1. 1 A Proposed Approach to BCS Energy Regulation AHAM PTI Proposal April 9, 2008

2. 2 Appliance Battery Charging Systems  This regulation establishes energy efficiency requirements for appliance battery charging systems  Appliance = a product where the primary output is mechanical motion, light, the movement of air, or production of heat, but excluding products for the transportation or conveyance of people or cargo.

3. 3 Scope  Our products include integral and detachable batteries:  Integral—battery is not removable and charged within the appliance (e.g. cordless shaver, some power tools)  Detachable—battery is a separate entity and is removed from the appliance for charging. (e.g. power tool with battery pack  We do not include batteries charged in the product that may be removed with the power source connected  We call “swappable” (e.g. laptop, cell phone)

4. 4 EPS’s  Some BCS’s use external adapters.  Usually wall- mounts  CEC has stated that BCS’s regulated by this standard would not also be regulated as EPS’s

5. 5 The effects of this scope definition is to:  Integral and Detachable are included as appliance BCS’s  Therefore adapters would NOT be regulated as EPS  Adapter efficiency measured as part of system efficiency  “Swappable” are not included  The adaptors for a “swappable” product could be covered by the EPS regulations

6. 6 Construction  Separate section of Title 20 for appliance battery chargers  Corresponding definitions  Reference to the appropriate sections of the test method for tests  Derive data from test method  Calculation and assessment of “efficiency” within regulation

7. 7 General Philosophy  Measure and save real energy  Sensitive to wide differences in product usage  Aggregate consumption in use  Focus on excess energy use  Not restrict design  Don’t separately regulate each contributing element

8. 8 Key differences from earlier approaches  Inclusion of active mode  Cycle normalized to 168 hours

9. 9 Key similarities  System Approach  Our products are really sold as systems  Focus on excess energy use  Maintenance and standby are already excess  Active includes retrievable energy of battery  Interest in active should be on excess consumed in conversion losses, acceptance losses, etc

10. 10 Regulation Philosophy Uses ER = Ea/Eb approach  Ea is the accumulated excess energy used by the BCS  Eb is energy retrieved from battery  Consider excess energy as the energy not retrievable from the battery  Ideal BCS would have zero excess energy  Retain as much of existing appliance methods as practical

11. 11 Differences  Include measurement of charging cycle (aka- active mode)  Use a few categories of Active, Maintenance, Stand By times as characteristic  Normalize Ea to 168h (1 week) usage  Avoid having test engineer open up the battery or appliance  Maintain safety of technician without compromising design confidentiality

12. 12 Test Procedure  Use Ecos test method for measurement of active energy, no-battery mode energy, and maintenance energy  With suggested simplifications

13. 13 Calculation of Eb – Battery Energy  Manufacturer reports Wh on battery or integral product using Ecos method  With modification for electronic cut-off  Consistent with IEC standards  Avoid conflict with UN/DOT for Li-ion  CEC require data submittal

14. 14 Use of test method  Ec = E24-Eb  Pm = Pm  Ps  Detachable – Ps=Pnb using method 2  Integral  Wall adapter – Ps=Pnb using method 3  AC cord – Ps=0

15. 15 Four BCS Categories 1. Infrequently charge –  e.g. shavers cord  Integral, cord connected or adapter  Charge once in two weeks or less, then disconnected 2. Cradle based chargers –  e.g. Cordless Vacuums with Charging Base  Integral, cord connected or adapter  Charged once per week or less, then left connected

16. 16 BCS Categories (tools) 3. Consumer (detachable)  e.g. “homeowner” power tools  three charges/week/battery  Remainder - mix of maintenance and standby  Product sold w/ one battery 4. Professional (detachable)  e.g. Professional or Industrial Cordless Tools  Five charges/week/battery  Remainder – mix of maintenance and standby  Product sold w/ two+ batteries

17. 17 Categories  Approximate based on intended use  Does not require analysis of product to categorize

18. 18 Formulas TitleCriteriaFormula Cradle- based charger Integral pack with cradle Ea=Ec + 144Pm One 24 hr charge cycle + balance of week in maint Infrequentlycharged Integral pack with connector, no cradle Ea = Ec (144h disconnected) One 24 hr charge cycle + balance of week disconnected Consumer (detachable) Detachable, packed w/ one battery Ea = 3Ec+72Pm+24Ps 3 x 24hr energy+72 hrs of maint+24 hrs of standby Professional (detachable) Detachable, packed w/2 batteries Ea = 5Ec+36Pm+12Ps 168 hrs per week

19. 19 Special cases  Medical products—regulated by FDA  Recommend exclusion  Have additional safety requirements  Low volume  Low voltage or inductively charged  Inherently less efficient—conversion  Safety issues  Less opportunity

20. Agreement  Can we arrive at agreement to regulate appliance battery chargers differently?  Separate the energy savings info by product type.  Recognize manufacturers need time.  Draw cutoff on graph using battery voltage as X axis? Look at with data.  Special cases 20

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