Final Draft Version 3.0 Imaging Equipment Specification and Test Method Comment Summary

Topic

Subtopic

Definitions

Professional
ProductsInternational
MarketingCommentResponse

Stakeholders made the following recommendations regarding the Although some edits were made, EPA has not made changes tothe definition such as:
professional imaging equipment test method:- Identifying professional products based on their power- Clarify whether accessories are included in the 180 kg weight
connector; orlimit;- Changing the paper size to SRA3 or 19" long.
- Clarify what is included in the definition of memory;- Clarify whether saddle stich stapling is included in the binding
EPA is concerned that power connector requirements couldrequirement;"lock in" particular energy consumption performance in- Reduce the number of optional professional product criteria
required for monochrome products to 4 (due to inapplicability of professional products, similar to an input power requirement,
while changing the paper size could alter the balance of products
the color certification criterion);that are included in either the professional or office categories.
- Use power outlet specifications to differentiate professional
EPA proposes to leave these more substantive issues to Version
products; and4.0 so they can be more fully vetted by stakeholders.
- Add an optional criterion for printing on SRA3 or longer than19" paper.
One stakeholder requested clarification about certifying products The EU agreement with ENERGY STAR has lapsed and thefor sale in Europe now that the EU is no longer an ENERGY STAR ENERGY STAR program is no longer referenced in the EU orpartner.
EFTA. There is still a formal agreement with Switzerland for
products that are sold in the US/Canada and Switzerland.
Products that are sold globally and meet the ENERGY STAR
requirements may utilize the mark regardless of where theproduct is sold, but any literature that is exclusively for aparticular market that is not a partner with ENERGY STAR should
not carry the mark.

Professional
ProductRequirements

DFEs

One stakeholder requested clarification whether Professional
DFE energy consumption can be excluded from that of theProfessional Imaging Equipment.

EPA has clarified that Professional DFE energy consumption canbe excluded.

Professional
ProductRequirements

Duplexing

Two stakeholders noted identical captions for the professional
imaging equipment duplexing requirements (Tables 9 and 10),
while one stakeholder noted that the tables are unnecessary
because of professional products' high speeds, and should bereplaced with the following requirement:

Since all professional imaging products are high-speed and shallmeet the duplexing requirement, EPA has simplified this section
by removing the tables.

"For all Professional Imaging Products, automatic duplexing
capability shall be present at the time of purchase. Professional
Imaging Products whose intended function is to print on special
single-sided media for the purpose of single sided printing (e.g.
release coated paper for labels, direct thermal media, etc.,) are
exempt from 3.4.2."
Professional
ProductRequirements

GeneralEPA thanks the stakeholder for their support.
One stakeholder expressed support for retaining Version 2.0
requirements for Professional Imaging Products, as this provides
continuity.

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Final Draft Version 3.0 Imaging Equipment Specification and Test Method Comment Summary

Topic

Subtopic

Comment

Professional
Product
Requirements

Rounding

One stakeholder commented that the rounding requirement forProfessional Imaging Product TEC reporting should be clarified
to “rounded to the nearest 0.1kWh”.

Re-TestingResponseCB Calculator One stakeholder commented that a calculator to help CBs
recertify products to Version 3.0 would be helpful and requested
further information about its release.

EPA has clarified the rounding language in Table 9 (formerlyTable 11) as well as Table 6.

EPA has included a calculator with the Final specification.

Re-Testing

GeneralOne stakeholder requested that products be re-certified toVersion 3.0 without retesting to reduce burden. The stakeholder
also requested that nominal (rather than tested) default delaytimes to sleep be allowed to be used.

As the test method has not changed significantly from Version2.0, EPA does not expect the need to re-test most products,
though that remains at the certification body's discretion. Inaddition, according to Third Party Certification Directive 2011-05,
nominal values may be used as long as they 1) meet the ENERGYSTAR specification and 2) are more conservative (longer) thantested values.

Re-Testing

Professional
Products

One stakeholder commented that the Sep-2014 test method beused for testing professional imaging products, for further
consistency with Version 2.0.

EPA proposes to reference the new (Dec-2018) TEC test method
for professional imaging products. Referencing the current, Sep2014 test method would provide more continuity for existingproducts, and the latest changes do not affect professional
imaging products (DC power, connection order for products
without Ethernet, elimination of instructions for fax machines andcopiers). However, the revised test method provides clarification
to variable names and markets for certification which could maketesting certification clearer for new products.

Scope

Three-phaseproducts

One stakeholder requested that three-phase products be included EPA has added this item to the list for consideration in a futurerevision so that it may be fully vetted by the Agency andin scope to extend ENERGY STAR labeling to all Professional
stakeholders.
Imaging Products.

TEC
Requirements

Duplexing

One stakeholder commented that duplexing only be required for EPA has made this revision for consistency with Blue Angel.
TEC products at speeds greater than 19 ipm for color and greaterthan 24 ipm for mono, to harmonize with Blue Angel, and further
requested that "enabled by default" be clarified to "the default
setting shall be 'duplex printing'".

TECRequirements

Paper
One stakeholder commented that the paper usage reduction inAssumptions Version 3.0 is not representative of high-speed printing. A factorof 2 reduction would be more realistic.

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EPA based the revised usage profile on manufacturer data and ishesitant to change it absent any additional data. However, theAgency is open to reconsidering this issue in a futurespecification, and welcomes any further data in the meantime.

Final Draft Version 3.0 Imaging Equipment Specification and Test Method Comment Summary

Topic

Subtopic

Comment

Response

TEC
Recovery Time Three stakeholders requested clarifications to the Recovery Time
Requirements
requirements table, while one stakeholder commented that fasterproducts should be subjected to a longer recovery time, as they
print larger jobs for which recovery time is not as important.

EPA has clarified the table, and has revised the recovery timerequirement to allow recovery times that are greater than or equal
to the Maximum Recovery Time, tR_MAX. Finally, EPA has
clarified that products with longer delay times than in Table 7 are
not subject to a requirement. EPA has also added an example toclarify.
EPA, however, has not changed the requirement in order tocontinue harmonizing with Blue Angel, consistent with the draft
specifications.

TEC
Requirements

Rounding

Three stakeholders requested clarifications to the TEC equation
rounding requirements.

EPA has clarified that the new TEC metric shall be rounded to0.01 kWh for reporting.

TEC
Requirements

VariableNames

One stakeholder requested minor changes to variable names forconsistency. Specifically:- Use of TEC_MAX and TEC_REQ;- Use of TEC_2018 instead of t_SLEEP.

EPA has made the first two requested changes and removed thetable footnote that contained t_SLEEP instead of t_DEFAULT but
was otherwise redundant.

Wi-Fi Enabled One stakeholder requested clarification whether the Wi-Fi adderallowance applies if products switch off the Wi-Fi whenconnected to Ethernet or if Wi-Fi is enabled by default.

EPA wishes to clarify that the allowance does not apply to Wi-Fi
Direct, which is not expected to be enabled by default. Otherwise,
any edge Wi-Fi device can receive the allowance unless Wi-Fi is1) not enabled as shipped and 2) the user is not prompted toenable Wi-Fi upon first use.

TECRequirements

For example, the following cases shall receive the allowance:- User manually disables when using Ethernet;- Equipment disables automatically when Ethernet cord plugged
in; and- Wi-Fi stays on even when Ethernet cord plugged in.
Verification
TestingInternational
Marketing

Test Variability One stakeholder requested a tolerance on verification testing due EPA has considered variability when developing the final
requirements and will not be providing a further tolerance.
to the stringent requirements and up to 10% tolerance in otherefficiency programs.
One stakeholder noted that the requirement in Section 5.1.B.2)d) EPA and DOE have removed the phrase “by making use of test
results that qualified the product in another market using otherto use "test results that qualified the product in another market
using other size of paper" appears to be in conflict with Section size of paper (e.g., A4 versus 8.5” x 11”). The rest of the4.3.1 of the specification, which states " “Products shall be tested requirement retains its meaning without conflicting with thetables of paper sizes or Section 4.3.1 of the specification.
for certification at therelevant input voltage/frequency combination for each market . . .
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Final Draft Version 3.0 Imaging Equipment Specification and Test Method Comment Summary

Topic

Subtopic

Comment

Response

TEC Test
MethodRecovery Time Two stakeholders commented that the current measurement of
Active 0 time used for meeting the recovery time requirement is
not repeatable because it is not always clear when a product is in
Ready State (e.g., may still be performing startup activities). Bothstakeholders recommended allowing the printing of one output
image, while another recommended removing the recovery timerequirement from verification testing.

EPA has not included any changes in the final test method. Whilethe Agency can see some value in the approach, this could result
in retesting across all products. In addition, this change appears
to be too significant to not get further feedback from all
stakeholders.

TEC Test
MethodPaper
One stakeholder requested combining paper sizes for various
Specifications markets to reduce the total number of tests required forworldwide certification.

EPA understands that the differences are small between papersizes. However, the addition of Taiwan was noted in response tostakeholder feedback over multiple drafts. As such, EPA has
retained the requirements in the final test method, but is open toconsidering this change with the next revision.

TEC Test
MethodSleep Time

Two stakeholders requested that the sleep measurement time bespecified consistently in Tables 8 and 9 of the test method.

EPA and DOE have updated the language to read "for 1 hour" toprovide further clarification. EPA and DOE note that the only time
this duration would be under 1 hour is if the unit has an Auto-offmode, which is why Table 9 retains ≤ 1 hour.

TEC Test
MethodVariableNames

One stakeholder requested that t_DEFAULT and t_SLEEP beused consistently in Tables 8 and 9 of the test method.

The tables appear to use the correct (new) variable names. EPA
has removed the note beneath Table 3 that referred to the oldvariable names.

Partner
Commitments

One stakeholder inquired whether there have been any changes
to the Partner Commitments, such as changes to the RoHS
requirements, labeling, or logo use outside the United States.

EPA has reviewed the RoHS requirements that will be in effect in2019 and has included the relevant updates in the partnercommitments. there have been no further changes to the partnercommitments.

FutureSpecification
Revision

One stakeholder inquired about the status of a future revision(either Version 3.1 or 4.0) and whether it would affectProfessional or Non-Professional Imaging Products.

While the primary intent of a future revision would be to address
professional products, the scope will depend on the state of themarket at the time of the revision.

Laboratory
Accreditation

One stakeholder requested that EPA "not require laboratories toupdate their Scopes of Accreditation when an ENERGY STAR
specification is revised” to avoid confusion and reduce burden.

The referenced test procedure has not changed significantly solaboratories do not need to be re-accredited for ENERGY STAR
imaging equipment.

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