Aug 2, 2017…

Aug 2, 2017

Senka Krsikapa
ManagerMinistry of Energy
Conservation and Renewable Energy Division
77 Grenville Street Floor 5 & 6
Toronto Ontario
M7A 2C1

Submitted via email: Senka.Krsikapa@ontario.ca

RE: Comments regarding Proposal to amend Regulation 404/12 under the Green Energy Act, 2009

Dear Ms. Krsikapa,

Electronics Product Stewardship Canada (EPSC) is a not-for-profit, industry-led organization. Our membership comprises the following leading electronics manufacturers:

Apple Canada Inc.; Asus; BenQ America Corp.; Brother International Corporation (Canada) Ltd.; Canon Canada Inc.; Cisco Systems Inc.; Dell Canada Inc.; Epson of America Inc.; Fujitsu Canada Inc.; HPCanada Co.; Hewlett Packard Enterprise; IBM Canada Ltd.; LG Electronics Canada Inc.; Lenovo Canada Inc.; Lexmark Canada Inc.; Microsoft Corporation; NetApp Inc.; Northern Micro Inc.; Oracle America Inc.; Panasonic Canada Inc.; Philips-MMD; Ricoh Canada Inc.; Samsung Electronics Canada Inc.; Sony of Canada Ltd.; Toshiba of Canada Ltd.; VIZIO, Xerox Canada Ltd.

We are pleased to submit the following comments to amend Regulations related to Labelling and Reporting provisions for consumer electronics, such as EPS, Battery Chargers, Televisions, Video products, and compact Audio products, under the Green Energy Act.

EPSC is seeking to align the labelling and reporting requirements for consumer electronics, with those at the Federal level under the NRCan requirements. NRCan requires labelling of the certification mark and date code on the product itself, not external cartons. There is also no Federal requirement to report certain information required in the Ontario regulation. Non-alignment will cause non- compliance.

Companies have been working over the last decade to reduce packaging. Many consumer electronicdevices have significantly reduced or eliminated external packaging and in some cases externalcartons are re-used. The current Ontario regulations requiring the date of manufacture on theexterior of the carton is contrary to both common practice and waste reduction initiatives.

Proposed language to align with the existing Federal Energy Efficiency Regulation, administered by NRCan.

(3) An energy using product referred to in paragraph ….need not be labelled in accordance with subsection … if
(a) a mark that is clearly and permanently applied to the product in accordance with the International Efficiency Marking Protocol for …. of ENERGY STAR®;
(b) the product’s energy performance has been verified by a certification body; and
(c) a model number is clearly marked on the product that can be traced to the certification body’s energy performance verification.
4) The verification mark shall be affixed to a surface of the energy-using product so that the mark is readily visible.

NRCan’s Guidelines state:

What is an energy efficiency verification mark? An energy efficiency verification mark indicates that the energy performance of the product has been verified. It is not a safety certificationmark. The certification body must be accredited for energy efficiency verification by the SCC. Under some provincial laws, a province can issue a provincial label that indicates that the product meets the provincial energy efficiency levels. NRCan accepts provincial labels as verification marks if the provincial energy efficiency standards are equivalent to, or exceed, the federal standards.

Where does the verification mark go? The verification mark must be affixed to a surface of theproduct in such a way that it is readily visible.

When does an energy efficiency verification mark go on a product? The energy efficiency verification mark can be placed on a product as soon as the product has met the terms of the applicable energy-performance verification program. At the latest, the dealer must ensure that the verification mark is on the product before the product leaves the dealer's possession or, if the product has been passed on to a consignee, before it leaves the consignee's possession.

Television compliance alignment required.A lack of alignment with Federal regulations, where NRCan has removed requirements to report on-mode power consumption and has no requirements for Power Factor, Luminance ratios, and requirements to transition from one mode to another means Ontario television regulations cannot be met. The data for on-mode, power factor, luminance ratio, and mode transition are not required tobe reported to NRCan. Ontario Ministry of Energy compliance is based on the NRCan registry. We request that Ontario regulations align with NRCan by removing the reporting requirements.

EPSC appreciates the opportunity to provide comment and looks forward to continued engagement andcollaboration with the Ministry of Energy.

Sincerely,

Shelagh KerrPresident and CEOEPSC

[Original Comment ID: 210710]