BRADLEY S. SCHNEIDER 10TH DISTRICT, ILLINOIS 

COMMITTEE ON FOREIGN AFFAIRS 

SUBCOMMITTEE ON MIDDLE EAST AND NORTH AFRICA 

SUBCOMMITTEE ON TERRORISM, NONPROLIFERATION 

AND TRADE 

COMMITTEE ON SMALL BUSINESS 

SUBCOMMITTEE ON HEAL TH AND TECHNOLOGY 

SUBCOMMITTEE ON ECONOMIC GROWTH, TAX 

AND CAPITAL ACCESS 

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The Honorable David Danielson 

Assistant Secretary 

March 29, 2013 

Office of Energy Efficiency and Renewable Energy 

U.S. Department of Energy 

1000 Independence Ave, SW 

Washington, DC 20585-0121 

317 CANNON BUILDING 

WASHINGTON, DC 20515 

(202) 225-4835 

DISTRICT OFFICE: 

111 BARCLAY BLVD, SUITE 200 

LINCOLNSHIRE, IL 60069 

(847) 793-0625 

RE: Energy Conservation Standards for Battery Chargers and External Power Supplies 

(Docket Number EERE 2008-BT-STD-0005) 

Dear Assistant Secretary Danielson: 

I write to you on behalf of my constituent, Schumacher Electric Corporation 

("Schumacher"), to ask that the Department of Energy enact a July 1, 2014 manufacturing 

deadline for compliance with the new energy standard. 

First, let me emphasize that I appreciate the work the Department of Energy (DOE) has 

done thus far on the rulemaking for the Energy Conservation Standards for Battery Chargers and 

External Power Supplies. Furthermore, Schumacher is supportive of the DOE's efforts to 

develop stronger efficiency standards. However, a near-term compliance deadline would create 

significant challenges for Schumacher that other manufacturers in the industry will not face. 

Schumacher Electric Corporation, based in Mount Prospect, Illinois, is the leading 

manufacturer of automotive battery chargers sold in the United States. Its battery chargers and 

maintainers lead the market for agricultural, automotive, marine, recreational and specialty 

applications. As a result of this significant market share, Schumacher has invested considerable 

capital to improve the efficiency of its products while ensuring that its customers are able to 

purchase safe, reliable and cost-effective chargers and maintainers. 

It is my understanding that some industry commentators have requested that the DOE 

enact a near immediate effective date for its new battery charger rule, forgoing its long-held 

practice with regard to the issuance of guidance. Many of these commentators produce 

rechargeable batteries that are used in consumer products, such as those for laptops, electric 

toothbrushes and cell phones that contain or utilize a battery charger. Schumacher, on the other 

hand, is unique in that the consumer product it produces is a battery charger, for example to be 

used to jumpstart a car battery in an emergency. 

PRINTED ON RECYCLED PAPER 
For the vast majority of manufacturers, they will simply need to package their product 

with a new battery charger, but otherwise the product itself will not demand significant 

packaging changes. Because of the distinct type of battery chargers Schumacher produces, the 

company's entire supply chain will be impacted. Schumacher will be required to provide new 

packaging with new SKU numbers for retailers, which could also likely result in a large 

inventory of existing products returned by retailers. Additionally, all of the new models will 

require agency approval from UL. As you know, UL has a standard lead time for approval of 

each SKU submitted. When applied across Schumacher's product line, a compliance date earlier 

than July 1, 2014 would be extremely difficult, if not impossible, to achieve. 

Due to the unique circumstances surrounding Schumacher's production of battery 

chargers that will be impacted by the DOE's rule, I respectfully request that the agency consider 

a July 1, 2014 compliance deadline for such dedicated battery chargers. 

Thank you for your attention to this matter. Please do not hesitate to contact me or my 

staff, if we can be of further assistance as the DOE completes its work on this pending rule. 

cc: 

Sincerely, 

~b-.~ 

Brad Schneider 

Mr. Jeremy Dommu, Office of Energy Efficiency and Renewable Energy, Building 

Technologies Program, EE-2J, jeremy.dommu@ee.doe.gov 

Mr. Michael Kido, U.S. Department of Energy, Office of the General Counsel, 

Michael.Kido@hg.doe.gov