Version 3.0 Imaging Equipment Test Method Draft 1 Comment Summary
Topic

Subtopic

3D Printers

Best Practices

Comment

EPA Response

Six stakeholders opposed the inclusion of 3D printers in the
Imaging Equipment specification, as both the products andstakeholders are different from those currently in scope.
However, four stakeholders suggested investigating a new
ENERGY STAR category for 3D printers, one noting theincreasing sales and opportunity for the ENERGY STAR program
to have an early impact.

EPA is proposing to remove 3D printers from the Imaging
Equipment specification development effort and may consider
these products under a separate scoping effort at a future date.

Maximum machine delay One stakeholder supported a maximum machine delay timetime
requirement as helpful to energy savings. Two others did notsupport this, as:- 4-hour limits are already standard, and- The Blue Angel program requirements already cover machinedelay time.

Although 4 hour limits are already standard, additional energy
savings could be achieved by decreasing these requirements.
EPA is therefore proposing to harmonize the maximum machinedelay time requirements for Operational Mode (OM) products withthose in the Blue Angel requirements and extend them to all
Imaging Equipment products. The Blue Angel requirements are 1
or 2 hours, depending on product speed.

Best Practices

Recovery Times

One stakeholder commented in favor of specifying maximum
As most ENERGY STAR certified Imaging Equipment products
recovery times from sleep, similar to the Blue Angel program, as already meet the maximum values for recovery time set by Bluelong resume times may encourage stakeholders to disable energy Angel, EPA has adopted a similar maximum recovery timesaving settings.
requirement for both OM and TEC products. Furthermore, arecovery time requirement ensures a quick wake-up for Imaging
Equipment, resulting in greater energy savings and increased
customer satisfaction. EPA also believes that enacting thisrequirement will help keep this functionality engaged andprovides greater harmonization with other programs.

Best Practices

AlertsTwo stakeholders commented against alerts when changing
settings that affect energy consumption, as- Almost any change in settings has an impact on energy
consumption so alerts would be ubiquitous, and- High-end products already provide alerts, so there is already acompetitive advantage to providing this feature.

GeneralTimeline

Two stakeholders argued that the proposed specification revision Due to the complexity of developing the proposed test method
timeline is too aggressive due to the network activity test and the updates, the development timeline has been extended into 2018.
change of connectivity priority of Wi-Fi over USB, both of which
In addition, EPA has reduced the number of changes to the
could require more data collection to set correct limits.
ENERGY STAR test method. After investigating the impact ofchanging the priority of Wi-Fi over USB, EPA noted that only nine
TEC products on the currently certified product list would be
impacted.

Page 1 of 9

EPA thanks stakeholders for their comments and has determined
to not pursue any requirements around user alerts at this time.

Version 3.0 Imaging Equipment Test Method Draft 1 Comment Summary
Topic

Subtopic

Maintenance
Modes

Comment

EPA Response

One stakeholder noted that maintenance modes have potential
impacts on energy use. The proposed test method suggests that
all maintenance modes be disabled during the test but excessive
waking of the imaging equipment from lower power modes toperform maintenance tasks can impact the product's efficiency.
The stakeholder proposed an addition to the TEC calculation to
include the duration and frequency of maintenance modes andthe average power demand.

EPA has investigated the prevalence of maintenance modes andconcluded that for most products, the maintenance modes areshort enough in duration to not significantly affect energy
consumption. Therefore, EPA proposes to continue to exclude
maintenance modes from the test. EPA welcomes any further data
regarding this issue.

Power Supplies

One stakeholder noted that verification of the power supply
EPA found through regression analysis that the power supply
allowance sometimes requires invasive inspection of the imaging size has an impact on sleep mode power consumption on aequipment and recommended this allowance for internal power
manufacturer-by-manufacturer basis (after controlling for othersupplies.
adders). Additionally, EPA investigated other, easier to verify
features to achieve similar results, such as product speed andmaximum paper width, but could not find an equivalent metricthat would be more easily verifiable. Therefore, despite thedifficulty in verification testing, EPA is proposing to retain theallowance.

Product Updates
and Component
Variation

One stakeholder commented that the power of products willchange throughout a model's lifetime due to firmware changes
and that EPA should consider the currency of data whendeveloping the Version 3.0 specification.

Professional
Products

Definition

Stakeholders agreed with the proposed definition criteria andencouraged further validation through market research. One
stakeholder commented that there is typically a clear
differentiation between commercial products and professional
products in manufacturers' catalogs.

When developing the Version 3.0 specification, EPA only
analyzed Imaging Equipment models that have been available on
the market since 2013 to ensure data relevancy.

EPA has proposed a definition for Professional Imaging Products
based on industry recommendations to differentiate heavy-duty
products that produce copies for sale, which will have different
test and energy requirements. EPA believes that this definition
better differentiates these heavy-duty products than that
presented in the Discussion Document, which stakeholders
One stakeholder suggested that EPA should make it clear that the indicated could encompass some non-professional products.
proposed professional product category is limited to TEC
products.

Page 2 of 9

Version 3.0 Imaging Equipment Test Method Draft 1 Comment Summary
Topic

Subtopic

Comment

Professional
Products

Scope

Stakeholders were generally opposed to excluding professional
products from the scope of the ENERGY STAR specification.

EPA Response

EPA is utilizing the Draft 1, Version 3.0 specification defines
Professional Imaging Products and the associated Draft 2 test
method to solicite early feedback on these products to ease the
One stakeholder commented in support of a separate category for incorporation of these products at the appropriate time.
professional products, as they are likely to use a considerable
Professional products will continue to be eligible for ENERGY
amount of energy.
STAR certification as in V2.0.
One stakeholder suggested that given the ENERGY STAR
program's prominence among government purchasers, EPA
should investigate the extent to which government institutions
use professional products to decide whether to include them inscope.

However, EPA intends this to be temporary until International
Organization for Standardization (ISO) Standard 21632 “Graphic
technology -- Determination of the energy consumption of digitalprinting devices including transitional and related modes” isfinalized, along with recommended job structures that can form a
TEC metric for Professional Imaging Products. This will allow
EPA to focus on the core of the imaging equipment
specification—the OM and TEC products—in Version 3.0, and add
Professional Imaging Products once the test method is finalized
and test data is available to set appropriate criteria. EPA
welcomes stakeholder feedback on the job structure proposal
and on all Professional Imaging Product proposals in thespecification and test method.
EPA acknowledges that government purchasing is an importantdriver of ENERGY STAR products, but is not the only driver.
Therefore, given stakeholder interest and the energy consumptionof these products, EPA plans to continue investigating theseproducts for inclusion within the ENERGY STAR scope.

Professional
Products

Requirements

One stakeholder suggested that further reduction of TEC limits
Professional products will continue to be eligible for ENERGY
for professional products would make it nearly impossible toSTAR certification as in V2.0. EPA intends to use the Version 3.0
qualify. As such, this stakeholder suggested that professional
specification development process to solicit stakeholder
products could be retained on the qualified products list by either feedback on these products. Once test data have been collected,
1) freezing the requirements for higher speed ranges where most EPA will propose criteria levels. This may be part of the Version
professional products fall, or 2) if version 3.0 includes a definition 3.0 process or a separate V3.1 process depending on when datafor professional products, adapting the version 2.0 requirements can be collected and analyzed.
in version 3.0 for these products.

Page 3 of 9

Version 3.0 Imaging Equipment Test Method Draft 1 Comment Summary
Topic

Subtopic

Professional
Products

Duty Cycle and Testing

Refillable Ink
Tanks

Scope
Exclusions

Comment

EPA Response

One stakeholder informed EPA of ISO 21632, a test method for
EPA understands Professional Imaging Products differ fromprofessional products (currently under development) that focuses Imaging Equipment intended for office use, and that the current
on energy efficiency during continuous printing.
ENERGY STAR TEC test method is not representative of theseproducts. As such, EPA has proposed a new test method for
One stakeholder confirmed that the duty cycle of professional
Professional Imaging Products that references ISO 21632.
products is higher than that of typical office equipment; theHowever, ISO 21632 is currently under development and a Draft
owners often maximize usage by operating multiple shifts.
International Standard (DIS) has been released for a vote in
December 2017. EPA does not expect significant changes to theAnother stakeholder commented that while the TEC test method standard at this stage and is therefore proposing language
may not be ideal for professional products, it is still areferencing the standard in key places for feedback in the test
standardized way to generally compare energy consumption and method. EPA will verify and update all references once the final
highlight the most efficient performers. This stakeholder noted
standard is published later in 2018.
that adding a separate test method and requirements for
professional products would significantly delay the timeline.

Six stakeholders argued that promoting refillable ink tanks areoutside of the scope of ENERGY STAR, which should be focusedon energy and energy efficiency. Two noted that refillable ink
tanks could have higher environmental impacts, and theirbenefits are speculative without a life-cycle analysis (LCA).

EPA reviewed Life Cycle Analyses that included life-cycle costs
and environmental impacts of a standard printer versus one thatutilizes a refillable ink tank. EPA concluded that, at times, thestandard printer had a lower life-cycle cost and lower
environmental impacts, while sometimes the refillable ink tankprinter fared better. Results are dependent on usage. Given
One stakeholder commented with strong support of EPA's
consumer usage variance, it is difficult for EPA to amend the
proposal to look further into the use of refillable ink tanks, as
program to require this capability. As such, EPA is proposing to-Non-refillable cartridges involve additional embodied energy, and include this information as a reporting requirement to allow
the consumables used during the operation of imaging
consumers with interest in this capability to identify thoseequipment can have a large contribution to the overall
ENERGY STAR products that offer it.
environmental impact-Duplexing is a precedent for non-energy requirements

GeneralTwo stakeholders recommended conducting further market
research and calculating market penetration before proposing to
exclude other products.

Additional data regarding digital duplicators was received, whichindicates that these products have a unique role within themarket and the market is innovating to reduce energy
consumption. Therefore, EPA has kept digital duplicators within
One stakeholder noted that the regular ENERGY STAR process of scope.
identifying top performing products would work better than
excluding categories of products outright.
Mailing machines were retaind within scope. There are new
products being certified and there is still the potential to
One stakeholder commented that faxes, copiers, and mailing
differentiate the highest performing products on the market.
machines should not be excluded as long as they're being sold.

However, stand-alone fax machines and copiers have been
excluded from scope. Due to the drop in shipments of theseproducts, there is a lack of incentive to invest in these products.

Page 4 of 9scope.
Mailing machines were retaind within scope. There are new

Version 3.0 Imaging Equipment Test Method Draft 1 Comment
productsSummary
being certified and there is still the potential todifferentiate the highest performing products on the market.
Topic

Subtopic

Comment

EPA Response

Scope
Exclusions

Digital Duplicators

Three stakeholders disagree with the proposal to exclude digital
duplicators, citing the needs of the EPEAT program. One
stakeholder noted continuing shipments, variety of users, andtechnical and energy efficiency innovations.

However, stand-alone fax machines and copiers have been
excluded from scope. Due to the drop in shipments of theseproducts, there is a lack of incentive to invest in these products.

Scope
Exclusions

Fax Machines

One stakeholder agreed with the exclusion of stand-alone fax
machines.

Scope
Exclusions

Copiers

Two stakeholders agreed with the exclusion of stand-alone
copiers.

Sleep Mode
Power
Requirement

Two stakeholders commented in favor of harmonizing network
standby requirements with others, such as those in EU Energyrelated Product (ErP) Regulations, specifically Lot 26 (network
standby, which is equivalent to Sleep Mode for networked
products).

Standby PowerDefinition

Two stakeholders agreed with the proposal to change the standby EPA has proposed to remove the standby definition in the test
power language, as it would provide further clarity.
method draft section 1.C.4 and change 3.4.5 to an off mode
requirement, allowing products that don't have an off mode toFour stakeholders argued against the proposal, citing its impacts qualify using sleep or ready state. This approach is used in otheron international harmonization and lack of value-add.
ENERGY STAR specifications, such as Displays, to simplify the
specification.
Finally, one stakeholder noted that any definitions should beharmonized, and two others have pointed out how the terms used
for low-power modes have changed over time.

Standby Power
Requirement

Two stakeholders commented in favor of harmonizing standby
requirements with others, such as those in EU Energy-related
Product (ErP) Regulations, specifically Lot 6 (standby, which isequivalent to Off Mode, or Sleep Mode for models without an Off
Mode).

Page 5 of 9

The EU set three tiers of network standby requirements: Tier 1(effective January 1, 2015) required 6 Watts (W); Tier 2 (effective
January 1, 2017) requires 3 W; and Tier 3 (effective January 1,2019) requires 2 W. EPA has not amended the criteria for OM
products in Draft 1. However, EPA encourages stakeholders toprovide additional feedback if there is interest in harmonizing the
network standby requirements with the 2019 requirements.

EPA has proposed to revise the Off Mode Power requirement(formerly the Standby Power requirement) to .3 W, whichharmonizes with the currently proposed European Commission
Energy-related Product Regulation Lot 6 (Standby), which would
take effect in 2019. The European Commission is conducting areview of this requirement (http://www.ecostandbyreview.eu), andthe draft conclusion is that a 0.3 W requirement is feasible.

Version 3.0 Imaging Equipment Test Method Draft 1 Comment Summary
Topic

Subtopic

Network Activity
Test

Automation

Network Activity
Test

Collaboration

Network Activity
Test

Definition of wake-up

Network Activity
Test

First-minute condition

Network Activity
Test

Investing Time

Network Activity
Test

Repeatability/fairness

Network Activity
Test

RepresentativenessNetwork Activity
Test

General Test

Network Activity
Test

Retesting

Network Activity
Test

Sleep Test

Comment

EPA Response

One stakeholder commented that the network activity test method The network activity test method on imaging equipment was
should be straightforward and automatable, so as to remove
validated in the field with the help of the California Plug Loadhuman error as much as possible.
Research Center (CalPlug). After testing 10 models, CalPlug has
been unable to replicate the network wakeup behavior that
prompted examination of this issue. All models investigated
One stakeholder expressed willingness to work/collaborate withincreased their power only slightly, and returned to sleep
other stakeholders to define the best/most complete network
promptly when subjected to Simple Network Management
activity test method.
Protocol (SNMP) and NetBIOS Network System (NBNS) packets,
Three stakeholders commented that EPA should clarify what
as well as several other protocols.
constitutes a "wake-up" in the network activity test method, as
equipment needs to perform some action to respond to the
network packets.
The only exception is specific user-initiated requests, such as
Two stakeholders mentioned that communication varies inprint jobs or Hypertext Transfer Protocol (HTTP) access to thefrequency and other parameters, such that the test requirements
device scan folders or administrative console; however, theseafter the first minute are not sufficiently specified.
activities should not occur outside of working hours when the
Two stakeholders are cautioning that more time must be spent to device is in sleep mode.
make sure the network activity test method is fully developed,with one stakeholder noting that it should accurately represent
real-world results and the other that it should consider future
network technologies.
Four stakeholders expressed concern about the repeatability ofthe test method. Two mentioned that the packet frequency andtiming would depend on the test environment and noted that
SNMP is a protocol which is expanded freely by any
manufacturer. Three were concerned with the impacts of theoperating system. Two stakeholders further commented that the
specific testing tools used could have an impact on results, with
one recommending they be specified.
Four stakeholders questioned whether the test will accurately
represent typical, real-world office use of imaging equipment, in
terms of the duration of the test, the protocol communication
tools, packet types, and frequency.
Two stakeholders commented that EPA should develop auniversal network test method for all network-connected
equipment rather than focusing on specific types of imaging
equipment.
Four stakeholders commented that network activity testing would
impose a burden, with one noting that additional staff would be
required. Two stakeholders requested that currently certified
products not be re-tested.
Two stakeholders commented that Step 5 in the TEC test method(the sleep mode test) not be changed.

Page 6 of 9

Therefore, EPA is withdrawing the network activity test methodfrom the proposal, pending additional information on models or
protocols that may be affected by unnecessary wakeups.

Version 3.0 Imaging Equipment Test Method Draft 1 Comment Summary
Topic

Subtopic

Comment

Network Activity
Test

Usefulness of data

Two stakeholders commented that data from the network activity
test will not be useful due to the absence of a wake-up problem.
One noted that customers have not complained about wakeups
while the other commented that there will be little difference
between test results for different equipment.

Network Activity
Test

Using the Data

Three stakeholders asked how network activity test data will be
used and whether EPA plans on setting any criteria based on thedata. One stakeholder opposed reporting or using the data
without the further vetting of the test method.

Other

Default Delay Time Test

Two stakeholders noted the addition of default delay time to sleep Default delay time to sleep mode, TDEFAULT, is currently reported tomode measurement in Step 4 of the draft test method and want
EPA via the Qualified Product Exchange (QPX) system. In theclarification about the purpose of this change.
Draft 1 test method, EPA had included this measurement
explicitly within the test method. In Draft 2, EPA has clarified thisedit with a new variable name and explained it in theaccompanying notebox.

Other

Paper Size

A few stakeholders asked EPA to consider testing models sold in A separate test condition of A4 and 70 grams per square meter
Taiwan using A4/70 gsm paper, which is more prevalent there
was added for testing standard format products sold in Taiwan.
than letter-size paper.

Paper Usage
Assumptions

Consumer Education

One stakeholder suggested that if the paper assumptions change, EPA has proposed to replace the TEC metric with the TEC2017
there should be a clear difference between the old ENERGY STAR metric that incorporates the lower print volumes and an annual
Imaging Equipment TEC variable and the new one.
energy consumption period, to avoid confusion in calculations
and messaging.

Paper Usage
Assumptions

TEC Formula

Two stakeholders appreciated that EPA was only proposing tomodify the TEC formula and not the test method, but noted thatchanging one but not the other is contradictory.
One stakeholder asked that the TEC Calculation for Imaging
Equipment with Print Capability be adjusted. The proposed
calculation reduces the Daily Job Energy by 4 but the number ofprint jobs to calculate the sleep time is unchanged, so the result
does not reflect an entire 168 hour week. An additional
adjustment should be made for products 32 ppm or greater,
dividing Njobs by 16 instead of 4.
Finally, two stakeholders commented that simply dividing thedaily job energy would affect other modes in addition to active
printing, with one arguing that extending periods of sleep mode
could increase total energy consumption.

Page 7 of 9

EPA Response

There may be some continuity issues with the change incalculation due to its usage in a variety of areas. However, theAgency notes that the calculation as currently constructed does
not provide an accurate representation of the market limiting theaccuracy of calculations made off of it.
The measured usage shared by manufacturers was reviewed andthe same conclusion that the values are too high was reached. To
better represent reality, the proposal decreases the contributionof the On Mode in the TEC by a factor of 4, dividing the energy
contributions from all jobs (EJOB_DAILY) by a factor of 4 inEquation 5 in the Draft 1 specification and increasing the durationof Sleep Mode by reducing the assumed time spent in On Modefrom NJOBS/4 (as each job is assumed to take 15 minutes or ¼hour) to NJOBS/16 in Equation 3 in Draft 1.

Version 3.0 Imaging Equipment Test Method Draft 1 Comment Summary
Topic

Subtopic

Paper Usage
Assumptions

Images/Day in Table 11

Paper Usage
Assumptions

Paper Usage Data

Comment

EPA Response

One stakeholder proposed to delete Image/Day on Table 11:
The Images/Day has been removed from Table 11 in the test
Number of Images per Day Calculated for Product Speeds, s, from method.
1 to 100 ipm since Images/Day is not used in the TEC Calculation.
Three stakeholders noted that EPA's proposal to change thepaper usage assumptions were based on limited data. Two ofthese stakeholders further commented against changing theassumption due to:- A lack of impact on product ranking; and- A break in continuity with past estimates and other programs,
such as Blue Angel.

EPA understands that there is limited data in this space, but
believes that all of the data presented to date indicates that paper
usage has decreased. EPA notes that there may be regional
differences in paper consumption, but is seeking to obtain anational average, which the Agency believes the data collected todate can provide.

The stakeholder also commented that EPA request more data,with one noting that the current assumptions reflect their usage.
Finally, two stakeholders commented on paper consumption
trends, with one noting that it has decreased, while anothernoting that paper consumption varies by market and region, so it
is difficult to ascertain a general trend, but that colorant use has
increased.
Paper Usage
Assumptions

Sensitivity

One stakeholder commented that the manufacturer-provided data The existing job structure was retained but the Agency welcomeson average usage excludes imaging profile (i.e. how many
additional data from manufacturers on the impacts of job
imaging jobs are conducted and how many images are produced) structure on TEC and typical job structures in the field.
and proposed a sensitivity impact to measure the impact imaging
job profiles may have on overall TEC.

Page 8 of 9

Version 3.0 Imaging Equipment Test Method Draft 1 Comment Summary
Topic

Subtopic

Product Speed

Comment

EPA Response

Several stakeholders supported the inclusion of international
standards (i.e. International Organization for Standardization(ISO)/Blue Angel) to measure product speed, with one noting thatallowing manufacturers to claim highest speeds leads toinconsistency.

After conducting some research and receiving more feedback andinformation from different stakeholders, EPA is not proposing tochange the product speed reporting requirements from Version
2.0. In particular, most manufacturers that can test to ISO/IEC
standard 24734 are already doing so, while others could do so
without the requirement.

One stakeholder mentioned that for electro-photographic
equipment, the speed value should be selectable between ISO
Therefore, rather than proposing a requirement, EPA has included
Estimated Saturated Throughput (ESAT) and the manufacturer's a permanent note providing ISO/IEC 24734 as an example fornominal speed value (ESAT would be consistent with the Bluedeclaring print speed.
Angel definition of speed). Another stakeholder proposed to use
the ESAT value rounded down to an integer; however, this shouldstill be a declaration and not a test.
However, one stakeholder opposed the change as manufacturer
declaration based on external standards would be toocomplicated while not being enforceable, as it would not be
tested or verified.

Product Speed

Calculation for Digital
Duplicators

One stakeholder mentioned that digital duplicators consist of two As EPA is no longer considering harmonizing product speed
different processes (master making and printing) so measuring
reporting as per international standards, manufacturers of digital
this product's speed is different than other imaging equipment.
duplicators can continue to report their claimed product speeds.
This stakeholder asked EPA to review Japanese standards for
digital duplicators.

Wi-Fi

Disabling

One stakeholder argued that disabling the Wi-Fi functionality in
EPA is not proposing to require manufacturers to provide
some imaging equipment products is difficult so the specification guidance on disabling the Wi-Fi functionality as EPA has foundshould require manufacturers to provide information on how tothat most manufacturers already provide this information indisable that functionality.
manuals and on their websites. EPA encourages all
manufacturers to provide this information to their customers.

Wi-Fi

Expectations

Wi-Fi

Priority

Wi-Fi

Allowances

One stakeholder asked EPA to clarify expectations with Wi-Fi
connectivity (similar to what has been done with wired
networking).

The network setup instructions based on the ENERGY STAR
Displays test method has been proposed for inclusion within thetest method.

Three stakeholders agreed with EPA's proposal of prioritizing Wi- The priority list in the Draft 2 test method has been retained.
Fi connections over USB in the test method.
One stakeholder requested that all of the networking allowances
should be reviewed.

Page 9 of 9

The OM product criteria was not changed in Draft 1. However, thescanner adder was incorporated within the base allowances. In
addition, EPA requests stakeholder feedback on the need for anadder for cordless handsets or internal disk drives.