This year, the California Energy Commission (CEC) fully implemented a mandatory regulation for both consumer and commercial electronic devices that are or contain battery charger systems (BCS). A BCS is any product that uses AC or DC power to recharge a battery. Whether it’s a golf cart or an electronic toothbrush, a phone or a laptop, a great number of products sold in California now fall under this regulation.
The first of its kind in the USA, other states are considering adopting the California standard, and Oregon has already done so. Earlier this year, the US Department of Energy (DoE) withdrew federal rulemaking activities for BCSs, citing the California Title 20 efficiency regulations as having established a de facto more stringent national standard for BCS as the reason for withdrawing the proposed federal rulemaking. State inspectors will be checking to ensure that all BCSs found on the market are listed on the CEC’s online Appliance Efficiency Database. Those not listed in the database would be subject to civil penalties, with a potential fine of up to $2,500 per violation. It is a serious matter that manufacturers need to pay attention to.
A Few, Specific Exceptions Exist
- Commercial products: Consumer products must comply with this regulation now, but for non-consumer products the rules are effective as of January 1, 2017. Consumer products are those designed to consume energy and be distributed for personal use. As the CEC document outlines, “if your product is sold or offered for sale to the general public of California, then it is likely a consumer product and not a non-consumer (commercial) product.”
- Some “a la carte” chargers: Chargers that may apply for an exemption include those that:
- Are sold separately for a battery powered product,
- Work with a variety of batteries,
- Are sold as replacements for systems that were sold in prior years, or
- Are provided directly from the manufacturer to the consumer, to a service, or to a repair facility.
- Electric car battery chargers
- Class II or Class III medical device products requiring FDA approval as medical devices
- Charging systems for illuminated exit signs
3 Steps to Compliance
To comply with the new CEC requirements, manufacturers must follow these three steps:
Adding the BC Mark
The last step in the process of meeting CEC requirements for your BCS is labelling. Take a look at our interactive guide and learn how to do it.
- Complete the testing and secure the test report: The BCS must be tested at a CEC approved laboratory. The test report should include all required information, such as: the specific model tested, the test configuration, and the test results. Because the CEC may ask to examine it at any time, the manufacturer or the test lab must retain the test report throughout the life of the product and beyond. Since the CEC also has the right to request retesting, an accurate and robust test report is critical for reproducing the testing in the future.
- Submit to the CEC for listing: The manufacturer or their designated third party certifier then submits the product to the CEC. The CEC reviews the documents and, upon approval, the CEC uploads the models into the appliance database.
- Label products with the BC label: Every BCS must be marked with a BC inside a circle. For more details, see our infographic.
How To Prepare For Your Testing
The test, in a nutshell: The test measures the energy consumption of the BCS in different modes. It measures energy consumption in the “No Battery” mode, and an active charging cycle of a minimum 24-hour period. The 24-hour power measurement is performed with a fully discharged battery, in order to capture the energy consumed during the active charging phase, as well as the energy consumed in the “Maintenance Mode”, (the phase after active battery charging has completed, when the battery is still connected to the charger.) After the test lab completes the energy consumption measurements, it determines the battery capacity, in Wh, by discharging the battery at a 0.2C (5 hour) rate. The California standards compare the energy used to charge and maintain the battery to the energy returned from the battery after a full charge.
What to provide to the lab: For the test, the lab requires: one model XYZ with power adapter and a new battery. The battery samples must be fresh batteries; the condition of the battery affects both the test result and its energy efficiency limits.
Ideally, manufacturers will also provide an adapter connector or cable for connection of the battery pack +/- terminals to the analyzer. Without an adapter, the lab may need to solder lead wires to connect the product to the analyzer. This may damage the battery pack cover or output connector wires.
Battery conditioning prior to testing: Li-Ion, Li-Po, and lead-acid battery types do not require battery conditioning prior to test. All other types, including NiCD and NiMH, require three complete charge and discharge cycles prior to execution of the energy consumption measurement.
Get Your Battery Charger Systems Tested Now
Manufacturers who sell consumer products with rechargeable batteries in California need to be aware of the new CEC regulations, and ensure their products are compliant. The three-step process to certification outlined above can be complex, so manufacturers should partner with an experienced test lab to help them navigate the process. The up-front effort is well worth it to avoid the risk of steep violation fines.