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

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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 government'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 Economics, 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.

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 compliance 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 visibility 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 subsequent expansion of this program to other regional test laboratories—with the goal of improving the consistency of testing results from different testing laboratories.

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