DOCKETED  
Docket Number:  20-AAER -04 
Project Title:  Appliance Efficiency Standards Regulations for Portable 
Electric Spas  
TN #:  237794  
Document Title:  Staff Paper - Proposed Test Procedure and Labeling 
Requirements for Portable Electric Spas  
Description:  Staff paper for portable electric spas appliance efficiency 
rulemaking.  
Filer:  Jessica Lopez  
Organization:  California Energy Commission  
Submitter Role:  Commission Staff   
Submission Date:  5/14/2021 9:05:45 AM  
Docketed Date:  5/14/2021  
  
 California Energy Commission  
STAFF PAPER  
Proposed Test Procedure and 
Labeling Requirements for 
Portable Electric Spas  
Jessica Lopez  
Primary Author 
Leah Mohney  
Supervisor  
Standards and Tools Unit  
Pierre H. duVair, Ph.D.  
Office Manager 
Appliances Office  
Michael J. Sokol Deputy Director  
Efficiency Division  
Drew Bohan Executive  Director  
Gavin Newsom, Governor  
APRIL  2021 |CEC- 400- 2021- 005  
  
DISCLAIMER  
Staff members of the California Energy Commission prepared this report. 
As such, it does not necessarily represent the views of the Energy 
Commission, its employees, or the State of California. The Energy 
Commission, the State of California, its employees, contractors and 
subcontractors make no warrant, express or implied, and assume no legal 
liability for the information in this report; nor does any party represent 
that the uses of this information will not infringe upon privately owned 
rights. This report has not been approved or disapproved by the Energy 
Commission nor has the Commission passed upon the accuracy or 
adequacy of the information in this report.  i 
 PREFACE  
On April 11, 2018, the California Energy Commission (CEC) adopted changes to Appliance 
Efficiency Regulations  (California Code of Regulations, Title 20, Sections 1601 through Section 
1609) amending the existing appliance efficiency regulations for portable  electric spas. The 
amended regulations for portable electric spas included scope clarifications ; more stringent 
efficiency standards for standard, exercise, and combination spas ; a separate efficiency 
standard for inflatable spas to encourage the design and development of more efficient 
inflatable spas ; test procedure modifications to accommodate exercise spas and combination 
spas; additional test lab report requirements to verify compliance ; and a labeling requirement 
to help consumers make informed choic es. The test procedure and label design requirements 
are derived from ANSI/APSP/ICC -14 (APSP -14), American National Standard for Portable 
Electric Spa Energy Efficiency, Version 2014. 
On November 19, 2019, the American National Standard Institute published the revised APSP -
14, Version  2019. The revised APSP -14 aligns with California’s efficiency standards, label ing 
requirements, and test procedure requirements for portable electric spas adopted in 2018. 
Other changes adopted in the revised APSP -14, include modifications to simplify test lab 
qualification and label application clarifications.  
On August 12, 2020, the CEC issued an order instituting rulemaking to consider modifying the 
existing regulations found in the Appliance Efficiency Regulations . The goal of the rulemaking 
is to update the test procedure and labeling requirements for portable electric spas with the latest industry standard. Additional changes to the Appliance Efficiency Regulations may also be considered as necessary.  
The CEC reviewed all the information received. This paper contains the proposed regulations 
for portable electric spas based on comments received during the meetings mentioned above and in writing in the C EC’s docket  for this rulemaking . 
  ii 
 ABSTRACT  
This paper discusses proposed updates to the portable electric spa regulations in the Appliance 
Efficiency Regulations  (California Code of Regulations, Title 20, Sections 1601 to 1609). These 
proposed updates are  part of the 2020 Appliance Efficiency Rulemaking (Docket #2020 -AAER -
04). The proposed updates include, but are not limited to, test procedure and labeling 
requirements with the latest industry standard.  
The proposed updates for portable electric spas are proposed to take effect on filing with the  
California Secretary of State . 
Existing efficiency standards and the scope of  coverage for portable electric spas will not be 
affected. Therefore, statewide energy use and savings, and related environmental impacts and 
benefits , will not be affected.  
Keywords : Appliance efficiency regulations, appliance regulations, portable electric spas,  test 
procedures, labeling, compliance  
Please use the following citation for this report:  
Lopez, Jessica. 2021 . Proposed Test Procedure and Labeling Requirements for Portable Electric 
Spas.  California Energy Commission. Publication Number : CEC- 400-2021-005. 
  iii 
 TABLE OF CONTENTS  
Page 
Preface  ................................................................................................................................ i 
Abstract ............................................................................................................................. ii 
Table of Contents ............................................................................................................... iii 
List of Figures  .................................................................................................................... iv 
List of Tables  ..................................................................................................................... iv 
Executive Summary  ............................................................................................................. 1 
CHAPTER 1: Regulatory Approaches  .................................................................................... 3 
California Appliance Efficiency Standards  ....................................................... 3 
Federal Approaches  ...................................................................................... 5 
Industry Standards  ....................................................................................... 5 
Other State Approaches  .............................................................................. 13 
CHAPTER 2: Proposed Regulations for Portable Electric Spas  ............................................... 16 
Scope  ........................................................................................................ 16 
Definitions  ................................................................................................. 16 
Test Procedure ........................................................................................... 16 
Test Lab Report Requirements  .................................................................... 17 
Efficiency Standards  ................................................................................... 17 
Reporting Requirements  ............................................................................. 17 
Labeling Requirements  ............................................................................... 17 
CHAPTER 3: Savings and Cost Analysis  .............................................................................. 20 
Incremental Costs  ...................................................................................... 20 
Statewide Savings  ...................................................................................... 20 
Impacts to Small Businesses  ....................................................................... 21 
CHAPTER 4: Environmental Impacts  ................................................................................... 22 
Energy Impacts  .......................................................................................... 22 
Environmental Impacts  ............................................................................... 22 
References  ....................................................................................................................... 23 
Glossary  ........................................................................................................................... 24 
APPENDIX A: Acronyms  ................................................................................................... A- 1 
 iv 
 LIST OF FIGURES  
Page 
Figure 1 -1: Sample of California’s Labeling Requirement for Spas  .......................................... 4 
Figure 1 -2: Qualification Summary for Test Laboratories and Certification Bodies  .................... 6 
Figure 1 -3: Sample of Label Requirement per APSP -14, Version 2014 .................................... 8 
Figure 1 -4: Qualification Summary for Test Laboratories and Certification Bodies per  APSP- 14, 
Version 2019  ...................................................................................................................... 9 
Figure 1 -5: Sample of Label Requirement per APSP -14, Version 2019 .................................. 10 
Figure 1 -6: International Swimming Pool and Spa Code Adoption Map ................................. 12 
Figure 2 -1: Label Design Comparison Between APSP -14, Version 2014 and CCR Title 20  ....... 18 
Figure 2 -2: Label Design Comparison Between CCR Title 20 and APSP -14, Version 2019  ....... 19 
 
LIST OF TABLES  
Page 
Table 1 -1: Recently Adopted or Pending Standards for Portable Electric Spas  ....................... 14 
Table 3 -1: Estimated Test Lab Savings for Manufacturers  .................................................... 21 1 
  
EXECUTIVE SUMMARY  
This paper presents the California Energy Commission staff analysis of proposed test 
procedure and labeling requirement  updates for portable electric spas. 
Staff proposes  to update the test procedure reference and update the labeling design 
requirements for portable electric spas. The scope of coverage will remain the same and 
continue to cover all type s of portable electric spas, such as standard spas, exercise/swim 
spas, combination spas, and inflatable/collapsible spas. The  existing  minimum  performance 
efficiency standards for portable electric spas will not be affected. The proposal also includes 
changes to simplify the structure  of existing regulations for portable electric spas. The 
proposal staff is recommend ing derive s from a recent update to the industry standard  for 
determining the efficiency of portable electric sp as, ANSI/APSP/ICC -14, Version 2019. 
  2 
  3 
 CHAPTER 1:  
Regulatory Approaches  
California Appliance Efficiency Standards  
In 2004, the California Energy Commission (CEC)  adopted the first set of standards for 
portable electric spas , which took effect i n 2006. The standards included setting the scope, 
test procedure requirements, test lab report requirements, and a performance standard 
requiring that the standby power of a spa must not exceed a sliding scale of wattage as a 
function of the volume of a spa : [5 x Volume2/3].1 The test procedure and performance 
standard w ere based on a collaborative effort that included major spa manufacturers, the CEC, 
and the California Investor Owned Utilities (IOUs) Codes and Standards Enhancement (CASE) 
Team.2  
On Apri l 11, 2018, the CEC adopted changes to Title 20 , Sections 1602- 1607 amending the  
existing appliance efficiency regulations for portable electric spas. The industry- approved 
standard ANS I/APSP/ICC- 14 (APSP -14), American National Standard for Portable Electr ic Spa 
Energy Efficiency , Version 2014 was the basis for the updated amendments to the regulations 
for portable electric spas. The amended regulations are in effect for portable electric spas 
manufactured on or after  June 1, 2019.  The amended regulations for portable electric spas 
include : 
• Scope clarifications  – specifying the inclusion of inflatable spas, exercise spas, and 
combinations spas . 
• A more stringent standby power limit of [3.75 x Volume2/3 +40]  for standard, 
exercise, and combination spas . 
• A separate efficiency standard for inflatable spas to encourage the design and 
development of more efficient inflatable spas . 
• Updating the test procedure to ANSI/APSP/ICC -14, Version  2014 with modifications  to 
accommodate exercise spas and combination spas . 
• Additional test lab report requirements to verify compliance . 
 
 
1 Lopez, Jessica. Final Staff Report: Analysis of Efficiency Standards and Marking for Spas.  CEC-400-2018-002. 
Sacramento: California Energy Commission, 2018. Docket Number: 2018- AAER -02 
2 Davis Energy Group, Energy Solutions. (2004). Codes and Standards Enh ancement Initiative for PY2004: Title 
20 Standards Development - Analysis of Standards Options for Portable Electic Spas.  Pacific Gas and Electric.  4 
 • Test lab qualification requirements to ensure proper testing . 
• Additional listing requirements to the appliance efficiency database . 
• A labeling requirement , based on the label design in ANSI/APSP/ICC -14, Version  2014,  
to help consumers make informed choices, as shown in Figure 1-1. 
Figure 1 -1: Sample of California’s Labeling Requirement for Spas  
 
Note: Leaf color equivalent to Pantone 363 green; Water drop color equivalent to Pantone 7691 blue.  
Source: California Energy Commission  5 
 Several modifications were made to APSP -14, Version 2014, in this update, and subsequently 
the label design in APSP -14, Version  2014,  had to be modified to be reflective of those 
modifications. Therefore, to differentiate between the label design in APSP -14, Version 2014, 
and the modified label design that meets California’s requirements, “California” was added to 
the titl e in the label. A detailed discussion of these amendments is provided in the 2018 Final 
Staff Report: Analysis of Efficiency Standards and Marking for Spas  3 and in the Final 
Statement of Reasons.4 
Federal Approaches  
There is no federal standard and no E NERGY STAR ® specification for portable electric spas.  
Industry Standards  
ANSI/APSP/ICC- 14 
The ANSI/APSP/ICC- 14, American National Standard for Portable Electric Spa Energy 
Efficiency , is a voluntary standard approved by the American National Standard Insti tute 
(ANSI), published in partnership with the International Code Council (ICC), and prepared by the Pool & Hot Tub Alliance (PHTA) writing committee, formerly the Association of Pool and 
Spa Professionals ( APSP), to provide guidelines for testing and meas uring the energy efficiency 
of portable electric spas. The standard is based on the 2004 adoption of California’s appliance 
efficiency regulations for portable electric spas.  
The first iteration of the industry standard ANSI/APSP/ICC -14 (APSP -14) was published on 
January 4, 2011. The maximum standby power limit for spas matched the performance 
standards in California,  [5 x Volume
2/3]. The 2011 version expanded on California’s appliance 
efficiency regulations for portable electric spas  by improving the test method with additional 
details to ensure reliability and repeatability. The standard deviate d from California’s standards 
by incorporating a test lab qualification requirement, guidelines for minimum chamber requirements , and a labeling requirement displaying energy performance information. The test 
lab qualification required testing laboratories to demonstrate the ability  to perform the tests in 
APSP- 14 by a third -party certification body. The certification body was required to  be 
accredited by a member of the International Accreditation Forum using ISO/IEC Guide 17065, 
 
 
3 Lopez, Jessica. Final Staff Report: Analysis of Efficiency Standards and Marking for Spas . CEC -400-2018-002. 
Sacramento: California Energy Commission, 2018. Docket Number: 2018- AAER -02. 
4 California Energy Commission. (2018, July 23). Final Statement of Reasons for Portable Electric Spas and 
Battery Charger Systems. Docket # 18 -AAER -02, TN#224256.  6 
 General Requirements for  Bodies Operating Product Certification Systems .5 Testing 
laboratories, whether they are accredited to ISO/IEC 17025 or not, were required to  be 
assessed by a third -party certification body, as summarized in Figure 1 -2 below.6 The 
labeling requirement required manufacturers to include the measured standby power 
consumption near the product’s label.7 
Figure 1 -2: Qualification Summary for Test Laboratories and Certification Bodies  
 Certification Body 
(CB)
Accredited by a member of 
International Accreditation 
Forum 
 
 Non-Accredited 
Test Laboratories
CB shall assess the testing 
laboratory's quality system 
to determine that it 
satisifies applicable 
requirements of ISO/IEC 
17025
CB evaluates the laboratory's 
facilities, test equipment, 
testing personnel and test 
procedures
CB audits annuallyAccredited Test 
Laboratories
Accredited to ISO/IEC 
17025 by a member of the 
International Laboratory 
Accreditation Cooperation
CB is permitted to accept 
the testing laboratory's 
accreditation as evidence of 
conformity
CB evaluates the laboratory's 
facilities, test equipment, 
testing personnel and test 
procedures
CB audits every three years
Source: ANSI/APSP/ICC -14, Version 2011  and Version 2014.  
The second revision of the standard was approved by ANSI on September 12, 2014 . The 
standard  required a more stringent standby power limit of [3.75 x Volume2/3 +40] for  
traditional sized portable electric  spas and a standby power limit of [5 x Volume2/3] for exercise 
5 Previously, ISO/IEC 65 General Requirements for Bodies Operating Product Certification Systems  in the 2011 
and 2014 versions of ANSI/APSP/ICC -14. 
6 ISO/IEC 10725 – General Requirements for the Competence of Testing and Calibration Laboratories . 
7 The Asso ciation of Pool & Spa Professionals. (2011, January 4). American National Standard for Portable Hot 
Tub Energy Efficiency. Alexandria, Virginia: The Association of Pool & Spa Professionals.  7 
 portable electric spas. The standard provide d specific testing  conditions  for exercise spas and 
combination spas. In addition, the standard require d labels on all spas to include information 
on spa volume, standby power, the maximum standby power allowed, total annual 
consumption in standby mode, annual standby energy cost, specified cover manufacturer, specified cover model number, spa manufacturer, and spa model number , as shown in Figure 
1-3. The label was required to  be printed on a removable adhesive -backed label and remain 
adhered to the spa until point of sale to the consumer. Lastly, the standard  still required all 
testing laboratories to be qu alified by an accredited certification body to ensure the testing 
facility, testing equipment, and personnel can perform the tests in the standard , as described  
in Figure 1 -2.
8 
 
 
8 The Association of Pool & Spa Professionals. (2014, September 12 ). American National Standard for Portable 
Electric Spa Energy Efficiency. Alexandria, Virginia: The Association of Pool & Spa Professionals.  8 
 Figure 1 -3: Sample of Label Requirement p er APSP -14, Version 2014  
 
Note: Leaf  color equivalent to Pantone 363 green; Water drop color equivalent to Pantone 7691 blue.  
Source: ANSI/APSP/ ICC-14, Version 2014 
The latest revision of APSP -14 was approved by ANSI on November 19, 2019. As noted  
previously, California’s appliance efficiency regulations for portable electric spas , adopted in 
April 2018, include  several modifications to APSP -14, Version  2014. Those modifications were 9 
 incorporated in to the recently revised,  APSP- 14, Version  2019. Those incorporated updates 
include adding inflatable spas into the scope ; a more stringent standby power limit of [3.75 x 
Volume2/3 +40] for standard, exercise, and combination spas ; a separate efficiency standard  of 
[7 x Volume2/3] for inflatable spas ; and test procedure clarifications  to support the updated 
scope and performance standards. Other notable changes  include  updates to the  test lab 
qualification requirements and label design requirements.  Test laboratories accredited to 
ISO/IEC 17025, no longer must be evaluate d and approved by an additional third-party 
certification body to prove conformity to APSP -14. Only non- accredited test laboratories sha ll 
be evaluated by a certification body to demonstrate competency to APSP -14, as summarized in 
Figure 1 -4. 
Figure 1 -4: Qualification Summary for Test Laboratories and Certification Bodies 
per APSP -14, Version 2019  
 Certification Body 
(CB)
Shall be accredited to ISO/IEC 
17065Non-Accredited Test 
Laboratories
CB shall assess the testing 
laboratory's quality system to 
determine that it satisifies 
applicable requirements of 
ISO/IEC 17025
CB evaluates the laboratory's 
facilities, test equipment, 
testing personnel and test 
procedures
CB audits annuallyAccredited Test 
Laboratories
Accredited to ISO/IEC 17025 
by a member of the 
International Laboratory 
Accredition Cooperation 
Test laboratory shall stay 
accredited on a continuing basis 
and certificate of accreditation 
must be available when 
requested
Source: ANSI/APSP/ICC -14, Version 2019  
In addition, the label design was updated to include the capacity of the spa,  rate volume, print 
date, listing of spa cover model number(s) and manufacturer(s), and details ensuring that only 
tested spa covers may be sold with the spa , as shown in Figure 1 -5. Lastly, the standard now 
include s instructions for labeling combination spas and inflatable spas.  10 
 Figure 1 -5: Sample of Label Requirement per APSP -14, Version 2019  
 
Note: Leaf color equivalent to Pantone 363 green; Water drop color equivalent to Pantone 7691 blue.  
Source:  ANSI/APSP/ICC -14 version 2019  11 
 International Code Council  
The 2012 and 2015 International Swi mming Pool and Spa Code (ISPSC) and the 2015 
International  Energy Conservation Code  (IECC) developed by the ICC adopted the energy  
consumption requirements of ANSI/APSP/ICC -14, Version 2011.  The 2018 ISPSC , the 2018 
IECC, and the 2018 International Residential Code  (IRC) reference ANSI/APSP/ICC- 14, Version 
2014.  The upcoming 2021 cycles of these I -codes are expected to  be updated to reference the 
2019 version of ANSI/APSP/ICC- 14.9 
As of February 2 021, the ISPSC  is in use or has been adopted by local governments and/or 
statewide in 2 6 states , the District of Columbia , and U.S Virgin Islands  (Figure 1-6). The IECC 
is in use or adopted in all states (except California and Indiana), the District of Columbia, 
Puerto Rico, and the U.S Virgin Islands.  The IRC is in use or adopted in all states (except 
Wisconsin), the District of Columbia, Puerto Rico, and the U.S. Virgi n Islands.10 
 
 
9 I-codes  developed by the International Code Council available  at http://shop.iccsafe.org/codes.html . 
10 International Codes Adoption by State list  available at http://www.iccsafe.org/international -code-adoptions / as 
of October 19, 2020. 12 
 Figure 1 -6: International Swimming Pool and Spa Code Adoption Map 
 
Source: International Code Council  (October 19 , 2020).  
  13 
 Other State Approaches  
Arizona, Oregon , and Connecticut  currently have a maximum standby power limit  of [5 x 
Volume2/3] for portable electric spas, match ing California’s  performance standards established 
in 2004.11,12,13 Several states have also begun  to issue proposals to add or amend their 
appliance efficiency regulations to adopt APSP -14, Version  2014 or Version  2019, see Table 1 -
1. The inclusion of APSP -14, Version  2019 is also in the latest Appliance Standards Awareness 
Project (ASAP) Model Bill.14 
 
 
11 Arizona State Legislature. Title 44, Chapter 9, Article 19, 1375.02.  
12 Oregon State Statue s. Chapter 469. Section 469.233.  
13 Connecticut General Assembly. Chapter 298, Title 16, Section 16a -48. 
14 Appliance Standards Awareness Pro ject. (2020). States . Retrieved from Appliance Standards Awareness 
Project: https://appliance -standards.org/states  14 
 Table 1 -1: Recently Adopt ed or Pending Standards for Portable Electric Spas  
State  Referenced  Standard Effective Date  
Colorado15 APSP- 14 (2014) January 1, 2021  
Connecticut16 APSP- 14 (2019)  January 1, 2022 * 
Hawaii17 APSP- 14 (2019)  January 1, 2022 * 
Illinois18 APSP- 14 (n/a)  January 1, 2021 * 
Massachusetts19 APSP- 14 (2019)  January 1, 2022 * 
Oregon20 APSP- 14 (2019)  January 1, 2022  
Pennsylvania21 APSP- 14 (2019)  January 1, 2022 * 
Rhode Island22 APSP- 14 (n/a)  January 1, 2022 * 
Vermont23 APSP- 14 (2014)  July 1, 2020  
Washington24  APSP- 14 (2014)  January 1, 2020  
Washington D.C.25 APSP- 14 (n/a)  2021/2022* 
Notes: *Pending adoptions ; (n/a) – version is not specified ; assumption is the latest version will be 
required. 
 
 
15 Colorado Revised Statues. Title6. Article 7.5.  
16 Connecticut General Assemb ly – Raised Senate Bill 178 , Session Year 2020. Retrieved from 
https://www.cga.ct.gov/asp/CGABillStatus/cgabillstatus.asp?selBillType=Bill&bill_num=SB178. 
17 Hawaii State Legislature  – Senate Bill 3024 , Session Year 2020. Retrieved from 
https://www.capitol.hawaii.gov/measure_indiv.aspx?billtype=SB&billnumber=3024&year=2020. 
18 Illinois General Assembly – House Bill 3658 , Session Year 2019. Retrieved from 
https://www.ilga.gov/legislation/BillStatus.asp?DocNum=3658&GAID=15&DocTypeID=HB&LegId=120377&Sessi
onID=108&GA=101 . 
 
 15 
  
 
19 Commonwealth of Massachusetts – Bill S.2478 , Session Year 2020. Retrieved from 
https://malegislature.gov/Bills/191/S2478. 
20 Oregon Department of Energy, Chapter 330, Division 92 . Retrieved from 
https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=1103. 
21 Pennsylvania General Assembly. House Bill 2136 , Session 2019- 2020. Retrieved from 
https://www.legis.state.pa.us/cfdocs/billInfo/BillInfo.c fm?syear=2019&sind=0&body=H&type=B&bn=2136. 
22 Rhode Island State Legislature. Senate Bill 2043 , Session Year 2020. Retrieved from 
http://webserver.rilin.state.ri.us/BillTe xt20/SenateText20/S2043.pdf. 
23 Vermon t Statues. Title 9. Chapter 74. Section 2791 -2798.  
24 Revised Code of Washington . Title 19. Chapter 19.260. Section 19.260.040. Adopted on January 06, 2020.  
25 Council of the District of Columbia. Bill 23 -204, Session Year 2020. Retrieved from 
https://lims.dccouncil.us/Legislation/B23- 0204?FromSearchResults=true . 16 
 CHAPTER 2:  
Proposed Regulations for Portable Electric Spas  
The proposed updates would maintain the existing scope, covering all types of portable 
electric spas such as standard spas, exercise spas, combination spas, and inflatable spas . The 
existing minimum performance efficiency standards for portable electric spas will not be 
affected. The proposed changes are based on updating all references of ANSI/A PSP/ICC- 14 
(APSP -14), V ersion  2014 to the 2019 version. As discussed in Chapter 1, existing regulations 
for portable electric spas in California are incorporated in APSP -14, Version  2019 except where 
noted in the following paragraphs. The proposed updates for portable electric spas are 
proposed to take effect  on filing with the  California Secretary of State . 
Scope  
There are no proposed changes to the scope for portable electric spas  set forth in the 
California Code of Regulations (CCR), Title 20, Section 16 01. 
Definitions  
The proposed change  to the definitions supporting the regulations for portable electric spas 
set for th in CCR, Title 20, Section 1602, is in the definition for “fill volume,” which includes the 
removal of a reference  to the test method description  that is being supplanted by APSP -14, 
Version 2019. The change is minor and does not affect the meaning of the term or its 
definition. 
Test Procedure 
Staff recommends all portable electric spas be tested in accordance with APSP- 14, Version 
2019, with no modifications. In April 2018 , the CEC adopted the test procedure APSP- 14, 
Version  2014, with modifications  for portable electric spas  to reflect the energy use of 
combination spas and exercise spas. These modifications have now been included in the 
recently revised APSP -14, Version  2019. Therefore,  the testing conditions and testing method 
for determining the standby power consumption remain the same. Differences between 
California’s existing appliance efficiency regulations for portable electric spas and APSP -14, 
Version  2019, are updates to the te st lab qualification requirements . Existing test lab 
certification requirements in APSP -14, Version  2014, specify that test labs must be qualified by 
a third -party certifier to verify competency, whether the test lab is accredited to ISO/IEC 
17025 or  not. APSP- 14, Version 2019, requires an unaccredited test lab to be qualified by a 
third-party certifier . 
In addition, staff is proposing to remove expired  test procedure requirements that applied to  
portable electric spas manufactured prior to June 1, 2019, which are no longer applicable. 17 
 Test Lab Report Requirements  
Staff is continuing to recommend test lab report requirements for portable electric spas.  This 
includes reporting data required per CCR, Title 20, Section 1606, Table X , Appendix D of APSP-
14, Version  2019, and other r equirements such as  listing temperature control accessories for 
inflatables spas, and data plot figures of the water temperature, ambient air temperature, 
voltage, and current. Many of the test lab report requirements remain the same except for the 
name of the test technician, test location, picture of test ed spa in chamber, and picture of data 
plate of tested spa, all of which are included in Appendix D of APSP -14, Version  2019.  
Changes proposed in CCR, Title 20, Section 1604 update the referenced test procedure and 
consolidates existing test lab report requirements that are incorporated in APSP -14, Version  
2019.  
Efficiency Standards  
The proposed changes to the efficiency standards for portable e lectric spas  set forth in CCR, 
Title 20, Section  1605.3, are changes to clarify the regulatory language  and efficiency 
standards of portable electric spas that are no longer applicable . However, CEC staff is not 
proposing to change the minimum level of operating efficiency of portable electric spas .  
The changes proposed eliminate references to APSP -14, Version  2014, for calculating the 
normalized standby power. Staff is proposing to replac e the references of Section 6.1 through 
6.3 of APSP -14, Version  2014, with equations used to calculate the normalized standby power. 
These equations are the same as those referenced in APSP -14, Version  2014 and Version  
2019, and do not change the existing efficiency standard . 
Reporting Requirements  
The proposed changes to the reporting requirements set forth in the C CR, Title 20, Section 
1606 Table X, involve removing the outdated qualifier “ (applie s to models manufactured on or 
after June 1, 2019 only)” to simplify the regulatory language, since that date has p assed and 
the requirements apply to models currently being manufactured and tested . 
Labeling Requirements  
Staff continues to recommend labeling requirements for portable electric spas. The current 
label design requirement derives from APSP -14, Version  2014. The language on the label  from 
APSP- 14, Version  2014, was amended in the Appliance Efficiency Regulations  to be 
representative of the modifications made to the test procedure, for the standardization of the 
label to verify compliance, and several other modifications for consumers to easily compare between spas. For example, the California -specific label requires manufacturers to display 
performance data of the least efficient spa cover -unit combination, which encourages  the 
customer to purchase a more efficient choice, encourages  retailers to present efficient options, 
and encourages  manufacturers to use more efficient spa covers.  However , the APSP -14, 
Version  2014, label requirement allows the manufacturer to display the performance data of 
any spa cover -unit combination preventing label standardization. Hence the inclusion of 
“California” in the title and several references to CCR, Title 20.  18 
 Figure 2 -1: Label Design Comparison Between  APSP -14, Version  2014 and CCR 
Title  20 
 
(Left) APSP- 14, Version  2014 (Right) California specific label design. Note: Leaf color equivalent to Pantone 
363 green; w ater drop color equivalent to Pantone 7691 blue. Red tags indicate a change from the APSP -
14, Version 2014 label design.  
Source:  California Energy Commission  and APSP- 14, Version 2014  
Staff propos es label requirements that meet the design specifications of APSP -14, Version 
2019, with no modifications. The requirements of the data displayed in the California specific 
label and the label in the revised APSP -14, Version  2019, are the same . Proposed changes 
include removing all references to CCR, Title 20, see Figure 2 -2. The APSP -14, Version  2019, 
label language references “ANSI/APSP/ICC -14” without indicating the version year. Therefore, 
to assist in compliance verification, staff is proposing an optional reference to state “2019” 
following “ANSI/APSP/ICC -14.” Although there are discernable differences between the 
California version, the 2014 version, and the 2019 version label de signs,  these differences are 
not apparent to those without knowledge of APSP -14. Other changes include clarifications for 
labeling combination spas and changing the label height from 6.25 inches to 6.75 inches. 
 19 
 Figure 2 -2: Label Design Comparison  Between  CCR Title 20 and APSP- 14, Version  
2019  
 
(Left) California specific label design (Right) APSP -14, Version 2019 , label design. Note: Leaf color 
equivalent to Pantone 363 green; w ater drop color equivalent to Pantone 7691 blue.  Red tags indicate a 
change fro m the California specific label design.  
Source: California Energy Commission  and APSP- 14, Version 2019 20 
 CHAPTER 3:  
Savings and Cost Analysis 
The proposed updates will not affect existing efficiency standards and the scope  of coverage 
for portable electric spas. Therefore, statewide energy use and savings and environmental 
impacts and benefits  related to efficiency standards  will also not be affe cted. In addition, the 
proposed updates are cost -effective and technically feasible, as explained in this chapter . 
Incremental Costs  
The cost of changes to the labeling design requirements are negligible since it is only necessary to update the template la bel design in the labeling software. The printing costs, 
which include material costs, ranges from $0.22 to $0.44 per unit.
26 Changing  the minimum 
labeling height from 6.25 inches to 6.75 inches is proportional  to a size increase of 8 percent . 
The material  cost to increase the minimum labeling height  ranges from less than $0.01 to 
$0.02 per unit.27 Therefore, the material cost s to increase the minimum labeling height  is also 
negligible. There are no changes to  the number of labels being applied or label application.  
There are no incremental costs associated to updating the test procedure reference. The test method for determining the efficiency of portable electric spas remains the same.  
Statewide  Savings 
The test lab qualification requirements being proposed differ from existing requirements. 
Existing test lab certification requirements in APSP -14, Versio n 2014 , specify test labs must be 
qualified by a third -party certifier to verify competency, whether the test lab is accredited to 
ISO/IEC 17025 or n ot. APSP -14, Version  2019, requires only an unaccredited test lab to be 
qualified by a third -party certifier. Accreditation to ISO/IEC 17025 can be a demanding and 
costly process, suited for major testing facilities testing several types of appliances and testing 
characteristics other than efficiency. Requiring an additional third -party certifier to verify 
accreditation is redundant and an unnecessary cost for manufacturers. The estimated savings of manufacturers using accredited test labs is approximately $1,667 per year, details of this 
estimate are shown in the table below.  
 
 
26 Lopez, J essica (2018). Final Staff Report: Analysis of Efficiency Standards and Marking for Spas . Sacramento: 
California Energy Commission. Retrieved from 
https://efiling.energy. ca.gov/Lists/DocketLog.aspx?docketnumber=18- AAER -02  
27 Staff assumes material costs are 50 percent of the printing costs. 21 
 Table 3 -1: Estimated Test Lab Savings for Manufacturers  
Description  Value  Units  
Test Lab Qualification by a Third -Party Certifier  $5,000  Per Test Lab  
Number of Portable Electric Spa Test Labs as of 2020  24 Test Labs  
Number of Accredited Portable Electric Spa Test Labs as of 2020  11 Test Labs  
Qualification Renewal Rate for Accredited Test Labs per APSP -14, 
Version  2014 3 Years  
Total Savings per Accredited Test Lab  $1,667  Per Year  
Total Statewide Savings  $18,333  Per Year  
Source: California Energy Commission and Energy Commission ’s Modern  Appliance Efficiency Database 
System  
Impacts to Small Businesses 
Staff estimates that 1,000 retailers, installers, manufacturers, and wholesalers that 
manufacture, install, or sell portable electric spas will be impacted by the proposed regulations. There are approximately 50 manufacturers and private brand packagers of portable electric spas selling within California, and the remaining share of businesses are retailers or wholesalers of portable electric spas. This estimate is based on the CEC’s Modern 
Appliance Efficiency Database (MAEDbS), which yields the number of manufacturers, and its 
estimate of the number of businesses in California that sell portable electric spas to consumers. Staff estimates that of the businesses impacted, approximately 10 percent are small businesses. Small businesses in the portable electri c spa industry include retailers, and 
some small manufacturers or private brand packagers.  
The proposed recommendation to align with APSP -14, Version 19 labeling requirements – 
changing the minimum labeling height from 6.25 inches to 6.75 inches  – results  in a material 
cost ranging from less than $0.01 to $0.02 per unit, as discussed in  the Incremental Costs  
section in this chapter.  There are no incremental costs associated to  updating the test 
procedure reference. Therefore, staff assumed there were no or negligible costs associated 
with updating the test procedure reference and the labeling design requirements . 
Manufacturers acc rue savings  of $1,667 per year  per man ufacturer  through  a reduction in test 
lab qualification fees as discussed in section Statewide Savings  in this chapter . The cost -
effectiveness ensures that the proposed standards will result in a net financial benefit for small 
businesses.  For these reasons staff does not expect any businesses, including small 
businesses, to be impacted negati vely by the proposed regulations for portable electric spas. 22 
 CHAPTER 4:  
Environmental Impacts  
The proposed regulations will update the test procedure reference and update the labeling 
design requirements for portable electric spas. The scope coverage will remain the same and 
continue to cover all types of portable electric spas, such as standard spas, exercise/swim spas, combination spas, and inflatable/collapsible spas. The existing performance standards will not be affected. The proposal als o includes editorial changes to simplify the structure of 
existing regulations for portable electric spas. Therefore, staff has not identified any adverse or beneficial environmental impacts from the proposed regulations.  
Energy Impacts  
The proposed regula tions will not affect existing performance standards yielding no energy 
savings nor a reduction in energy savings, translating to neither an increase or a reduction in greenhouse gas and criteria pollutant emissions.  
Environmental Impacts  
Updating the tes t procedure reference does not affect the existing testing method for 
generating the energy efficiency value of the unit. Therefore, the proposal does not change 
the energy or the process of manufacturing this appliance type.  
Updating the label requirement to increase the minimum height from 6.25 inches to 6.75 inches does not alter the existing process of labeling this appliance type. Existing labeling requirements instruct manufacturers to use a removable adhesive- backed white polymer label 
or an equivalent. The paper stock and adhesive may vary from manufacturer to manufacturer. Most manufacturers already include labels on their spas to provide the consumer with safety instructions, connection instructions, or basic product information. Thus, an increase  in label 
size will not change industry practice, or the material composition of the label. In addition, the non-hazardous materials in the label do not pose any harm to the user and would not cause a 
significant environmental impact.  
The proposed regulati ons are not expected to have any environmental impacts, as they do not 
increase or decrease energy consumption, change the materials used to comply with the regulations, change the design life, or change the total sales or shipments of these products into the state.  
  23 
 References  
Appliance Standards Awareness Project. (2020). States . Retrieved from Appliance Standards 
Awareness Project: https://appliance -standards.org/states  
California Energy Commission. (2018, July 23). Final Statement of Reas ons for Portable Electric 
Spas and Battery Charger Systems. Docket # 18-AAER- 02, TN#224256.  
Davis Energy Group, Energy Solutions. (2004). Codes and Standards Enhancement Initiative 
for PY2004: Title 20 Standards Development - Analysis of Standards Options for 
Portable Electic Spas.  Pacific Gas & Electric.  
Lopez, J. (2018). Final Staff Report: Analysis of Efficiency Standards and Marking for Spas.  
Sacramento: California Energy Commission. Retrieved from 
https://efiling.energy.ca.gov/Lists/DocketLog.aspx?dock etnumber=18-AAER- 02 
Pool & Hot Tub Alliance. (2019, November 19). American National Standard for Portable 
Electric Spa Energy Efficiency. Alexandria, Virginia: Pool & Hot Tub Alliance. Retrieved from https://www.phta.org/standards -and-codes/phta -standards/ industry- codes -and-
standards/  
The Association of Pool & Spa Professionals. (2011, January 4). American National Standard 
for Portable Hot Tub Energy Efficiency. Alexandria, Virginia: The Association of Pool & Spa Professionals.  
The Association of Pool & Sp a Professionals. (2014, September 12). American National 
Standard for Portable Electric Spa Energy Efficiency. Alexandria, Virginia: The Association of Pool & Spa Professionals.  
 
  24 
 Glossary 
Term  Definition  
Certification Body An independent third -party that operates a product, process, or 
service certification system.  
Combination Spa  A portable electric spa with two separate distinct reservoirs, where 
(1) one reservoir is an exercise spa; (2) the second reservoir is a 
standard spa; and (3) each reservoir has an independent water temperature setting control.  
Exercise Spa  A portable electric spa that includes specific features and 
equipment to produce water flow for water physical therapy or physical fitness activity, including, but not limited to, swimming in place. 
Inflatable Spa  A portable electric spa where the structur e is collapsible and is 
designed to be filled with air to form the body of the spa. 
MAEDbS The Modernized Appliance Efficiency Database System established 
pursuant to section 1606(c) of this Article and maintained by the CEC. 
Manufacturer  Any person engaged in the original production or assembly of an appliance or commercial and industrial equipment or any person that assumes the complete legal responsibility for the original production or assembly of an appliance, which includes, but is not limited to, t he responsibility normally held by the manufacturer for 
product liability, warranty, and compliance with state and federal 
law. “Manufacturer” also means a private brand packager or reassembler.  
Portable Electric Spa  A factory -built electric spa or hot tub, supplied with equipment for 
heating and circulating water at the time of sale or sold separately for subsequent attachment.  25 
 Term  Definition  
Standard Spa  A portable electric spa that is not an inflatable spa, an exercise 
spa, or the exercise spa portion of a combination spa. 
Testing Laboratory  A facility where the actual testing of the spa is conducted.  
Test Lab Qualification A process that requires testing laboratories to demonstrate the 
ability to perform the tests in A NSI/APSP/ICC- 14 by a third -party 
certification body.  A-1 
 APPENDIX A:  
Acronyms  
 
 Acronym  Description  
ANSI American National Standards Institute  
APSP The Association of Pool & Spa Professionals  
CASE Codes and Standards Enhancement  Team  
CCR California Code of Regulations  
CEC California Energy Commission  
CFR Code of Federal Regulations  
ICC International Code Council  
IECC International Energy Conservation Code  
IOU California Investor Owned Utilities  
IRC International Residential Code  
ISPSC  International Swimming Pool & Spa Code  
MAEDbS Modernized Appliance Efficiency Database System  
PHTA  The Pool & Hot Tub Alliance  
WCAG  Web Content Accessibility Guidelines