© European Power Supplies Manufacturers’ Association (EPSMA) 2018. All Rights Reserved

Energy Efficiency Standards for Battery Charging Systems according to DOE

Relevant documents:

DEPARTMENT OF ENERGY 10 CFR Parts 429 and 430 [Docket No. EERE–2014–BT–TP–0044] RIN 1904–AD45 Energy Conservation Program: Test Procedure for Battery Chargers

ELECTRONIC CODE OF FEDERAL REGULATIONS PART 430—ENERGY CONSERVATION PROGRAM FOR CONSUMER PRODUCTS


 As reported in the November TC minutes, the US Department of Energy (DOE) has published a Federal Register notice of final rule pertaining to energy conservation standards for battery chargers 81 FR 38266 (June 13, 2016) with effective date June 13, 2018.

 FRIWO have assessed the new DOE standard and concluded as follows:

 The test method, limit values and evaluation is clearly described and can therefore be applied immediately. The evaluation and limits differ strongly from the CEC standard, However, we did some spot checks on existing, CEC compliant battery systems (charger and battery pack) and they all also fulfilled the DOE standard! So in the end, the results are comparable - as stated, that's the result of some spot checks.

FRIWO comment: CEC was a clearly structured scheme which made technically and economically sense and easy to follow! DOE is quite the opposite!

 FRIWO have made enquiries to DOE with questions at the end of this email chain however they haven't yet received any feedback.

 

Summary (From TC Report to MC1Q18):


Energy Efficiency Standards for Battery Charging Systems           

[Armin Wegener, FRIWO]

US Department of Energy (DOE) published 81 FR 38266 (June 13, 2016) with effective date June 13, 2018.

FRIWO have assessed the new DOE standard and have sent technical questions to DOE but still no replies. In discussion with colleagues and customers however, FRIWO think that they have a clear picture.

Notes from Armin in an email 27/02/2018 with attachments will be filed in the EPSMA Members area for detailed information.

The email includes an Excel template. From June 13th, 2018, this file must be completed for all chargers to be sold in the USA and uploaded to the DOE website. (That is the biggest news!)

Also from June 13th, 2018, CEC are willing to accept no marking on the charger - if they are sold nationwide. (Previously the chargers must bear a "BC" marking)

From FRIWO perspective the above are the latest developments regarding battery charger efficiency standards. There are no new developments in Europe or elsewhere in the world.


ATTACHMENTS:

10CFR430_Sub_B_Apnd_Y___batteries-and-test-methods (1)

2018_01_30-TN222394_20180129T162307_Initial_Statement_of_Reasons_for_Portable_Electric_Spas_and_Bat

2018_01_30-TN222395_20180129T162306_Express_Terms_for_Portable_Electric_Spas_and_Battery_Charger_Sy

2018_01_30-TN222396_20180129T162308_Notice_of_Proposed_Action_for_Portable_Electric_Spas_and_Batter

DOE_FINAL_RULE_06_2016___EERE-2014-BT-TP-0044-0023

TEMPLATE_Battery_Chargers_v5.0


CORRESPONDENCE:

From: armin.wegener@friwo.com <armin.wegener@friwo.com>

Sent: 27 February 2018 07:47

To: Paul Conway <conwaypk@gmail.com>

Subject: EPSMA - Energy Efficiency Standards for Battery Charging Systems according to DOE - progress for MC 15 March 2018

Dear Paul,

thanks for your patience - but you have retired and have time....  ;-)

In the meantime quite a lot happened:

- we did not receive any feedback from the DOE (by neither contacts!)

- we did discuss (of course) with several collegues and also customers this issue and finally we think, that we have a clear picture: Our questions referred to the possibility, that several battery packs (with different # of cells and different capacities) can be charged by one charger => The DOE standard states that the battery pack with highest voltage and biggest capacity needs to be tested to be compliant. (personal comment: if it is such clear/easy - as it looks to us currently, why does DOE not reply??)

- DOE is less demanding than CEC ("California Energy Commission"): For CEC stand-by and maintenance is limited to a certain portion of the total energy consumption (which was sometimes difficult to fulfill); while DOE does not consider stand-by => easier to fulfill, but simultaneously less stringent.

- DOE has adapted the same test precedure from CEC, however - as stated previously - the interpretation is diffent from CEC => we are currently setting up an automatic test gear and also an .xls template to be able to evaluate all our chargers with the requested battery pack (we are using VBA to control the test equipment and then record the test data and do data processing to extract and compare with the limit values)

- DOE requests a similar .xls file for the charger listing like they do for power supplies. This .xls file needs to be filled with all chargers models and test data - see attached .xls template. This file with all chargers to be sold in the USA must be uploaded to the DOE website by June 13th, 2018 (that is the biggest news!)

- For the same date CEC has released an announcement (see excerpt and attachments below) that they are willing to accept no marking on the charger - if they are sold nationwide. (Before the chargers must bear a "BC" marking)

So, these are from our perspective the latests developments regarding battery charger efficiency standards. There are no new developments in Europe or elsewhere in the world.

Take care and best regards

Mit freundlichen Grüßen / Best regards

ppa. Armin Wegener

Vice President R&D

P.S.: Jetzt bequem und einfach online bestellen: https://www.friwo-shop.de

P.S.: Order comfortably and easily online: https://www.friwo-shop.de/en

Tel:+49 2532 81 301

Fax:+49 2532 81 112

E-Mail:armin.wegener@friwo.com

Web:

https://www.friwo.de


FRIWO Gerätebau GmbH - Von-Liebig-Strasse 11 - 48346 Ostbevern

Managing Directors: Rolf Schwirz, Martin Schimmelpfennig

Commercial Register Amtsgericht Münster - HRB 9325

*** Please consider the environment before printing this e-mail ***


Von:        "Paul Conway" <conwaypk@gmail.com>

An:        <armin.wegener@friwo.com>

Datum:        03.02.2018 22:43

Betreff:        EPSMA - Energy Efficiency Standards for Battery Charging Systems according to DOE - progress for MC 15 March 2018


Hello Armin

I hope you are well.

The MC meet in a little over 5 weeks and I wonder if you have any update on BCS?

In particular any feedback by DOE on your questions, and can the database be updated with the changes now?

Best regards

Paul

  

From: Paul Conway [conwaypk@gmail.com]

Sent: 07 September 2017 14:28

To: armin.wegener@friwo.com

Subject: Re: Antwort: FW: EPSMA - Energy Efficiency Standards for Battery Charging Systems according to DOE - progress for Teleconference 14 Sept 2017

  

Hello Armin

Thanks for your update which I will pass on to the MC.

Maybe PSMA could help us with this as they may have access to USA contacts?

  

Best regards

Paul

    

-------- Original message --------

From: armin.wegener@friwo.com

Date: 07/09/2017 13:31 (GMT+01:00)

To: Paul Conway <conwaypk@gmail.com>

Subject: Antwort: FW: EPSMA - Energy Efficiency Standards for Battery Charging Systems according to DOE - progress for Teleconference 14 Sept 2017

  

Dear Paul,


thanks for your email checking for the feedback by DOE (due to vacation time I was not able to respond earlier).


We have sent 1-2 reminders to about 5 contacts, but did not receive any feedback by DOE on our questions! For me, it seems, that DOE is not really putting attention on this issue (I also assume, that other companies are asking similar questions)


Mit freundlichen Grüßen / Best regards


ppa. Armin Wegener

Vice President R&D


P.S.: Jetzt bequem und einfach online bestellen: http://www.friwo-shop.de

P.S.: Order comfortably and easily online: http://www.friwo-shop.com


Tel:+49 2532 81 301


Fax:+49 2532 81 112


E-Mail:armin.wegener@friwo.com


Web:http://www.friwo.com


FRIWO Gerätebau GmbH - Von-Liebig-Strasse 11 - 48346 Ostbevern

Managing Directors: Rolf Schwirz, Martin Schimmelpfennig

Commercial Register Amtsgericht Münster - HRB 9325

*** Please consider the environment before printing this e-mail ***

Von:        "Paul Conway" <conwaypk@gmail.com>

An:        "'Armin Wegener'" <wegener@friwo.de>

Datum:        31.08.2017 16:19

Betreff:        FW: EPSMA - Energy Efficiency Standards for Battery Charging Systems according to DOE - progress for Teleconference 14 Sept 2017


Dear Armin

Could you send me a quick reply on this for the TC report to MC Teleconference please?

Thanks

Best Regards

Paul

 

From: Paul Conway [conwaypk@gmail.com]

Sent: 18 August 2017 17:19

To: 'Armin Wegener' <wegener@friwo.de>

Subject: EPSMA - Energy Efficiency Standards for Battery Charging Systems according to DOE - progress for Teleconference 14 Sept 2017

 

Dear Armin

Could you let me know the situation on subject Energy Efficiency Standards for Battery Charging Systems according to DOE please?

In below email FRIWO have made enquiries to DOE with questions at the end of this email chain.

 Have you received any feedback and if yes when could FRIWO update the database?

 Thanks

Best Regards

Paul

 

From: Paul Conway [conwaypk@gmail.com]

Sent: 30 January 2017 18:35

To: secretariat@epsma.org

Cc: armin.wegener@friwo.de

Subject: FW: EPSMA - Energy Efficiency Standards for Battery Charging Systems according to DOE

 

Hi Paul

There are changes to be added to the Database ‘Energy Efficiency Database battery Charging Systems Spreadsheet’ in http://www.epsma.org/page4.html

I will try to summarise the changes in the TC report and would like this email and attachments to be added to the members area please.

It would be appropriate to add something to the database itself to alert to the changes but there are outstanding answers needed from DOE to clarify the standard as explained below.

 

As reported in the November TC minutes, the US Department of Energy (DOE) has published a Federal Register notice of final rule pertaining to energy conservation standards for battery chargers 81 FR 38266 (June 13, 2016) with effective date June 13, 2018.

 

FRIWO have assessed the new DOE standard and concluded as follows:

 

The test method, limit values and evaluation is clearly described and can therefore be applied immediately. The evaluation and limits differ strongly from the CEC standard, However, we did some spot checks on existing, CEC compliant battery systems (charger and battery pack) and they all also fulfilled the DOE standard! So in the end, the results are comparable - as stated, that's the result of some spot checks.


FRIWO comment: CEC was a clearly structured scheme which made technically and economically sense and easy to follow! DOE is quite the opposite!

 

FRIWO have made enquiries to DOE with questions at the end of this email chain however they haven't yet received any feedback.

 

Paul could you add this email to the members area please and somehow alert to the upcoming change either in the title for the link or maybe we need to alter the database itself?

 

Best regards

Paul

 

From: armin.wegener@friwo.com [armin.wegener@friwo.com]

Sent: 30 January 2017 09:23

To: Paul Conway <conwaypk@gmail.com>

Cc: dirk.vanalmsick@friwo.com

Subject: EPSMA - Energy Efficiency Standards for Battery Charging Systems according to DOE

 

Dear Paul,

thanks for your email. I saw your previous one - but the topic is not that easy (unfortunately). Here comes our reply:

Yes, since August 2016 there are new requirements by DOE for battery chargers published. They are effective for all chargers to be sold in the USA from June 2018 onward. See the statement below:

From our point of view their standard is very complicated and thus not easy to follow - compared with the CEC standard, which was in place before. DOE adopts the same test methode (10CFR430 Subpart B Appendix Y) like CEC; however, the evaluation of the test results are completely different! Pls refer to the description below for the test flow.

Summary:

The test methode, limit values and evaluation is clearly described and can therefore be applied immediately. The evaluation and limits differ strongly from the CEC standard, However, we did some spot checks on existing, CEC compliant battery systems (charger and battery pack) and they all also fulfilled the DOE standard! So in the end, the results are comparable - as stated, that's the result of some spot checks.

FRIWO comment: CEC was a clearly structured scheme which made technically and economically sense and easy to follow! DOE is quite the opposite!

I hope, that gives you (and the MC) a good overview on the new DOE energy standard for battery charging systems. Pls feel free to comment or ask any topics.

Mit freundlichen Grüßen / Best regards

ppa. Armin Wegener

Vice President R&D

P.S.: Jetzt bequem und einfach online bestellen: http://www.friwo-shop.de

P.S.: Order comfortably and easily online: http://www.friwo-shop.com

Tel:+49 2532 81 301

Fax:+49 2532 81 112

E-Mail:armin.wegener@friwo.com

Web:http://www.friwo.com

FRIWO Gerätebau GmbH - Von-Liebig-Strasse 11 - 48346 Ostbevern

Managing Directors: Lothar Schwemm, Martin Schimmelpfennig

Commercial Register Amtsgericht Münster - HRB 9325

*** Please consider the environment before printing this e-mail ***

Excerpts from the DOE standard:

DOE applies the same test methode (10CFR430 Subpart B Appendix Y) like CEC; the evaluaton of the test results are completely different!

DOE groups all models depending on the voltage and stored energy of the battery pack into 7 different product classes. Each product class then also assues a different user profile resulting in different limit values.

See the relevant tables from the standard:

Die nach 10CFR430 Subart B Appendix Y ermittelten Werte, werden nun zusammen mit den von der Kategorie abhängigen Zeiten in einer der beiden Formeln ausgewertet:

The following limit values must be fullfilled:

There are some questions by FRIWO, how to handle different battery packs to be charged by the same charger. We addressed these questions below to DOE, however, haven't yet received any feedback. Pls see the questions below:

FRIWO is a manufacturer of battery chargers.

Most of these chargers are small battery consumer chargers for which new federal test procedure as of june 20, 2016 is applicable.

A majority of these chargers are multi voltage, multi capacity chargers.


Our battery chargers are sold in different configurations:


1.) Battery charger is sold seperately without batteries.

If I understand right, we need to test according to 10 C.F.R. section 430.23(aa) ( Appendix Y to subart B of part 430).

Only one battery needs to be tested. According to new methodology this would be highest voltage, highest charge capacity battery type.


In 10 C.F.R. section 429.39(b) it is stated, that final rule adds "sampling methodology to be used for determining representations of battery charger energy consumption and also adds provisions for enforcement testing".

Does this mean, that we only need to test one battery type, but this type needs to be tested serveral times on different chargers, to see if the measurements are valid?

If yes, how many units need to be tested?

2.) Some of our battery chargers are sold in a bundle with battery and power tool. The bundles can be 10.8V battery + charger + lamp , 14.4V battery + charger + drill, 36V battery + charger + saw.....

If I understand right, we need to test according to 10 C.F.R. section 430.23(aa) ( Appendix Y to subart B of part 430).

Do we also only need to test highest voltage, highest charge capacity battery type in this case?

Because in federal register/Vol. 81 No.98 Friday May 20, it says:

..."These criteria are applicable to multi-voltage, multi-capacity battery chargers packaged or sold without a battery or packaged and sold with more than one battery."

Or do we need to test according to old table (lowest voltage, lowest capacity + highest voltage lowest capacity + highest energy content = 3 measurements)?

What about sampling methodology mentioned above?


If it really would be the case, that we need to test according to old table (3 measurements) and also use sampling methodology to have stable results, we would have a huge number of tests and every single test is quite time consuming.


Attachments:

 

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