Third-Party Certification ofENERGY STAR Products
Kathleen Vokes and Eamon Monahan
ENERGY STAR Program Integrity
December 7, 2010

Changes to Program
Requirements• Partner Commitments– Require third-party certification of all products– Require annual reporting of unit shipment data
– Effective January 1, 2011

• Product Specifications– Minor changes to ensure a clear and effective productqualification process; where manufacturer concern,reverted to original language– EPA will continue aligning testing and otherrequirements through the specification revision
process2

Transition from Self-Certification toThird-Party Certification•Self-Certification (1992-2010)– Partners test products, confirm
conformance to specification,and label with the ENERGYSTAR– Partners submit test data toEPA to qualify their products– EPA reviews test data andadds products to lists ofqualified products– EPA verifies energy
performance of select models
only•

Third-Party Certification (startingin 2011)– Partners will have products tested
in EPA-recognized labs prior toqualification and labeling– CBs will certify that products meet
program requirements based on areview of test data
– CBs will upload certified data toEPA for creation of qualified
product lists– CBs will conduct verification andchallenge testing afterqualification– CBs will evaluate retested
products that have undergone
significant post-qualification
changes3

Program Updates: Implementation ofENERGY STAR® Certification
Requirements

Qualifying Products as ENERGY STAR
Submissions received by EPA through December 31,
2010• Continue using the existing system of a Qualified Product
Information form or the Online Product Submittal tool.
• EPA must receive complete and correct submissions,
including lab reports, in order to process the productsubmission through OPS.
• For IT product categories (computers, displays, imaging
equipment and servers), EPA will review for qualification
product data constituting a complete submission, pending atest report, received by EPA through December 31, 2010.
– These submissions must include model name/type, model
number, and estimated introduction date.
– EPA must receive the test reports for these submissions no later
than February 1, 2011 or submission will be returned to thepartner for subsequent submission to a certification body forreview.

5Qualifying Products as ENERGY STARSubmissions on or after January 1, 2011• New products must be certified by an EPA-recognizedCertification Body (CB)– Products may not be submitted to EPA for qualification– List of CBs maintained onwww.energystar.gov/testingandverification• Products must be tested in an EPA-recognizedlaboratory• CBs will certify products, conduct regular verification
testing of products, and conduct challenge testing per
EPA requirements• EPA will continue qualification of products that areadditions to a product family qualified prior to January
1, 2011 until the specification revision is effective

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Laboratory Requirements under New
Third Party Certification Scheme• CBs may accept data for certification only fromlabs that are recognized by EPA• Based on accreditation to ISO 17025; or• If lab participates in CB’s Supervised or Witnessed
Manufacturers Testing Lab Program• Manufacturers labs are not required toparticipate in an SMTL or WMTL if they arerecognized by EPA• CB is responsible for ensuring that test data is
acceptable if testing conducted prior toaccreditation
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ENERGY STAR Standard Operating
Procedures (SOP)Product Certification Overview• The Guide for Certification Review: An ENERGYSTAR Standard Operating Procedure (SOP) for
Product Evaluation• Designed by EPA to reflect the steps followed whenreviewing products against ENERGY STAR productspecifications• Key Sections of the SOP––––General Requirements
Eligibility Criteria
EPA-Recognized Laboratory Report Checklist
Product-Specific Appendices9Collecting Required Data
• CBs will collect all information needed todetermine that the product can be certified– The information on the Certified Product Data
Submission form usually only represents a subset of
this data• Collect other information as needed for purposesof verification and challenge testing• The ES partner must submit information to certify
a product– If a recognized lab or other party submits a subset ofdata and includes the partner in the correspondence,
the CB should consider this information submitted bythe partner
10Verifying Product Family Membership• If Applicant/Partner wishes to certify aproduct in a member of a specificationappropriate product family, it must provide:– Test report(s) for representative model(s)– An explanation of any variations within the family– An up-to-date list of models included in the family• CBs must maintain a list of all products in afamily11

Certifying Product-Specific Aspectsand Performance• Product must meet Program Requirement to becertified.

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Checking Laboratory Test Reports• CBs must at a minimum locate lab report fields specified on
the SOP to ensure that the product was appropriately tested– Test procedure name listed– Test date listed– Serial number listed– Sample description listed (e.g., # of products tested)– Equipment calibration dates and next due date listed and within
range– Test engineer and witness names and signatures provided– Test results organized by applicable test procedure section andclearly marked to indicate results that are relevant to ES• If the information cannot be verified, the product cannot becertified until that information is furnished13Adhering to Supplemental EPAGuidance• SOP Appendix A – product-specificguidance– Power supply requirements for IT products• Routing Further Inquiries– If other product-specific aspects ofcertification review are unclear, route any andall questions back to EPA via product-specific
ENERGY STAR inboxes
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Certifying Privately-Labeled Products• CB can certify a different brand of thesame model without data review if themodel is already certified by the CB– EPA encourages CBs to work together toavoid duplicative testing and review– CBs will need to flag models that are certified
under different brand names– CBs will need to maintain a data field with themodel tested to help track this information15

Keeping Certified Product Lists
Current• CBs are responsible for keeping lists of certified
products up to date
– Need to establish a policy for ensuring thatcertified products are available for verification
testing– Partners will need to indicate when products
are no longer manufactured and the expected
shelf-life– CBs will need to flag products that aredisqualified
16

Transferring Data to EPA• If product can be certified– Enter the relevant product and productsubtype being certified into the relevant
Certified Product Data Submission form

• After data entry– Submit data to EPA using the MESA interface• Frequency of data submission– Initially will start on a bimonthly basis, but will
move to monthly for most products
17Notes on Verification and Challenge
TestingVerification Testing Model Selection• EPA will be issuing specific guidance regardingselection of products– Annually test a minimum of 10% of certified products
in each category and included subtype• Category: Imaging.
– Subtypes: copiers, digital duplicators, fax machines, mailing machines, multifunction devices, printers, scanners.

– Product Families• All members of family are subject to testing, but not more than one
per round– Private labelers• Brand A, B, and C are all one product for verification testing
purposes19

Verification Testing Model Selection• Information not included in QPL that caninform model selection:– All relationships between products, including:• Base model and manufacturer for each privately labeledproduct• All privately labeled model numbers associated with each
OEM product• Clear indication of which qualified products are OEMproducts and which are privately labeled products– All relationships between manufacturers not coveredby OEM-PL relationship• e.g.: “ Acme submitted this product on behalf of Roadrunner”
20Procurement of Units for Verification
Testing• Off-the-shelf procurement is favored• EPA does not define “prohibitively expensive topurchase or transport…”– If a CB allows for warehouse or off-the-lineprocurement, it should be prepared to justify thatchoice.

• Partners are required to provide at least threelocations where a product is available, EPA
suggests this be included in productsubmissions for certification.
21

Preferred Locations for Verification
Testing• Verification must generally occur only atEPA-recognized third party labs.
• EPA-Recognized first party facilities arepermissible ONLY when off-the-line testingis the only practical option, provided that:– CBs witness the test
– CBs must be able to defend their decision toallow use of first party lab (as withprocurement)22

Re-evaluation of Products in the
Event of Significant Changes• CBs require partners to notify them of productchanges• CB is not required to re-test all changed
products– The CB retains discretion to decide if changes warrant are-test• Notify EPA– If there is no change in status, on the normal upload
schedule– If there is a change in status (product no longer meets ES
requirements), within two business days
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Challenge Testing• CB must have a policy built into thecontracts it signs with partners.
– Challenges can be initiated by partners
outside of your certification scheme• CB must judge the legitimacy of achallenge claim• CBs have discretion to establish the rules
for challenge testing program– A “loser pays” scheme may be easiest
24Questions?
ENERGYSTARVerificationProgram@energystar.gov
Eamon Monahan
Phone: 202-343-9589
monahan.eamon@epa.gov
Kathleen Vokes
Phone: 202-343-9019
vokes.kathleen@epa.gov
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