1 | Energy Efficiency and Renewable Energy eere.energy.gov

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Test Procedure:

Notice of Proposed Rulemaking for

External Power Supplies

November 21st, 2014 

Jeremy Dommu

Department of Energy

Building Technologies Program

EERE-2014-BT-TP-0043

battery_chargers_and_external_

power_supplies@ee.doe.gov 
2

Welcome

• Introductions (around the room)

• Role of the Facilitator

• Ground Rules

– Speak one at a time.

– Say your name for the record – there will be a complete transcript of 

this meeting.

– Be concise – share the ‘air-time’.

– Keep the focus here – cell phones on silent; limit sidebar 

conversations.

– Webinar participants turn phone on mute; “raise your hand” to be 

recognized to speak.

• Housekeeping Items

• Agenda Review

• Opening Remarks
3

Agenda

1) 9:00 AM Introductions

2) 9:15 AM Stakeholder Opening Statements

3) 9:30 AM Discussion on Proposed Amendments

4) 10:30 AM Break

5) 10:45 AM Continued - Discussion on Proposed Amendments

6) 12:00 PM Conclusion
4

Public Meeting Slides Topics

1 Introductions

2

3

4

EPS Definitions & Scope of Coverage

5

Measurement Accuracy and Precision

6

Testing Configuration

7

EPSs with Current Limits

8

Adaptive Charging EPSs

9 EPS Guidance Document

10 Conclusions

Sampling Plan

Optional 10% Loading & Power Factor Test
5

Listening Via the Webcast

• The Department is broadcasting this meeting live over the 

Internet.

• DOE is providing the webcast to accommodate stakeholders 

who are unable to attend the public meeting in person.

• The web broadcast allows stakeholders to listen in and view 

the slides.

• All stakeholders are encouraged to submit written comments 

after the public meeting.
6

Purpose of the Public Meeting

• Present DOE’s proposed amendments to the test procedure 

for External Power Supplies (EPSs)

• Invite comment on the notice of proposed rulemaking 

(NOPR) document. 

• Discuss next steps in the rulemaking.

• Invite participants to provide summary comments or 

statements and raise additional issues for discussion. 
7

Summary of Proposed Amendments

• Fundamental testing methodology remains the same

• Proposed amendments would not alter the measured 

efficiency of tested EPSs; rather, it would provide clarity on 

how to apply the test procedure in certain cases.

Summary of Proposed Amendments

Harmonize resolution and measurement uncertainty requirements with latest 

version of IEC 62301

Define and clarify how to test Adaptive EPSs

Clarify test set-up to avoid the introduction of additional losses

Clarify how to test EPSs that are not capable of measuring one or more loading 

conditions

Add an optional test at 10% loading condition and measurement of power factor

Update sampling plan to be applicable to all EPSs subject to standards
8

Test Procedure and Standards Rulemaking Timeline

Milestone Date

Direct Operation EPS Standards Final Rule February 10, 2014

Notice of Proposed Rule – EPS Test Procedure October 9, 2014

Final Rule – EPS Test Procedure Estimated: Summer 2015

Compliance with Direct Operation VI Standard February 10, 2016

• Public meeting on November 21, 2014

• Written comments due December 23, 2014

• Final Rule is expected to be issued by Summer 2015.

• Representations made 180 days after publication of final rule must be made in 

accordance with new test procedure, but may opt to use it earlier.

• Given this timing, certification to the new and amended standards will be made using the 

updated test procedure.
9

Issues for Discussion

Issue boxes corresponds to the list of issues published at the 

end of the NOPR document, available at: 

http://www.regulations.gov/#!documentDetail;D=EERE-2014-

BT-TP-0043-0001

Issue Box: DOE welcomes comments, data, and information 

concerning its proposed amendments to the test procedure 

for external power supplies. Issues that correspond to those 

raised in DOE’s published material will be numbered in 

accordance with that material. Whether invited by an issue 

box or not, comments are welcome on any part of DOE’s 

analysis.
10

Opening Remarks

Meeting participants are invited to provide opening remarks or 

statements at this time.
11

Public Meeting Slides Topics

1 Introductions

2

3

4

EPS Definitions & Scope of Coverage

5

Measurement Accuracy and Precision

6

Testing Configuration

7

EPSs with Current Limits

8

Adaptive Charging EPSs

9 EPS Guidance Document

10 Conclusions

Sampling Plan

Optional 10% Loading & Power Factor Test
12

External Power Supplies - Definitions

• External power supply means an external power supply 

circuit that is used to convert household electric current into 

DC current or lower-voltage AC current to operate a 

consumer product.

• Class A external power supply means a device that—

• is designed to convert line voltage AC input into lower voltage AC or DC 

output;

• is able to convert to only one AC or DC output voltage at a time;

• is sold with, or intended to be used with, a separate end-use product 

that constitutes the primary load;

• is contained in a separate physical enclosure from the end-use product;

• is connected to the end-use product via a removable or hard-wired 

male/female electrical connection, cable, cord, or other wiring; and

• has nameplate output power that is less than or equal to 250 watts
13

External Power Supplies - Definitions

• Direct operation external power supply means an external 

power supply that can operate a consumer product that is 

not a battery charger without the assistance of a battery.

• Indirect operation external power supply means an external 

power supply that cannot operate a consumer product that 

is not a battery charger without the assistance of a battery.

• The amended regulations pertain to direct operation EPSs, 

regardless of whether they are Class A. Indirect operation 

Class-A EPSs must meet the standards established by EISA.

Class-A EPS Non-Class A EPS

Direct Operation EPS Level VI Level VI

Indirect Operation EPS Level IV No Standards
14

Indirect and Direct Operation EPSs

• The definition of an indirect operation EPS includes the method to determine 

whether an EPS is an indirect operation EPS:

1. If batteries are removable, remove them and attempt to operate the product 

off mains power. If it cannot operate, it is indirect operation.

2. If the batteries cannot be removed, then the time necessary for a product in 

“off–mode” to turn on and become operational should be recorded when (1) 

the battery is completely charged and (2) when the battery is completely 

discharged.

3. If the difference in these two conditions is greater than 5 seconds, then the 

EPS is an indirect operation EPS

• DOE proposes to modify the definition of an indirect operation EPS to specify 

that an indirect operation EPS:

1. cannot operate a consumer product (that is not a battery charger) without 

the assistance of a battery or;

2. solely provides power to a battery charger that is contained in a separate 

physical enclosure from the end-use product.
15

Scope – Indirect and Direct Operation EPSs

• Stakeholders have inquired as to whether an EPS that can be 

used with multiple end-use applications, some of which are 

operated directly and some operated indirectly – would be 

treated by DOE as an indirect or direct operation EPS. 

• So long as the EPS can operate any consumer product 

directly, even if that EPS is only capable of operating the 

consumer product it ships with indirectly, then DOE would 

still consider that EPS to be a direct operation EPS.

Issue: DOE seeks comment on its proposed revision to the definition and 

applicability of “indirect operation external power supply.”
16

Scope – Power Over Ethernet (PoE) Adaptors

• PoE describes a system which passes electrical power along 

with data on Ethernet cabling allowing a single cable to 

provide both data connection and electrical power.

• An EPS may be considered a Class A EPS if it connects to the 

end-use application using any type of electrical connection, 

cable, cord, or other wiring, including both removable and 

hard-wired connections.

• An Ethernet cable meets these criteria, so an EPS that 

connects to the end-use product via an Ethernet cable would 

still be considered a Class A EPS if it meets the other five 

criteria of the Class A EPS definition. 
17

Scope – Security or Life Safety Alarm or Surveillance Systems

• Under 42 U.S.C. 6295(u)(3)(E), an EPS that:

1. is an AC-to-AC EPS; 

2. has a nameplate output of 20 watts or more, and;

3. is certified to the Secretary as being designed to be connected to a security or life safety 

alarm or surveillance system component

does not have the meet the no-load mode requirements.

• A security or life safety alarm or surveillance system means equipment designed and 

marketed to perform certain functions on a continuous basis, such as:

1. monitoring intrusion to real property

2. providing notification of threats to life safety or physical property

3. controlling access to real property or physical assets

4. Preventing unauthorized removal of physical assets

• The term “security or life safety alarm or surveillance system” does not include any product 

with a principal function other than life safety, security, or surveillance that is designed and 

marketed with a built-in alarm or theft-deterrent feature or does not operate necessarily 

and continuously in active mode.

• Examples of products with principal functions other than life safety, security, or surveillance 

include:

• landscape lighting with motion sensors

• video cameras

• smart phones with theft deterrent features
18

Scope – One AC or DC Output Voltage at the Same Time

• Class A EPSs are “designed to convert to only one AC or DC 

output voltage at a time.”

• This requirement is met if:

– An EPS can provide two or more outputs at the same voltage at 

the same time 

– An EPS can provide two or more different output voltages, but 

not at the same time

• This requirement would not be met if the EPS can provide 

two or more different lower-voltage AC or DC output 

voltages. These EPSs are considered multi-voltage EPSs.
19

Scope – Solid State Lighting (SSL)

• SSL products contain LED drivers and transformers that use constant 

current or constant voltage to drive LEDs with direct current (DC), or, 

sometimes, alternating current (AC). 

• These components may otherwise meet the statutory definition of an 

EPS (circuit used to convert household electric current into DC current or 

lower-voltage AC current to operate a consumer product), and may 

therefore be subject to the Class-A and/or direct operation EPS 

standards.

• As stated in the EPS Standards Final Rule (79 FR 7845, Feb 10, 2014) and 

in the EPS Test Procedure NOPR, DOE has determined that there are no 

technical differences between these components and EPSs, and that 

many of them would be subject to the applicable energy conservation 

standards.
20

Scope – Solid State Lighting (SSL)

Examples – In Scope

• Drivers/Transformers used 

with LED task lighting, desk 

lamps, landscape lighting

Examples – Out of Scope

• Drivers for fluorescent 

ballasts output higher 

voltage AC waveforms to 

ionize the gas inside the 

tubes and generate light.

• LED drivers contained 

directly within the 

luminaire.
21

Public Meeting Slides Topics

1 Introductions

2

3

4

EPS Definitions & Scope of Coverage

5

Measurement Accuracy and Precision

6

Testing Configuration

7

EPSs with Current Limits

8

Adaptive Charging EPSs

9 EPS Guidance Document

10 Conclusions

Sampling Plan

Optional 10% Loading & Power Factor Test
22

EPS Measurement Accuracy and Precision

• The International Electrotechnical Commission (IEC) published the 62301 

standard for measuring the standby power of household appliances in June 

2005.

• DOE adopted instrumentation and resolution measurement uncertainty 

requirements identical to those in the IEC 62301 standard in its test procedure 

final rule published June 1, 2011. (76 FR 31750)

• The second edition of IEC 62301, published in January 2011, made several 

revisions to the standard including:

• Refined test equipment specifications

• Clarifications to the measurement techniques required

• Revisions to the uncertainty determination method for measuring loads with high 

crest factors and/or low power factors

• DOE is proposing to incorporate by reference the resolution parameters for 

power measurements and uncertainty methodologies in the second edition of 

IEC 62301 for the application of testing EPS energy consumption. 

Issue: DOE seeks comment on its proposal to incorporate the accuracy and precision requirements 

found in the current version of IEC 62301 (2nd ed.) as part of DOE’s EPS test procedure. 
23

Public Meeting Slides Topics

1 Introductions

2

3

4

EPS Definitions & Scope of Coverage

5

Measurement Accuracy and Precision

6

Testing Configuration

7

EPSs with Current Limits

8

Adaptive Charging EPSs

9 EPS Guidance Document

10 Conclusions

Sampling Plan

Optional 10% Loading & Power Factor Test
24

EPS Testing Configuration

• DOE incorporated by reference certain sections of the 

California Energy Commission’s (CEC) “Test Method for 

Calculating the Energy Efficiency of Single-Voltage External 

AC-DC and AC-AC Power Supplies” in its test procedure final 

rule published December 8, 2006. (71 FR 71340)

• Section 5 of the CEC test procedure, “Measurement 

Approach”, states:

“Power supplies that are packaged for consumer use to power a 

product must be tested with the dc output cord supplied by the 

manufacturer. There are two options for connecting metering 

equipment to the output of this type of power supply: cut the cord 

immediately adjacent to the dc output connector, or attach leads and 

measure the efficiency from the output connector itself.”

• This section, however, does not clearly outline how the 

voltmeter and ammeter connections should be made to 

ensure testing accuracy. 
25

EPS Testing Configuration

• DOE examined two test configurations based on different 

interpretations of the CEC test procedure and found that 

efficiency differed significantly.

25% Load 50% Load 75% Load 100% Load

Average ActiveMode Efficiency

SETUP #1* 

(LOSSY)

Input Power (W) 10.37 20.57 30.89 41.36

Output Voltage (V) 11.69 11.12 10.37 9.83

Output Current (A) 0.75 1.5 2.25 3

Efficiency 84.5% 81.1% 75.5% 71.3% 78.1%

SETUP #2*

(LOSSLESS)

Input Power (W) 10.37 20.57 30.89 41.36

Output Voltage (V) 12.01 11.85 11.6 11.53

Output Current (A) 0.75 1.5 2.25 3

Efficiency 86.9% 86.4% 84.5% 83.6% 85.3%

Difference 2.3% 5.3% 9.0% 12.3% 7.2%

Lossy Lossless
26

EPS Testing Configuration

• DOE proposes to amend section 4(a)(i) of Appendix Z to 

require that any equipment necessary to measure the activemode efficiency of a UUT at a specific loading condition must 

be directly connected to the output cable of the unit. 

• This revision will serve to clearly outline the intended 

metering connections and ensure that any unintended losses 

in the test measurement introduced by the metering 

equipment are not included in the active-mode efficiency 

calculation.

Issue: DOE seeks comment on its proposed clarification 

regarding the test set-up.
27

Public Meeting Slides Topics

1 Introductions

2

3

4

EPS Definitions & Scope of Coverage

5

Measurement Accuracy and Precision

6

Testing Configuration

7

EPSs with Current Limits

8

Adaptive Charging EPSs

9 EPS Guidance Document

10

Sampling Plan

Optional 10% Loading & Power Factor Test

Conclusions
28

EPS with Current Limits

• Average active-mode efficiency is calculated using an average of the active-mode 

efficiencies measured at 25%, 50%, 75%, and 100% the rated load of the EPS 

under test.

• DOE has become aware of certain EPSs that implement “hiccup protection” 

under specific loading conditions so it is not possible to measure the efficiency of 

that loading point.

• DOE is proposing to test only the loading conditions at which an EPS can 

maintain the necessary output current.

• DOE seeks to define “average active-mode efficiency” within the test procedure 

as, “the average of the loading conditions (100%, 75%, 50%, and 25% of its 

nameplate output current) for which the EPS can sustain the output current”.

Issue: DOE seeks comment on the proposed method for testing 

EPSs with current limits.
29

Public Meeting Slides Topics

1 Introductions

2

3

4

EPS Definitions & Scope of Coverage

5

Measurement Accuracy and Precision

6

Testing Configuration

7

EPSs with Current Limits

8

Adaptive Charging EPSs

9 EPS Guidance Document

10 Conclusions

Sampling Plan

Optional 10% Loading & Power Factor Test
30

Adaptive EPSs

• Some EPSs have the ability to rapidly charge depleted batteries by boosting their 

output voltage during charging to reduce overall charging time.

• This “adaptive charging” relies on a specific communication protocol between 

the EPS and certain end-use products. 

• Absent this protocol, an “adaptive charging” (or “adaptive”) EPS may still be 

capable of charging other products without these adaptive charging features 

using the standard Universal Charging Solution.

• These types of EPSs are single-voltage EPSs because they are able to convert line 

voltage AC input into only one lower voltage DC output at a time. 

Proposed Definition for Adaptive EPSs

An adaptive external power supply means an external power supply that can 

alter its output voltage during active mode based on an established 

communication protocol with the end-use application without any usergenerated action.
31

Efficiency Testing of Adaptive EPSs

• The test procedure should be able to capture the efficiencies 

at the various output conditions in which it will operates.

• DOE is proposing to test these EPSs once at the highest 

achievable output voltage that is utilized while 

communicating with a load and once at the lowest voltage 

regardless of the nameplate ratings.

Proposed metrics to report to certify Adaptive EPSs

1. The average of the efficiencies recorded at the lowest voltage 

achieved during the charging cycle 

2. The average of the efficiencies recorded at the highest voltage 

achieved during the charging cycle

3. Nameplate output power in watts

4. Output current in amperes

5. Highest and lowest achievable output voltage

6. No-load mode power consumption in watts.
32

No-Load Testing of Adaptive EPSs

• DOE requires that an input power measurement taken at the 0% loading 

condition is measured and recorded as no-load mode power 

consumption.

• The test procedure for single-voltage EPSs does not instruct technicians 

to explicitly remove any external loads or to put the EPS into “no-load 

mode” in order to conduct the test at a 0% loading condition.

• DOE suspects that if the current demand is decreased to zero 

electronically, with the load still physically connected, that the output 

voltage may remain artificially high and impact the results of the no-load 

power measurement when testing adaptive EPSs.

• The single-voltage test procedure will be modified to state that any UUT 

must be in no-load mode and any additional signal connections be 

disconnected before taking a measurement at 0% load.

Issue: DOE seeks comment on the proposal for defining, testing, 

and certifying adaptive external power supplies.
33

Public Meeting Slides Topics

1 Introductions

2

3

4

EPS Definitions & Scope of Coverage

5

Measurement Accuracy and Precision

6

Testing Configuration

7

EPSs with Current Limits

8

Adaptive Charging EPSs

9 EPS Guidance Document

10 Conclusions

Sampling Plan

Optional 10% Loading & Power Factor Test
34

EPS Sampling Plan

• For certification and compliance, manufacturers are required 

to rate each basic model according to the sampling 

provisions specified in 10 CFR 429 (429.37 of Subpart B of 10 

CFR Part 429 for Class A EPSs)

• The recent energy conservation standards expanded the 

scope of regulation to Class A EPSs and direct operation EPSs 

that do not meet the Class A definition – eliminating the 

need to differentiate between Class A and non-Class A EPSs 

for the purposes of Part 429.

• DOE proposes to amend 429.37 so that the sampling plan, 

which currently applies only to Class A EPSs, would be 

applied to any EPS subject to energy conservation standards.

Issue: DOE seeks comment on creating a single sampling plan 

for both Class A and non-Class A EPSs. 
35

Public Meeting Slides Topics

1 Introductions

2

3

4

EPS Definitions & Scope of Coverage

5

Measurement Accuracy and Precision

6

Testing Configuration

7

EPSs with Current Limits

8

Adaptive Charging EPSs

9 EPS Guidance Document

10 Conclusions

Sampling Plan

Optional 10% Loading & Power Factor Test
36

Optional 10% Loading Test

• The current DOE test procedure does not consider EPS 

loading points below 25% when calculating the average 

active-mode efficiency.

• Smarter consumer products have lower operating loads and 

standby modes in the field, many of which fall below the 

25% load threshold.

• DOE proposes to add a sixth, optional loading condition at 

10% of the nameplate output current to the EPS test 

procedure.

Issue: DOE seeks comment on including an additional, optional 

loading condition at 10% of the rated nameplate output power 

of the unit under test in the EPS test procedure. 
37

Optional Power Factor Test

• Power factor is a relative measure of transmission losses between the 

power plant and an item plugged into AC mains (i.e. a wall outlet)

• The widespread adoption of switched-mode power supplies and 

other non-linear loads has brought overall system efficiency into 

consideration.

• DOE believes that in order to capture a representative average use 

cycle for EPSs, power factor should be examined at each loading 

condition.

• DOE is proposing to include optional power factor measurements at 

each loading condition in the test procedure for EPSs. 

Issue: DOE seeks comment on its proposal to optionally 

measure power factor at each loading condition. 
38

Public Meeting Slides Topics

1 Introductions

2

3

4

EPS Definitions & Scope of Coverage

5

Measurement Accuracy and Precision

6

Testing Configuration

7

EPSs with Current Limits

8

Adaptive Charging EPSs

9 EPS Guidance Document

10 Conclusions

Sampling Plan

Optional 10% Loading & Power Factor Test
39

Guidance Document – EPSs 

• Draft Guidance Document on EPSs issued November 14

• Comments Due: December 15, 2014 to 

ExtPowerSupplies2014GUID0052@ee.doe.gov 

• EPSs that are packaged with and used to operate commercial or 

industrial equipment that are of a type capable of operating a consumer 

product would be considered a covered product and possibly be subject 

to DOE’s energy conservation standards, without regard to whether that 

EPS was in fact distributed into commerce to operate a consumer 

product. 

• Only EPSs that have identifiable design characteristics that would make 

them incapable of operating a consumer product would be considered to 

not meet the definition of an EPS

Issue: DOE welcomes comment on the clarifications provided in the guidance 

document on EPSs operated with commercial or industrial equipment.
40

Public Meeting Slides Topics

1 Introductions

2

3

4

EPS Definitions

5

Measurement Accuracy and Precision

6

Testing Configuration

7

EPSs with Current Limits

8

Adaptive Charging EPSs

9 EPS Guidance Document

10 Conclusions

Sampling Plan

Optional 10% Loading & Power Factor Test
41

DOE Seeks Comment on its Test Procedure

In all correspondence, please include all of the following:

– Test Procedure for External Power Supplies

– Docket Number: EERE-2014-BT-TP-0043 

– Regulatory Identification Number (RIN): 1904-AD36

Email: ExtPowerSupplies2014TP0043@ee.doe.gov

Comment period closes: December 23rd, 2014

Postal: Hand Delivery/Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Mailstop EE-2J

1000 Independence Avenue, SW

Washington, DC 20585-0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Suite 600

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202-586-2945
42

Relevant URLs

DOE Appliance Standards:

– http://www1.eere.energy.gov/buildings/appliance_standards/index.html

EPS DOE Product Website:

– http://www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid

/23

EPS Rulemaking Website:

– http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx?ruleid=

102

Rulemaking Docket (EERE-2014-BT-TP-0043):

– http://www.regulations.gov/#!docketDetail;D=EERE-2014-BT-TP-0043