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Are you compliant with Energy Efficiency Level VI?

Written by Doug Massey on . Posted in Certifications, Information Technology, Product Quality & Performance

In February 2016, the U.S. Department of Energy (DoE) enacted energy efficiency regulations that require external AC/DC power adapters to meet Energy Efficiency Level VI. In Europe, even more stringent requirements, which are currently voluntary, are expected to become mandatory Ecodesign rules by January 2018.

In 2004, the California Energy Commission (CEC) implemented the first mandatory standard, but the global regulatory environment surrounding the legislation of external power supply efficiency and no-load power draw has rapidly evolved since that time. Now, external power supplies (EPS) sold in the U.S. must meet the updated and expanded U.S. DoE Level VI Energy Efficiency requirements. Regulators estimate that these new requirements may significantly reduce the amount of energy consumed by external power adapters, saving consumers up to $3.8 billion and cutting emissions by nearly 47 million metric tons of carbon dioxide over 30 years.

Undoubtedly, mandating higher average efficiencies in external power supplies has had a real impact on global power consumption. However, with the benefit of a reduced draw on the power grid come challenges and questions for the electronics industry as it tries to keep up with the evolving landscape of the regulatory environment. It is our goal to address those uncertainties and to provide ACS customers with the most up-to-date information on current regulations worldwide, ensuring your compliance with new standards.

Global Requirements:
While many countries still have voluntary programs harmonized to the international efficiency marking protocol system first established by the ENERGY STAR Program, the U.S., Canada, and European Union now have mandatory energy efficiency regulations in place for external power supplies: Level IV for Canada, Level V for European Union and Level VI for the United States. Today, Level VI will meet or exceed the requirements of any governing body around the globe, and is mandatory in the U.S. Power supply manufacturers indicate compliance by placing a Roman Numeral VI on the power supply label as specified by the International Efficiency Marking Protocol for External Power Supplies. . The EU is expected to implement as a mandatory requirement under the Ecodesign Directive in January 2017 its ‘CoC Tier 1’ requirements, which are close to DoE Level VI, with the addition of efficiency requirements at the 10% load point, which is a challenge for manufacturers to meet. While CoC Tier 1 includes the new 10% load measure, its no-load and active mode limits are less stringent than DoE Level VI. CoC Tier 2 further tightens the no-load and active mode power consumption limits for key classes of power adapters enacted by Level VI i.e. at output powers ≤49 W and 49 W < Pout ≤ 250 W and covers both standard voltage and low voltage adapters. The CoC Tier 2 standard is proposed to become mandatory in January of 2018.

Complying with Level VI:
In addition to tightened regulations for existing adaptors, Level VI expands the range of products that fall under the new standard. Regulated products now include: products with power levels greater than 250 watts and products with multiple-voltage external power supplies.

Direct vs Indirect Operation EPS’:
The new standard only applies to direct operation external power supplies, which are defined as products that function without the assistance of a battery. An indirect operation supply is not a battery charger, but cannot operate the end product without the assistance of a battery. Indirect operation models will still be governed by the limits as defined by EISA2007. The DoE has provided the instructions below to help distinguish between direct and indirect operation power supplies:

A. If the external power supply (EPS) can be connected to an end-use consumer product and that consumer product can be operated using battery power, the method for determining whether that EPS is incapable of operating that consumer product directly is as follows:
Step 1: If the end-use product has a removable battery, remove it for the remainder of the test and proceed to step 4. If not, proceed to step 2.
Step 2: Charge the battery in the application via the EPS such that the application can operate as intended before taking any additional steps.
Step 3: Disconnect the EPS from the application. From an off mode state, turn on the application and record the time necessary for it to become operational to the nearest 5-second increment (5 sec, 10 sec, etc.)
Step 4: Operate the application using power only from the battery until the application stops functioning due to the battery discharging.
Step 5: Connect the EPS first to mains and then to the application. Immediately attempt to operate the application. If the battery was removed for testing and the end-use product operates as intended, the EPS is not an indirect operation EPS and paragraph B of this definition does not apply. If the battery could not be removed for testing, record the time for the application to become operational to the nearest 5-second increment (5 sec, 10 sec, etc.)

B. If the time recorded in paragraph A, (step 5) is greater than the summation of the time recorded in paragraph A (step 3) of this definition and five seconds, the EPS cannot operate the application directly and is an indirect operation EPS.

There are a number of exemptions that affect whether or not a given EPS needs to be Level VI compliant. In the U.S., Congress has written provisions into section 301 of EISA 2007 that exclude some types of external power supplies. These are devices that fall into the following criteria:

  • Require Federal Food and Drug Administration listing and approval as a medical device in accordance with section 360c, title 21 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 360c).
  • Power the charger of a detachable battery pack or charges the battery of a product that is fully or primarily motor operated.
  • Are made available as a service part or spare part by the manufacturer of an end-product that was produced before July 1, 2008 for which the external power supply was the primary load. Power supplies used for this purpose can be manufactured after July 1, 2008.

Similar exemptions have been instituted by the European Union. These exemptions include the following:

  • External power supplies for medical devices, battery chargers and service products
  • Low-voltage EPS devices with a nameplate output voltage of less than 6 volts and a nameplate output current greater than or equal to 550 mA

Legacy Products:
Compliance with the DoE Level VI requirement will be regulated from the date of manufacture, so legacy products can still be shipped as long as the U.S. manufacture date is prior to February 10, 2016.

Complying with EU CoC and EcoDesign:
The European Union published its Code of Conduct (CoC) on Energy Efficiency of External Power Supplies Version 5 in October 2013. Tier 1 effectively harmonizes the EU with DoE Level VI and is now a voluntary requirement. However, its adoption as an EU Ecodesign rule is expected to be mandated from January 2017. The more stringent Tier 2 became effective on a voluntary basis from January 2016 and is expected to become mandatory as an Ecodesign rule in January 2018.

The key difference between the CoC requirements and Level VI is the new 10% load measure, which imposes efficiency requirements under a low-load condition where historically most types of power supplies have been notoriously inefficient. It is important to note that CoC does not distinguish between direct and indirect operation external power adapters. While CoC Tier 1 includes the new 10% load measure, its no-load and active mode limits are less stringent than DoE Level VI.
CoC Tier 2 further tightens the no-load and active mode power consumption limits for key classes of power adapters enacted by Level VI i.e. at output powers ≤49 W and 49 W < Pout ≤ 250 W and covers both standard voltage and low voltage adapters.

It is expected that other nations will soon follow suit with the DoE Level VI standard. In the European Union, the current voluntary CoC Tier 1 and Tier 2 requirements are expected to become mandatory European Ecodesign Directives. You should anticipate that other countries with existing efficiency regulations in-line with the U.S, including Canada and Australia, will soon move to harmonize with these newer standards as well.

ACS is equipped to test for the Department of Energy, along with energy efficiency testing and certification for ENERGY STAR, CEC, EU ErP & Ecodesign, Natural Resources Canada and other emerging market requirements. For more information or a free quote, please contact us at or call 770-831-8048.

Doug Massey

Doug Massey

Since 2002, Doug has been spearheading the entire product safety department at ACS into one of the world’s leading players. Thanks to him, ACS is one of only a handful of third-party laboratories recognized by Underwriters Laboratories to test Information Technology Equipment. READ MORE