NRCan Proposes Decoupling ENERGY STAR Specs from its Energy Efficiency Regulations

Natural Resources Canada’s (NRCan) ENERGY STAR Initiative is considering significant changes in how products manufactured and/or sold in Canada are qualified and listed. 

NRCan proposes to de-couple Canada’s ENERGY STAR technical specifications from its Energy Efficiency Regulations.  NRCan intends to use the ENERGY STAR technical specification published by the United States Environmental Protection Agency (EPA) exclusively for ALL product categories (except fenestration products).  A one month commentary period revealed that the harmonization of technical specifications with the EPA was not an issue for the majority of Canadian manufacturers.

This change, however, will result in other changes:  using the EPA’s specification could result in manufacturers using test procedures which, at any given time, may not be identical to those used for Canada’s Energy Efficiency Regulations, for regulated products.  As such, NRCan will not be collecting data from manufacturers’ EERs to auto-qualify their products for ENERGY STAR designation.

Analysis by NRCan reveals that this decision will only impact a small subset of manufacturers who sell regulated products in Canada only – and for the most part, only for those product categories whose ENERGY STAR specification’s test procedure differs significantly from the one required in Canada’s Energy Efficiency Regulations.  These manufacturers may be required to pay for additional testing, in order to fulfill reporting obligations to both NRCan and the EPA.

Not changing: Canada’s Energy Efficiency Regulations stipulate that all prescribed energy-using products, imported or shipped inter-provincially for sale or lease in Canada, must bear an energy efficiency verification mark authorized by a certification body accredited by the Standards Council of Canada.  (See MET’s energy efficiency verification mark here).  The dealer of the energy-using product must ensure that an energy efficiency report is filed with NRCan for models available for sale or lease in Canada.

At the time that the ENERGY STAR Initiative was introduced into Canada in 2001, NRCan chose to set its own efficiency levels and testing procedures for some products subject to Canada’s Energy Efficiency Regulations, in order to harmonize them with those required for the Regulations.  As such, ENERGY STAR qualification was automatically given to products which met the higher efficiency level required by the Canadian ENERGY STAR specification (harmonized with NRCan’s Regulations).  Manufacturers wishing to designate products as ENERGY STAR qualified simply filled out voluntary fields in their EERs, and if their product met the specified level set by a database filter, they were listed as such.

Since that time, the number of product categories eligible for ENERGY STAR recognition has doubled, the frequency of technical specification updates or revisions has doubled, and NRCan has found that the efficiency levels of ENERGY STAR specifications in Canada and the United States are identical, regardless of the units of measure or the test procedures specified.

Products for sale or lease in Canada that are not subject to Energy Efficiency Regulations have always followed the EPA’s certification process in order to achieve ENERGY STAR qualification: 

  • Manufacturers must submit their product for testing to an EPA-approved laboratory
  • Testing results must be validated by an EPA-approved Certification Body (CB)
  • The CB must seek ENERGY STAR designation on behalf of manufacturers whose products they have validated as meeting the EPA’s specifications for ENERGY STAR qualification
  • The product is recognized by the EPA and listed on their Web site

Moving forward, NRCan proposes that the above steps apply to all products which are currently eligible for ENERGY STAR designation in Canada, with the exception of fenestration products and HRVs.  This means that EPA-recognized Certification Bodies must submit data to the EPA on behalf of their clients, for all products that manufacturers wish to be recognized as ENERGY STAR qualified.  It also means that in order to do so, the data must come from an EPA-certified lab.

Comments and questions should be sent to NRCan’s ENERGY STAR Chief Dianna Miller at Dianna.Miller@nrcan-rncan.gc.ca.  Include “ENERGY STAR Canada proposed changes” in your subject line.

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