| Comment Number: | 523596-00001 |
| Received: | 9/8/2006 4:50:03 PM |
| Organization: | China WTO/TBT National Notification & Enquiry Center |
| Commenter: | Huang |
| State: | Outside the United States |
| Agency: | Federal Trade Commission |
| Rule: | Ceiling Fan Labeling |
| Attachment: | 523596-00001.pdf Download Adobe Reader |
Comments:
Comments from China on USA Notification G/TBT/N/USA/197 Appliance Labelling Rule Dear Sir or Madam, We appreciate the opportunity to submit comments on this regulation proposed by Federal Trade Commission (FTC). Enclosed please find the comments in English and Chinese. Please acknowledge receipt of comments by e-mail to tbt@aqsiq.gov.cn. Thank you very much in advance for Federal Trade Commission taking our comments into consideration. Best regards Huang GuanSheng Director General China WTO/TBT National Notification & Enquiry Center No. 9 Ma Dian Dong Lu, Hai Dian District, Beijing Post Code: 100088 Tel: 86-10-82260611/0618 Fax:86-10-82262448 E-mail: tbt@aqsiq.gov.cn COMMENTS FROM CHINA ON USA NOTIFICATION G/TBT/N/USA/197 Appliance Labelling Rule Chinese government appreciates that U.S. proposed the Appliance Labeling Rule on ceiling fans for the purpose of energy conservation, and thanks U.S. for providing opportunities for WTO Members to summit comments. China would like to make the following comments on G/TBT/N/USA/197: 1. We suggest that the test method set out in international standard IEC60879-1986 be adopted as the test method of Appliance Labeling Rule on ceiling fans. Discrepancy between IEC test method and the U.S. ones needs to be explained. 2. Before the labeling requirements of ceiling fan entry into force in January 1, 2009, the labeling requirements of highly decorative fans with air movement performance is the secondary design feature should be exempted. Regulation to distinguish fan categories to be exempted from the labeling requirements should be issued as soon as possible. 3. The final test procedure and method for parameters required by energy label should be confirmed by U.S. as soon as possible, and published in time. At the same time, the test facilities applicable for the test procedure and method should also be specified in detail. 4. The proposed Rule requires manufacturers to submit information on applicable type of airflow, energy efficiency and airflow efficiency of ceiling fans to FTC. Explaining is needed on: Through which approach the manufacturers outside the U.S. should submit their reports? Should they provide the report that third party has been accredited? Should they submit the report annually? How does U.S. confirm the submitting report? If the confirmation is in written form, how long would this reply period last? We hope the above mentioned questions be clearly explained at an early date. 5. The range of energy efficiency value should be dynamic, and be published by FTC periodically. The actualization and product’s manufacturing cost of most ceiling fan products should be well considered in setting the efficiency range. The energy efficiency range, the minimum requirements of airflow and airflow efficiency of all kinds of ceiling fans should be published as early as possible. 6. The labels directly sticking on a ceiling fan itself should not affect the out-looking of the ceiling fan product and its operation balance. Manufacturers can be required to stick the labels on the outside of the package. As for the location of “Money-Saving Tip: Turn off fan when leaving room”, it may be revised as “place it to the suitable position on the ceiling fan’s switch box”, so as to remind the users in their daily usage. Comments in Chinese are in below: