2012-07-13 Response to published NOPR.

Subject: Notice of Proposed Rulemaking to Establish Energy Conservation Standards for Battery Chargers and External Power Supplies Docket Number: EERE-2008-BT-STD-0005 To the U.S. DoE: Logitech Inc. has reviewed the proposed changes to subject standards, and we would like to make the following comments: 1) We note that for class B and class C external power supplies rated from 0 to 49 Watts, the no-load power limit in the proposed rulemaking is 0.1 W. a. Currently, the smallest regulatory limit for no-load power is 0.3 W (required for compliance with EC278/2009 phase II). b. The DoE stands alone in regulatory rulemaking by requiring a no-load power limit of 0.1 W. c. Logitech has just completed a costly and time consuming effort to update the design of all of our external power supplies to comply with EC278/2009 phase II (currently the smallest no-load limit). d. The proposed new change from DOE will require Logitech to perform this costly exercise again without the benefit of revenue from the sale of products impacted by the exercise that we have just completed (i.e. there has not been sufficient time since Logitech last updated our power supplies to achieve a return on investment). 2) We note that the battery charger requirements include regulation of DC-DC power adapters. Logitech would like to request a specific exemption for USB powered battery chargers, as energy control would already be accounted for by the USB host device. 3) We note that the DoE is proposing new markings for compliance with the consumption requirements for the battery charger system. Logitech would like to request a harmonization of the marking with the existing marking that is required by the CEC for California’s version of Battery Charger energy consumption. We recognize that there are differences in requirements between the California regulation, and the DoE regulation, but a standardized marking system would reduce confusion and errors by manufacturers.