemistries DOE considered are still in their infancy. (Joint Trade Associations, No. 24 at p. 9)

Schumacher requested that DOE add Lead-Carbon based Valve-Regulated Lead Acid (“VRLA”) batteries to the list of batteries, stating that such batteries are quickly developing and are mostly used in Solar Charging and RVs. However, Schumacher indicated that they were not sure of the per-cell rating or end-of-discharge voltage for these batteries. (Schumacher, No. 21 at p. 2) In response to Schumacher's comment,

DOE reviewed the Lead-Carbon based VRLA battery market and was not able to find valid data to establish the end-of-discharge voltages for these batteries. At this time, the Lead-Carbon based VRLA battery market appears to still be developing. As such, DOE is not including Lead-Carbon based VRLA batteries in Table 3.3.2 of appendix Y.

Schumacher also suggested DOE provide a tolerance to end-of-discharge voltage to ensure uniformity, because not all test equipment stops the discharge test at the exact voltage. (Schumacher, No. 21 at p. 3) DOE notes that battery voltages can fluctuate during discharge and might drop suddenly around end-of-discharge voltage. Therefore, it would be more accurate for the test equipment and lab technician to determine when exactly should discharge be stopped once it reaches close to DOE specified end-of-discharge voltage. From DOE's own testing according to the current test procedure, the discharge tests are usually terminated by either the battery analyzer at the specified end-of-discharge voltage, or by the built-in battery protection circuitry. DOE does not anticipate the current test procedure language to cause repeatability or reproducibility issues, nor did DOE receive other stakeholder concerns on the current approach.

Delta-Q claimed that the name change from “Lithium Polymer” to “Lithium-Ion Polymer” does not address the issue that virtually all commercialized lithium-ion batteries have a polymer separator. (Delta-Q, No. 28 at p. 1) Delta-Q further proposed DOE to simply delete “Lithium Polymer” from the table to avoid confusion and redundancy.

Id.

DOE notes that although most lithium-ion batteries on the market utilize a polymer separator, there are still potentially some batteries that do not have the polymer separator, and the additional battery chemistry would not cause variation in test results. Therefore, DOE will maintain both the Lithium-Ion Polymer and Lithium-Ion chemistries.

For the reasons discussed in the November 2021 NOPR and in the preceding paragraphs, in this final rule DOE is adopting the proposed updates to the battery chemistry table to update “Lithium Polymer” term to “Lithium-Ion Polymer” and updating the term “Nanophosphate Lithium-ion” to “Lithium Iron Phosphate”.

4. 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.

Although DOE did not propose to make changes to the current battery selection criteria in the November 2021 NOPR, Schumacher suggested DOE reconsider the battery selection method for automotive chargers. (Schumacher, No. 21 at pp. 1-2) Schumacher stated that it is better to use 12V Absorbent Glass Mat (“AGM”) batteries with Thin Plate Pure Lead (“TPPL”) technology for testing multi-voltage automotive battery chargers because they have lower stratification, do not need electrolytes measurement, are easier to maintain, are safer, have lower losses, and have more repeatable and reproducible results. Schumacher also indicated that these batteries are more popular, with 12V batteries being the most common voltage. Schumacher stated that for multi-voltage automotive battery chargers that can charge 12V batteries, batteries of other voltages should not be required for testing because of their significantly fewer annual volumes. (

Id.

) Schumacher added that these batteries can be reused more times to keep test costs lower. Schumacher further suggested DOE add reusing of automotive batteries and float charging specifications to the test procedure as many automotive battery chargers reuse the same batteries for testing. (Schumacher, No. 21 at p. 2)

DOE reiterates that its current battery selection criteria specifically states that if multiple batteries meet the battery selection criteria, the battery or configuration of batteries with the highest maintenance mode power should be selected for testing. Section 3.2.3.(b)(2) of appendix Y. In real world scenarios, consumers do not always choose the most efficient battery chemistry to use with their battery chargers. Therefore, testing a lead acid charger with more efficient AGM batteries with TPPL technology would not be representative. If a manufacturer can select either a regular AGM battery or an AGM battery with TPPL technology, the battery with higher maintenance mode power would be selected for testing. As for selecting batteries for testing with multi-voltage chargers, Table 3.2.1 of appendix Y specifically states that battery with the highest voltage should be used for testing.

DOE's battery charger test procedure requires manufacturers to use new battery chargers and associated batteries. Section 3.2.2 of appendix Y. Battery charge capacity can vary with number of charge cycles and discharge rates, especially for lead acid batteries. As such, testing a battery charger with a new battery versus with the same battery, but after repeated number of charge and discharge cycles, can result in significant variation that diminishes the accuracy and repeatability of the testing. To determine if a used battery is still suitable for testing would require monitoring and testing of various factors, which can also add undue burden. Therefore, DOE is not changing the requirement that new batteries be used for testing, to maintain test procedure repeatability as well as test result reproducibility and comparability.

5. Mode-Specific Metrics

Currently, DOE's battery charger test procedure is based on the integrated UEC approach. The UEC equation in section 3.3.13 of appendix Y integrates active mode, standby mode, and off mode power measurements by combining certain 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 the usage profile for each battery charger product class, meaning the 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). In incorporating usage profiles into the integrated metric, DOE in the June 2016 Final Rule stated that aggregating the performance parameters of battery chargers into one metric and applying a usage profile would allow manufacturers more flexibility for improving performance during the modes of operation most beneficial to their consumers, rather than being required to improve the performance in each mode of operation, including those which may not provide any appreciable benefit. 81 FR 38266, 38286-38287.

UEC integrates active mode, standby 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. The UEC approach therefore requires the use

of usage profiles to appropriately reflect the period of time a product spends in each mode, in order to maintain the representativeness of the metric for an average use cycle or period of use as required by EPCA. The usage profiles provide a weighted average of application-specific usage for battery chargers within a specific product class. The usage profiles are based on data for a variety of applications from user surveys, metering studies, and stakeholder input that DOE considered in the June 2016 Final Rule. 81 FR 38266, 38287. DOE's product-class specific usage profiles were initially also 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 was for each usage profile to be representative of the usage of the product class as a whole.

EPCA requires that DOE 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)) EPCA requires the use of an integrated metric unless such a test procedure is technically infeasible. If an integrated test procedure is technically infeasible, DOE must prescribe separate standby mode and off mode energy use test procedures, if a separate test is technically feasible. (

Id.

)

However, under EPCA, DOE is 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)) The requirement for a representative test procedure that does not impose an undue burden underpins EPCA's ability to develop and enforce standards, and therefore is a fundamental requirement of EPCA. EPCA does not define what is technically infeasible or what it means. But DOE finds it reasonable when considering the technical feasibility of a test procedure that provides for a metric that integrates active mode, standby mode, and off mode energy use to consider the representativeness and burden of a test procedure using that metric. An integrated test procedure metric that cannot be reasonably expected to produce representative test results or that would result in undue burden cannot be considered technically feasible under EPCA, because it is unable to meet the requirements to be a permissible test procedure under the statute—even if an integrated metric is theoretically possible approach were those requirements to not apply.

As explained in the November 2021 NOPR, 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. 86 FR 66878, 66887. In the November 2021 NOPR DOE presented the example of the current Product Class 2, which includes both smartphones and small capacity home power tools—two products with widely different usage patterns and annual shipments.

Id.

A more recent market review shows that the shipments for certain applications, such as smartphones, cordless phones, wireless headsets, have changed significantly since the usage profiles in appendix Y were originally established.

Id.

Furthermore, there has been a recent but rapid market adoption of smart wearable devices, tablets, consumer drones, and mobility scooters from DOE's internal research. Some of these products would have drastically different usage profiles from their respective product classes, which adversely impacts the representativeness of the corresponding usage profiles. Changes in consumer use of a number of products within a product class or the emergence of new or altered end use products impacts the representativeness of the usage profile for that product class under the UEC metric. DOE anticipates that the battery charger market will continue to change dynamically at a rate that will render usage profiles unrepresentative more quickly than EPCA's review cycles anticipate. Because the UEC metric requires integrating active mode, standby mode, and off mode energy use, which requires representative usage profiles, the need for new or amended usage profiles to maintain representativeness would result in the need to repeatedly and frequently amend test procedures, which in turn potentially would require manufacturers to update representations, increasing undue manufacturer burden.

In an effort to maintain the representativeness of the test procedure for battery chargers in light of the rapidly changing market, while maintaining a consistent test procedure for manufacturers, in the November 2021 NOPR, DOE proposed an approach that does not rely on the UEC equation or usage profiles. 86 FR 66878, 66887. Specifically, DOE proposed 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.

Id.

DOE is not aware and has not been made aware of any other integrated approach that integrates the energy consumption of different battery charger modes of operations.

The Joint Efficiency Advocates and CA IOUs noted in response to DOE's proposal that developing accurate and representative usage profiles has become more difficult with the constant development of new end use product types and changes in consumer usage patterns, risking the market usage assumptions used to calculate UEC becoming obsolete for specific classes of battery chargers unless continuously updated. (

See,

Joint Efficiency Advocates, No. 23 at pp. 2-3; CA IOUs No. 25 at p. 2) The Joint Efficiency Advocates noted that the multi-metric approach presented a more representative method. (Joint Efficiency Advocates, No. 23 at pp. 2-3) The Joint Efficiency Advocates commented that they found it would be more representative to separate the test procedure to three separate metrics for active mode, standby mode, and off mode. (Joint Efficiency Advocates, No. 23 at pp. 2-3) The CA IOUs also supported the development of separate reported metrics for active charge energy, standby mode, and off mode energy use. (CA IOUs, No. 25 at p. 1). The CA IOUs agreed that the evolving nature of battery charger technology tends to quickly make obsolete the market usage assumptions used to calculate UEC obsolete for specific classes of battery chargers.

Id.

The CA IOUs stated that the benefits of the disaggregated metric test procedure have become increasingly relevant for reasons such as products having different usage profiles within the same product class, evolving technology and

usage patterns, increases in battery energy density and capacity across products, and variation in charge time profiles. (CA IOUs, No. 25 at p. 2) The CA IOUs stated that as battery charger technologies and markets evolve, an integrated metric becomes less representative of the product classes as currently defined in the test procedure and stated that because DOE's proposed approach does not rely on a UEC equation or usage profiles, it should be more flexible. (CA IOUs, No. 25 at p. 2)

NEEA also supported DOE's proposed multi-metric approach and noted that its research demonstrated that the use of separate active, standby, and off mode metrics aligns with the current battery charger market. (NEEA, No. 27 at p. 2) NEEA noted that battery charger end uses are substantially more varied than when DOE promulgated its UEC metric, citing AHAM's comment that there are hundreds, if not, thousands of battery-charged consumer products in the market. NEEA noted that there are many factors that contribute to this growth, such as price reduction for lithium-ion batteries, increased wireless applications, and smaller charger formats. NEEA stated that this proliferation makes it technically inappropriate to continue using usage profiles to represent the energy use of hundreds of widely varying applications. (

Id.

) NEEA explained as well that markets for and shipments of battery chargers can change rapidly, as products evolve and consumer demand shifts. NEEA listed certain products as examples, such as landlines, smartphones, drones, cameras and MP3 players.

Id.

NEEA stated that while the UEC approach is appropriate for more stable appliance categories such as refrigerators, it is not a useful measure for the continuously evolving array of battery charger end uses. (NEEA, No. 27 at p. 3) In contrast, NEEA noted that there are multiple advantages to DOE's multi-metric approach: increasing representativeness of the range of battery chargers, both now and as the market continues to change; improving harmonization with DOE's EPS test procedure approach; and enabling more detailed standards analysis. (NEEA, No. 27 at p. 3)

ITI suggested, however, that DOE continue using the UEC metric while gathering active charge energy data to fully understand the complexity of these energy use parameters before deciding to switch metrics. (ITI, No. 20 at 3) ITI and the Joint Trade Associations stated that current class groupings are not perfect, but that they were based on objective criteria and still provide a clear indication of which product class a charger should fall into. (ITI, No. 20 at 3; Joint Trade Associations, No. 24 at p. 3) Delta-Q acknowledged the imperfection of the UEC and its usage profiles but did not support replacing the usage profiles-based UEC system with the multi-metric approach, stating that the multi-metric approach will unduly constrain design options to minimize overall energy use while managing trade-offs with cost and customer value. (Delta-Q, No. 28 at p. 1) Delta-Q suggested that the multi-metric approach would cause uncertainty and could require redesigns, increase costs, and remove features that may not reduce energy consumption in real-world usage.

Id.

DOE does not agree that the multi-metric approach lacks the potential to reduce energy consumption in real-world usage. DOE's UEC metric currently represents the annualized amount of the non-useful energy consumed by a battery charger (

i.e.,

energy losses) among all tested modes of operation. As battery and battery charger technology develops along with change in usage profiles, DOE is noticing that more and more energy losses happen during maintenance mode and no-battery mode, as battery chargers are simply either maintaining the battery at a fully charged state or monitoring the charger circuitry to facilitate active charging when a battery is inserted. In these modes, the battery charger is not doing any useful work to transfer energy into the battery, and because these modes can last indefinitely, they can result in significant energy savings potential if regulated separately from active mode. DOE further notes that the potential redesign and additional costs are not associated with change to multi-metric testing approach, but directly related to the energy conservation standards rulemaking. However, DOE notes that any energy savings potential and cost burdens from increased efficiency levels would be analyzed thoroughly in the separate energy conservation standards rulemaking.

The Joint Trade Associations opposed the proposed multi-metric approach, asserting that the multi-metric approach does not satisfy EPCA's intent or requirements, and it would make savings and energy savings difficult for the consumer to understand as well as for DOE to analyze. (Joint Trade Associations, No. 24 at pp. 1-3) The Joint Trade Associations asserted that DOE failed to demonstrate that its proposals are justified and are not arbitrary and capricious, and that DOE's proposal does not meet the requirements of the Administrative Procedure Act or the Data Quality Act. (Joint Trade Associations, No. 24 at p. 3) The Joint Trade Associations asserted that DOE has not shown that the current approach does not represent an average consumer use cycle, that it cannot be updated to maintain its representativeness of average consumer use, that it is infeasible to integrate active mode and standby mode, or that the current test procedure approach would be unduly burdensome to conduct. (Joint Trade Associations, No. 24 at pp. 2-4) The Joint Trade Associations also noted that the proposed appendix Y1 would add significant burden and is contrary to EPCA's clear preference for aggregated metrics. (Joint Trade Associations, No. 24 at pp. 1-2)

The Joint Trade Associations acknowledged, however, that the current product classes are not perfect and that they have acknowledged their imperfection from the beginning; they acknowledged that there are difficulties in developing product classes for battery chargers, with thousands of different end use products, and that usage and shipments of products within classes differs. (Joint Trade Associations, No. 24 at pp. 2-3) The Joint Trade Associations solution to these issues was not to remove the UEC metric and usage profiles but to update the usage profiles and shipments analysis more regularly, considering the breadth of products in each class from both usage and shipments perspectives. The Joint Trade Associations offered to provide data to assist in that analysis. (Joint Trade Associations, No. 24 at p. 3). The Joint Trade Associations noted that EPCA requires DOE to review and update test procedures at least once every 7 years, and that DOE has further discretion to initiate an early review if usage profiles or shipments for product classes become unrepresentative. (Joint Trade Associations, No. 24 at p. 4) Because DOE is already required to update the test procedures periodically, the Joint Trade Associates could not see how the multi-metric approach solved any issue. The Joint Trade Associations noted that these reviews and updates are critical to DOE's analysis, and it is difficult to understand why it is too challenging to do these as part of the test procedure review. The Joint Trade Associations speculated that DOE did not want to be bothered re-assessing its categorizations and updating usage profiles.

Id.

DOE is undertaking this rulemaking in compliance with its requirement under EPCA to review and update test procedures at least once every 7 years. However, the issue DOE identified with keeping the current integrated UEC

approach was not the need to update the test procedures according to the requirements of EPCA, but the frequency of updates required to maintain the UEC metric as a representative approach to testing as required under EPCA. DOE reiterates that it has determined it would need to update the test procedures more often than the 6- and 7-year standards and test procedure update cycles to maintain the UEC metric; as other commenters also noted, the battery chargers' dynamic market already would warrant far more frequent updates and DOE projects this need to only increase over time. While the Joint Trade Associations pointed out that DOE regularly updates annual use cycles for products such as residential dishwashers, laundry products, and air treatment products based on varying sets of data, DOE notes an approach that is both feasible and representative for some products may not be feasible or representative for others where there are clear and significant differences between the products such as quantity of end use products for battery chargers.

The Joint Trade Associations further stated that DOE failed to present data supporting its conclusions from a recent market review showing that shipments for certain applications have changed significantly since the usage profiles were established, or that market and shipments of battery chargers change quickly as the market and consumer use changes. (Joint Trade Associations, No. 24 at p. 3) The Joint Trade Associations further disputed that the current approach is no longer representative, and that DOE has presented no compelling evidence that the test procedure has become overly burdensome, noting that the simple solution is to simply update the test procedures. They concluded that because the current test procedure has accomplished EPCA's requirements of representative results without undue burden relatively well, DOE cannot show it is infeasible to have an integrated metric representative of consumer use. They therefore also disputed DOE's findings of a repeated need to update leading to increased manufacturer burden and claimed the multi-metric approach would be more burdensome than minor revisions to update usage profiles and shipments.

Id.

DOE notes that an approach's historical success or validity does not necessarily justify maintaining that approach in the face of changed and changing circumstances. DOE has projected that the battery chargers' market and the variety of consumer end uses make the UEC metric increasingly infeasible and untenable to maintain, both administratively and for regulated parties. The technical requirements to maintain the UEC metric and its attendant usage profiles are no longer feasible to meet. The need to frequently review and update usage profiles, while known in the 2016 rulemaking, was of a different scope than the need for review and updating dictated by the current market for battery chargers. DOE believes this need to update would only increase in rapidity. And as DOE has noted, even if DOE were able to maintain these profiles on its own end the frequent changes to the test procedures and standards would require frequent recertifications for manufacturers and may cause impermissible undue burden.

The Joint Trade Associations disputed that the test procedure must be representative of consumer use at every moment, noting that this is not only impossible, but also unnecessary and not consistent with EPCA's intent. (Joint Trade Associations, No. 24 at p. 4) DOE agrees that this is not the statutory standard, but DOE notes that DOE is required to maintain test procedures reasonably designed to produce representative test results without undue burden. Maintaining the current battery charger test procedure, which DOE reasonably believes will lead to foreseeably unrepresentative test results on a regular basis, is contrary to EPCA's requirements where an alternative test procedure exists to provide more representative results without undue burden. While EPCA expresses a preference for an integrated metric, this preference yields before EPCA's more fundamental need for accurate and representative test results, without which EPCA's standards are undermined.

The Joint Trade Associations also argued that DOE originally grouped products with different usage profiles into the same product class, and that DOE did not present data in the November 2021 NOPR on what has changed since the initial test procedure and standards development. (Joint Trade Associations, No. 24 at p. 2) The Joint Trade Associations stated that DOE was placing the burden of proof for retaining the integrated metric on commenters but claimed that the burden was in fact on DOE to demonstrating that its proposals were justified and not arbitrary and capricious. Joint Trade Associations, No. 24 at p. 3) DOE has acknowledged that it is changing its position on whether the UEC metric can meet the requirements of EPCA but disagrees that it has not explained the basis for this change in position. DOE, and other commenters in response, noted that the changes in the market justified reconsideration and ultimately departure from the UEC and usage profile approach. The market review has shown that the UEC integrated metric approach can no longer feasibly be reasonably expected to produce representative test results as required by EPCA, absent such frequent updates to the test procedures as to constitute undue hardship—which itself would contravene EPCA. DOE is adopting its multi-metric approach because an integrated metric is now infeasible.

The Joint Trade Associations asserted that UEC is a more representative approach because it accounts for consumer usage, whereas DOE's multi-metric approach does not account for the contribution of each to the overall product efficiency. (Joint Trade Associations, No. 24 at p. 7) However, as DOE has noted the representativeness of the UEC approach is dependent on representativeness of the usage profiles and shipment data underpinning the metric, and the current battery chargers market dynamics make maintaining the representativeness of that metric infeasible without incurring undue burden. DOE's UEC approach would only be representative of the annual non-useful energy resulting from battery chargers, provided that the usage profiles are updated frequently and repeatedly. DOE's multi-metric approach would, still representatively but separately, measure and certify the active mode energy, standby mode energy, and off mode energy. As battery charger overall efficiency is highly dependent on usage profiles, the multi-metric approach can further help consumers in learning which battery charger would provide best overall efficiency under that specific consumer's usage profile by providing the separate metrics.

The Joint Trade Associations stated that not only is DOE's proposal inconsistent with EPCA's clear preference for integrated metrics, but it is also inconsistent with DOE's systems approach, which aims to allow flexibility in component designs while ensuring an overall efficiency requirement. The Joint Trade Associations stated that they assumed the proposed appendix Y1 will translate to three separate energy conservation standards requirements and noted that not all products have the capability to reduce energy consumption of a particular mode which may require redesign to meet DOE standards. The Joint Trade Associations commented that by separating active, standby, and off modes into three metrics DOE is requiring the redesign of products and

effectively increased design complexity. The Joint Trade Associations stated that manufacturers are allowed flexibility to distribute energy across the different modes with the current UEC compliance requirements. The Joint Trade Associations stated that the integrated UEC approach therefore allows more innovation and flexibility in designs and posited that the burden associated with DOE's multi-metric approach will likely be more significant as it will inhibit innovation inhibit innovation and the ability to differentiate one's products from others in the market. (Joint Trade Associations, No. 24 at pp. 4-6) DOE acknowledges that the original UEC approach provides greater design flexibility because of its integrated nature, and that this was one purpose of the UEC metric. 81 FR 38266, 38286-38287. However, DOE cannot maintain an approach that will not meet EPCA's requirement of representative test procedures or lead to undue burden. Furthermore, DOE's multi-metric approach will still regulate the integrated power draw of battery chargers in standby mode operations, allowing manufacturers to still have significant design flexibility in improving either maintenance mode or no-battery mode efficiency.

The Joint Trade Associations further stated that manufactures have already developed their products to comply with DOE's current standards, which is challenging for some battery chargers, especially the infrequently charged ones. The Joint Trade Associations claimed that if DOE were to change its approach, some products will likely need to be redesigned and the investments manufacturers have made to comply with the current standards would be stranded. (Joint Trade Associations, No. 24 at p. 2)

The Joint Trade Associations commented that they cannot fully comment on DOE's proposal when DOE has not provided more detail on how the product classes or standards would be amended. The Joint Trade Associations stated it is likely that that some currently compliant products may no longer be compliant under the newly proposed approach but with no real savings but only additional costs on consumers and manufacturers. The Joint Trade Associations suggested DOE analyze this further during manufacturer interviews. (Joint Trade Associations, No. 24 at p. 5)

Schumacher stated that if DOE's amended test procedure impacts existing CCD reported models, they recommend the currently compliant products to be grandfathered in under the amended standards or required to be updated several years after the revised standard publication. (Schumacher, No. 21 at p. 6) Schumacher argued that if a newly revised standard was to be put into effect immediately, it would result in higher cost to manufacturers; whereas a buffer period of several years would minimize costs and let manufacturers retest the products or redesign the products.

Id.

DOE is adopting the mode-specific metric approach as proposed in the December 2021 NOPR and consistent with its authority and duties under EPCA. As previously noted, when considering the feasibility of a test procedure with a metric integrating active mode, standby mode, and off mode energy use, DOE must also consider whether that metric will satisfy the test procedure criteria prescribed by EPCA: the representativeness of the test procedure and whether a test procedure is unduly burdensome. The UEC test procedure approach specifies an integrated metric relying on usage profiles. However, changes in consumer use and the emergence of new products can both impact the representativeness of that usage profile and therefore the UEC metric overall. While the Joint Trade Associations suggested that maintaining the representativeness of the current usage factors is simply a matter of updating the data, as discussed in the November 2021 NOPR the market and shipments of battery chargers has been 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 charger changes. 86 FR 66878, 66887. As an example, DOE noted 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.

Id.

Because of the nature of battery chargers, they serve a great variety of end use products, updated on an annual basis. Although DOE collects and reviews usage profiles and shipment data constantly, going through the process of updating the test procedure and energy conservation standards in a similar way would impose undue burden on manufacturers. Needing to update the test procedure in order to avoid reliance on obsolete usage profiles and comply with EPCA's representativeness requirement would in turn require updating the energy conservation standards to reflect the test procedure changes. Manufacturers would then need to frequently retest and recertify their products, creating significant and undue burden.

By regulating the different battery charger operating modes separately, DOE avoids the risk of usage profiles becoming increasingly unrepresentative before having a chance to update them, as the multi-metric approach is not reliant on usage profiles, but rather performance in individual operating modes. The multi-metric approach provides for a more stable regulatory environment, by minimizing the possibility that manufacturers would need to retest and recertify products with changes in the market and the associated usage profiles, thereby reducing potential test burden.

DOE notes that the multi-metric test procedure approach in appendix Y1, adopted in this final rule, would not be required until such time as compliance is required with amended battery chargers energy conservation standards developed based on the new test procedure, should DOE establish such standards. Were DOE to establish amended energy conservation standards reflective of the multi-metrics, DOE would consider, in part, the efficiencies of battery chargers on the current market at each metric and the technologies available to improve the efficiencies at each metric.

DOE reiterates that adoption of the multi-metric test procedure in appendix Y1 itself will not require manufacturers to redesign their products. Moreover, the multi-metric testing approach provides results that more directly correlate to direct testing of a battery charger, as opposed to results that are dependent on shipments data and data regarding consumer usage patterns. As such, the test procedure is less dependent on data that may quickly become obsolete or data that may be unable to fully reflect appropriate market and consumer usage conditions. Therefore, DOE anticipates that it will provide a more stable regulatory environment for manufacturers moving forward.

DOE also notes that it is adopting the alternate active mode test method proposed in the NOPR, which essentially relies on the current active and maintenance modes test method found in appendix Y with only an added step for test technicians to analytically compute the integrated active mode energy from the active mode and maintenance mode test data. DOE estimates the additional time required to perform the active energy calculation would be roughly the same as that for calculating UEC. However, because technicians would no longer need to compute UEC under the multi-metric approach, overall testing burden would be the same between the multi-

metric approach and the current UEC approach.

The CA IOUs further recommended that DOE require manufacturers to report values for different operating modes, and that DOE publish these values in the CCD to allow calculations of UECs for specific products in specific use cases. (CA IOUs, No. 25 at p. 2) The CA IOUs stated this performance data would be essential for assessing the impacts of the new test procedure metrics.

Id.

DOE notes that the performance values are already presented on the CCD, and DOE will make necessary amendments to the reporting template to account for the reporting changes under the multi-metric approach.

ITI also requested DOE to consider harmonizing and coordinating the test procedure with Canada so they remain consistent. (ITI, No. 20 at p. 6) DOE notes that Canada's Department of Natural Resources primarily references DOE's existing test procedure for battery chargers, which relies on the consolidated UEC metric. While there is an effort to harmonize with widely and internationally adopted industry standards, DOE is required by EPCA to ensure that its test procedure for a covered product is representative. For the reasons stated above relating to DOE's own UEC-based test procedure metric, DOE is therefore unable to continue harmonizing with Canada's test procedure for battery chargers. DOE notes however that the test procedure's conduct between the current UEC approach and the adopted multi-metric approach still remains largely the same; therefore, DOE does not anticipate there to be significant difference between how tests are conducted in Canada and in the US. DOE will work with international agencies to reduce manufacturer burden to a reasonable extent, where doing so aligns with DOE's statutory requirements under EPCA.

Based on the discussion presented in the November 2021 NOPR and in the preceding paragraphs, DOE has determined that the adopted multi-metric approach more fully meets the representativeness requirements of EPCA without being unduly burdensome. Moving to a multi-metric approach avoids DOE imposing an undue burden on manufacturers by requiring frequent recertification and retesting due to frequent updates to an integrated metric, updates that would be needed to maintain the metric's compliance with EPCA's representativeness requirement in a shifting market landscape. DOE reiterates that testing under the new multi-metric approach would not be required until after DOE's battery charger energy conservation standards have been amended. DOE will also study the potential redesign needs and costs because of the multi-metric approach in the separate standards rulemaking.

6. Active Mode Test

Battery charger active mode is the state (condition) in which the battery charger system is connected to a main electricity supply (main power source) and is actively delivering power to bring the depleted battery to a fully charged state (the charger's main function), as defined in section 2.1 of appendix Y.—(

See also

42 U.S.C. 6295(gg)(1)(A)(i)) Appendix Y currently tests the active mode power consumption along with battery maintenance mode power

to produce a consolidated 24-hour energy consumption value, or E

24,

which is then used in the UEC calculation. As previously discussed, in the new appendix Y1, DOE is replacing 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.

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 November 2021 NOPR, DOE proposed 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. 86 FR 66878, 66888. The active mode energy, E

, 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.

Id.

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 provided in the manufacturer's materials.

Id.

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 so that the battery discharge test is performed immediately after this active mode test is completed, but prior to the 24-hour charge and maintenance mode test that would then be used to determine maintenance mode power.

Id.

Joint Trade Associations commented that the November 2021 NOPR preamble stated the battery discharge test would be performed immediately after the active mode test, but the proposed appendix Y1 regulatory text appropriately included a wait period. The Joint Trade Associations urged DOE to retain the wait periods, should DOE continue with the amended test procedure. The Joint Trade Associations expressed concern that going immediately from active mode testing to maintenance mode testing

would impact the test because the battery could be hot and stated the wait times are important for reducing test variation. (Joint Trade Associations, No. 24 at p. 7)

As discussed in the following section, in this final rule DOE has determined that energy use during maintenance mode is appropriately assigned to standby mode.

DOE's proposed charge test would begin upon insertion of a depleted battery and would end when the battery is fully charged and require that the test be terminated when there is indication that the charge test has ended. DOE's intent was to explain that manufacturers should terminate charging immediately after the battery reaches full charge, rather than wait for the original total charge and maintenance mode test duration to complete. The proposal was not intended to remove the wait period between the charge and discharge test. As such, DOE clarifies in this final rule that it is not removing the wait period between the charge and battery discharge test, and a wait period continues to be included in the newly established appendix Y1.

ITI suggested that the proposed charging test would be challenging to conduct for the following reasons: the maintenance mode power would be difficult to measure under the new approach for products with integrated battery; and if a battery charger does not have charge status indicator, it would be hard to monitor when the battery is fully charged as there many variables that can affect the total charging time, which makes it difficult to develop an automated and consistently accurate process. (ITI, No. 20 at p. 3) ITI suggested DOE collect more power data before proceeding with the new active charge test and reiterated that separating

active charge test with maintenance mode test would require significantly longer testing time, and the maintenance mode power would not be possible to measure after battery discharge test for products with integrated batteries. (

Id.

) ITI suggested that DOE also consider the cost associated with potential redesign of battery charger products. (ITI, No. 20 at p. 6)

ITI and the Joint Trade Associations stated that the multi-metric test would either require active technician monitoring or additional special equipment for monitoring, which adds significant time and cost. (ITI, No. 20 at p. 6; (Joint Trade Associations, No. 24 at pp. 5-6) The Joint Trade Associations opposed the proposed active mode test procedure, stating it would significantly increase test burden and incur undue burden. (Joint Trade Associations, No. 24 at p. 5) The Joint Trade Associations stated that because the test takes longer, fewer tests can be conducted. (Joint Trade Associations, No. 24 at pp. 5-6)

CSA commented that the current appendix Y allows laboratory technicians leave the battery charger unattended for 19 hours before having to check on the charging status to determine total test duration, and the batteries will usually be charged within 19 hours for the test to be terminated at the 24-hour mark; this test can be left running overnight and requires very little time and effort from the lab technician. (CSA, No. 12 at p. 1) CSA further commented that if the active charge test needs to be terminated immediately after indication of battery is fully charged, the lab technician would need to continuously monitor the charge indicator and immediately terminate the charge when the fully charged indicator turns on. (CSA, No. 12 at pp. 1-2) Although CSA conceded this could be done by implementing sensors and other controls, CSA stated that it would be more burdensome than the appendix Y test method.

Id.

Similarly, Delta-Q argued that the proposed test procedure change adds test complexity and duration with the addition of the separate maintenance mode test. (Delta-Q, No. 28 at p. 2) Delta-Q also noted that the active mode test procedure was problematic both because it appeared to require constant monitoring and because it reduces battery rest time, which can increase test-to-test variation.

Id.

NEEA recommended DOE test a wide variety of battery chargers to evaluate appropriateness of the active mode test. (NEEA, No. 27 at pp. 7-8) NEEA asserted that relying on a battery charge indicator may result in different charge levels at the end of the active mode tests, because not all chargers indicate charge status and those that do may signal full charge at different thresholds, which could result in unfair comparisons. (NEEA, No. 27 at pp. 7-8)

DOE notes that battery chargers are typically designed for a specific battery or combination of batteries. Therefore, manufacturers should already have an understanding of the full charge time for each battery and charger combination, making it unlikely that a technician would need to monitor a unit under test during the entire test period.

However, DOE also stated in the November 2021 NOPR that in its 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: the active mode energy and maintenance mode power. 86 FR 66878, 66888. DOE therefore considered this alternative approach, in which active mode energy consumption, E

, 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

, from the 24-hour charge and maintenance mode test data. DOE stated that it would consider the discussed alternate approach in the development of the final rule.

Id.

Under this approach, lab technicians do not need to rely on charge status indicator to determine when the battery reaches the full charge, which would ensure that the test battery would always be fully charged at the end of the combined charge and maintenance mode test.

CA IOUs agreed that calculating energy in active mode as the integral of applied power during the charge period is a practical and reasonable approach based on sound physics. (CA IOUs No. 25 at p. 2) The Joint Trade Associations stated the alternative active mode test would not work because battery chargers may have points at which the battery power is turned off, such as a series of pulses at the end where the battery attempts to get full charge. The Joint Trade Associations stated that such instances could be misinterpreted at the end of the appendix Y1 active test, and for products with complex charge profiles, it is difficult to detect the end of active mode given different battery sizes. (Joint Trade Associations, No. 24 at p. 7)

NEEA similarly commented that analyzing charge status based on AC input power is difficult for slower trickle chargers because input power may not indicate a transition from active to battery maintenance mode. (NEEA, No. 27 at p. 8) NEEA also suggested that although additional instrumentation can be used to monitor battery charger output and more accurately determine the state of charge, measuring additional charger DC output may interfere battery and charger communication signals, impacting testing safety; affect the measurement directly; and increase test burden. (NEEA, No. 27 at p. 8-9) NEEA claimed that determining charge status by using AC input power may result in different charge levels for fast chargers because these chargers transition from fast to slow charging with different algorithms. (

Id.

) NEEA encouraged DOE to investigate the issues it identified, and to retain its current appendix Y active and maintenance mode testing approach if the challenges prove difficult to overcome. (

Id.

) NEEA stated that advantages of the appendix Y 24-hour active mode test include reduced test burden for technicians, the ability to address both slow and fast chargers through a uniform approach and eliminating the need to determine/define charge status. (

Id.

)

WPC supported DOE's alternate approach of conducting a single 24-hour charge and maintenance mode test and determining active charge energy based on the data generated. (WPC, No. 22 at pp. 2-3) WPC also commented however that it may be difficult to define the actual transitioning point between active mode and maintenance mode. (

Id.

)

To minimize any potential additional burden that may be associated with an active-mode only test as noted by commenters, DOE is adopting the alternative active charge energy approach discussed in the November 2021 NOPR, under which active mode energy is calculated from the combined charge and maintenance mode test, similar to the test procure in appendix Y. DOE notes that battery chargers may have different charging profiles. Based on DOE's testing, most battery chargers exhibit a distinctive drop off in power indicating a transition to maintenance mode. In certain limited instances, the battery charger shows unstable power consumption towards the end of charging phase. However, such periods would be classified as active charging because the battery is pining the charger to get full charge, and as stated in section 2.1 of appendix Y and the new appendix Y1 active mode is when “the battery charger is delivering current,

equalizing the cells, and performing other one-time or limited-time functions in order to bring the battery to a fully charged state.” Therefore, by defining the state that would be classified as active mode and by determining when the charger enters maintenance mode, lab technicians can precisely identify the transition point from active mode to maintenance mode and calculate the active charge energy from this alternative approach, as prescribed in sections 3.3.9 and 3.3.10 of appendix Y1.

Schumacher commented that the best way to calculate the efficiency of an automotive battery charger with non-integrated batteries is similar to the calculation used for UPSs. (Schumacher, No. 21 at p. 1) Schumacher further noted that including a non-integrated battery into the efficiency calculation is not an effective measure of the charger's efficiency because different batteries have different losses, and the charger has no control over these batteries.

Id.

Schumacher therefore stated that it is better and more accurate to measure the efficiency of the charger directly, by itself, so that the chargers would not be affected by the battery efficiencies.

Id.

Schumacher stated that lower quality batteries can result in manually reduced charge cycles just to pass the standard, which causes faster battery degrading and adds user costs with greater environmental impact. (

Id.

)

DOE understands that for battery chargers designed for large-capacity lead-acid batteries, manufacturers are less involved in the end use product design and usually cannot pick which battery will be used with their chargers. However, battery performance is a crucial part for measuring battery charger efficiencies. Different battery chemistries have different self-discharge rate, affecting the charge and maintenance modes algorithms. DOE's battery charger test procedure also determines the amount of “useful energy” by measuring how much energy the fully charged battery can output.

In this final rule, DOE is adopting the alternate active charge energy approach discussed in the November 2021 NOPR, in which active mode energy is calculated from the combined charge and maintenance mode test that is similar to the test procure in appendix Y.

7. Standby Mode Tests

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

(1) Connected to a main 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. Section 2.25 of appendix Y. 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 test procedure in appendix Y relies on a metric that integrates active mode, standby mode, and off mode, it is less critical in that context 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 tentatively determined in the November 2021 NOPR that maintenance mode is also appropriately characterized as a standby power mode. 86 FR 66878, 66888. 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, DOE referenced power tool chargers in the November 2021 NOPR, which in residential environments routinely spend an indefinite amount of time maintaining batteries that are not regularly used but are required to be fully charged.

Id.

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.

In the November 2021 NOPR, DOE tentatively determined that these continuous functions in maintenance mode satisfy both EPCA's and IEC 62301's definition of standby. 86 FR 66878, 66888-66889. To better account for these conditions, DOE proposed to first 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).

Id.

DOE proposed to then define in appendix Y1 the term “standby mode” to include both no-battery mode and maintenance mode.

Id.

Specifically, DOE proposed that in appendix Y1, standby mode power of a battery charger (P

), would be calculated as the sum of the no-battery mode power (P

), and maintenance mode power (P

Id.

The Joint Efficiency Advocates supported DOE's proposal to regulate no-battery mode and maintenance as standby mode. (Joint Efficiency Advocates, No. 23 at p. 3) NEEA supported DOE's proposal to include both battery maintenance mode and no battery mode within standby mode but encouraged DOE to require reporting of these two modes separately to support more accurate standards analysis. (NEEA, No. 27 at p. 3) NEEA also supported DOE's proposal to regulate standby power mode as the sum of maintenance mode power and no battery mode power, as this metric gives manufacturers greater design flexibility. (NEEA, No. 27 at pp. 3-4)

ITI stated that the new proposed test procedure would prolong the maintenance mode test until maintenance mode power has been captured representatively, and that it does not make sense to combine no-battery mode power and maintenance mode power as products spend different time in each of these states. (ITI, No. 20 at p. 3) The CA IOUs, while otherwise supportive, stated that the proposed integrated standby metric does not clearly delineate no-battery and maintenance modes power. (CA IOUs, No. 25 at p. 2) The CA IOUs recommended that the no-battery and maintenance modes power be reported separately as unique values, especially in the case of combination products that provide battery charging in addition to other functions. (CA IOUs, No. 25 at p. 2) The CA IOUs also reiterated their support of using IEC 62301 to develop a no-load standby measurement so that DOE's test procedure can harmonize with industry practices and improve

low power factor treatment. (CA IOUs, No. 25 at p. 3) DOE notes that the no-battery mode test procedure was indeed developed based on IEC 62301 test procedure, with resolution parameters for power measurements and uncertainty methodologies, including input crest factor tolerance parameters, referenced directly from IEC 62301.

Honda disagreed with DOE's approach of combining maintenance mode power and no-battery mode power under standby mode power, stating that the approach would not properly evaluate standby power and would result in double evaluation of the power to boot up the battery charger. (Honda, No. 26 at pp. 1-2) Honda additionally asked DOE to monitor the current supply in maintenance mode when calculating standby power, because there can be differences when the charger is “providing limited charge” and when the charger is “not charging”. (

Id.

) DOE reiterates that in maintenance mode operation, the battery charger is only continuously monitoring the fully charged battery's voltage to facilitate limited charging, if the voltage drops below a certain threshold. In no-battery mode, the battery charger is constantly “scanning” to determine if a battery has been inserted, or connected, to activate charging. The actual power to boot up the battery charging function to charge the depleted battery would be regulated in active mode itself. Therefore, combining maintenance mode power and no-battery mode power would not be double evaluating the power to boot up the battery charger.

WPC stated that it may be more accurate to determine the start of maintenance mode by measuring the decrease in power rather than using a charge indicator or timed rate of charge, as some device charge indicators may show a premature full charge state when compared to the rated capacity or after a period of maintenance mode charging. (WPC, No. 22 at p. 2) WPC, however, did not agree with DOE's proposal to combine no-battery mode and maintenance mode power into standby mode power for fixed-location wireless chargers, and suggested that focusing on “no battery” or “no receiver” mode would let DOE focus on standby power reduction. (WPC, No. 22 at p. 3)

DOE is aware of some instances in which battery chargers may enter a low power mode similar to no battery mode prior to entering maintenance mode, which exhibits higher power consumptions in comparison. Therefore, to ensure test procedure repeatability and representativeness, DOE adopts the proposal that the maintenance mode testing period should continue until 5 hours after true maintenance mode has been captured. This ensures that the consumption in the alternate low power mode described above is not being inadvertently captured as maintenance mode. For example, if a battery charger does not enter maintenance mode until the 50th hour of being in the active charge and maintenance mode test, then the total active and maintenance mode test period should be 55 hours, which ends at 5 hours after the charger enters maintenance mode.

EPCA requires DOE to include standby mode and off mode energy consumption, taking into consideration the most current versions of Standards 62301 and 62087 of the IEC, and to integrate such energy consumption into the overall descriptor for each covered product, unless technically infeasible, such as here. However, where integration into an overall metric is infeasible, EPCA directs DOE to 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)) The operation of a battery charger in maintenance mode meets the definition of “standby mode” as that term is defined by EPCA. (

See

42 U.S.C. 6295(gg)(1)(A)(iii)) As discussed, maintenance mode provides the continuous function of maintaining a battery at full charge following active mode until such time as the fully charged battery is removed from the charger by the user. (

Id.

) The energy used during this continuous (and potentially indefinite) mode is distinct from energy use during active mode, the discrete period following placement of a depleted battery on the charger, as the energy used in maintenance mode does not contribute to direct battery charging. Further, because it is providing a user-oriented or protective function, maintenance mode does not meet the definition of off mode, which is defined as the condition in which an energy-using product is connected to a main power source; and is not providing any standby or active mode function. (42 U.S.C. 6295(gg)(1)(A)(ii))

As noted in section III.B.5 of this document, most energy losses happen during maintenance mode and no-battery mode, with the battery charger not doing any useful work to transfer energy into the battery. As these modes can last indefinitely based on different consumer usage and product types, calculating the energy losses based on a weighting factor would not be representative, which is also why DOE is discontinuing the integrated UEC approach. By combining the power draw of battery charger in maintenance mode and no-battery mode, DOE would be able to representatively capture the energy usage metrics for battery chargers in these states regardless of how much time the battery charger spends in each state, while still giving manufacturers freedom in design flexibility. Unlike with the overall UEC metric, DOE would not be reliant on usage profiles and the requisite updates here; therefore, it is not infeasible to combine maintenance mode and no-battery mode. Furthermore, because maintenance mode power computes the average power during at least the last four hours of maintenance mode period, it would not be necessary to separately measure the power of when the battery charger is providing limited charge.

As stated in section III.B.6 of this document, DOE is adopting the NOPR discussed alternative approach that calculates the active mode energy and maintenance mode power analytically from the combined charge and maintenance mode test. DOE reiterates that from extensive internal testing, DOE found that by monitoring battery charger input power, most battery chargers would exhibit a distinctive drop off in power, indicating a clear transition to maintenance mode. In rare instances when the battery charger shows unstable power consumption towards the end of charging phase, DOE notes that technically, they would still be considered as active charging phase as the battery is pining the charger to get full charge. Therefore, DOE does not anticipate there to be obstacles that prevents stakeholders from identifying the maintenance mode power under the alternative approach.

DOE is adopting the NOPR proposal to combine both maintenance mode and no-battery mode under battery charger standby mode. DOE further clarifies that for open-placement chargers, only no-battery mode power would need to be tested, as prescribed in section 5 of appendix Y1.

8. 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.

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.

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).

In the November 2021 NOPR, DOE reviewed the market and initially determined that the products subject to the waivers granted to Dyson are no longer available; therefore, DOE proposed to not amend the test procedure to include instructions regarding disabling power to functions not associated with the battery charging process that are not consumer controllable, or to allow adders for such functions. 86 FR 66878, 66889-66890. DOE noted that this proposal would also terminate the existing Dyson waivers consistent with 10 CFR 430.27(h)(3) and 10 CFR 430.27(l).

Id.

In response to DOE's proposal, the Joint Efficiency Advocates supported DOE's proposal to maintain the current approach for disabling power to non-battery-charging related functions, and supported DOE's proposal to terminate Dyson's waivers as these products are no longer available on the market. (Joint Efficiency Advocates, No. 23 at p. 3) NEEA supported maintaining the present approach to waiver petitions, auxiliary functions in the test procedure, and DOE's decision to terminate the existing waiver granted to Dyson. (NEEA, No. 27 at 11)

The Joint Trade Associations asked DOE to provide additional clarity on requirements regarding disabling power to non-battery-charging related functions, because although some functions do not contribute to battery charging, they cannot be disabled directly by the user. The Joint Trade Associations stated that DOE and stakeholders have struggled with how to address these functions in the past and suggested a proposal to allow disabling of these functions but with non-circumventing language. (Joint Trade Associations, No. 24 at p. 10) The Joint Trade Associations suggested DOE to include a publicly viewable column with the CCD so that the public can know when an alternative means is used to isolate the charging function. The Joint Trade Associations further suggested DOE to add a confidential column so manufacturers can report instructions on how to disable the non-battery-charging related functions or set them to the lowest power consuming state. The Joint Trade Associations also proposed to DOE that anti-circumvention language should be added to make the intent that battery-charging related circuit or function cannot be changed in the test procedure clear, as such language has been successful in other appliances categories. (

Id.

) ITI and Delta-Q also supported the joint comments. (ITI, No. 20 at pp. 4-5; Delta-Q, No. 28 at p. 2) Delta-Q further expressed their support of the existing Dyson waiver approach and suggested that DOE integrate allowances to more battery charger models, because it is not always practical or desirable for the user to have the ability to manually disable non-charging-features or reduce their consumption. (Delta-Q, No. 28 at p. 2)

STIHL commented that when STIHL's lawn mower battery is charging, there are some non-battery-charging related functions still running, such as connected functions or safety functions. (STIHL, No. 16 at p. 1) STIHL inquired if these functions can be deactivated or be given appropriate power adders when calculating for energy consumption during testing, because they do not relate to the charging process.

Id.

DOE's current battery charger test procedure specifically requires non-battery-charging functions to be turned off during testing, unless manufacturers did not provide ways for end user to disable these functions. Section 3.2.4 of appendix Y. DOE notes that, due to the intricate nature of battery charger products, disabling non-battery-charging related functions through non-user-accessible ways can have unexpected effects on the battery charging circuitry, which raises repeatability and reproducibility concerns. Therefore, DOE is not amending the test procedure to allow disabling of non-battery-charging related functions through alternative means. In the case suggested by STIHL's comment, the same requirements would also apply, and the battery charger would only be tested with these non-battery-charging functions on if they cannot be switched off by the end user. Due to the huge variety of non-battery-charging related functions and different ways they can be implemented, DOE is not prescribing power adders for these non-battery-charging related functions.

Schumacher added that there is new automotive battery charger technology that uses internal super capacitors or Li-Ion batteries, which charges the standalone (end-use product's) battery normally, and then the internal battery or supercapacitor, if needed, after charge is complete. (Schumacher, No. 21 at p. 6) Schumacher asked if the charging of these internal batteries should be included into E24 or Pm or some other parts of the standard that are yet to be described. (Schumacher, No. 21 at p. 6) DOE's notes that its battery charger test procedure only measures the energy consumption at the input of the charger. Based on when charging of these super capacitors occur, it could be regulated either under active charge mode or maintenance mode of DOE's test procedure.

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 with this final rule.

1. Certification Flowcharts

In the November 2021 NOPR, DOE proposed to include certification flowcharts in the docket upon publication of the final rule, shown in Figure III.C.1 and Figure III.C.2,

help manufacturers better understand the battery charger testing and certification process. The flowcharts 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, the difference between a rated value, a represented value, and a certified rating, and the statistical criteria for determining compliance with energy conservation standards. The flowcharts 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 flowcharts for testing and compliance. Manufacturers of battery chargers are required to comply with the applicable provisions under 10 CFR parts 429 and 430.

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 flowcharts as substantive guides for testing and compliance.

BILLING CODE 6450-01-P

ER08SE22.000

ER08SE22.001

BILLING CODE 6450-01-C

The Joint Trade Associations

suggested that DOE consistently update the flowcharts as needed and make it clear that the regulatory text would override anything in the flowcharts because many manufacturers will rely on these flowcharts, if finalized. (Joint Trade Associations, No. 24 at p. 11) ITI also supported this comment. (ITI, No. 20 at p. 6)

Appendix Y1 test procedure would not be effective until after energy conservation standards have been amended to account for the multi-metric approach.

DOE acknowledges these comments and will ensure that the flowcharts are updated as necessary. DOE also reemphasizes that the regulatory text would override anything in the flowcharts.

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. DOE proposed clarifications in the November 2021 NOPR, based on stakeholder comments.

a. 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 429.39(a)(1). The calculation of UEC in section 3.3.13 of appendix Y is based in part on the tested (measured) battery energy.

In the November 2021 NOPR, DOE proposed to further clarify 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

”. As for the proposed appendix Y1, DOE noted that all of the instructions rely on measured E

batt

, making it unnecessary to distinguish between measured and rated E

batt

. 86 FR 66878, 66893.

Delta-Q supported the extra clarifications on measured and nameplate nomenclature. (Delta-Q, No. 28 at p. 2)

The Joint Trade Associations stated that it is not clear whether measured or rated values for battery energy should be used, and they would support DOE's proposal to update the nomenclature if coupled with an enforcement provision that allows for tolerance, as there could be inherent variations in test and production that affect how standard and product class applies. The Joint Trade Associations stated that their proposed approach is consistent with DOE's enforcement approach for other appliances, such as measured volume for refrigerators, freezers, clothes washers, dehumidifiers, etc. (Joint Trade Associations, No. 24 at p. 11) ITI supported this comment and further requested DOE to continue using the term “rated” instead of “represented”, unless DOE can provide a clear definition on when should the “represented” term be used. (ITI, No. 20 at p. 5)

DOE recognizes the inherent variations in testing and production, especially for tested battery energies. However, DOE notes that due to the nature of how battery energy differs even for the same models from the same batch, when determining compliance through enforcement testing DOE would be looking at the individual sample performance more closely and determine compliance based on per sample basis, if necessary. DOE will also ensure that its battery charger energy conservation standards would show comparable standards for battery chargers that fall on the border of two neighboring product classes.

DOE notes that under the term “rated”, some manufacturers might confuse it with “nameplate” values, which can differ for batteries. Therefore, to ensure test procedure repeatability and reproducibility, DOE is avoiding using the term “rated”, and is updating the terms to “represented”, “nameplate”, and “measured” instead.

b. Other Nomenclatures

Schumacher stated that appendix Y's specified 5-hour discharge time resulted from the 0.2 C-rate, and conflicts with real world automotive battery ratings which are usually based on 10-to-20-hour rates. Schumacher stated that the 5-hour discharge time results in a much lower rating than the nameplate rating because of energy loss through heat.

(Schumacher, No. 21 at p. 2)

Schumacher proposed DOE to clarify the 0.2C C-rate means a 5-hour discharge rate to ensure manufacturers are conducting the tests correctly and reporting correctly. (Schumacher, No. 21 at pp.2-3)

DOE notes that discharge rates will vary by end-use application. It would be infeasible and add burden if DOE was to prescribe a unique discharge rate for each type of application in the test procedure. DOE's specified 0.2C discharge rate offers a practical and repeatable solution for different applications with either slow or fast discharge rates. By maintaining the same discharge rate, it would also improve comparability in results. For batteries that serve the same end-use application, although the tested value may differ from manufacturer designed ratings, they would still be comparable to other batteries from the same application.

The definition for C-rate is prescribed at section 2.10 of appendix Y, which specifies that the C-rate is calculated by dividing the charge or discharge current by the nameplate battery charge capacity of the battery. DOE has not received stakeholder comments suggesting that the current 0.2 discharge C-rate causes confusion prior to Schumacher's comment. DOE is also unaware of any manufacturer discharging the batteries differently than the prescribed 0.2C discharge rate. However, to further improve test procedure language clarity, DOE will amend the C-rate definition in both appendix Y and appendix Y1 to give an example that time needed to charge or discharge with a 0.2 C-rate would equal 5 hours.

Schumacher stated that the term used to refer to “Product Classes” and “wall adapters” are not consistent between the standard, test procedure, and CCD report template. (Schumacher, No. 21 at pp. 4-5) Schumacher commented that making consistent use of terms would avoid ambiguity and DOE should clarify that wall adapters indeed refer to EPSs.

Id.

DOE's mention of wall adapters in the test procedure was to facilitate understanding and readability of the test procedure. In most cases, the term “wall adapter” can be used interchangeably with “EPS”. To further improve language consistency, DOE is changing the “wall adapter” terms used in appendices Y and Y1 to the more technically appropriate term “EPSs”. As for the term “Product Classes”, DOE notes that in the CCD reporting template, they are referred to as “Product Group Codes”, which should not cause confusion as the “Product Group Codes” worksheet details the product groups with matching product classes.

c. Alternate Test Method for Small Electronic Devices

In the November 2021 NOPR, DOE did not propose to amend the test procedure to rely on the measured battery energy value for the purpose of the testing and certification, because DOE has observed several occasions in which the measured battery energy was lower than the marked nameplate energy, which could lead to unrepresentative value of UEC or active energy consumption. 86 FR 66878, 66893.

ITI reiterated their recommendation for DOE to simplify the test procedure for small electronics by relying on the nameplate battery energy so that testers would not need to obtain special standalone battery samples or solder on tiny terminals. (ITI, No. 20 at pp. 6-7) ITI suggested DOE to reconsider its stance on these devices because inconsistencies caused by these small energy batteries would have negligible impact on overall results. (

Id.

) ITI also requested DOE to review data from

small electronics as they normally have passed the UEC standard with large margins, but with maintenance mode energy contributing to majority of energy consumption. (

Id.

) NEEA expressed general support for DOE's assertion that rated and measured battery capacities can differ substantially, and that requiring measurement ensures fair competition under the standard. (NEEA, No. 27 at p. 11)

DOE reemphasizes that DOE's battery charger test procedure relies on the tested battery energy to carry out UEC calculation. DOE has encountered several occasions where the actual battery energy differs from the rated battery energy. Relying on the rated battery energy to test the product therefore would result in inaccurate measurements and certifications, contrary to EPCA's requirement that DOE adopt test procedures reasonably designed to produce representative results. Therefore, DOE is not prescribing any alternative test methods for small electronics.

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 proposed 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. 86 FR 66878, 66893. DOE did not receive comments on this topic and is adopting the proposed changes in this final rule.

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 prescr

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