BUREAU OF ENERGY EFFICIENCY. MINUTES OF MEETING Name of the Committee Date & Time. Venue 4:00 PM Conference Hall, Energy Efficiency.

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1 I 13 NE C*IISIIIVE IT MINUTES OF MEETING Name of the Committee Date & Time Technical Committee Meeting of LED Lamps onwards Venue :00 PM Conference Hall Energy Efficiency Bureau of A meeting of technical committee was convened to discuss and resolve various issues regarding the registration of models for star labelling program of LED lamps under mandatory regime List of participants is Annexed Agenda of the meeting The following Agenda points comprising the concerns of ELCOMA were discussed during the meeting: (i) Scope of existing star labelling program of LED lamps (ii) Clarifications on the family of models/ grouping guideline (Parent and child model concept) (iii) Safety test report requirement as per IS (Part 1) (iv) Photo biological test report requirement (v) Pre-requisite for submitting 1000 hours test report (vi) Extension in the label validity period (vii) Implementation Date for mandatory regime Initiating the course of discussions DG BEE welcomed all the technical committee members followed by a quick round of introduction Subsequently the aforesaid agenda points were discussed in detail through a case by case approach The representatives of ELCOMA made presentation to the committee For each of the Agenda item the salient points discussed and conclusions drawn are given below: Agenda Point (i): Scope of existing star labelling program (i) ELCOMA members submitted their proposal to exempt certain lamps based on industry data given by them as under;

2 [PORGY IS lift pramil Ce k IT Attachment 1 % Industry Sales of LED Lamps In Trade ( Lumen Range/ Wattages /CCT) Group lumen % of Sales Remarks Wattage Range Range CCT 2700-<3500K CCT 3500-<5000K CCT 5000-<6500K A * 1W -5W 150% 0% 15% * Best Selling 5 W B W-10W 370% 0% 6190% Best Selling 7 W & 9W C W-15W 080% 0% 1050% Best Selling 12 W & 15W I) W-25W 050% 0% 80% Best Selling 18 W & 20W L >2500** >25W 010% 0% 09%** Total 650% 0% 9350% As per the data submitted ELCOMA members highlighted that 9% of the total sales is restricted to only 1 CCT range ie CCT <6500 K while the other two CCT ranges just comprise 6% of the total sales ELCOMA proposed to exempt the LED lamps being manufactured under the two CCT range ie 2700-<3500K and 3500-<5000 K to be removed from the scope of mandatory star labelling Exemption of Colour changing coloured/dimmable lamps used for Decoration purpose ie to exempt the low wattage lamps ranging from 1W- 5W from the star labelling paradigm as it is quite difficult for low wattage lamps to adhere to the luminous efficacy of 79 L/W DG BEE mentioned that if testing of LED lamps under low wattage range and under the two CCT bands ie (2700-<3500 K & 3500-<5000 K) was cumbersome for the industry then BIS would have already exempted these lamps from the scope of IS (Part l& Part 2) BEE's labelling program for LED lamps is in harmony with the IS standards Moreover the compliance to the performance requirements is under the purview of BEE labelling whereas compliance to safety requirements is under the purview of MeitY/DIPP He also stated that removing certain lamps with different CCT may possibly lead to availability of such products in the market with inferior quality/ performance Agenda Point (ii): Clarifications on the family of models/ grouping guideline (Parent and child model concept) ELCOMA submitted its 5 point proposal to group the LED lamps with common star rating level under a family as mentioned below: 2

3 ENERGY I LI ws 1E E Co MUIR IT 1 Star rating can be given only on the basis of initial testing (0 hours) of Lumen/Watt for each wattage (the efficacy as defined in IS (Part 2)) 2 Only one wattage in each group will go for complete life test hours test report to be submitted within 3 months 25% of declared life test report to be submitted within 1 year 5 For additional CCT only the lumen/watt and CCT report has to be submitted and no need to submit the Life test report again 6 For a different (higher) star rating band the process SNo 1 to 5 will be repeated ELCOMA members presented the aforesaid grouping concept with the help of few scenarios: Scenario 1: A manufacturer has applied to BEE for 9W model 3 star rating LED lamp under CCT range 5000K-<6500K then in such a case if manufacturer has declared 9W model as the parent model then he will be given the star rating approval on the basis of 0 hour lumen output test (ie the declared lumen output and power rating) The 1000 hours test report for the same model will be submitted by the manufacturer within a period of 3 months and 25% of declared life test report will be submitted by manufacturer within a period of 1 year All the test reports would be from NABL accredited laboratory Scenario 2: If the manufacturer wishes to get the star rating approval for 9W model under a different CCT range (ie 2700K-<3500K / 3500K-<5000K) then he will submit only the Lumen/watt and CCT report for that model from NABL accredited laboratory Life test will not be carried out again for that specific model Scenario 3: If the manufacturer wishes to apply for another model say 5 W/7W etc with same star rating (ie 3 star) under the same CCT range (say 5000K-<6500 K) then he can declare the 5W/7W as the child model and will be granted star rating approval based on the initial testing (0 hours) of lumen/watt for each wattage But the manufacturer need not to submit the 1000 hours test report 25% of declared life test report for the child model DG BEE reviewed the 6 point proposal submitted by ELCOMA and mentioned that the timelines for mandatory labelling were well known to the industry Even as the grouping concept was not frozen each manufacturer should have at least got the 1000 hours test 3

4 ENERGY IS LI E E r lit Mill IT report for the parent model done as the industry was given ample time to gear up since 2016 Agenda Point (iii) & (iv): Requirement of Safety test report as per IS (Part 1) & Photo biological test report (i) ELCOMA members proposed to remove the clause for submission of safety requirements as per IS (Part 1) or to give direction for directly uploading the CRS (Compulsory registration scheme) certificate validating the compliance of model to the safety requirements (ii) To remove the clause for submission of photo-biological safety test report for the model DG BEE mentioned that pre-requisite in issuing star label approval to a model should be its compliance to safety requirements Only after the verification for compliance to safety requirements the certificate regarding performance has relevance Secondly photo biological test being one of the safety aspect cannot be exempted as it is an integral part of IS (Part 1) Agenda Point (v): Pre-requisite for submitting 1000 hours performance test report ELCOMA members requested removal of the clause of submission of 1000 hours test report from the pre-requisite of getting star label ELCOMA also proposed to relax the % of lumen maintenance at 1000 hours of test being carried by providing tolerance limit Members from ELCOMA mentioned that many lamps fail meeting 95% of initial luminous flux at 1000 hours and thus the same needs to be relooked by BEE DG BEE stated that submission of 1000 hours test report as the pre-eligibility criteria was finalized by BEE during the launch of program in 2015 based on the consensus from all the stakeholders including ELCOMA The decision on relaxing the % lumen maintenance and providing the tolerance could only be taken once the data sheet representing the lumen maintenance value for models is reviewed in detail by BEE It was also noted that at least 3 members agreed that their registered models have passed this 95 % criterion Agenda Point (vi): Extension in the label validity period

5 ENERGY IS LIFE LI C*IISIIIIR IT ELCOMA members requested DG BEE to extend the label validity period to 3 years rather than 2 years ie to revise the label validity period from 1St January 2018 to 31" December 2020 rather than 15t January 2018 to 31' December 2019 DG BEE clarified that by the end of next year ie by the end of label validity period (31St December 2019) BEE may call a technical committee meeting to observe the market scenario as well as review the existing star rating plan and to check whether it needs to be ratcheted up depending upon the availability of technology Thus at this stage no decision can be taken and the star rating table will have a validity period of 2 years as done in case of appliances under S&L scheme Agenda Point (vii): Implementation Date for manda too regime ELCOMA members sought clarification regarding the effective date of compliance to the mandatory star labelling ELCOMA proposed to allow the non-star labelled LED lamps already out in chain at the retail outlets to be sold even after the date of meeting compliance ie 28th June 2018 If this is not so they requested BEE to please extend the compliance timelines beyond 28th June 2018 DG BEE mentioned that ELCOMA's understanding on this matter was not correct He stated that manufacturers must ensure this as soon as possible No non-star labelled LED lamps should be manufactured wef 28th June 2018 Also no further extension can be granted as the industry has already been given ample time to meet the timelines As regards to the material/ products already in supply chain stocks/retails etc a view may be taken separately Conclusion: Chairman noted all technical queries and issues flagged by members and concluded following to facilitate simple registration process with minimum timelines: Clarification for Agenda (i): BEE's labelling program will cover the range of wattage ie from 3W-25 W and all CCT range ie (2700-<3500K 3500-<5000K and <6500K) as per IS (Part 2) for the star rating plan as per Table 31 of the SO 097 (E) dated 28th December

6 ENERGY IS LIFE e MEM IT Clarification for Agenda (ii): The family of models (grouping guidelines) for registration purpose will be considered as per the procedure given below: 1 Star rating can be given only on the basis of initial testing (0 hours) of Lumen/Watt for each wattage (the efficacy as defined in IS (Part 2)) 2 Only one wattage in each group will go for complete life test hours test report to be submitted within 3 months 25% of declared life test report to be submitted within 1 year 5 For additional CCT only the lumen/watt and CCT report has to be submitted and no need to submit the Life test report again 6 For a different (higher) star rating band the process SNo 1 to 5 will be repeated Clarification for Agenda (iii) & (iv): Every manufacturer has to submit the test report as per IS (Part 1) - safety requirements or the manufacturer may submit the requisite attachments regarding the CRS certificate validating the safety compliance against each model to be registered under the star labelling scheme Relevant portion of test report stating compliance to photo biological test also needs to be uploaded Clarification for Agenda (v): As already stated in item 3 of the clarification of agenda item 2 the report should reveal minimum lumen maintenance of 95% at 1000 hours Clarification for Agenda (vi) & (vii): Effective date of coming into force of these regulations is 28th June 2018 (ie 6 months after the date of notification) Thus no manufacturer is allowed to import/manufacture non-star labelled LED lamps wef 28th June 2018 However as regards to the material/ products already in supply chain stocks/retails etc a view may be taken separately subject to Ministry's approval Chairman again advised ELCOMA members to take immediate steps for registration of their models without any further delay The meeting concluded with vote of thanks to the chair 6

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