A Proposed Approach to BCS Energy Regulation

1. A Proposed Approach to BCS Energy Regulation AHAM PTI Proposal April 9, 2008

2. Appliance Battery Charging Systems • This regulation establishes energy efficiency requirements for appliance battery charging systems • Appliance = a product where the primary output is mechanical motion, light, the movement of air, or production of heat, but excluding products for the transportation or conveyance of people or cargo.

3. Scope • Our products include integral and detachable batteries: • Integral—battery is not removable and charged within the appliance (e.g. cordless shaver, some power tools) • Detachable—battery is a separate entity and is removed from the appliance for charging. (e.g. power tool with battery pack • We do not include batteries charged in the product that may be removed with the power source connected • We call “swappable” (e.g. laptop, cell phone)

4. EPS’s • Some BCS’s use external adapters. • Usually wall- mounts • CEC has stated that BCS’s regulated by this standard would not also be regulated as EPS’s

5. The effects of this scope definition is to: • Integral and Detachable are included as appliance BCS’s • Therefore adapters would NOT be regulated as EPS • Adapter efficiency measured as part of system efficiency • “Swappable” are not included • The adaptors for a “swappable” product could be covered by the EPS regulations

6. Construction • Separate section of Title 20 for appliance battery chargers • Corresponding definitions • Reference to the appropriate sections of the test method for tests • Derive data from test method • Calculation and assessment of “efficiency” within regulation

7. General Philosophy • Measure and save real energy • Sensitive to wide differences in product usage • Aggregate consumption in use • Focus on excess energy use • Not restrict design • Don’t separately regulate each contributing element

8. Key differences from earlier approaches • Inclusion of active mode • Cycle normalized to 168 hours

9. Key similarities • System Approach • Our products are really sold as systems • Focus on excess energy use • Maintenance and standby are already excess • Active includes retrievable energy of battery • Interest in active should be on excess consumed in conversion losses, acceptance losses, etc

10. Regulation Philosophy Uses ER = Ea/Eb approach • Ea is the accumulated excess energy used by the BCS • Eb is energy retrieved from battery • Consider excess energy as the energy not retrievable from the battery • Ideal BCS would have zero excess energy • Retain as much of existing appliance methods as practical

11. Differences • Include measurement of charging cycle (aka- active mode) • Use a few categories of Active, Maintenance, Stand By times as characteristic • Normalize Ea to 168h (1 week) usage • Avoid having test engineer open up the battery or appliance • Maintain safety of technician without compromising design confidentiality

12. Test Procedure • Use Ecos test method for measurement of active energy, no-battery mode energy, and maintenance energy • With suggested simplifications

13. Calculation of Eb – Battery Energy • Manufacturer reports Wh on battery or integral product using Ecos method • With modification for electronic cut-off • Consistent with IEC standards • Avoid conflict with UN/DOT for Li-ion • CEC require data submittal

14. Use of test method • Ec = E24-Eb • Pm = Pm • Ps • Detachable – Ps=Pnb using method 2 • Integral • Wall adapter – Ps=Pnb using method 3 • AC cord – Ps=0

15. Four BCS Categories • Infrequently charge – • e.g. shavers cord • Integral, cord connected or adapter • Charge once in two weeks or less, then disconnected • Cradle based chargers – • e.g. Cordless Vacuums with Charging Base • Integral, cord connected or adapter • Charged once per week or less, then left connected

16. BCS Categories (tools) • Consumer (detachable) • e.g. “homeowner” power tools • three charges/week/battery • Remainder - mix of maintenance and standby • Product sold w/ one battery • Professional (detachable) • e.g. Professional or Industrial Cordless Tools • Five charges/week/battery • Remainder – mix of maintenance and standby • Product sold w/ two+ batteries

17. Categories • Approximate based on intended use • Does not require analysis of product to categorize

18. Formulas 168 hrs per week

19. Special cases • Medical products—regulated by FDA • Recommend exclusion • Have additional safety requirements • Low volume • Low voltage or inductively charged • Inherently less efficient—conversion • Safety issues • Less opportunity

20. Agreement Can we arrive at agreement to regulate appliance battery chargers differently? Separate the energy savings info by product type. Recognize manufacturers need time. Draw cutoff on graph using battery voltage as X axis? Look at with data. Special cases