Check-Testing of Manufacturer Self Reported Labeling Data & Compliance with MEPS

Abstract

China first adopted minimum energy performance standards (MEPS) in 1989. Today, there are standards for a wide range of domestic, commercial and selected industrial equipment. In 1999, China launched a voluntary endorsement label, which has grown to cover over 40 products including water-saving products. Further, in 2005, China started a mandatory energy information label that initially covered two products and in 2007 was extended to cover four products total including: air conditioners; household refrigerators; clothes washers; and unitary air conditioners. These programs have had an important impact in reducing the energy consumption of appliances in China. China has built up a strong infrastructure to develop and implement standards. Historically, however, the gov¬ernment’s primary focus has been on the technical requirements for specifying efficiency performance. Less attention has been paid to monitoring and enforcement with a minimal commitment of resources and little expansion of administrative capacity in this area. Thus, market compliance with both mandatory standard and labeling programs has been questionable. Furthermore, actual energy savings have quite possibly been undermined as a result. The establishment of a regularized monitoring system for tracking compliance with the mandatory standard and energy information label programs in China is a major area for program improvement.

Over the years, the Collaborative Labeling and Appliance Standards Program (CLASP) has partnered with several Chinese institutions to promote energy-efficient products in China. CLASP, together with its implementing partner Lawrence Berkeley National Laboratory (LBNL), has assisted China in developing and updating the above-mentioned standards and labeling programs. Because of the increasing need for the development of a monitoring system to track compliance with the standard, CLASP, with support from Japan’s Ministry of Economy, Trade and Industry (METI) and the Institute of Energy Eco¬nomics, Japan (IEEJ), has expanded its on-going collaboration with the China National Institute of Standards (CNIS) to include enforcement and monitoring. CNIS has already begun working on the issue of compliance. In early 2007, LBNL compiled a report, with the support of METI, summarizing the findings from these activities and indicating China's progress to date. The report concluded that although the existing legal basis for monitoring and enforcement is sufficient— with multiple laws and regulations defining the responsibility of each government agency and specifying a system of fines and penalties for non-compliance—compared with international best practices, there is still a big gap in China’s monitoring and enforcement efforts for mandatory standards and labels.

Concerned about the integrity of the mandatory energy information labeling and MEPS, CNIS conducted modest sample testing in 2006 for refrigerators and room air-conditioners. In contrast to the national product quality testing, where samples are taken from manufacturers’ warehouses, samples were purchased from retail markets in Beijing, Heifei, and Guangzhou. They were then tested in three national test laboratories in those same three cities. Tests were done in two rounds with products that failed the first time re-tested for a second time.

As a second phase of this effort (and with support from METI/IEEJ), CNIS repeated the same task in 2007 with a similar sample size for three products (refrigerators, air-conditioners and clothes washers). Tests were done in two rounds with products that failed the first time re-tested for a second time.

The 2007 results showed that while most products meet the claimed performance levels, there were also cases of non-compliance. Varying compliance rates were observed both by product type and by city. Overall, in the first-round of 2007 testing, refrigerators, air-conditioners and clothes washers had higher compliance rates than did freezers. The com¬pliance rates were:

• 91 percent for air-conditioners;
• 90 percent for clothes washers;
• 87 percent for refrigerators; and
• 71 percent for freezers;

The results after re-testing were more favorable and the overall compliance for all products reached 96 percent in 2007. These out-of-compliance products were composed of two clothes washer models (1 each from Beijing and Guangzhou) and 1 refrigerator model from Guangzhou. These three model samples came from three different manufac¬turers, which represent 6.8 percent of the 48 surveyed manufacturers.

Regarding the geographic distribution of the testing results, in 2007, Beijing had higher compliance rates for each type of product than Guangzhou and Hefei. Of the three cities Guangzhou had the lowest compliance rate for refrigerators and clothes washers, as well as a relatively low compliance rate for its freezer sample. Clothes washers had more sig¬nificant geographically divergent compliance rates than the other products. Specifically, Beijing had a 94 percent compliance rate while Guangzhou had only a 67 percent compliance rate in the 2007 testing,

In comparison with the 2006 testing results, the 2007 testing showed significant improvements in compliance across product types and regions. The number of non-compliant product models (after the second round of testing in each year) decreased from 11 out of 54 in 2006, to only three out of 73 models in 2007¹. On the regional level, Beijing not only achieved higher compliance rates for refrigerators (from 86 percent to 100 percent), but also achieved 100 percent compliance for air-conditioners and 94 percent for clothes washers. Further, the 2006 performance and compliance rates varied between models sold in high-end, first-tier appliance retailers versus those sold in second-and third-tier retailers, with those sold in high-end retailers having higher compliance. In 2007, this result was not replicated. However, because the vast majority (69 out of 73) of the sample was taken from a single high-end retailer, it is not clear that this actually signifies an improvement in the compliance of lower-tier retailers.

Also, the results from both years suggested that the testing results can vary significantly when tested in different laboratories. Improving the consistency of test results between test laboratories is a critical and necessary step in setting up a comprehensive national testing program. This can be achieved through a round-robin testing scheme and capacity-building activities.

Further, the 2007 testing shows that most products' actual energy efficiency is in compliance with the product’s energy efficiency rating. Also, no systematic variation (e.g., by product, by class, etc) was observed in deviations between actual performance and ratings. There is a slight tendency to over-rate energy efficiency. However, the difference is not significant. Among the different products, refrigerators show slightly greater overrating with an average deviation of 3.3 percent.

Another finding regarding sample selection was that the selection of testing samples seems to be biased towards certain grades. In 2007, the tested refrigerators were all selected from grade 1 while freezers were selected from grades 3, 4, and 5. The sample air-conditioners and clothes washers were from a wider distribution of grades but lacked a focus on some particular grades. In order to make the testing more meaningful, future selection of test products should target a wider variety of products from across the entire market. Similarly, as noted above, the 2007 study is limited by the fact that so much of the sample came from a single retail chain.

In sum, the report concludes that while the sample size is far smaller than the mid-term goal of developing a regular check testing program for 20 percent of the market for each of the three products, this study provides highly valuable feedback on manufacturer com¬pliance rates in the absence of a large-scale national testing program. With METI/IEEJ support, CLASP could assist the China Energy Label Center (CELC) in expanding its verification testing programs to cover more models and products, and in developing a plan for ramping up the national verification testing program over the next three to five years. This is particularly important as the information labeling program gains more visi¬bility and expands to additional product categories. CLASP could also assist CELC to plan for a round-robin testing scheme—first among three national laboratories with sub¬sequent expansion of this program to other regional test laboratories—with the goal of improving the consistency of testing results from different testing laboratories.

1. The sample size discussed for each year (2006 and 2007) represents the number of models tested. In both cases, the number of individual units tested is actually higher than that due to the re-testing of models that failed to be found compliant the first round of testing. Sample size (N) in both years is equal to the number of models, and not the higher number of individual units tested.