2. Current Vietnamese Requirements 2

REVIEW OF VIETNAMESE COMPACT FLUORESCENT LAMP STANDARD TCVN 7896:2008 A report for the Vietnamese Government’s Energy Efficiency Program

Prepared for Department of Industry (Australia)

Final Report

August 2014 TABLE OF CONTENTS

TABLES

FIGURES

ACKNOWLEDGEMENTS

The author would like to thank staff at the Australian Department of Industry for their assistance with this report, and Kevin Lane and Mark Ellis who provided information for this report. Project Manager: Mark Ellis, Mark Ellis & Associates, Australia

Disclaimer

The authors have made their best endeavours to ensure the accuracy and reliability of the data used herein, however make no warranties as to the accuracy of data herein nor accept any liability for any action taken or decision made based on the contents of this report. GLOSSARY AND ABBREVIATIONS

Ballast Device connected between the power supply and one or more discharge lamps primarily to limit the current of the lamp(s) CCT Correlated colour temperature CFL Compact fluorescent lamp CRI Color rendering index, or “Ra” ELI Efficient Lighting Initiative HEPS High efficiency performance standard IEC International Electrotechnical Commission Lamp Source of artificial optical radiation lm lumen, the international measure of light output (luminous flux) MEPS Minimum energy performance standard Nominal / Rated value The manufacturer’s declared value for a lighting product SDCM Standard deviation of colour matching W Watt

3REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 1. INTRODUCTION VSQI are seeking to update the existing energy efficiency standard (TCVN 7896:2008) for compact fluorescent lamps (CFLs). This report aims to assist this process by undertaking the following tasks: 1. Identify relevant CFL MEPS and high performance levels (HEPS) implemented in neighbouring countries. 2. Recommend new CFL MEPS and endorsement label levels appropriate for Vietnam. 3. Examine TCVN 7896 and recommend improvements to prevent loopholes and accommodate new technology. It is strongly recommended that consultation with relevant stakeholders in Vietnam be undertaken (i.e. with technical persons familiar with the Vietnamese lighting market) before reaching final conclusions regarding this standard. Note that CLASP and the en.lighten initiative have developed the following document: Assessment of Opportunities for Global Harmonization of Minimum Energy Performance Standards and Test Standards for Lighting Products1. This resource is useful when developing lighting MEPS and HEPS requirements for CFLs (see page 19 of the document).

2. CURRENT VIETNAMESE REQUIREMENTS The current requirements contained in TCVN 7896 are summarised below:  Scope: CFLs of power 5-60W with high frequency electronic ballast.  CFLs shall meet the safety and performance requirements contained in TCVN 7672 and 7673 (IEC 60968 and 60969 respectively).  CFLs shall meet the minimum MEPS efficacy requirements in the following table (and meet HEPS if seeking an endorsement label):

Table 1: Vietnamese MEPS and HEPS levels

Power (W) Efficacy (lm/W)

CCT < 4400 K CCT ≥ 4400 K MEPS HEPS MEPS HEPS 5 to 8 45 55 40 50 9 to 14 50 60 45 55 15 to 24 55 65 50 60 25 to 60 60 70 55 65

 CFL colour temperature shall meet requirements of TCVN 7863 (IEC 60901 - single capped fluorescent lamp performance requirements), which states that measured X/Y colour coordinates of lamps shall be within 5 SDCM (standard deviations of colour matching) from the rated value.  CFL lumen maintenance at 2000 hours shall be >= 80%.  CFL lamp life (rated) shall be >= 6000 hours.

1 Available from http://www.clasponline.org/Resources/Resources/PublicationLibrary/2011/Global- Harmonization-Lighting-MEPS-TestStandards

4REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 3. MEPS The following neighbouring countries have MEPS for CFLs:  Australia - introduced 2009 (currently under review).  China - introduced 2003 and updated 2013.  India (voluntary) - introduced 2006.  Indonesia - introduced 2011 (new proposals).  Philippines - introduced 2010.  Thailand - introduced 2006.

Efficacy requirements For the purpose of comparing the MEPS efficacy requirements of the countries and initiatives listed above, Figure 1 shows MEPS efficacy levels for lamps with “low” colour temperatures (i.e. <4400K) and Figure 2 shows MEPS efficacy levels for lamps with “high” colour temperatures (i.e. ≥4400K). It should be noted that although many countries have adopted separate MEPS for cool and warm CFLs, as is the case in Vietnam, Australia has one MEPS level for all CFLs, irrespective of their colour temperature. The data provided for Indonesia’s MEPS is the current proposal2, which is yet to be ratified. The data provided for Australia represents the current MEPS levels, although these are under review.

Figure 1: National MEPS efficacy levels for low colour temperature CFLs

2 As presented at the lites.Asia meeting in Kuala Lumpur, April 2014, see: http://www.lites.asia/files/otherfiles/0000/0285/Kuala_Lumpur_lites.asia_meeting_1.8_Country_Update_Indonesi a.pdf

5REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 Compared with other national MEPS requirements for CFLs with a low colour temperature, the current Vietnamese MEPS requirements for efficacy for products with rated power less than 15 Watts are less stringent than the Philippines, China and India, but are more stringent than Australia, Thailand and Indonesia. For lamps with a rated power of more than 15 Watts, the current Vietnamese requirements match those of Thailand but are less stringent than all other countries in this comparison, with the exception of Indonesia (proposed).

Figure 2: National MEPS efficacy levels for high colour temperature CFLs

Compared with other national MEPS requirements for CFLs with a high colour temperature, the current Vietnamese MEPS requirements for efficacy are less stringent than all other countries in this comparison, with the exception of Indonesia, and Thailand for low power lamps. It is worth noting that some countries have adopted an efficacy “curve” requirement (e.g. China and Australia) and some a “step function” requirement (e.g. Vietnam), as can be seen in the above figures. The step function is less desirable, as it encourages CFL manufacturers to manufacture higher power lamps which consume more electricity. For example, the current Vietnam (high colour temp) requirement is 45 lm/W for lamps 9-14W. It is easier to manufacture a 14W lamp to meet this requirement, than a 9W lamp. This is because CFLs become naturally more efficient as they become larger. For this reason, and to prevent gaming, it is preferable to adopt a curved efficacy requirement which follows the natural efficacy advantage of CFLs as they become larger.

Performance of CFLs in Vietnam The following data has been used to assess the current performance of CFLs in Vietnam:  9 CFL models purchased in 2008 and tested as part of the EcoAsia report3 (these are primarily high colour temperature lamps).

3 Available from http://www.lites.asia/document/55/testing-for-quality-benchmarking-energy-saving-lamps-in- asia

6REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896  20 CFL models purchased and tested as part of the 2013 VEESL checktesting program (all of these lamps have high colour temperatures (>=4400K)).  280 CFL models registered with MOIT, comprising 58 models with a colour temperature <4400K and 222 models with a colour temperature >=4400K. It should be noted that the performance of these models reflects the unverified declarations of suppliers. These samples are summarised in Table 2.

Table 2: Data sources for Vietnamese CFLs

<4400K ≥4400K Total

EcoAsia samples 1 8 9 VEESL samples 0 20 20 MOIT registered models 58 222 280 Totals 59 250 309

Based on either the tested or claimed performance, 94% of these models pass the relevant MEPS level. It is surprising that the majority of those models which didn’t pass MEPS levels have been identified from the registration data. It is not known why these models were granted approval for registration when they fail MEPS, but it is an issue that will be resolved through the transition to the electronic registration process now in place.

Table 3: Vietnamese CFL models that pass MEPS levels

<4400K >=4400K Total

EcoAsia samples 1 (100%) 7 (88%) 8 (89%) VEESL samples - 20 (100%) 20 (100%) MOIT registered models 54 (93%) 210 (95%) 264 (94%) Totals 55 (93%) 237 (95%) 292 (94%)

Of greater significance for this analysis is the extent to which the declared performance values of CFLs exceed MEPS. Figure 3 shows that a large number of models with colour temperature <4400K have a declared efficacy that is far greater than the MEPS level across the full range of declared power bands. Figure 4 and Table 4 provide a breakdown of the average, minimum and maximum efficacies for each bin (power bands). This data suggests that there is scope to increase the stringency of MEPS without significantly limiting the availability of products for Vietnamese consumers.

7REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 Figure 3: CFLs registered in Vietnam and Vietnamese MEPS levels (CCT<4400K)

Table 4: Characteristics of CFLs registered in Vietnam by power bins (CCT<4400K)

Power Bins 5 to 8 9 to 14 15 to 24 25 to 60 All

Average efficacy 56 62 63 71 62 Minimum efficacy 46 53 53 60 46 Maximum efficacy 70 70 74 81 81

Figure 4: Characteristics of CFLs registered in Vietnam by power bins (CCT<4400K)

8REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 The situation is similar for CFLs in Vietnam with a colour temperature of ≥ 4400k, as shown in Figure 5, Table 5 and Figure 6. This data also strongly suggests that there is scope to make the MEPS requirements more stringent.

Figure 5: CFLs registered in Vietnam and Vietnamese MEPS levels (CCT≥4400K)

Table 5: Characteristics of CFLs registered in Vietnam by power bins (CCT≥4400K)

Average efficacy 53 57 59 62 58 Minimum efficacy 42 47 52 55 42 Maximum 59 64 69 72 72 efficacy

Figure 6: Characteristics of CFLs registered in Vietnam by power bins (CCT≥4400K)

9REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 Note that for this analysis, only registration data has been used to avoid duplication, since it is assumed that all tested products are also registered. Figure 7 and Table 6 present the efficacy data for 20 lamps tested as part of the VEESL project compared to the claimed performance of these lamps in the database.

Figure 7: Comparison of tested and claimed performance

Table 6: Comparison of tested and claimed performance

Lamp Tested Efficacy Claimed Efficacy Difference (%) Reference (lm/W) (lm/W)

1 49.0 n/a 6 43.0 47.0 9% 11 48.0 50.0 4% 12 54.0 55.0 2% 16 46.0 n/a 2 54.0 56.2 4% 17 51.0 n/a 7 49.0 52.0 6% 13 58.0 59.0 2% 3 59.0 63.6 8% 8 54.0 52.0 -4% 18 54.0 n/a 14 61.0 61.0 0% 4 58.0 62.5 8% 9 55.0 61.1 11% 19 58.0 n/a 10 58.0 61.7 6% 15 62.0 59.0 -5% 20 56.0 n/a 5 63.0 68.5 9% Average 4%

10REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 This comparison shows that in general most lamps claim a higher efficiency than justified by the test results. While it is not known whether the 4% difference is universal for all efficacy claims, without further data it is reasonable to assume that the actual efficacy of most lamps will be slightly less than declared.

Other Performance Parameters Many programs include a range of requirements for lamps in general and CFLs in particular. The reason for this is (a) the interrelation between different lamp characteristics means that it is possible to produce lamps with a high efficacy but which otherwise perform poorly, and (b) governments aim to ensure a minimum lighting quality for efficient lighting products so that consumers feel confident when they make the transition away from inefficient incandescent lighting. The key performance parameters to ensure the quality of efficient lighting for households are as follows:  Colour temperature (SDCM): ensures that CFLs have a similar colour to the intended colour (e.g. 6500K).  Lumen maintenance at 2000 hours: ensures that CFL light output does not decrease too much during its life. Note that testing of lamps from Australia and Asia has shown that achieving lumen maintenance of more than 80-85% is difficult. Also, checking lumen maintenance compliance requires testing lamps for 2000 operating hours.  Life: ensures long life.  Colour rendering index (CRI): ensures that CFLs “render” colours accurately, e.g. red objects look red, blue objects look blue, etc.  Starting time: ensures that CFLs light up quickly, i.e. minimum time spent waiting in darkness.  Run-up time: ensures that CFLs reach their full light output quickly.  Mercury content: reduce CFL mercury contribution.  Heavy switching withstand (rapid cycle test): ensures that CFLs can survive when they are switched on and off frequently.  Power factor: not a significant consumer issue, but has benefits for the electricity utility in reducing harmonic currents on the electricity network. Table 7 lists the requirements for performance parameters, other than efficacy, for Vietnam and the countries being examined.

Table 7: Requirements for other performance parameters in CFL MEPS

China India Vietnam Australia Philippines MEPS Voluntary MEPS MEPS MEPS (2013) MEPS

Colour temperature (SDCM) ≤5 ≤5 ≤5 ≤5 - Lumen maintenance at 2000 hours ≥80% ≥88% ≥85% ≥85% ≥80% Life ≥6000 hrs ≥6000 hrs - ≥6000 hrs ≥6000 hrs Colour rendering index (CRI) ≥80 ≥80 - - - Starting time - ≤2 sec - ≤4 sec - Run-up time (to 60% output) - ≤60 sec - ≤120 sec - Mercury content - ≤5 mg ≤5 mg - - Heavy switching withstand (rapid - ≥ 3000 - - -

11REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 cycle test) cycles Power factor - ≥0.55 - - -

The Vietnamese requirements for other performance parameters, compared to the requirements used in other countries, are as follows:  The Vietnam MEPS colour temperature (SDCM) requirement is in line with other countries / initiatives.  The Vietnam MEPS lumen maintenance requirement agrees with 3 other countries (where they include a requirement) although is at the low end of the requirements used by other countries / initiatives.  The Vietnam MEPS life requirement is in line with other countries / initiatives (where they include a requirement).  The Vietnam MEPS CRI requirement is in line with other countries / initiatives (where they include a requirement).  Vietnam does not specify other requirements such as starting time, run-up time, mercury content, switching withstand and power factor. These parameters are included in MEPS by some countries in order to ensure the minimum quality of CFLs in the market.  The need to include minimum requirements for mercury content in CFL MEPS is important since Vietnam is a signatory to the Minamata Mercury Convention4, which states that CFLs for general lighting purposes that are ≤30 watts shall be phased-out if they have a mercury content exceeding 5 mg per lamp burner. This suggests that it would be beneficial to include requirements for starting time, run-up time, mercury content, switching withstand and power factor in any future revision of MEPS in Vietnam.

4. HEPS LEVELS

Efficacy requirements Figure 8 shows the high efficiency levels used in China, Indonesia5 and the ELI initiative compared to the current HEPS level in Vietnam for CFLs with a low colour temperature. For these lamps, the Vietnamese HEPS level is more stringent than the ELI requirements and those proposed in Indonesia, but less stringent than the Chinese high efficiency levels, particularly for lower power CFLs.

4 http://www.mercuryconvention.org/Countries/tabid/3428/Default.aspx 5 The requirements shown for Indonesia are the proposed requirements for 4-star CFLs.

12REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 Figure 8: HEPS levels for low colour temperature CFLs

Figure 9 shows the high efficiency levels used in China, Indonesia6 and the ELI initiative compared to the current HEPS level in Vietnam for CFLs with a high colour temperature. For these lamps, the current Vietnam HEPS levels lie approximately in the middle of HEPS levels in neighbouring countries.

Figure 9: HEPS levels for high colour temperature CFLs

Performance of CFLs in Vietnam

Registered CFLs The following section includes an analysis of the information included in current CFL registrations with MOIT. 50% of registered CFLs with a colour temperature <4400K meet the relevant HEPS levels, as shown in Figure 10.

6 The requirements shown for Indonesia are the proposed requirements for 4-star CFLs.

13REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 Figure 10: CFLs registered in Vietnam and Vietnamese HEPS levels (CCT<4400K)

45% of registered CFLs with a colour temperature ≥4400K meet the relevant HEPS levels, as shown in Figure 11.

Figure 11: CFLs registered in Vietnam and Vietnamese HEPS levels (CCT≥4400K)

As shown in Table 8, the share of models that meet HEPS levels is fairly consistent across the range of wattages.

14REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 Table 8: Models that pass Vietnamese HEPS levels by colour temperature and wattage

CCT < 4400 K

Meet HEPS (number) 6 14 6 3 29

Meet HEPS (%) 50% 64% 30% 75% 50%

CCT ≥ 4400 K

Meet HEPS (number) 16 38 29 18 101

Meet HEPS (%) 55% 66% 43% 26% 45%

These figures include models that currently do not meet current MEPS levels. If these were removed, the share of models meeting relevant HEPS levels would be greater. It should also be noted that the data shown above refers to models that are registered with MOIT, and is not sales-weighted. Therefore it does not necessarily reflect the situation in the market. A better understanding of the number of models in the Vietnamese market that meet HEPS levels can be gained from consideration of the use of the endorsement label. This is discussed in the following section.

Use of Endorsement Label The labelling display survey, undertaken in January 2014 as part of the VEESL program, involved the visual inspection of products in stores to ascertain whether models within the scope of regulations are displaying the label correctly. In Vietnam, lighting products that meet the specified ‘high efficiency’ level of performance are eligible to display an endorsement label shown in Figure 12.

Figure 12: Vietnamese endorsement label

The survey included 1,021 CFLs in stores located in Hanoi, HCMC, Quang Tri and Can Tho. Of these, 537 (53%) were found to display the endorsement label on CFL packaging. While it is not possible to state whether the performance of all these models matched the requirements of the endorsement label (until verified through laboratory tests), a recent VEESL project involved the testing the efficacy of 600 CFLs and verified that their actual energy performance matched their claimed performance7. It is therefore a reasonable assumption that most of the labeled products are eligible.

7 Testing of CFLs was undertaken on 30 samples of 20 different models.

15REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 Since 53% of models in stores are found to be carrying the label, which is higher that the share of registered models that meet HEPS levels, it suggests that many models with a higher market share are labeled.

Other Attributes Table 9 lists the requirements for other performance parameters, in addition to efficacy, for Vietnam and the countries / initiatives HEPS being examined.

Table 9: Requirements for other performance parameters in CFL HEPS

Vietnam HEPS China HEPS ELI HEPS (2013) Colour temperature (SDCM) ≤5 ≤5 ≤5 ≥80% Lumen maintenance at 2000 hours ≥80% ≥85% (at 40% life) Life ≥6000 hrs - ≥8000 hrs Colour rendering index (CRI) ≥80 - ≥80 Starting time - - ≤1.5 sec ≤180 sec Run-up time (to 60% output) - - (to 80% output) Mercury content - ≤5 mg ≤5 mg Heavy switching withstand (rapid cycle test) - - ≥ 50% of rated life hours Power factor - - ≥0.5 For both Vietnam and China, the HEPS requirements for these other attributes are no more stringent than MEPS. Vietnam does not currently specify other requirements such as starting time, run-up time, mercury content, switching withstand and power factor that are needed to ensure high quality efficient lighting.

5. TRANSITIONAL ARRANGEMENTS A report provided by the Australian Government to MOIT in September 2013, entitled “Proposal for grandfathering in VNEEP”, identified the need to implement transitional arrangements when moving from one set of product performance requirements to another. These transitional arrangements enable industry to make the necessary adjustment to the products that are placed on the market by the time that new requirements come into force; enable products to be tested and registered in an orderly fashion to avoid excessive pressure on laboratories or registration systems; and minimise the potential confusion to consumers of having different labels in the market at the same time. Most national regulatory Standards and Labelling programs around the world have agreed similar transitional arrangements with industry. They:  Allow industry time to adjust to new requirements.  Provide time for laboratories to test products.  Provide time for products to be registered to new requirements.  Avoid confusion by retailers and consumers.  Minimise the time when two versions of the energy label appear in the market at any one time.  Facilitate compliance monitoring.

16REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896  Minimise market disruption & costs.

Key Procedures To put in place effective transitional arrangements, the following important procedures should be implemented and communicated to stakeholders:  Finalise the test method.  Finalise the new performance requirements.  Publish the date the new requirements come into force (known as the “effective date”): o We suggest that at least 12 months is allowed from announcement to the effective date to enable suppliers to start testing and registering to the new standard.  Set a ‘grandfathering start date’: o Products manufactured or imported before this date do not have to meet new requirements. o Products manufactured or imported after this date must meet new requirements.  We suggest that the ‘grandfathering start date’ should be 12 months before the ‘effective date’ in order to avoid ‘stockpiling’ of old products to circumvent new regulations.

 Set the relevant dates for registrations, including:

o The date when the regulator will commence accepting registrations to the new standard (known as the commencement of voluntary registrations to the new standard).

 It is suggested that this is the ‘grandfathering start date’.

o The date when the regulator will cease to accept registrations to the old standard (known as the commencement of mandatory registrations to the new standard).

 It is suggested that this is the ‘effective date’.

o The date when registrations to the old standard will be superseded, effectively this is a cancellation of the old registrations (made after the grandfather start date).

 It is suggested that this is the ‘effective date’.

In order to claim grandfathering provisions for individual models, suppliers must provide evidence of the date of manufacture or date of importation. All suppliers should be able to lodge a claim for grandfathering status through the registration system and disclose that they will either: . Date stamp the product, or . Provide information on how the model serial numbers can be used to demonstrate the date of manufacture.

Additional requirements for transition to new labelling requirements Where there are existing labels for a product and these are being upgraded, it is extremely important that the incoming label is distinguishable from the previous version. This can be achieved through the use of different colours or the inclusion of a date on the label, while taking care that the overall brand recognition of the label is not lost.

17REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896  From 12 months before the effective date, suppliers may voluntarily register products according to the new TCVN requirements and display the new label. Figure 13 illustrates these arrangements for a labelling transition.

Figure 13: Grandfathering and transitional arrangements for the introduction of revised labelling requirements

For example, if the new MEPS and labelling requirements for CFLs were published in September 2014, the corresponding dates could be as follows: Grandfathering Start Date: 1 January 2015 Commencement of voluntary registrations to the new standard: 1 January 2015 Commencement of voluntarily display of new label: 1 January 2015 Effective Date: 1 January 2016 Commencement of mandatory registrations to the new standard: 1 January 2016 Cancellation of the registrations to the old standard: 1 January 2016

18REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 6. CONCLUSIONS AND RECOMMENDATIONS FOR VIETNAM The evidence from the labeling survey, product tests and database entries suggest that the current MEPS and endorsement levels for CFLs require upgrading so that they continue to have a beneficial impact on the Vietnamese market. As a result of the product improvements and the impacts of Standards and Labelling programs, it is typical that regulators need to make requirements increasingly stringent to match the technical improvements of products available in the market. In considering suitable new performance requirements there are benefits from closer alignment with the levels already met by another country in the region. This may make sourcing product easier and enable cooperation in compliance activities. As noted previously, Australia has the same requirements for all CFLs irrespective of their colour temperature, which assists communication with industry. Analysis of registration data in Vietnam suggests that there is currently a clear distinction between the efficacy levels obtained by lamps according to their colour temperature. This is illustrated in Figure 14.

Figure 14: Efficacy of CFLs registered in Vietnam by colour temperature

As a result it is suggested that the current process of setting different efficacy levels according to the colour temperature of the CFL is justified.

MEPS recommendations Based on the information presented in this report, the following recommendations are made: 1. A significant number of CFLs currently available in Vietnam exceed the current MEPS levels by a considerable margin. As a result, there is scope to increase the stringency of MEPS for all CFLs without reducing the availability of products for Vietnamese consumers. 2. Consideration should be given to setting a revised MEPS levels for CFLs based on an efficacy curve, rather than a stepped function, since this avoids gaming by suppliers and does not provide an incentive to supply CFLs that consume higher quantities of electricity. 3. This would also overcome the current issue with defining the bins. At the moment it is unclear what requirements, if any, apply to lamps that fall between the power values for each bin (e.g.

19REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 lamps with a rating of 8.5 or 14.5 Watts). If a stepped function is implemented, then it should be made clear how such lamps should be treated. 4. Consideration should be given to implementing revised MEPS levels that match a neighbouring country, as this will increase the availability of products, reduce compliance costs for suppliers and assist Vietnamese enforcement processes. It will also facilitate future benchmarking and improve policy alignment in the region. 5. Figure 15 shows some possible options for alignment, including the current MEPS in Australia, China and the Philippines for products with a CCT <4400K, compared to CFLs registered in Vietnam. The Australian MEPS level would appear to have very little impact on the market, while 91% of Vietnamese models would pass the Chinese MEPS level if implemented in Vietnam, based on their declared performance. Based on a limited number of test results, it is likely that the actual performance of lamps is slightly less than their declared value, and hence the impact of these MEPS will probably be marginally greater. While both of these options have the advantage that they are based on an efficacy curve, their impact on the market is estimated to be less than usually expected of MEPS, which typically aim to remove the worst performing third of the market providing there is a sufficient range of models retained on the market. As a result, neither of these options would deliver the full opportunity to maximize energy savings, and meet government expectations of the program. Implementing the Philippine MEPS levels in Vietnam would ensure that approximately 79% of Vietnamese registered models would still be able to be sold in Vietnam (based on declared values), without reducing choice for consumers for any size of lamp. This option would appear closer to optimizing energy savings, although consideration could be given to whether a hybrid version should be implemented in Vietnam that matched the Philippine levels but replaced the stepped function with a curve. An illustration of this is shown in Figure 15 as “New Curve”.

Figure 15: Alignment options for revised CFL MEPS, CCT<4400K

20REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 6. Figure 16 shows some possible options for alignment, including the current MEPS in Australia, China and the Philippines for products with a CCT ≥4400K, compared to CFLs registered in Vietnam. Implementation of the Chinese MEPS level in Vietnam would leave 80% of the currently registered models on the market (based on declared values), while the Philippines MEPS level would leave 70% of Vietnamese models on the market. Both of these appear viable options, but so would be a new a hybrid that matches the Philippines MEPS but is configured as a efficacy curve. This option is illustrated on Figure 16, identified as “New Curve”.

Figure 16: Alignment options for revised CFL MEPS, CCT≥4400K

7. It is strongly recommended that performance parameters for CRI, starting time, run-up time, mercury content, switching withstand and power factor are included in any revision of MEPS to ensure the performance of lamps sold in Vietnam. Suggested values are included in Table 10.

Table 10: Performance parameters for consideration in future Vietnamese MEPS for CFLs

Attributes Proposal for Vietnam Colour temperature (SDCM) ≤5 Lumen maintenance at 2000 hours ≥80% Life ≥6000 hrs Colour rendering index (CRI) ≥80 Starting time ≤2 sec Run-up time (to 60% output) ≤60 sec Mercury content ≤5 mg Heavy switching withstand (rapid cycle test) ≥3000 cycles Power factor ≥0.55

8. The transitional arrangements identified in Section Transitional Arrangements should be implemented, including the provision that new MEPS will not come into force until at least 12 months after the announcement of new MEPS requirements and any revised test procedures.

21REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 9. In addition to revisions to MEPS, the changes to the test method, TCVN 7896, identified in Section should be implemented.

HEPS Recommendations There is strong evidence that the majority of lamps in the market are now using the endorsement label, which suggests that it is time to consider revising the current HEPS level upwards so that the objectives of the endorsement label can continue to be met. While we do not believe that MOIT have a policy on how to define ‘high performance’ or best performing products’, experience suggests that endorsement labels are most effective when they provide clear differentiation in the market. For example, the Energy Star label has been in existence since 1992 and is now the most widely used endorsement label worldwide. As the uptake of more efficient products happens, the criteria or specifications are upgraded, with the intention to endorse approximately the top 25% of the market. Improvements in product efficiency have led to over 150 specification revisions covering 60 product groups since its inception. “When ENERGY STAR qualified models represent a high percentage of the market for a given product category, it suggests there may be an opportunity for additional savings and further refinement in the specification. As a general rule, product specifications will be reviewed for possible revision at least once every three years or when the market share of qualified products reaches about 35%. For products that evolve rapidly in the market, such as displays, ENERGY STAR specifications are reviewed every 2 years.” 8 Based on the information presented in this report, the following recommendations are made: 1. A significant number of CFLs currently available in Vietnam meet or exceed the current HEPS levels and are therefore eligible to use the endorsement label. As a result, the advantage of the label to suppliers and consumers is starting to be eroded. It is therefore recommended that HEPS are made more stringent. 2. Consideration should be given to setting a revised HEPS levels for CFLs based on an efficacy curve, rather than a stepped function, for the reasons identified above. 3. Consideration should be given to implementing revised HEPS levels that match a neighbouring country, as this will increase the availability of products, reduce compliance costs for suppliers and assist Vietnamese enforcement processes. It will also facilitate future benchmarking and improve policy alignment in the region. 4. Figure 17 shows some possible options for alignment, including the current HEPS in China (level 1) and the Chinese HEPS level 29 for products with a CCT <4400K, compared to the current HEPS requirements in Vietnam and CFL models registered in Vietnam. If implemented in Vietnam, the Chinese level 2 requirements would leave 43% of products registered in Vietnam eligible for the high efficiency label (based on declared values), which is little change from the existing situation. Implementing the current Chinese HEPS level 1 in Vietnam would leave 16% of Vietnamese registered models eligible for the high efficiency label. While this would appear to be a significant reduction in the number of labeled products available in the market, it is highly likely that this proportion would rise by the time that new HEPS levels came into force. Clearly suppliers value

8 ES (2012), ENERGY STAR® Products Program Strategic Vision and Guiding Principles, May 2012. Available at: http://www.energystar.gov/ia/partners/prod_development/downloads/ENERGY_STAR_Strategic_Vision_and_Guid ing_Principles.pdf?2758-38da 9 The Chinese level 2 performance requirements refer to the performance thresholds for the "certification" mark which qualifies products to apply the CQC label.

22REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 the benefits provided by the label and the provision of at least 12 months notice would enable suppliers to manufacture or import better performing lamps for the Vietnamese market.

23REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 Figure 17: Alignment options for revised CFL HEPS, CCT<4400K

5. Figure 18 shows some possible options for alignment, including the current HEPS in China (level 1) and the Chinese HEPS level 2 for products with a CCT ≥4400K, compared to the current HEPS requirements in Vietnam and CFL models registered in Vietnam. Implementation of the Chinese Level 1 HEPS in Vietnam would leave very few of currently registered models eligible for the high efficiency label, although as above it is highly likely that given sufficient advanced notice the market would respond by providing models that meet these requirements. The Chinese level 2 HEPS requirements are more stringent that the current Vietnamese HEPS levels particularly for lower power lamps. Implementation of these requirements in Vietnam would leave 28% of currently registered models eligible for the high efficiency label (based on declared values).

24REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 Figure 18: Alignment options for revised CFL HEPS, CCT≥4400K

6. It is strongly recommended that performance parameters for CRI, starting time, run-up time, mercury content, switching withstand and power factor are included in any revision of HEPS to ensure the performance of lamps sold in Vietnam. Suggested values are included in Table 11.

Table 11: Performance parameters for consideration in future Vietnamese HEPS for CFLs

Attributes Proposal for Vietnam Colour temperature (SDCM) ≤5 Lumen maintenance at 2000 hours ≥80% Life ≥8,000-10,000 hrs Colour rendering index (CRI) ≥80 Starting time ≤1 sec Run-up time (to 60% output) ≤30 sec ≤3 mg Mercury content (Note: many countries are moving to 3mg as a MEPS) ≥ lamp lifetime expressed in hours (same as Heavy switching withstand (rapid cycle test) Europe) Power factor ≥0.5

7. The transitional arrangements identified in Section Transitional Arrangements should be implemented, including the provision that new HEPS will not come into force until at least 12 months after the announcement of new HEPS requirements and any revised test procedures. 8. In addition to revisions to MEPS, the changes to the test method, TCVN 7896, identified in Section should be implemented.

25REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 26REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 7. POTENTIAL IMPROVEMENTS TO TCVN 7896 The Standard TCVN 7896:2008 Compact Fluorescent Lamps - Energy Efficiency, has been reviewed. This chapter contains suggestions for revisions to the standard in order to remove ambiguities. Note that these do not include any changes to MEPS and HEPS levels, which are discussed in previous sections of this report. Further revision would be required in order to implement any of the options discussed above. Red text in this appendix denotes explanatory notes – this text is not for inclusion in the standard itself. Blue text denotes suggestions for additions to the standard. Struck-out text denotes suggestions for deletions from the standard. ======1. Scope of application This standard applies to self-ballasted compact fluorescent lamps (hereby referred as CFL), operating with integral high-frequency electronic ballast, with capacity ranged from 5W to 60W. 2. References The following references are crucial to application of this standard. For those with issuance year, the standard is effective for that year. Or else, the standard is effective on the latest version (with modification included) TCVN 7541 – 2: 2005, high efficiency lighting products – Part 2: methods for determination of energy efficiency TCVN 7672: 2007 (IEC 60968: 1999), lamps with assembled ballast used for common lighting – safety requirement TCVN 7673: 2007 (IEC 60969: 2001), lamps with assembled ballast used for common lighting – specification requirement TCVN 7863: 2008 (IEC 60901: 2003 and 3rd edn: 2004), single-pin fluorescent lamps - specification requirement 3. Terminology and definition This standard uses some terms and definitions mentioned in TCVN 7541-2: 2005 and the following terminology: 3.1. CFL’s initial lighting efficiency Defined as the ratio between lamp initial luminous flux and its measured capacity power 3.2. CFL Energy efficiency CFL’s initial lighting efficiency is determined within the specified testing condition. 4. Technical requirement 4.1. General requirement CFL should meet the safety and specification requirement specified in TCVN 7672: 2007 (IEC 60968: 1999) and TCVN 7673: 2007 (IEC 60969: 2001) Average measured luminous flux capacity is not allowed to be less than 15% 90% lower than of issued capacity rated luminous flux. Note this is in line with IEC standards requirements.

27REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 4.2. Energy efficiency Energy efficiency of CFL is determined on 2 levels: minimal efficiency level and high efficiency level, as specified in Table 1. Table 1:

Energy efficiency (lm/W) Capacity range Colour temperature Tc < 4400 K Colour temperature Tc ≥ 4400 K (W) Minimal level High level Minimal level High level 50 5 to 8 45 55 40 50 9 to 14 50 60 45 55 15 to 24 55 65 50 60 25 to 60 60 70 55 65

Note: Color temperature of CFL in Table 1 must meet the requirement of the color coordinates specified in TCVN 7863: 2008 (IEC 60901: 2000 and its 3rd edn: 2004). Note: The capacity range should be continuous, i.e. 5 to <9; 9 to <15, etc. 4.3. Luminous flux maintenance factor Luminous flux of CFL after 2000 hours lighting should not be lower than 80% of initial luminous flux. 4.4. Life cycle The manufacturer must specify the life cycle of CFL, noting that it should not exceed 6000 hrs. Should this say “should not be less than 6000 hrs” ? 5. Testing method 5.1. Determination for initial lighting efficiency Initial luminous flux and capacity of CFL are measured as specified in TCVN 7541-2: 2005, followed by measurement of initial lighting efficiency. 5.2. Luminous flux factor measurement Luminous flux factor of CFL is measured as specified in TCVN 7541-2: 2005. 5.3. Determination for color coordinates and temperature Color coordinates and temperature of CFL are measured as specified in TCVN 7673: 2007 (IEC 60969: 2001). 5.4. Color index (Ra) determination Color index Ra of CFL is measured as specified in TCVN 7863: 2008 (IEC 60901: 2003 and 3rd edn: 2004) 5.5. Life cycle determination CFL’s life cycle is tested and determined as specified in TCVN 7863: 2008 (IEC 60901: 2000 and its 3 rd edn: 2004).

28REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896 It is allowed to use rapid testing method (method of switching cycle) to determine the life of CFL. Switching mode includes:

− Switching on for 0.5 min; − Cutting off for 4.5 min. This test is continuously carried out until half of the CFL lamps are no longer operating. Each cycle is determined by:

− 1 hour, connecting to a 9W lamp; − 1.5 hour, connecting to a lamp with capacity lower than 9W. As discussed for LFL we are not aware that this “rapid test method” is used elsewhere. Since there is no experience or data relating to the usefulness or accuracy of this test we would probably have to err on the side of not recommending this option, at this stage. Note there is no widely accepted “accelerated” life test for CFLs.

29REPORT ON VIETNAMESE COMPACT FLUORESCENT LIGHTING STANDARD TCVN 7896