Version 3.0 Imaging Equipment Draft 1 Specification and Draft 2 Test Method Comment Response Document

Topic

Comment

EPA Response

Digital Front
Ends (DFEs)

One stakeholder commented that lowering the requirement for
Category B Type 1 DFEs to 624 kWh/yr (equivalent to 71 watts in
Idle State) would mean that OEMs will consider the use of lower
performance DFEs that will not keep up with the engine, which willcause the total system energy usage to increase. The stakeholder
suggested that EPA add a third category for high performancesystems based on dual server processors.

EPA has defined high performance DFE systems based on dual
server processors as a "Professional Digital Front End" in thespecification. Due to an inability to differentiate based on limited data
within the niche professional DFE market, professional DFEs will not
be subject to TECDFE requirements in Version 3.0. Their energy
consumption will still be reported in the same way energy is reported
for all other DFEs in the specification.

Duplexing

Following further review, EPA determined that while the unit savings
One stakeholder opposed the proposal to require duplexing atof embedded energy due to a more stringent duplexing requirements
lower speeds (Color at 16-20 images per minute (ipm) andare significant, only five color and 15 monochrome models would be
Monochrome at 11-25 ipm) because:
affected, reducing the total savings.
- It does not harmonize with Blue Angel;- Half of affected products do not meet the proposed requirements;- Moreover, for these products, customers do not need Automatic Furthermore, after reviewing product literature for eight of thesemodels, EPA found similar duplex models in four of the cases. For
Duplexing.
the remaining four, there were no similar duplex models available or
the upgrade would incur significant cost.
Another stakeholder commented that low-end, low-speed TEC
products have low print volumes, which limit the amount of energy
To achieve greater savings at less cost, EPA is proposing to revise
to be saved with duplexing.
the duplexing requirement in line with Blue Angel, by requiring
duplexing by default over the current speed bins. EPA is also
Both stakeholders asked for clarification on how EPA determined
proposing to require that imaging equipment at intermediate speed
the proposed thresholds for the duplexing requirement, including
bins (20–34 ipm color; 25–36 ipm monochrome) provide duplexing
analysis/methodology.
as part of the base product, rather than an optional accessory.

External Power
Supply (EPS)

Subtopic

Two stakeholders argued that harmonizing with U.S. Federal
energy conservation standards for EPSs (Level VI on theInternational Efficiency Marking Protocol) was inappropriate
because:- The scope differs. Federal standards cover consumer products
only, while ENERGY STAR covers commercial, industrial, andconsumer products; and- ENERGY STAR is recognized internationally, but the U.S. is the
only country to adopt the strict Level VI requirements.

Further research indicates that this issue appears to mainly impact
scanners and small-format printers, which constitute the majority of
ENERGY STAR models with EPSs (672 out of 683 certified
models). EPA evaluated the concern regarding commercial
products, but does not see a particular reason that commercial
applications would have difficulty meeting these requirements as
Federal Communication Commission (FCC) electromagnetic
emission limits are lower for commercial applications. Furthermore,when DOE evaluated the Level VI standard in 2014, it did not finddifferential impacts on commercial users.
DOE found that per-unit costs of the Level VI standard across a
range of applications would be between $0.47–0.89 more expensive
than Level V at the 18–60 W power levels representative of the
majority of Imaging Equipment EPSs, but would generate$1.35–1.61 in savings. International users should see similar
benefits. Therefore, EPA is continuing to propose this requirement.

Maximum Delay
Times to Sleep
Adjustable by
the User

EPA continues to propose shortening both Default and Maximum
Two stakeholders commented against the proposed Maximum
Delay Times to Sleep Adjustable by the User requirement of either Delay Times to Sleep Adjustable by the User. While EPA
understands that the Blue Angel requirements apply only to TEC
60 minutes or 120 minutes, depending on product speed, andproducts and ErP regulation does not specify default delay time,argued for keeping the 4 hour requirement in V2.0 as shortening
could impact business operations. Harmonization with Blue Angel there is significant energy savings from faster transitions between
Ready State and Sleep Mode for OM products (e.g., 9 W for
and the EU was not necessary as:
standard format scanners, 3 W for standard format ink jet printers, 4- Unlike ENERGY STAR, Blue Angel does not cover scanners;- EU's Energy-related Products (ErP) Lot 6 Ecodesign requirements W for standard format ink jet MFDs, and 13 W for mailingfor standby power do not specify Maximum Delay Times to Sleep or machines).
Maximum Delay Times to Sleep Adjustable by the User.
In response to the concern that shorter delay times could potentially
impact software applications that depend on long delay times, EPA
According to the stakeholders, the new requirement would
invites manufacturers to provide case studies of any past transitions
inconvenience users and impact businesses; furthermore, theand further notes that service technicians may override thesestakeholders argued the adjustable range should not be limited
settings if necessary.
significantly.

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Version 3.0 Imaging Equipment Draft 1 Specification and Draft 2 Test Method Comment Response Document

Topic

Subtopic

Comment

EPA Response

Several stakeholders opposed the Off Mode Power Requirement of According to data on the ENERGY STAR Certified Product List,
1077 of 1168 ENERGY STAR OM products with data would meet a
0.3 Watt and requested that EPA increase the limit to 0.4 watts,
harmonizing with Blue Angel. The stakeholders commented that the 0.3 W requirement, including 123 large format printers and MFDs.
EPA therefore continues to propose this requirement.
EU has not finalized the new criteria of 0.3 watts and even when
finalized, the effective date would be two years after publication.

Off Mode
Requirement

One stakeholder commented against harmonizing the Sleep Mode
Power Requirement with other programs, because ENERGY STAR
covers more products than Blue Angel (i.e. large format printers)
and the ErP directive (EC) No 1275/2008 (which covers electronic
household and office equipment only).

Paper Size

Professional
Imaging
Products

EPA is proposing to allow models intended for the Taiwanesemarket to be tested with either A4/70 g/m2 or 8.5”×11”/75 g/m2
paper. This will allow manufacturers to use the same conditions as inNorth America for models sold in both Taiwan and North America,
Two stakeholders commented that, in addition to the now-specified while allowing others with models specific to Taiwan to test themwith more typical paper.
A4/70g/m2 for the paper size and weight for the Taiwan market,
ENERGY STAR should also include letter-size/75g/m2 paper, which
is used in Taiwan government offices.

Taiwan Market One stakeholder urged EPA to remove the separate paper
requirement for Taiwan, as that would create another test with apaper type which is uncommon in the US.

Definition

Two stakeholders asked EPA to revise the definition of Professional EPA shares stakeholders' concerns that there may not be clear
differentiation between office and Professional Imaging Products,
Imaging Products to differentiate clearly from office equipment,
recommending criteria for the weight of the base engine at greater and therefore proposes to adopt the additional weight requirement at
180 kg.
than either 180 or 200 kg.
EPA also welcomes further suggestions for ways to differentiatethese products, including whether to remove some of the criteria thatare often shared with office equipment.

Professional
Imaging
Products

Test Method
Structure

Professional
Imaging
Products

Excluded
Products

One stakeholder requested that the Professional Imaging Products EPA has drafted a separate test method for Professional Imaging
Products to help ease laboratory accreditation.
test method be placed in one discrete section of the specification
as "this will better allow accredited labs to limit the scope of theiraccreditation to exclude Professional Product testing if suchproducts are not tested in the lab."

Two stakeholders requested that EPA clarify whether Professional
Imaging Products are within the scope of ENERGY STAR V3.0. If
not, the stakeholder also requested that EPA clarify how
Professional Imaging Products will be included in V3.1.

EPA confirms that Professional Imaging Products remain in scope of
the Version 3.0 specification. They will be tested as TEC products
and compared to the other TEC product types when setting
requirements, as they were in V2.0. Then, under V3.1, newProfessional Imaging Products will be tested with the new
Professional Imaging Equipment test method and meet requirements
based on that test method.

Professional
Imaging
Products

Product Speed Two stakeholders asked to change the Professional Imaging
Product definition to clarify that the monochrome product speed
requirement shall not apply to color products, as follows.
• Change “Monochrome product speed equal to or greater than 86
ipm” to “Monochrome product: Monochrome print speed equal toor greater than 86 ipm”; and,• Change “Color product speed equal to or greater than 50 ipm (ifproduct is color capable)” to “Color product: Color print speed
equal to or greater than 50 ipm”.

EPA has clarified the monochrome speed criterion to only apply to
monochrome products.The color speed requirement will apply tocolor products.

Professional
Imaging
Products

Test Method

EPA has incorporated the proposed departures from ISO 21632 to
make the test method more comparable to ENERGY STAR into theseparate Draft 1 Professional Imaging Product test method. EPA
has attempted to include as much of ISO 21632 as appropriate tomaintain consistency between the test methods.

Several stakeholders asked that the Test Method of Professional
Imaging Products be customized for ENERGY STAR whennecessary. ISO 21632 covers a wide range of products beyond
Professional Imaging Products, so test condition provisions may
be inappropriate for ENERGY STAR.

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Version 3.0 Imaging Equipment Draft 1 Specification and Draft 2 Test Method Comment Response Document

Topic
Professional
Imaging
Products

Subtopic

Comment

EPA Response

Testing in
One stakeholder asked that the proposed test method for
Accordance Professional Imaging Products be as specified in Section 4.5.4 ofwith ISO 21632 ISO 21632. In particular, the test method should include Job 1
energy and the average of Jobs 2 and 3, along with Off Mode andSleep Mode. The stakeholder also commented that a streamlined
test procedure is necessary and that ENERGY STAR keep the main
provisions of ISO 21632 (e.g., skip test print／sleep／5%
consistency check between jobs).

Professional
Imaging
Products:
GeneralConfiguration

As-Shipped
Condition

Professional
Imaging
Products:
GeneralConfiguration

Color

Professional
Imaging
Products:
GeneralConfiguration

Network
Connections

To simplify the test, EPA proposes to reference Section 4.5.4 of ISO
21632, which in turns references specific preceding sections; also,
certain previously-referenced sections, including 4.4 Measuring
Conditions, no longer need to be referenced as these requirements
have been brought over from the non-Professional Imaging Product
ENERGY STAR test method.

To simplify the test, EPA has proposed this departure from ISO
One stakeholder commented that under ISO 21632, Professional
21632. This will also make the test method more comparable to the
Imaging Products can be tested under one Best Quality/Best
Picture (BQ/BP) condition, which makes two separate tests (one BQ existing ENERGY STAR test.
and one BP) unnecessary. Following this, the stakeholder
commented that testing with different speeds for BQ and BP
combinations would be unnecessary.

Two stakeholders commented that Professional Imaging Products
be tested with the default (As-shipped) setting.

To simplify the test, EPA has proposed this departure from ISO
21632. This will also make the test method more comparable to theexisting ENERGY STAR test.

One stakeholder further specified that for color products, thedefault will be four colors, which may be fewer than what isavailable in the Best Quality (BQ) setting required to be tested
under ISO 21632.

One stakeholder agreed with EPA's proposal to require the same
network configuration for Professional Imaging Products as forother products.

EPA thanks the stakeholder for the comment and will not set a
separate provision for the network configuration of Professional
Imaging Products.

Professional
Imaging
Products:
GeneralConfiguration

To simplify the test, EPA has proposed this departure from ISO
Product Speed One stakeholder opposed EPA's proposal of measuring andfor Calculations calculating product speed for Professional Imaging Products based 21632. This will also make the test method more comparable to theexisting ENERGY STAR test.
and Reporting on productivity and commented that product speed should be
declared as is the case under Version 2.0.

Professional
Imaging
Products:
GeneralConfiguration

Service/Mainten One stakeholder commented that Professional Imaging Products be EPA proposes to keep measuring the energy consumption of any
automatic adjustments that happen by default, but has added
ance Modes tested with default settings and without disabling the automatic
clarification that any manual processes shall be excluded to ensureadjustment function of color or registration, if it is incorporated in
repeatability of the test method.
the default setting. The stakeholder commented Professional
Imaging Products require daily maintenance, though this includes
human involvement and should not be counted in the energy
consumption amount.

Professional
Imaging
Products:
General
Initialization

Preconditioning

One stakeholder agreed with EPA's proposal of applying 2 hours or EPA has incorporated the proposed departure from ISO 21632 to
make the test method more comparable to the ENERGY STAR test
more for pre-conditioning for Professional Imaging Products.
method for non-Professional imaging Products.

Professional
Imaging
Products:
General Test
Setup

Ambient
Temperature
and Relative
Humidity

One stakeholder agreed with EPA's proposal to keep with current
ENERGY STAR requirements for ambient temperature and relative
humidity conditions when testing Professional Imaging Products.
The temperature and humidity conditions in ISO 21632 are more
stringent than current ENERGY STAR requirements toaccommodate larger, three-phase equipment. However, threephase equipment is not in the scope of ENERGY STAR, therefore
the current requirements should be sufficient.

EPA has incorporated the proposed departure from ISO 21632 to
make the test method more comparable to the ENERGY STAR test
method for non-Professional imaging Products.

The stakeholder also agreed with EPA's proposal of leaving
identifying the energy consumption by air-conditioning equipment
as unspecified, though ISO 21632 factors it in.

Professional
Imaging
Products:
General Test
Setup

Ac Input Power One stakeholder agreed with EPA's proposal to continue excluding EPA thanks the stakeholder for the comment and continues topropose to exclude all three-phase products.
three-phase products, such as three-phase Professional Imaging
Products.

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Version 3.0 Imaging Equipment Draft 1 Specification and Draft 2 Test Method Comment Response Document

Topic

Subtopic

Comment

EPA Response

Professional
Imaging
Products:
General Test
Setup

Measurement
Uncertainty

One stakeholder commented that the change in the measurement
uncertainty from 2% to 3% was unnecessary, since the large
equipment with three-phase power connection is out of scope forProfessional Imaging Products.

EPA has incorporated the proposed departure from ISO 21632 to
make the test method more comparable to the ENERGY STAR test
method for non-Professional imaging Products. However, EPA also
relaxed the uncertainty between 0.5 W and 1 W to equal 0.02 W, for
all Imaging Equipment (including Professional). This is consistent
with IEC 62301 Ed. 2.

Professional
Imaging
Products:
General Test
Setup

Paper
One stakeholder asked EPA to add the standard test paper ofSpecifications Professional Imaging Products to Table 4: Paper Size and Weight
Requirements, which is 127.9g/m2, 85lb, or equivalent.

To simplify the test and ensure consistency across tests of different
models, EPA has proposed to add this information to theProfessional Imaging Products Test Method.

Professional
Imaging
Products:
General Test
Setup

Power Meter:
Minimum
Frequency
Response

One stakeholder agreed EPA's proposal of 3.0 kHz for the sampling EPA has incorporated the proposed departures from ISO 21632 torate of power meters when testing Professional Imaging Products make the test method more comparable to ENERGY STAR into theinstead of 5 kHz (ISO 21632's specification). EPA's proposal is more separate Draft 1 Professional Imaging Product test method.
stringent than ISO 21632, and the stakeholder agreed with EPA's
reasoning that the difference would not be significant as mostpower meters would easily surpass 3.0 or 5.0 kHz.

Professional
Imaging
Products:
General Test
Setup

Power Meter:
Minimum
Resolution

One stakeholder agreed with EPA's proposal to keep less stringent EPA has incorporated the proposed departures from ISO 21632 to
make the test method more comparable to ENERGY STAR into theminimum meter resolution requirements from Version 2.0 whenseparate Draft 1 Professional Imaging Product test method.
testing Professional Imaging Products.

Recovery Time

Equation

Recovery Time

Two stakeholders proposed a change to the Recovery Timeequation (Equation 6). The time subtracted from tActive1 shall betActive0, not tActive2. The stakeholder suggested the equation to
be revised as:tR = tActive1 – tActive0

EPA revised the equation for recovery time to refer to t_Active0
rather than t_Active2. The quantity t_Active0 is measured
immediately after the TEC model is placed in Ready State, so is amore reliable measure of response time from that State.

EPA reviewed the Blue Angel Recovery Time test (Annex E-M,
Section 5), and expects there will not be a need to change theproposed Recovery Time requirements, from Blue Angel, as thedifferences between the ENERGY STAR and Blue Angel Recovery
Time test method are small:- Blue Angel requires that the measurement of time from Ready
Mode shall be initiated 2 minutes after the end of another print,
One stakeholder mentioned the industry is aware of the importance thereby ensuring the unit is warmed up. In contrast, ENERGY STAR
requires measurement of Active 0 when the unit "has enteredof controlling recovery time, but the proposed requirement would
Ready" (i.e., "can enter Active State with minimal delay").
not make the customer experience better.
- Blue Angel requires tests be conducted in the simplex mode. In
contrast, ENERGY STAR testing permits duplex if faster.
The other stakeholder commented that the Recovery Time- Blue Angel requires testing with A4 paper at 230 V. EPA reviewed
requirement should not be harmonized with Blue Angel because:- In order to meet those requirements, manufacturers would need ENERGY STAR tests conducted at 230 V (presumably with A4
paper, as the two are combined for EU testing), and saw a 1 second
to develop new technologies, andmedian difference in recovery times (Active1 - Active 0) compared- Blue Angel focuses on the European market, where operating
to products tested at 115 V.
conditions are consistent (for example, same input voltage). The

Harmonization Two stakeholders were concerned with harmonizing with BlueAngel on Recovery requirements because:-The introduction of a new test which would be burdensome, and-The print speed difference between letter and A4 is not consideredin setting speed limits, which makes the ENERGY STAR
requirement more stringent than Blue Angel.

stakeholder noted that, "if Recovery Time requirements wereadopted as it is proposed in V3.0, this will, depending on region,
lead to lower usability and productivity for customers."

However, EPA welcomes further feedback and data frommanufacturers.
Regarding other feedback, EPA does not believe this requirement
would be burdensome as:- It would not require new testing; and- Seventy-five percent of currently certified unique TEC models (717
of 962) meet the criteria.

Recovery Time

Maximum
Requirement

One stakeholder requested clarification as to why the Table 7:
Determination of Maximum Recovery time differs from Blue Angel,though EPA has harmonized the Maximum Recovery Timerequirement with Blue Angel.

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Table 7 in the Draft 1 specification was equivalent to Table 15 in theBlue Angel specification and has been retained in Draft 2.

Version 3.0 Imaging Equipment Draft 1 Specification and Draft 2 Test Method Comment Response Document

Topic

Subtopic

Recovery TimeOM Products

Comment

EPA Response

EPA confirms that OM products are excluded from the recovery time
Several stakeholders commented that OM products be excluded
requirement.
from the scope of the Recovery Time requirement because:-The test method that includes Active Times does not apply to OM
products,-Energy savings cannot be achieved with the proposed Recovery
Time requirement for OM products,-Blue Angel sets forth a different measurement method, and-The scope of products for ENERGY STAR differs from that of BlueAngel.
Furthermore, several stakeholders commented that, if the Recovery
Time requirement is applied to OM products, then scanners should
not be added to OM products.

TEC Calculation

TEC Calculation

Conversion to One stakeholder commented against reporting TEC a yearly basis EPA has reverted back to kWh/wk for level setting purposes, but willcontinue to show both kWh/wk and kWh/yr on the ENERGY STAR
Yearly Measure (kWh/year). Historically, many stakeholders measured TEC using
website.
kWh/week. To avoid customer confusion and enable historicalcomparisons, the stakeholder requested EPA to revert the measure
to kWh/week.

Lower Page
VolumeOne stakeholder opposed the change to the TEC calculation, in
which variables EJOB_daily and NJOBS are divided by 4, because
users would not be able to compare with past products.

While EPA welcomes additional data on paper consumption(including from outside the U.S.), EPA proposes to keep the revised
TEC calculation where the job energy is quartered.
In addition, EPA proposes to continue publishing TEC results under
the Version 2.0 usage assumptions to enable historical comparisons.

TEC
Requirement

TEC Test
Procedures

Measurement

TEC
Requirement

A3 AdderTwo stakeholders are concerned with the proposed TEC
requirements. Using EPA's dataset, one stakeholder found a 21%
pass rate across 11 models. One stakeholder is waiting for the
updated dataset to analyze and expected a change to the proposed
requirements. One stakeholder also wanted clarification of where
speed bins were divided and where criteria lines were drawn.

EPA has revised the TEC requirements based on the updated
dataset. As before, EPA conducted the analysis as follows:• Speed bins roughly follow the visible distribution of models of eachproduct type this was roughly 20 ipm, but not always• Analysis for each product type (e.g., mono printers) was conducted
separately, so bins could be slightly different between types, andrequirements would be different, but the goal was to achieve aneven pass rate across product types and speed bins.

Two stakeholders commented that the measurements of Active
Times in the TEC Test Procedures should be in seconds, not inminutes.

EPA proposes to revise the measurement of Active0, Active1, andActive2 times in the TEC test methods in Table 8 and Table 9,
above, to be reported in seconds, as the time is typically shorter than
1 minute and is furthermore displayed in seconds in the ENERGYSTAR public dataset.

Two stakeholders asked to maintain the current A3 adder, since A3 After updating the dataset, EPA did see a difference in pass rates
models require more power than A4 "due to device configuration". between A3 and non-A3 models, and proposes a 0.05 kWh/week
adder allowance to account for the additional energy consumption.

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Version 3.0 Imaging Equipment Draft 1 Specification and Draft 2 Test Method Comment Response Document

Topic

Subtopic

Comment

EPA Response

TEC
Requirement

Data Set

Two stakeholders commented that the TEC requirement bereconsidered using a dataset not filtered based on the registration
year; while another expressed support for including Version 2.0(V2.0) models and non-certified products into EPA's dataset andwould provide supplemental industry data to strengthen EPA's
analysis.
The stakeholder noted that the current dataset excludes models
that have the same print speed, TEC, and other data of existingmodels, and argued that it is possible for different models to havethe same TEC value (potentially due to rounding) and each models
should be counted separately. However, another stakeholder
commented that there are duplicates in the dataset, and thesemodels should be removed.

EPA revised the dataset to include the latest ENERGY STAR
certified model data, across all years. EPA then removed models
that are:
1. OM, or TEC copiers and fax machines
2. Members of the same product family based on Product Type,
Speed, Color, Size, and TEC test procedure measurements (i.e.,
not just the final TEC result)
3. Sold only outside the United States
4. With document width reported less than standard (210 mm)
5. With no color information
EPA continued to remove multiple entries for product family models
as some Brand Owners qualify product family models separately
while others do so under one parent model, so removing themultiples ensures fairness between brands.
EPA also coordinated with 13 manufacturers, who reviewed thedataset and provided some corrections:
1. Removed models no longer being sold;
2. Added several models that are not ENERGY STAR certified. As
most of these models did not have energy test data, EPA assumed
that these models do not meet the current ENERGY STAR
requirements and would not meet the more stringent proposed V3.0
ENERGY STAR requriements.

Wifi Adder for
TEC Products

One stakeholder commented that, since Wi-Fi uses more power
than USB, ENERGY STAR should include a Wi-Fi adder for TEC
products.

Because the current ENERGY STAR test method prioritizes USB
over Wi-Fi, the current dataset does not fully reflect the performanceof Wi-Fi models. Based on an analysis of 20 TEC models with Wi-Fi,
EPA observed that models with Wi-Fi and USB (tested with Wi-Fi
disconnected under the current test method) were able to meet the
proposed requirements at a higher rate than models with Wi-Fi andno USB (tested with Wi-Fi connected), indicating that the Wi-Fi
interface does require more power on average.
A 0.1 kWh/wk allowance (equivalent to 0.6 W continuous) provided
to the Wi-Fi-only models resulted in equivalent pass rates and iswithin the range of Wi-Fi allowances in other ENERGY STAR
specifications.

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