UNITED STATES ENVIRONMENTAL PROTECTION AGENCYWASHINGTON, D.C. 20460

OFFICE OF AIR AND
RADIATION
September 9, 2021
Dear ENERGY STAR® Televisions Brand Owner or Other Interested Party,
The U.S. Environmental Protection Agency (EPA) is revising the ENERGY STAR Televisions
specification and most recently published the Version 9.0 Draft 2 specification for review and comment
on April 22, 2021. In response to stakeholder feedback on the Draft 2 and subsequent further
discussions with stakeholders, EPA is proposing changes to aspects of the On Mode criteria that
relate to the High Contrast Ratio (HCR) capabilities of some display technologies. EPA is now
releasing a limited topic proposal to provide stakeholders an opportunity to comment on theproposed changes before releasing a Version 9.0 Final Draft specification. Comments on thislimited topic proposal may be submitted no later than October 7, 2021.
Stakeholder Comments Regarding the Version 9.0 Draft 2 HCR Criteria
EPA received public comments from several stakeholders in response to the Version 9.0 Draft 2specification. They can be found on the ENERGY STAR Televisions Version 9.0 productdevelopment webpage. Comments regarding the proposed HCR criteria can be condensed into twomain considerations:

1. EPA should more clearly specify the technical characteristics that a TV must possess to2.

qualify for the HCR Adjustment Factor so that the risk of certification bodies incorrectly
designating models is reduced.
EPA should monitor TV technology development to ensure that no new display technology
makes the HCR Adjustment Factor unnecessary and reevaluate the current value of theHCR Adjustment Factor to confirm that it reflects an aspirational level.

EPA also received test data measured per a recent draft of CTA-2037C, the test procedure
specified for use in the Version 9.0 specification, for an additional five OLED TV models from twostakeholders. CTA-2037C was near completion at the time of reference and no subsequentchanges to the procedure affect the relevance of this data. Considering this feedback and thesubmitted data, EPA is proposing refinements to the definition of an HCR Display and the value ofthe HCR Adjustment Factor through this limited topic proposal.
Proposed Definition Refinement

A TV must meet the definition of an HCR Display as outlined in the Version 9.0 specification toqualify for the HCR Adjustment Factor. The definition for an HCR Display was presented in the Draft
2 specification as follows:
A display where pixels emit no light when displaying a pure black color, thus yielding a contrast ratio
of infinity:1 when comparing these pixels against those that do emit light.
According to several stakeholders, this assertion of an infinity-to-1 contrast ratio has been a heavily
debated marketing claim. EPA thus proposes the following definition for an HCR Display to reduce
the possibility of a Certification Body incorrectly designating whether the HCR Adjustment Factor
should be applied:A display where pixels emit no light when displaying a pure black color.
EPA believes that this simplified definition for an HCR Display eliminates the possibility of marketing
materials influencing a Certification Body’s decision to apply the HCR Adjustment factor. After brief
research into the display technologies available today (e.g., LCD, OLED, etc.), EPA has been able
to easily determine those that are able to disable individual pixels and thus project no light whendisplaying a pure black color on-screen.
Proposed Changes to the HCR Adjustment Factor
The value of the HCR Adjustment Factor as presented in Draft 2 varies depending on the viewable
screen area of the TV being evaluated. This relationship is defined by the following equation:
HCR Adjustment Factor Value= 0.4588×Area0.138

The analysis leading to Draft 2 indicated that there was no available TV model meeting thedefinition of an HCR Display that could meet the On Mode criteria without some allowance. EPA
then developed the HCR Adjustment Factor with the intention of providing HCR TVs with an On
Mode efficiency target that encourages demonstrable efficiency improvements.
In response to the Draft 2 specification, EPA received On Mode testing data for an additional five
OLED TVs, all of which would qualify for the HCR Adjustment Factor. These models all have ascreen size (diagonal) of 65 inches. Analysis of this data confirms the idea that models meeting thedefinition of an HCR Display will not be able to meet requirements without some allowance but
updates EPA’s understanding of the size of the adder that would be needed to allow any OLEDmodels to earn ENERGY STAR certification.
Per Draft 2, the proposed value of the HCR Adjustment factor with a 65 inch diagonal screen size is
1.29 or 29%. This means that an HCR TV of this size would be able to meet On Mode Powerrequirements while using 29% more On Mode Power on average than a non-HCR TV with the same
diagonal screen size and measured dynamic luminance. However, the data from the five newly
submitted TVs indicates that all five models were within 20% of the requirement. The performancesof these five TVs with respect to the proposed On Mode Power requirements are outlined below:

Model(anonymous identifier)O3O4O5O6O7

% Over the Proposed On
Mode Power Requirement

12%

15%

20%

16%

18%

*For example: O3 was measured to use 12% more W than allowed by the proposed On Mode Powerrequirement

This data demonstrates that the Adjustment Factor proposed in Draft 2 does not fulfill its intended
purpose of recognizing the most efficient HCR models. Further investigation indicates that anexplanation for this overestimation is likely the absence of information regarding High DynamicRange (HDR) picture settings from the dataset that informed Draft 2 – TVs with individual pixel
control are especially efficient in an HDR picture setting when compared to LCD TVs because theyachieve a black color by turning off a pixel rather than using a filter. By using data for only Standard
Dynamic Range (SDR) picture settings, the models in the Draft 2 dataset did not capture this benefit
and the added energy need was skewed high. This review of the referenced dataset against thenewly submitted data also suggests that the correlation between viewable screen area and needed
allowance is not as strong as previously indicated.

As such, EPA proposes a universal HCR Adjustment Factor of 1.12 allowing the very topperforming HCR-capable TVs to qualify while encouraging significant efficiency improvements formost HCR TVs to meet these On Mode requirements. This requirement would be presented in theVersion 9.0 Final Draft specification as:

Comment Submission
Stakeholders are encouraged to provide written comments for EPA consideration toTelevisions@energystar.gov by October 7, 2021. EPA also invites stakeholders to submit any datataken per CTA-2037C relevant to the Adjustment Factor value proposed by this document. All comments
will be posted to the ENERGY STAR Televisions product development website unless the submitter
requests otherwise.
Please contact me at (202) 564-8538 or Kwon.James@epa.gov, or Cody Niblett at (202) 862-1245 orCody.Niblett@icf.com, with questions or to share feedback for this effort.
Thank you for your continued support of ENERGY STAR.
Sincerely,

James Kwon, EPA Product Manager
ENERGY STAR for Consumer Electronics
For more information, visit: www.energystar.govENERGY STAR is the simple choice for energy efficiency. To manage the types of emails you receive fromENERGY STAR, visit the subscription center.

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