What Household Appliance Manufacturers Have Asked Our Compliance Experts? March 2018

In March our Subject Matter Experts received a number of questions from our household appliance clients regarding a wide range of subjects. You can find the full questions and answers below, but here is a summary of the topics covered:

• U.S. product labels

• Canadian ICES standards for home appliances

• Labeling criteria of products in Taiwan

Question: The effective date of ‘USA: FTC Appliance Labeling Rule, 16 CFR Part 305.3-20, 2008 – Amendment – (on labeling for dishwashers, furnaces, room air conditioners, and pool heaters), Final Rule, 83 FR 7593, February 2018’ is May 23, 2018. Does it mean that the relevant products manufactured on of after May 23, 2018 should use the new format FTC labels? Should the effective date of the new labels point to the manufacture date for products manufactured in US, and the imported date for products manufactured outside US?

Answer: This amendment updates the ranges of comparability and unit energy cost figures on Energy Guide labels for dishwashers, furnaces, room air conditioners, and pool heaters. In accordance with section 305.10 of the Rule, manufacturers must begin using this new information on product labels within 90 days after publication of the updated tables. The updated tables were published on 22 February 2018. This gives manufacturers until 23 May 2018 (effective date) to begin using the new information on the product labels. It further states that products that have been labeled prior to the effective date (23 May 2018) of a modification under this section need not be relabeled. Based on this, it would mean that products must bear the new format FTC label from 23 May 2018 onwards.

Question: Query regarding the Canadian ICES standards for home appliances. Existing standards ICES-001 to 008 do not seem applicable to home appliances like washing machines, vacuum cleaners and air conditioners. What is the scope of existing standards, and does the proposed ‘General Requirements for Compliance of Interference-Causing Equipment, Draft Standard’ expand the scope of standards to include those home appliances?

Answer: In reviewing the definitions for ICES-001, it appears that it includes domestic radio frequency generators as well as typical ISM equipment. In this standard, ISM radio frequency generator means any interference-causing equipment that generates and/or uses radio frequency energy for industrial, scientific, medical, domestic or similar purposes, excluding applications in the field of telecommunications, information technology and other applications covered by other Industry Canada standards.

Compliance & Risks impression is that the draft general requirements will not expand the scope of coverage for the ICES standards but consolidate certain requirements that are common to all of the standards, such as equipment class identification, test reports and labels.

Question: Is the Taiwan Announcement (No. 10602403410, 2017) on Labeling Criteria of Electrical and Electronic Products applicable to coffee makers? Also is this a new requirement or it is just a modification of something already existing for coffee makers?

Answer: Yes, this Announcement applies to coffee makers, as stated in the Annex. While similar labeling obligations existed under the previous Announcement of 2000 (now repealed) in relation to consumer electronics, these did not appear to apply to coffee makers.

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