LBNL Report Number
Enforcement of appliance standards and consumer trust in appliance labeling are important foundations of growing a more energy efficient economy. Product certification and verification increase compliance rates which in turn increase both energy savings and consumer trust. This paper will serve two purposes:1) to review international practices for product certification and verification as they relate to the enforcement of standards and labeling programs in the U.S., E.U., Australia, Japan, Canada, and China;and 2) to make recommendations for China to implement improved certification processes related to their mandatory standards and labeling program such as to increase compliance rates and energy savings potential.
Practices for product certification and verification vary across the world, with some programs focusing solely on either certification or verification (such as in Australia and Canada) and other programs focusing on both (such as ENERGY STAR in the U.S.). Accreditation practices for testing laboratories and certification bodies also vary, and some appliance standards and labeling programs are building databases to house all information on products and compliance.
Costs are imposed on manufacturers and program administrators when either product certification or verification processes are implemented. When designing or refining standards and labeling programs,program administrators make a comparison (estimation or calculation) of the costs of non-compliance to the costs of various third party certification and verification processes. The costs of third party processes fall on manufacturers (often passed on to consumers) and administrators (often paid for with taxpayer money), while the costs of non-compliance fall on consumers (in lost savings), society(increased costs associated with energy and climate change), and some manufacturers (those who do not comply and go unpunished have an advantage over those that do comply). A standards and labeling program decision on which monitoring methods to use (certification and/or verification) are based on a number of factors including legal framework, cost and budget, human resources, number of products,number of manufacturers, whether the program is voluntary or mandatory, and other factors.
For instance, when the U.S. Environmental Protection Agency (EPA) designed new certification and verification processes for its ENERGY STAR program, it tried to minimize costs for manufacturers and itself as the administrator. Recognizing that there would be new costs for any process involving a certification body and a third party testing laboratory, the EPA decided to allow witnessed manufacturer testing laboratories as a lower cost option for manufacturers that already had testing laboratories in place. Although the tests still have to be witnessed by a certification body, the cost of this process is lower than sending products to third party laboratories for testing.
The EPA was able to ramp up their new certification and verification processes in a relatively short amount of time by focusing on existing legal frameworks and processes that were similar in function to the ones they were implementing. For example, there were already internationally recognized standards for accrediting and operating the certification bodies that are integral to EPA's product certification and verification processes, so EPA incorporated these directly into their new requirements. The EPA requires paperwork for all accreditation, certification, and verification performed relevant to products in the ENERGY STAR program; while this increases administrative burden, it provides them with a database of information that helps to guarantee the integrity of the ENERGY STAR label and the savings the label provides to consumers.
In China, the number of products covered by its mandatory standards program and labeling program has rapidly increased in recent years up to 44 products and 23 products, respectively. Now, China is seeking to improve the compliance rate for these products, but it wants to do so without reinventing its current organizational structure. China has bodies that oversee certification and accreditation processes under the authority of the General Administration of Quality, Supervision, Inspection and Quarantine. For instance, the Certification and Accreditation Commission of China oversees all certification and accreditation processes for product testing laboratories and certification bodies and specifically places the authority of accreditation with the China National Accreditation Service for Conformity Assessment.There are currently no standardized product certification and verification processes in place for China's mandatory standards and labeling program.1 The common practice is have to have manufacturer's "self-declare" the energy efficiency performance of their products based on testing in their own laboratories or third party laboratories. Introducing third party product certification and verification for China's mandatory standards and labeling programs has the potential to significantly improve compliance levels without heavy administrative burden. Having reviewed international practices in product certification and verification, we offer the following summary recommendations for China to improve its practices in this space:
Organize certification bodies: A call for certification bodies in energy efficiency standards should be organized, and the accreditation for these bodies can be managed by the China National Accreditation Service for Conformity Assessment or other accreditation bodies.
Mandate certification process: New regulations should be announced to mandate that all new models in product categories covered by mandatory standards or labeling requirements need to have their performance and labeling information certified by these certification bodies prior to being sold.
Allow witness testing: Provisions can be made in the certification requirements to allow manufacturers to use in-house testing laboratories to produce performance and labeling information, so long as the tests are witnessed by an accredited certification body. This provision should allow for a lower cost of certification and compliance for the manufacturers, when the new certification requirements are introduced.
Adapt from international standards: If gaps of knowledge exist in China's current accreditation and certification system to adequately meet the needs of the new requirements for energy efficient product certification, ISO and IEC standards used internationally can provide a good reference for various conformity assessment practices such as staff competence and impartiality.
Standardize verification testing: If China would like to impose stricter standards beyond certification and achieve a higher level of integrity for its standards and labeling (albeit at increased cost), it can also introduce a standardized system for verification testing.