Verification Labels
and Options

With all of the certification programs that exist, there is still cause for uncertainty about the energy use of certain products. Although the Federal Trade Commission issued "Guides for the Use of Environmental Marketing Claims" in 1992 to deter manufacturers from misrepresenting the environmental attributes of their products, these guidelines do not address energy or water conservation claims, creating a potential opening for unsubstantiated marketing. According to Consumer Reports, "Manufacturers [of air conditioners] are likely to call all models 'high efficiency' -- even those that just meet the government minimum [standards]." (June 1994)

Furthermore, not all products have the energy-efficiency rating that they report. Michael Martin at the California Energy Commission has tested several gas water heaters and electric water heaters which failed to have the energy efficiency that the manufacturers had claimed. The performance of these products had never been verified. In this climate, how can you become more certain that a product has the energy use or the general environmental attributes that the manufacturer claims?

There are two main options. First, you can look for one of the many types of verification labels. The Scientific Certification Systems Eco-logo verifies general environmental claims made about a product (See "SCS's Detective Work"). Many other labels verify specific energy-efficiency ratings. And Underwriters Laboratories's Energy Verification Label indicates that a product has been independently tested and found to meet federal minimum energy efficiency standards. A second option is to hire a third-party organization to test specific products under consideration. Both of these options are discussed below.


VERIFICATION LABELS: LABELS THAT CERTIFY ENERGY PERFORMANCE

A variety of nonprofit organizations and trade associations operate programs that verify the stated energy efficiency of many energy-using products. These programs issue a verification label on all products that participating manufacturers voluntarily submit. Verification labels are typically found on the product itself instead of on its packaging. Organizations that issue verification labels tend to publish the results of their tests in a comprehensive directory. Many of the programs that issue verification labels are listed below.

AIR-CONDITIONING AND REFRIGERATION INSTITUTE (ARI) ARI is an industry trade association which verifies the performance data and energy-efficiency ratios of central air-conditioning (air source and water source), heat pumps (air, ground, and water source), and electric chillers submitted by manufacturers that belong to the association. Over 90 percent of U.S. central air-conditioning, heat pump, and electric chiller manufacturers submit their products for verification. ARI verifies these products by testing up to 30 percent of each manufacturer's product line at an independent, certified laboratory.

ARI produces a directory of the energy efficiency ratios of all tested products that meet the minimum standards for efficiency set by the National Appliance Energy Conservation Act and the Energy Policy Act of 1992. ARI's directory includes a guide for estimating annual operating costs of a unit. It is available on paper ($10) or diskette ($50 plus $8 handling). For more information, contact: ARI Publications Department, Air-Conditioning and Refrigeration Institute, 4301 North Fairfax Drive, Suite 425, Arlington, VA 22203 Phone: (703) 524-8800 Fax: (703) 528-3816 Web Page: http://www.ari.org

ASSOCIATION OF HOME APPLIANCE MANUFACTURERS (AHAM): AHAM is a not-for-profit industry trade association that certifies the performance of a broad range of electrical home appliances that also can be purchased by government agencies. AHAM also specifically certifies the energy-efficiency ratings for air conditioners. Verification tests are conducted by ETL Testing Laboratories, Inc., an independent laboratory. Manufacturers voluntarily submit their products for certification. The products of 35 brand name companies were verified in 1995.

AHAM's publishes a Directory of Certified Room Air Conditioners which lists the energy-efficiency ratings of verified products in a horizontal chart, making it easy to compare the values of hundreds of air conditioners at a time. The directory is published bi-annually in March and October and costs $7.50. For more information, contact: The Association of Home Appliance Manufacturers, 20 N. Wacker Drive, Suite 1500, Chicago, Illinois 60606, (312) 984-5800

National Fenestration Ratings Council (NFRC): The NFRC is a nonprofit council of manufacturers, state officials, consumers, and utility representatives that promotes the use of a standard system for measuring the ability of fenestration products (windows, doors, skylights, etc.) to retain heat and admit solar energy. Manufacturers voluntarily submit products to be evaluated and tested at AFRC-accredited laboratories. The results of these certified independent testings are printed in a Certified Product Directory which allows readers to compare whole-window "U values" and solar heat gains of similar window products. The lower the U value the better a window maintains heat within a room. NFRC yearly tests 16,000 products, which they say account for about half of all window products made in the United States. This covers most windows made by major manufacturers. A hard copy of the directory can be obtained from NFRC for $15. For more information, contact: National Fenestration Rating Council, 1300 Spring Street, Suite 126, Silver Spring, MD 20910 (301) 589-6372 Fax: (301) 588-0854 E-Mail: NFRCUSA@aol. com

GAS APPLIANCE MANUFACTURERS ASSOCIATION (GAMA): GAMA is a nonprofit trade association that certifies the energy-efficiency ratings of six categories of commercial products: (1) gas and oil central furnaces; (2) gas and oil boilers; (3) gas room heaters; (4) gas floor furnaces; (5) gas wall furnaces; and (6) gas, oil, and electric water heaters. The tests are conducted by ETL Laboratories. Publications of their results can be obtained from pubic libraries or by contacting ETL directly at (607) 753-6711. For more information, contact: Gas Appliance Manufacturers Association, 1901 North Moore Street, Suite 1100, Arlington, VA 22209 (703) 525-9565

HYDRONICS INSTITUTE: The Hydronics Institute is a trade association that conducts its own random in-house testing of the energy-efficiency of 90 percent of the market of boilers, baseboard radiation, and thinned-tube radiation. The Institute also yearly publishes IBR Ratings for Boilers, Baseboard Radiation, and Thinned-Tube Commercial Radiation which records its findings. Paper copies of the directory are available for $14.50 plus shipping/handling. For more information, contact: Channing Starke, Technical Director, Hydronics Institute, P.O. Box 218, 35 Russo Place, Berkeley, NJ 07922 Phone: (908) 464-8200 Fax: (908) 464-7818

SOLAR RATINGS AND CERTIFICATION CORPORATION: The nonprofit Solar Ratings and Certification Corporation tests and certifies the performance of solar hot water collectors and systems. According to SRCC, a majority of major manufacturers' hot water collectors are tested. In addition to testing systems for performance and quality, SRCC gives efficiency ratings to hot water collectors. These ratings are included in their certified products directory, which costs $25.00. For more information, contact: Solar Ratings and Certification Corporation, 122 C Street, N.W., Washington, DC 20001 (202) 383-2570


UNDERWRITERS LABORATORIES OFFERS MINIMUM-EFFICIENCY VERIFICATION

Most new models of household appliances and several commercial energy products, such as general service fluorescent lamps, must meet federal minimum energy efficiency standards to be sold in the United States. Underwriters Laboratories (UL), an organization that has been certifying the safety and performance of products for more than a century, issues a UL Energy Verification Label to certify that voluntarily submitted products meet the applicable Federal minimum efficiency standard.

Most of the products submitted to UL for energy verification come from manufacturers who are interested in substantiating the declared value of their energy efficiency rating but may not have the capacity to do so on their own. But this verification is not mandated by U.S. federal law; a product subject to the minimum efficiency standards can be sold without a third-party verification of its efficiency. Presently, the UL label can be found on a small percentage of products subject to Federal minimum energy efficiency standards.

The Energy Policy and Conservation Act of 1975, and subsequent amendments through the 1987 National Appliance Energy Conservation Act and the Energy Policy Act of 1992, have established energy and water-efficiency standards for the following products:

COMMERCIAL: General service fluorescent lamps, incandescent reflector lamps, showerheads, faucets, water closets, and urinals, fluorescent lamp ballasts, motors, and central air conditioners and heat pumps.

RESIDENTIAL: Refrigerator-freezers and freezers, room air conditioners, central air-conditioners and heat pumps, water heaters, furnaces and boilers, dishwashers, clothes washers and dryers, small heaters, kitchen ranges and ovens, microwaves, pool heaters, fluorescent lamp ballasts, and televisions.

The standards for the plumbing products mentioned above are described in terms of maximum water flow rate. For example, showerheads made since 1994 must emit no more than 2.5 gallons of water per minute. The standards for the remaining products are set in terms of minimum energy efficiency.

A directory of products with UL-verified energy-efficiency ratings will be published by early 1996, according to UL Engineering Group Leader Lenore Berman. The directory will be arranged by product type. = For more information, contact: Lenore Berman, Underwriters Laboratories, Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096; (708) 272-8800, ext. 42848; fax: (708) 509-6256.


TESTING SERVICES

If you are suspicious of the advertised energy ratings of equipment under consideration, there are several testing organizations you can turn to for energy performance verification. Underwriters Laboratories, ETL Testing Laboratories Inc., the Canadian Standards Association, and BR Labs offer testing services. Since we at Energy Ideas do not know how reliable these testing organizations are, we have refrained from making any recommendations. ETL Testing Laboratories tests products for several of the trade associations listed above. As one of the testing organizations accredited by the Standards Council of Canada, the Canadian Standards Association will test products marketed in Canada or the United States. BR Labs otherwise tests equipment for the California Energy Commission.

For more information, contact: W.T. Fiske, ETL Testing Laboratories Inc., U.S. Route 11, Industrial Park, P.O. Box 2040, Cortland, NY 13045-0950 (607) 753-6711 Fax: (607) 756-9891

Irma Vescan, Canadian Standards Association; Electrical, Mechanical Photometric Laboratories, 178 Rexdale Boulevard, Rexdale, Ontario M9W 1R3 (416) 747-4356 Fax: (416) 747-4178 or Elizabeth White (613) 238-3222

Bodh Subherwal, BR Labs, 15161 Triton Lane, P.O. Box 1249, Huntington Beach, CA 92647 (714) 891-0206

Lenore Berman, Underwriters Laboratories, Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096 (708) 272-8800, ext. 42848; fax: (708) 509-6256


SCS's Detective Work

Since 1990, Scientific Certification Systems (SCS), formerly Green Cross, has operated a for-profit Environmental Claims Certification Program to verify and certify the accuracy of environmental claims about products. In addition to assessing such claims as the "biodegradability" of cleansers and the "recycled content" of paper, SCS can verify the accuracy of "energy-efficient" and "water conservation" claims. Instead of setting their own definitions for these terms, SCS verifies those efficiency and water conservation claims where comparisons are made, for example "10 percent more water efficient than federal standards."

SCS only verifies and certifies environmental claims on products that are voluntarily submitted by manufacturers. If the claim is deemed truthful, a manufacturer uses the SCS Cross and Globe emblem to demonstrate to the public, including government purchasers, that their product has a certain environmental attribute. Single characteristic claim verifications cost a manufacturer between $2500 and $6000, according to Environmental Marketing Director Chet Chaffee.

Chaffee says that as of December, 1995, over 500 products on the market bore the SCS Cross and Globe emblem verifying their eco-claims. SCS produces Environmental Claims Certification Summaries which list all the product claims SCS has certified to be accurate. These summaries list products by manufacturer and brand name. They do not list those products whose claims could not be certified. The summaries are free to anyone interested and are updated monthly.

In addition to verifying single characteristic claims, SCS quantifies the multiple environmental burdens associated with products. For those products voluntarily submitted by a manufacture, SCS develops "Certified Eco-Profiles" which quantify the "life cycle" burdens that result from the manufacture, use and disposal of the product and its packaging. Using life cycle analysis to evaluate the product's inputs (energy and water use, for example) and outputs (toxic chemical releases, etc.), SCS is able to quantify a product's cradle-to-grave environmental advantages and trade-offs. The resulting Certified Eco-Profile quantifies such things as the natural resources consumed, the energy used, the air and water emissions released, and the wastes generated by the manufacture of the product. Like a nutritional label, it is printed with, or on the packaging of, each evaluated product. As of December 1995, the products of five manufacturers bore SCS Certified Eco-Profiles.

SCS's stated goal is not to give an endorsement to any product but to disclose verified information about its environmental attributes so that consumers can make "more informed" choices for themselves. According to SCS, its life-cycle approach and the "Certified Eco-Profiles" labels help manufacturers, consumers, retailers, procurement officials and policy makers understand the array of environmental considerations associated with a product choice. SCS believes that unlike seals of approval, certified Eco-Profiles reveal environmental tradeoffs and encourage innovation by putting environmental achievements, like recycling, into a broader perspective.

SCS offers an additional service that has already been used by several state government purchasing officials. SCS helps government and corporate procurement officials establish guidelines for verifying the environmental claims of contract bid applicants and for encouraging voluntary environmental improvements by vendors. Both components of this service may be useful to government purchasing officials interested in green procurement. The cost for such a service, according to Chaffee, ranges from $1000 to $250,000 depending upon the scope of the work involved.

CASE STUDY: ARIZONA PUBLIC SERVICE

In January, 1995 Arizona Public Service, a utility, and Arizona State University constructed an Environmental Showcase Home to present component, design, and appliance technologies that not only lower a home's energy use, but also decrease indoor air-pollution and minimize a home's environmental burdens throughout its useful life. The project organizers sought to accurately quantify the home's numerous environmental burdens in order to educate home builders and buyers about the diverse ecological implications of design, construction, and furnishing strategies. SCS was hired to measure these burdens by developing an approximate Eco-Profile of the Showcase Home, using the same life-cycle analysis they use to evaluate individual products.

As part of quantifying the environmental burdens associated with the Home, SCS verified the claims of manufacturers who submitted materials and products for use in the Showcase Home. SCS's verification procedure primarily focused on determining what resources were used to produce input materials. The Environmental Studies Department of the Arizona State University worked with SCS to use this information to compare the Showcase Home's environmental burdens with a "typical" residential home. Based on SCS's research, the organizers were able to show among other things that the Showcase Home was approximately 60 percent more energy-efficient and used 60 percent less water than a "typical" home.

According to Brent Gifford, Project Manager of the Arizona Public Service Environmental Showcase Home, the project's organizers retained SCS to substantiate and boost the project's credibility with the environmental and technical communities. Says Gifford, "That's really where we got our bang for the buck." The cost of retaining SCS for the Home project was approximately $30,000. According to SCS, the cost of similar projects ranges from $25,000 to $50,000.

Gifford's only concern with SCS was that their product inquiries could be intimidating or confusing to small manufacturers because these manufacturers were simply not prepared to talk about the environmental attributes of their products. Otherwise, Gifford says that Arizona Public Service's experience with SCS was very positive.

For more information about the Environmental Showcase Home, contact: Hotline: (602) 250-2100

Brent Gifford, P.E., Environmental Showcase Home, Arizona Public Service, P.O. Box 53999, Mail Station 8641, Pace, Arizona 85072 (602) 250-4716 E-Mail: JGifford@APSC.com

Arizona State University Center for Environmental Studies, Dr. David Pijawka (602) 965-2976, Dr. Mike Pasqualetti (602) 956-9533

For more information on SCS: Chet Chaffee, Ph.D., Director, Environmental Marketing, Scientific Certification Systems, 1611 Telegraph Avenue, Suite 1111, Oakland, CA 94612-2113 (510) 832-1415; fax: (510) 832-0359


Verification Investigations

Have you purchased an energy-consuming product that is performing less efficiently than it should based on manufacturer claims? If so, you can either file a complaint with the Federal Trade Commission (FTC) or the California Energy Commission (CEC). If the product is covered by the FTC-administered EnergyGuide Program (see "EnergyGuide Appliance Labels: Information, Not Endorsement"), and you have reason to believe that the EnergyGuide label contains incorrect information, start with the FTC. If you live in California, or if the product is not regulated by the EnergyGuide Program, the best route may be to initiate an investigation with the CEC, according to CEC Codes and Standards Coordinator Michael Martin. Martin comes to this conclusion after having seen the CEC conduct many more product investigations than the FTC over the past two decades.

The CEC will investigate claims that a manufacturer exaggerated its product's performance so long as the product is regulated by the CEC and the product in question is sold or installed in California. Products subject to CEC regulation include most of the products subject to federal minimum energy efficiency standards as well as commercial refrigerators and freezers, spot air-conditioners, computer room air-conditioners, unit heaters, gas duct furnaces and very small water heaters (under 20 gallons). If these conditions are met, it does not matter whether the complaint originates from within or outside California.

Typically, CEC will first approach any relevant trade association to investigate the product's performance. For products that are not certified by industry trade associations, CEC currently has a contract with BR Labs in Huntington Beach, California to test the product. The investigation is free to the individual or entity that submits the challenge.

To file a complaint concerning a product regulated by the Federal EnergyGuide program, write James Mills at the Federal Trade Commission: James Mills, Federal Trade Commission, 601 Pennsylvania Avenue, N.W., 4th Floor, Room 4616, Washington, DC 20580 (202) 326-3035

For more information on CEC, contact: Michael Martin, California Energy Commission, 1516 Ninth Street, MS-42, Sacramento, CA 95814-5512, Phone: (916) 654-4039 Fax: (916) 654-4304