ENERGY STAR®: General Questions
After partnering with a new CB may I continue to mark my existing products with the ENERGY STAR logo?
Manufacturers may continue to mark currently approved products as ENERGY STAR until March 30, 2011. At that time, your designated CB is required to randomly select 10% of each manufacturer's products for Annual Verification Testing.
Am I required to use an ENERGY STAR accredited laboratory?
You are required to use an EPA-Recognized laboratory, however not all EPA-Recognized laboratories must be accredited. For example, first-party laboratories may gain EPA recognition by demonstrating enrollment in an EPA-Recognized Certification Body’s supervised or Witnessed Manufacturer Testing Laboratory (SMTL/WMTL) program. This path to recognition is an alternative to gaining recognition via EPA’s laboratory recognition application form, which requires formal accreditation.
Are Certification Bodies able to certify product categories NOW that are currently under revision?
When under revision, new draft product specifications are constantly being modified, perhaps on a daily basis. A CB is able to perform testing on products currently under revision, however these products cannot receive passing results on up-to-date standards until the specifications are set and finalized by EPA.
Are the ErP Directive European requirements in line with the ENERGY STAR requirements?
For the most part, yes. Many aspects are borrowed from environmental requirements from around the world.
Can an EPA Recognized manufacturer’s lab conduct its own verification testing?
In-house testing will be permitted only under the supervision of the manufacturer’s designated CB, provided that the manufacturer is a participant in the CB’s Data Acceptance Program. Manufacturer testing through data acceptance will be accepted only for certifications managed by an accredited, EPA-Recognized Certification Body. Manufacturers will need to undergo CB evaluation to demonstrate their ISO 17025 compliance, as well as compliance to required test methods. (Formal ISO 17025-accreditation for manufacturer in-house labs has not yet become a requirement.)
Can I conduct qualification testing through a first-party (manufacturer-owned) laboratory?
Yes, you may use a first-party laboratory as long as it is EPA-recognized. A requirement for first-party laboratories is that they be supervised or witnessed by an EPA-recognized Certification Body. Intertek has announced the SATELLITE Data Acceptance Program to support ENERGY STAR Partners that will conduct testing in their own labs. Partners will submit test data to Intertek for engineering review to product specification requirements, and then ENERGY STAR certification will be awarded for compliant products.
Can I conduct verification testing through a first-party laboratory?
Yes, in some rare cases where off-the-line testing is the only feasible option. If the unit selected for verification is obtained off-the-line from the manufacturing facility, the verification testing may be performed at an EPA-recognized, first-party laboratory provided that qualified CB personnel witness the test. EPA anticipates that off-the-line testing will only be an option for extremely large, expensive, or custom-built products.
Do I need formal ISO 17025 accreditation to be an EPA-Recognized Lab?
No, you do not. If you are a manufacturer participating in a Certification Body’s SMTL or Witness Program (like the Intertek Satellite program), then you are acknowledged as an EPA Recognized Laboratory. If you do choose to become accredited to the ISO 17025 standard, you still must work with an EPA Recognized Certification Body to get your products ENERGY STAR qualified.
Do private labelers have to go through ENERGY STAR testing or are they exempt if the OEM already tested the product for ENERGY STAR?
The OEM or the private labeler picks up the testing responsibility. It is up to either one of those parties to take on the responsibility of the verification process. If a manufacturer makes the device and brands it for someone else or wants to extend approval to someone else, that should be ok. Each party must apply separately to partner with ENERGY STAR, but the testing only needs to be conducted once.
For product certification, what documentation does the CB require? Similarly, what documentation does the CB provide?
Required: The CB will require the completed test report and a signed certification agreement, as well as the product data.
Provided: Once the product is certified, the CB will provide a Notice of ENERGY STAR Certification to the client which confirms approval and access to use the ENERGY STAR logo with each certified product. This Notice is also an indication that the CB has submitted documentation to the EPA.
How does a laboratory participating in a CB’s Data Acceptance program demonstrate its participation to EPA? What about participation with multiple certification bodies?
For manufacturers participating in an SMTL program, the CB assesses the manufacturer laboratory and assembles evidence to establish confidence that the laboratory will produce accurate results without the presence of a CB representative. Once qualified, the manufacturer laboratory performs testing and submits data to the CB for review and acceptance for program certification purposes. For manufacturers participating in a WMTL program, the CB assesses the manufacturer laboratory and assembles evidence to establish confidence that the laboratory will produce accurate results while a CB representative is present. Once qualified, the manufacturer laboratory performs testing in the presence of a CB representative, and submits data to the CB for review and acceptance for program certification purposes.
How does EPA recognition of Accreditation Bodies, Laboratories, or Certification Bodies work?
An Accreditation Body (AB) for the ENERGY STAR Laboratory Recognition Program is responsible for assessing laboratory operations for compliance and maintaining documentation and an up-to-date directory identifying all EPA-Recognized laboratories that the AB has accredited. An EPA-Recognized Laboratory is required to comply with test methods outlined in the ENERGY STAR program. As part of the reporting process the lab must submit a copy of their accreditation certificate and scope of accreditation to EPA. EPA-Recognized Certification Bodies must maintain ISO Guide 65 accreditation. The CB is responsible for assessing whether a product meets relevant ENERGY STAR performance parameters and for determining a product’s qualification. Through direct communication with EPA, a CB submits qualified products for listing, maintains auditable records of each product’s qualification and verification history and issues each Notice of ENERGY STAR Certification. Essentially, this certification notice is a green light for manufacturers to use the ENERGY STAR logo with each certified product.
How does EPA regulate which products earn the label?
Products earn the ENERGY STAR label by following a set of key guiding principles regulated by EPA. General ENERGY STAR product requirements for efficiency are detailed here:
• Product categories must contribute significant energy savings nationwide.
• Qualified products must deliver the energy efficient features and performance that consumers demand.
• Verification with testing can be used to measure a product’s energy consumption and performance.
• Should the qualified product cost more than a comparable, less-efficient product, the purchaser will recover their investment in increased energy efficiency within a reasonable period of time through utility bill savings.
How long will it take to have my products published on the ENERGY STAR® website once my CB submits the test data?
This portion of the process is out of the CB’s control—it is at the full discretion of EPA as to when they will publish results on their Qualified Products list.
How much time is required for a Certification Body to review a test report?
Intertek guarantees 24-hour Certification and submittal to the EPA once testing is completed. That means that once test data is received, Intertek will review and accept the test report, AND provide the Notice of ENERGY STAR Certification within 24 hours! You can start marking immediately (as long as all partner agreements are in place), but it is unsure at this time how long it will take for the product to appear on ENERGY STAR qualifying products lists. However, EPA anticipates this will differ between product categories and certification bodies. As part of its application, a CB is required to provide EPA with a detailed description of its review process in order to allow EPA to estimate its potential impact on Partners’ product cycles. EPA intends to seek a commitment from Certification Bodies to review test reports within a timeframe that adequately addresses Partners’ concerns regarding product development cycles and time-to-market objectives.
How will the new ENERGY STAR Third-Party Certification procedures change the ways in which Partners qualify products?
Under the new requirements, Partners will be required to test their products in an EPA-Recognized Testing Laboratory of their choice, and ensure that the laboratory submits the resultant product test reports to an EPA-Recognized Certification Body. Upon a successful review of a product test report, the CB will notify the Partner that the product in question is qualified, and submit the qualified product data to EPA for listing on the ENERGY STAR website. Intertek is an EPA-recognized CB and promises 24-hour certification once testing has been completed.
If a manufacturer gets a product certified for ENERGY STAR, can the ENERGY STAR label be available for a multitude of private branding, or does the product require separate testing and certification for each brand?
If the products are the same and there is the chain of multiple listing within the CB, then one test will suffice. However, if you want the product to appear under two manufacturers, then each manufacturer will need to enroll separately in the ENERGY STAR program.
If I am an EPA-Recognized manufacturer lab, can I use multiple Certification Bodies?
Yes, as long as you are in compliance with EPA programs. That being said, it should be specifically noted that a manufacturer can choose only one CB per product category. For example, a partner could have one CB for televisions and one for computers, but not two for computers. However, from an operational standpoint it would prove strategically beneficial for manufacturers to develop a confident partnership with a single Certification Body.
Is Intertek an EPA-Recognized Certification Body?
Yes. Intertek was among the first EPA Recognized CBs to cover certification for all gas and electrical ENERGY STAR product categories, including more than 60 product types across Appliances, Home Electronics, HVAC, Information Technology, Lighting, and Commercial Food Service Equipment.
Is the ENERGY STAR program mandatory in the United States?
ENERGY STAR is a voluntary program, not mandatory. Its purpose is to distinguish highly energy-efficient products from those that only just meet mandatory energy regulations. ENERGY STAR seems like a mandatory program because there are very rigid requirements for getting a product qualified, and for maintaining that qualification.
Is there a cost associated with choosing Intertek to be their CB and timeline?
Yes. As a Certification Body Intertek charges $2,500 per manufacturing location. There is no limit to the number of ENERGY STAR products that a client can submitt to EPA. The price can vary depending upon different client situations.
Is there an energy consumption requirement per product category?
Each product type has energy requirements, either maximum limits on measures of energy consumption, or minimum limits for measures of energy efficiency.
What does the ENERGY STAR label represent?
The ENERGY STAR label signifies savings: energy and money. In general, ENERGY STAR qualified products including: appliances, HVAC equipment, office equipment, residential lighting, and even homes, reduce energy costs by at least 30 percent.
What factors are considered when EPA decides to revise specifications?
There are several factors that contribute to EPA’s decision. A market share of 50 percent or higher in a particular product category is generally the cause for consideration to revise current specifications. Other factors include:
• A change (or changes) to federally recognized minimum efficiency standards
• Technological changes with advances in energy efficiency that have the potential to yield additional savings
• Product availability/demand on the market
• Issues with consumers coming to expected specific energy savings
• Performance and/or quality issues
• Issues with test procedures
What is the deadline for choosing an ENERGY STAR CB to partner with?
There is no deadline per say, though it would benefit the manufacturer to choose a CB in advance because an agreement must be made before any new products can be submitted to the EPA. If you have existing product, you will need to partner with a CB prior to March 30th so that existing ENERGY STAR products can continue to be certified. In addition, don't forget to sign your new program agreements with ENERGY STAR prior to November 30th. Forms can be found here.
What is the ENERGY STAR Program?
ENERGY STAR is energy-efficient solutions for businesses and consumers through a dynamic government and industry partnership. The program makes it easy to save money while protecting the environment for future generations. ENERGY STAR has become the nation's symbol for energy efficiency and enables consumers to easily identify energy-efficient appliances, electronics, office equipment, lighting, heating and cooling equipment, buildings, and new homes.
What is the process to choose Intertek as my CB?
Reach out to your preferred EPA Recognized CB and let them know you are interested in partnering with them. The CB will provide a quotation and once an agreement is made, a project is open and the relationship begins.
When did the updated ENERGY STAR Third-Party Certification procedures take effect?
December 31, 2010.
When may I start marketing my product as ENERGY STAR qualified?
Existing Partners may begin to market products as ENERGY STAR qualified as soon as they receive the Notice of ENERGY STAR Certification from their CB, indication that the product meets ENERGY STAR specifications. For prospective Partners qualifying their first product, the application process will need to be completed by EPA, which will then provide the new Partner with label and to market its product as ENERGY STAR qualified.
Where can I find a list of EPA recognized Accreditation Bodies, Laboratories, or Certification Bodies?
Links to these lists are provided at the ENERGY STAR website. Here you will find information about Intertek’s various EPA-verified accreditations. The EPA continues to process applications for recognition, and will update these lists on an ongoing basis.
Where can I find the published ENERGY STAR program requirements?
The program requirements are available at http://www.energystar.gov/.
Where can I obtain the mandatory product control list?
The list of products that may be ENERGY STAR qualified is at this link, which also contains links to the qualification requirements for each type of product: http://www.energystar.gov/index.cfm?c=partners.enhanced_test_verification
Which ENERGY STAR products can receive a Federal Tax Credit?
Geothermal Heat Pumps, Small Wind Turbines, and Solar Energy Systems qualify for a Federal Tax Credit of 30% of cost with no upper limit. The offer expires December 31, 2016. Existing homes and new construction, as well as principal residences and second homes all qualify.
Fuel Cells qualify for 30% of the cost, up to $500 per .5 kW of power capacity. The offer expires December 31, 2016. Existing homes and new construction within a principal residence qualify. Rentals and second homes do not qualify. Consult the Federal Tax Credit specifications page of the Energy Star website to learn exactly which products apply.
Which FCC requirements relate to ENERGY STAR?
ENERGY STAR requires electronic lighting products be evaluated to FCC part 15 or part 18 for consumer limits depending on the product.
Why is External Power Supplies not a current product category included in EPA’s laboratory recognition application form?
The ENERGY STAR External Power Supplies, Digital-to-Analog Converter Boxes, and End-Use Products (with qualified External Power Supplies) programs will be phased out at the end of calendar year 2010.
Will ENERGY STAR models tested during the certification cycle for AHRI testing (AHRI 210 and 240 – which covers verification for 30% of all basic models) go towards the 10% verification audit for ENERGY STAR models?
Yes. All of the testing work will count towards 10% market. The verification component of ENERGY STAR products which are also in the AHRI program (AHRI is an EPA recognized CB) will be taken care of through the normal AHRI 30% annual verification scheme.
Will ENERGY STAR qualified products prior to December 31. 2010 remain qualified after the effective date, or will they have to be retested?
It depends. It is anticipated that currently qualified products will not need to be retested to remain qualified. However, Partners have been asked to inform EPA of the currently-qualified products for which they would like to retain said qualifications. EPA will then provide that list of products to an EPA-recognized Certification Body of the partner’s choice. The Certification Body will then be able to select models from that list for the purpose of Annual Verification Testing.
Will EPA fund the new testing and verification procedures? How much will they cost?
No. Partners will pay laboratories and CBs directly in order to obtain the required third-party testing and verification. Fees and costs associated with the mandatory testing and certification will vary between CBs, and test labs.
Will my currently qualified ENERGY STAR products need to be retested in the New Year?
If your products currently maintain an ENERGY STAR label, there are two things that can happen:
1. Products will be subject to new ENERGY STAR specifications which have effective dates in either 2011 or 2012. Those related products will not have to go through re-verification until the defined specifications go into effect.
2. If an existing, qualified ENERGY STAR product does not have any new specifications coming out in 2011 or early 2012 and you wish to continue ENERGY STAR labeling on that product, then you must provide product characteristics and ratings to a Certification Body of your choice by March 31, 2011. The product types subject to this requirement are: commercial steam cookers, commercial refrigerators and freezers, commercial gas griddles, roofing products, windows, doors skylights, central air conditioning systems, air source heat pumps, geothermal heat pumps, light commercial HVAC, and room air cleaners. As required by the EPA, CBs will begin the verification testing regimen in 2011 on the above listed products as well as newly certified ENERGY STAR products.
Will my laboratory be evaluated by EPA during the recognition process?
EPA will not conduct a site visit. Instead, staff from an EPA-Recognized Accreditation Body will conduct a site visit for manufacturers seeking accreditation. If you are seeking enrolment in Intertek’s SATELLITE Data Acceptance Program (for Partners that will conduct testing in their own labs and submit test data to Intertek for engineering review), view details for setting up a site visit at www.intertek.com/SATELLITE.
Will my products be subject to ongoing verification testing, and how often will this occur?
Under the new restrictions, the qualifying process doesn't end with EPA's approval to use the ENERGY STAR label. A product model approved for the ENERGY STAR logo does not have free reign to use the label throughout its lifecycle. EPA’s objective is to ensure that a product continues to comply with ENERGY STAR requirements in production after initial certification. As required by EPA, CBs will begin the verification testing regimen in 2011 on the above listed products as well as newly certified ENERGY STAR products. CBs also have that discretion to determine when products will be selected, so the testing may take place on a quarterly, bi-annual, or annual schedule depending on CB preference and product category.