Review of Vietnamese Rice Cooker Standards · Review of Vietnamese Rice Cooker ... the test procedure are similar across countries in the region. ... methods make the results of the

Review of Vietnamese Rice Cooker Standards

A report for the Vietnam Energy Efficiency Standards and Labelling (VEESL) Program August 2014 Prepared for the Department of Industry (Australia)

Produced by

Kevin Lane, Mark Ellis

Executive Summary This report provides an analysis of the current rice cooker energy efficiency regulations In Vietnam and examines the options for the potential revision of the relevant test standard and performance requirements.

The main conclusions that can be drawn from the analysis presented in this report are:

• There is no agreed international testing procedure for rice cookers, though many aspects of the test procedure are similar across countries in the region.

• The currently required time of four minutes of cooking in TCVN 8252: 2009 is too short to provide a sufficiently accurate or reliable estimate of cooking efficiency.

• There is a currently a reasonable spread of efficiency of rice cookers on the Vietnamese market, so no change in the label performance requirements is necessary at this stage, although this should continue to be monitored.

• The performance requirements do not currently make distinction for the size (or power) of the rice cooker, whereas most other countries have stricter requirements for large rice cookers. Addressing this issue in Vietnam could mean a slight increase in the MEPS requirements for the larger products.

• Some neighbouring countries include non-cooking modes in their requirements, specifically the ‘keep-warm’ and the ‘standby’ modes.

Recommendations for testing standard

The main suggested change to the test method (TCVN 8252: 2009) is to increase the temperature rise during the energy performance test. It is recommended that the test duration of four minutes cooking time is replaced by the requirement to conduct the test until the water reaches a temperature of 90oC.

To align it with other countries in the region, it is also recommended to alter the start test temperature to 23oC ± 2oC. This is a minor change, and should not result in any significant change in the measured energy performance of the products under test.

In addition, it is suggested that the test procedure specifies that, in order to calculate the cooking efficiency, the average of all four tests should be used (Clause 5.2.3). This will provide a more robust average for the efficiency calculation.

Recommendations for performance requirements

Since the current market shows a good spread of efficiency of products on the market, no major change in performance requirements is recommended. However, we do recommend that performance requirements are more closely linked to the size of rice cookers, as indicated by their power rating. Recommended new MEPS levels are shown in the following table.

Proposed new MEPS requirements

Rated Power, P (Watt) Minimum heat efficiency (%)

P< 400 80 400 <P <= 600 81 600 < P <= 800 82 800 < P <=1000 83

1000 < P <= 2000 84 It is suggested that the labelling requirements should remain linked to the energy efficiency index (K). Therefore, if higher MEPS requirements for larger rice cookers are adopted, the energy efficiency requirements for each label grade will also be higher for the larger rice cookers. VEESL REVIEW OF VIETNAMESE ELECTRIC RICE COOKER STANDARDS, AUGUST 2014 i

Contents Executive Summary ............................................................................................................. i

1 Introduction .................................................................................................................. 1

2 Current requirements in Vietnam ................................................................................. 2

3 Examining the testing methods ..................................................................................... 3 3.1 International test methods ............................................................................................................ 3 3.2 Test methods used in the region ................................................................................................... 3 3.3 Potential for harmonisation and amending the testing standard ................................................. 6

4 Examining MEPS and label performance levels ............................................................. 7 4.1 Performance levels used in the region .......................................................................................... 7 4.2 Current market performance ....................................................................................................... 11 4.3 Potential for harmonisation and amending performance standards .......................................... 15

5 Transitional arrangements .......................................................................................... 17 5.1 Key Procedures ............................................................................................................................ 17

6 Conclusions and recommendations ............................................................................. 19 6.1 Conclusions .................................................................................................................................. 19 6.2 Recommendations ....................................................................................................................... 19

7 Potential improvements to the regulations ................................................................. 22

8 References .................................................................................................................. 22

VEESL REVIEW OF VIETNAMESE ELECTRIC RICE COOKER STANDARDS, AUGUST 2014 ii

Figures Figure 1: Proportion of registrations by efficiency grade (from registration database and label survey)

...................................................................................................................................................... 12 Figure 2: Reported efficiency index (K) of all registered rice cookers, ordered by efficiency .............. 13 Figure 3: Efficiency (K) registered rice cookers versus capacity (litres) ................................................ 13 Figure 4: Efficiency (K) registered rice cookers versus rated power (W) .............................................. 14 Figure 5: Reported average cooking efficiency (%) of the 20 models of rice cookers .......................... 15 Figure 6: Grandfathering and transitional arrangements for the introduction of revised labelling

requirements ................................................................................................................................ 18 Figure 7: Impact of revised MEPS on registered products (March 2014 database) ............................. 20

Tables Table 1: Energy efficiency grade given in TCVN 8252: 2009 and the implied efficiency ........................ 2 Table 2: Detailed comparison of regional testing standards .................................................................. 5 Table 3: China MEPS and label requirements ......................................................................................... 7 Table 4: Hong Kong MEPS requirements ................................................................................................ 8 Table 5: Thailand MEPS requirements .................................................................................................... 8 Table 6: South Korea label levels for rice cookers................................................................................... 9 Table 7: Japan Top Runner standard targets ........................................................................................ 10 Table 8: Distribution of efficiency rice cookers (Market survey, March 2014) ..................................... 11 Table 9: Distribution of efficiency rice cookers (registration database, March 2014) .......................... 12 Table 10: Proposed new MEPS requirements ....................................................................................... 20 Table 11: Proposed efficiency thresholds for MEPS and label requirements ....................................... 20

VEESL REVIEW OF VIETNAMESE ELECTRIC RICE COOKER STANDARDS, AUGUST 2014 iii

Acknowledgements The authors would like to thank staff at the Australian Department of Industry for their assistance with 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.

VEESL REVIEW OF VIETNAMESE ELECTRIC RICE COOKER STANDARDS, AUGUST 2014 iv

1 Introduction The Government of Vietnam has introduced legislation to implement Minimum Energy Performance Standards (MEPS) for appliances and equipment alongside a program of Energy Labelling. The Australian Government Department of Industry (DoI) is providing assistance to Vietnam through the Vietnam Energy Efficiency Standards and Labelling (VEESL) Program, funded by the Australian Agency for International Development (AusAID).

The aim of the VEESL Program is to improve prosperity in Vietnam, while increasing energy security and reducing carbon emissions. This will be achieved through a range of activities designed to build sustainable capacity within Vietnam to set and enforce appliance and equipment energy standards, and monitor and evaluate the MEPS and Labelling Program.

The legislation to implement MEPS and energy labelling for appliances and equipment came into effect during 2013. This has required new products to meet minimum energy efficiency performance levels and, in many cases, be required to display an energy label at the point of sale. However, these standards have now been in place for some time, and Vietnam Standards and Quality Institute (VSQI) and Ministry of Industry and Trade (MOIT) are seeking to update the regulations for rice cookers.

This report provides an analysis of the current rice cooker regulations and examines the options for the potential revision of the relevant test standard and performance requirements.

The report will cover the following aspects:

1. Current regulations for rice cookers.

2. Opportunities for improving the test method.

3. Opportunities for improving MEPS and label performance levels.

4. Transitional issues for updated regulations.

5. Conclusions and recommendations.

This report has been compiled by consultants with extensive experience of product-related policy who are providing direct assistance and advice to the VESSL Program. The conclusions and recommendations contained in this report are those of the authors and do not necessarily reflect the opinions and positions of either the Australian or Vietnamese governments.

VEESL REVIEW OF VIETNAMESE ELECTRIC RICE COOKER STANDARDS, AUGUST 2014 1

2 Current requirements in Vietnam The current testing and performance requirements for rice cookers are given in TCVN 8252: 2009 and are summarised below:

• Scope: electric rice cooker for family use, up to a capacity of 3 litres.

• Shall meet performance and safety requirements in TCVN 5699-2-15: 2007 (IEC 60335-2-15: 2005), Household electric appliances and similar electric appliances - Safety- Part 2-15: Specific requirements for liquid boiling appliances.

• Testing of cooking efficiency is done using the following steps:

o Add water to 80% of maximum capacity,

o Heat the water for 240 seconds, measure the energy,

o Stir the water for 20 second and measure the temperature rise,

o Repeat four times and take the average values of the last three readings,

o Calculate the energy efficiency ratio, Rd(%), which is based on the ratio of energy ‘out’ (additional thermal energy of the liquid and the inner pot at a higher temperature) over the energy ‘in’ (electricity),

• Minimum energy efficiency performance standard (MEPS) is (Rd(%)=) 80%.

• The Energy label grades are based on and energy efficiency index (K) - which is the ratio of the measured efficiency over the minimum efficiency requirement. Note that this index can be multiplied by 0.8 to give the implied energy efficiency. The efficiency Grade thresholds are presented in Table 1 in terms of the energy efficiency index and the implied efficiency.

Table 1: Energy efficiency grade given in TCVN 8252: 2009 and the implied efficiency

Grade Energy Efficiency Index (K) Implied efficiency (%)

1 ≥ 1.00 80%

2 ≥ 1.05 84%

3 ≥ 1.10 88%

4 ≥ 1.15 92%

5 ≥ 1.20 96%

The effective date of the regulation is July 2013.


3 Examining the testing methods Before examining the performance requirements in Vietnam, and examining options for amending the requirements, it is important to understand the underlying testing requirements. This section will examine regional testing standards and compare them to international testing standards.

3.1 International test methods There is no international standard specifically for the testing the efficiency of rice cookers; different countries develop their own, sometimes borrowing testing practice from neighbouring countries.

There is, however, an internationally recognised standby power testing method. Standby or equivalent low power loads can be measured by IEC 62301:2011 Ed2 ‘Household Electrical Appliances: Measurement of Standby Power’.

3.2 Test methods used in the region 3.2.1 Test methods for cooking efficiency In this section a UNDP report by Liu et al (2012) provides a useful insight into the different testing procedures, along with the Vietnamese standard. In summary, there are major similarities across the countries, which are:

• Instruments used to perform the tests,

• Parameters that are measured,

• Ambient testing conditions, such as ambient temperatures.

The main differences are:

• Ways of heating:

o In the Chinese testing procedure, the pot is heated from the initial temperature to 90oC,

o In the Indonesian testing procedure, the pot is heated from initial temperature to 95oC,

o In the Korean and Vietnamese testing procedure, the pot is heated for a fixed duration of four minutes. After four minutes of heating, the temperature rise is significantly less than 90oC. A four minute temperature rise means the test can be done quickly. However, it also has implications for providing sufficiently accurate results. With a lower temperature rise, the accuracy of the testing equipment becomes a greater factor. Indeed this was apparent and highlighted in the independent witness testing of rice cookers at three QUATEST laboratories (Sub-section 4.2.5).

• Warm-keeping and standby power consumption:

o Vietnam does not include these operating modes in the requirements, unlike Japan and China.

• Heat or cooking efficiency calculation formula:

o In both Vietnam and Indonesia, the heat efficiency calculating formulas include the heat absorbed by the inner pan in the heat efficiency calculation formulas In China only the heat absorbed by the water is included. These different calculation methods make the results of the heat efficiency incomparable. If both the heat absorbed by water and the inner pan are taken into account, the efficiency will be higher than the case where only the heat absorbed by the water is considered).


Based on the Liu et al (2012) report and a CLASP database on product polices, a more detailed comparison of the test methods used in the region is presented in Table 2. The calculation formula to convert the test measurements into efficiency metrics is also included for some countries.


Table 2: Detailed comparison of regional testing standards

Vietnam Indonesia China Hong Kong Japan South Korea Test conditions:

Relative humidity 45-75%

45-75%

45-75%

45-75%

45-75%

Test conditions:

Environmental temperature

20oC ± 2oC

20oC ± 2oC

20oC ± 2oC

23oC ± 2oC

20oC ± 2oC

Test conditions: Water temperature

20oC ± 2oC

23oC ± 2oC

23oC ± 2oC

23oC ± 2oC

Test conditions: Power voltage

220V ± 10% 220V+/-10% 100 ± 1 volts 220V+/-10%

Test conditions: Power frequency

50Hz ± 0.5Hz Rated power voltage ± 1%

50 ± 0.5 Hz 50 ± 0.1 Hz, or 60 ± 0.1 Hz

60 ± 0.6 Hz

Test conditions: Air pressure

86k-106kPa

86k-106kPa

86k-106kPa

Test of thermal efficiency

Energy consumption under 4 tests

Water volume 80% of rated capacity (litres) 80% of rated capacity (litres)

80% of rated capacity (litres)

Manufacturer specification

80% of rated capacity (litres)

Test duration 240 seconds n/a 240 seconds Temperature rise n/a temperature of water

is raised up to 95oC n/a

Calculation formulae of energy efficiency level (%)

Test of standby power consumption (W)

n/a n/a n/a

Test of keep warm power consumption (W)

n/a n/a n/a

Source: Based mainly on Liu et al (2012) and CLASP online database


3.3 Potential for harmonisation and amending the testing standard Even though there is no internationally recognised testing procedure for rice cookers, the approach taken is very similar within the region. In the case of Vietnam, there are a few aspects which could be altered to bring it in line with neighbouring countries.

For Vietnam, a small change to the test conditions would be to have the starting test temperature at: 23℃ ± 2℃, rather than 20oC ± 2oC. This is a minor change and would have little impact on the final efficiency results, but would mean it is harmonised with other countries in the region.

The main change that is needed for the Vietnam cooking test is to have a larger temperature rise (beyond the amount that could be reached in four minutes) to reduce the variation in testing results. There are two potential solutions:

• Choose a longer cooking time. Since there is no other country in the region with a longer fixed cooking time, the Vietnamese regulators could unilaterally choose a value, say 20 minutes.

• Alternatively, the regulators could use a fixed temperature rise. The regional harmonisation options would be either 90oC or 95oC.

This would have little significant difference on the calculated efficiency value, but would significantly improve the accuracy of the efficiency measured in the laboratory.

In addition, there may be merit in considering the following:

• Include keep warm and standby measurements (though these would only be needed if there was regulatory requirement to include these). These are used in some neighbouring countries.

Ideally, any changes to the regulations would not be done in isolation or unilaterally; it would be done in discussion with neighbouring countries to ensure the most appropriate aspects are included.


4 Examining MEPS and label performance levels 4.1 Performance levels used in the region Since the underlying test procedures are not entirely consistent across the region it is not possible to undertake a direct comparison of the performance levels. It would be possible to make assumptions on how to translate results from one test standard to another (with a reasonable degree of accuracy) if sufficient test data to the different standards were available

Although these are not entirely comparable (especially the heating/cooking efficiency), the performance requirements from neighbouring countries are listed in the following sub-sections. Most of the following are based on information from the Liu et al (2012) report.

4.1.1 China The Chinese standard (GB 12021.6: 2008) provides the testing and performance requirements. The requirements make a distinction on size (rated power, W), such that the more powerful the rice cooker, the stricter the requirements.

Table 3: China MEPS and label requirements

Rated Power (W)

Heat Efficiency (%)

Energy Efficiency Grades

1 2 3 4 5

P≤400 85 81 76 72 60

400<P≤600 86 82 77 73 61

600<P≤800 87 83 78 74 62

800<P≤1000 88 84 79 75 63

1000<P≤2000 89 85 80 76 64

Rated Power (W) Warm-keeping Energy Consumption (Wh)

P≤400 40

400<P≤600 50

600<P≤800 60

800<P≤1000 70

1000<P≤2000 80

In addition, there is a standby requirement of a maximum of 2W, and 1.6W for products listed efficiency grade of 3 and higher.


4.1.2 Hong Kong MEPS requirements Where the Hong Kong testing tends to follow the Chinese standards, the MEPS requirements are based on slightly different efficiency calculations, so the requirements are not directly comparable. However, the same product power (rated power, W) classifications are used to set the requirements.

Table 4: Hong Kong MEPS requirements

Rated Power P, (watt) Minimum Allowable Heat Efficiency, %

P ≤ 400 84

400 < P ≤ 600 85

600 < P ≤ 800 86

800 < P ≤ 1000 87

1000 < P ≤ 2000 88

4.1.3 Thailand MEPS requirements Thailand also uses product rated power (W) as a criteria to impose more stringent performance levels on larger rice cookers, and its MEPS efficiency requirements seem slightly stricter (by 1%) than the Hong Kong requirements. The rated power classifications are the same as China and Hong Kong.

Table 5: Thailand MEPS requirements

Rated Power P, (watt) Minimum Heat Efficiency, %

P ≤ 400 85

400 < P ≤ 600 86

600 < P ≤ 800 87

800 < P ≤ 1000 88

1000 < P ≤ 2000 89

4.1.4 South Korea MEPS requirements South Korea has different requirements depending if plate or induction heating and whether the appliance is a pressure or non-pressure rice cooker. There are also standby requirements for the highest efficiency (level) products.

South Korea’s MEPS and label energy efficiency grades are determined for each rice cooker classification, as seen in the following four sub-tables (Table 6) where R is the rated cooking efficiency (%). The MEPS requirement thresholds are at Level 5.


Table 6: South Korea label levels for rice cookers

Plate heating in non-pressure rice cookers

Level Rated Energy Efficiency (R) 1 94% <=R 2 90%<= R <94% 3 86%<= R < 90% 4 82%<= R < 86% 5 78%<= R < 82%

Plate heating in pressure rice cookers

Level Rated Energy Efficiency (R) Standby power (W)

(no load mode) 1 94% <=R <=1.0 2 90%<= R <94% N/A 3 86%<= R < 90% N/A 4 82%<= R < 86% N/A 5 78%<= R < 82% N/A

Induction heating in non-pressure rice cookers


(no load mode) 1 92% <=R <=1.0 2 92%<= R N/A 3 88%<= R < 92% N/A 4 84%<= R < 88% N/A 5 80%<= R < 84% N/A

Induction heating in pressure rice cookers


(no load mode) 1 90% <=R <=3.0 2 90%<= R N/A 3 86%<= R < 90% N/A 4 82%<= R < 86% N/A 5 78%<= R < 82% N/A

4.1.5 Japanese requirements A different calculation methodology to the other countries, using different operating modes, and requirements based on the top runner approach.


Table 7: Japan Top Runner standard targets

Category

Calculation equation for standard energy

consumption Heating method Maximum rice cooking capacity

Category name

Electromagnetic induction heating products

0.54 =>Capacity <0.99 A EK=0.209M + 48.5 0.99 =>Capacity <1.44 B EK=0.244M + 83.2 1.44 =>Capacity <1.80 C EK=0.280M + 132 1.80 > Capacity D EK=0.252M + 132

Non-electromagnetic induction heating products

0.54 =>Capacity <0.99 E EK=0.209M + 36.7 0.99 =>Capacity <1.44 F EK=0.244M + 75.6 1.44 =>Capacity <1.80 G EK=0.280M + 99.0 1.80 > Capacity H EK=0.252M + 122

Notes:

The maximum rice cooking capacity shall be determined by multiplying the volume of the measuring cup specified by the manufacturer (liter) by the maximum number of cups that the product is designed for.

EK and M represent the following numerical values:

EK: Standard energy consumption efficiency (kWh per year)

M: Mass of evaporated water (this is the mass of the water expelled from the rice cooker when electric power consumption is measured for each rice cooking operation, and is the mean value of the mass of evaporated water obtained at every measurement of electric power consumption during cooking rice. The mass of the water expelled from the rice cooker is calculated by subtracting the measured weight of the rice cooker within 1 minute after completion cooking prior to opening the lid from the weight of the rice cooker containing water and rice prior to the start of cooking. It is expressed in grams and rounded off to 1 decimal place).

Source: Liu et al (2012) quoting: http://www.eccj.or.jp/top_runner/index_contents_e.htlm

4.1.6 Summary In summary, the major similarities and differences include:

• Several countries set increasingly stringent MEPS and labelling requirements for rice cookers which are larger (or rather more powerful). They do this by setting different performance requirements for products within set power ranges or ‘bins’. Usefully, many countries in the region use the same ‘bin’ sizes.

• Japan uses a top runner approach, and a more complex calculation methodology. Furthermore, Japan uniquely uses the capacity (litres) to set up four size bins for different requirements.

• China and Japan includes standby and keep warm function in their efficiency requirements.

• The cooking/heating requirements are different in each country; though without a detailed analysis not immediately possible to tell how different they are in practice (since the threshold values are based on different testing standards, so they are not entirely comparable). For example the Chinese efficiency calculation does not include the additional heat in the inner pot, whereas Vietnam does: thus, the efficiency figures are not comparable.

Based on the above analysis there is scope to consider some alignment, depending on the performance of products in Vietnam, and this is discussed in the following section.


http://www.eccj.or.jp/top_runner/index_contents_e.htlm

4.2 Current market performance The evidence for the efficiency of products on the market comes from three main sources:

• Analysis of a store labelling survey.

• Analysis of the registration database.

• Testing of 20 models of rice cookers, each one tested in three QUATEST laboratories.

4.2.1 Store labelling survey The VEESL project undertook a labelling survey in March 2014. The survey of 5,375 individual appliances in 263 stores located in Hanoi, Ho Chi Minh City (HCMC), Quảng Trị and Can Tho provides a useful snapshot of progress with implementation of energy performance labelling in Vietnam. Around 16% (846 out of the 5.375) of the products surveyed were rice cookers. This survey involved the visual inspection of products in stores to ascertain whether models within the scope of regulations are displaying the label correctly (DoI, 2014). The distribution of efficiency of rice cookers on the market is given in Table 8.

Table 8: Distribution of efficiency rice cookers (Market survey, March 2014)

Efficiency level Number Proportion (%)

Grade 1 46 7%

Grade 2 115 18%

Grade 3 176 27%

Grade 4 186 28%

Grade 5 132 20%

TOTAL 655 100%

From the 2014 labelling survey it is evident that there is a reasonable spread of efficiency of products on the market, though higher grades are being used more than the lower grades, so there is a need to continue monitoring the market to see when a re-grading of the efficiency thresholds is needed.

4.2.2 Product registration database As part of the VEESL project, the team had access to the MOIT product registration database, (up to 25 March 2014), which records the declared performance of products currently covered by regulations in Vietnam. The registrations were done by an Officer at MOIT entering the supplier-submission data into an Excel spreadsheet. This database has been cleaned up and analysed. Although, there is scope for error (from input and interpretation), and the database may not be fully populated, it provides a useful resource for understanding what is being placed on the Vietnamese market (or at least registered with MOIT). The distribution of efficiency of rice cookers registered with MOIT is given in Table 9


Table 9: Distribution of efficiency rice cookers (registration database, March 2014)

Efficiency level Number Proportion (%)

1 112 9.7%

2 299 26.0%

3 365 31.7%

4 151 13.1%

5 223 19.4%

TOTAL 1,150 100.0%

The efficiency distribution of products in the registration database is very similar to that found in the labelling survey (which should be a better representation of the products actually found on the market).

The two sets of data are compared graphically in Figure 1, which shows a good match, as expected. The label survey shows slightly more high efficient products being placed on the market than in the registration database.

Figure 1: Proportion of registrations by efficiency grade (from registration database and label survey)

The registration data provides a more detailed insight into the efficiency of products being registered; specifically the efficiency index (K) values which are used to determine the grade levels (Figure 2 shows the efficiency index of almost 1500 rice cookers, ordered by their efficiency values).

All, except two, of the products in the registration database have been declared as meeting the MEPS requirements, though a significant number are above the grade 5 threshold (K=1.2), and some are reported to be much higher. This suggests that the MEPS could be made more stringent and also that the label could be revised to better highlight those products significantly over the K=1.2 threshold.


Figure 2: Reported efficiency index (K) of all registered rice cookers, ordered by efficiency

4.2.3 Efficiency by size As part of the registration process, the capacity (in litres) and the power (W) have to be declared. This allows analysis to see if any correlation between size and efficiency can be found.

Figure 3 shows the plot of efficiency (K values) against capacity (litres) of each products registered. It can be seen that there is a clear (and statistically significant) correlation between efficiency and capacity.

Figure 3: Efficiency (K) registered rice cookers versus capacity (litres)

A similar, though much less pronounced, pattern is observed when a plot of efficiency (K) and rated power (W) is undertaken (Figure 4). This similarity is not unexpected as there is a strong correlation between capacity and rated power.


Figure 4: Efficiency (K) registered rice cookers versus rated power (W)

The efficiency versus capacity plots suggests that size should be taken into account when (re) defining performance thresholds, since size is statistically correlated with efficiency: the larger the appliance the higher efficiency, on average.

There are two main approaches to setting higher efficiency requirements for different sized products:

• Using size ‘bins’,

• Using continuous curve functions.

The main advantage of using discrete bins is that they are usually easy to describe and understand. However, if there are too few bins or the boundaries between them are not set in an appropriate point, suppliers may (quite legally) adjust the declaration of their products attributes, or alter their products so their products fit into the lower requirements bin. To avoid this situation, a larger number of bins are required, or a continuous curve may be described.

For rice cookers, there appears to be a consistent set (number and size range) of bins already used in the region, and it is recommended that these are followed, if this approach is adopted.

4.2.4 Summary In summary, the analysis of the March 2014 registration database suggests the following for any revision to rice cooker standards:

• The efficiency distribution of products is slightly towards the top end of the efficiency scale; therefore it is suggested to keep monitoring the market efficiency distribution to help determine when a re-grading should be considered.

• It appears that larger (capacity) rice cookers are more efficient than smaller ones. This suggests that the performance requirements should be stricter for the larger products, as is the case in several countries which use power bins to set requirements based on the input power.

A noticeable number of products have efficiency index (K) values above 1.25, the value of which would imply a cooking efficiency of over 100%. This suggests there may be some measurement inaccuracy issues in the test or other declaration issues.


4.2.5 Laboratory testing Inter-laboratory comparisons were undertaken by the three QUATEST laboratories in Vietnam (Evans and Lane, 2014). Each tested the same samples of 20 different models of rice cookers.

The main purposes of these trials were to provide:

• A measure of the extent of the variation and uncertainty of results.

• An understanding of the cause of these variations, in order to be able to advise MOIT and the laboratories on steps that could be taken to minimise these variations.

The trials found a large variation in the star rating (up to 3 grades), which was due to the large variation in the measured cooking efficiency. Figure 5 shows this variation by plotting a line between the highest and lowest efficiency measurement from the three laboratories for each product. The variation between the three laboratories is in part due to slightly different practices, though a large reported difference was due to the test itself not providing sufficiently accurate and repeatable tests.

Figure 5: Reported average cooking efficiency (%) of the 20 models of rice cookers

NOTE: the efficiency reported by QUATEST2 as exceeding 100% was assumed to be an error (whether measurement, or within testing tolerances)

The report from the testing and training program concluded that the variations in measuring the cooking efficiency were largely due to the tolerances of the test being relatively large compared to the temperature rise during the test. The Vietnamese test currently specifies a fixed four-minute cooking time. This elapse time does not provide a large increase in temperature, relative to the accuracy of the equipment and testing procedures. One of the main recommendations of the laboratory testing was to increase the time of the test to get a larger temperature rise. This could be done by having a longer test or by specifying a temperature rise for the test (as is done in some countries).

4.3 Potential for harmonisation and amending performance standards Since the efficiency of the cooking (heating) mode is the main performance metric used by most countries, this would be the obvious metric to try to examine for potential harmonisation. However,


since the underlying test standards are not entirely consistent across different countries, care needs to be taken so that only appropriate harmonisation is undertaken.

There are potentially two areas that Vietnamese regulators could examine to improve future regulation. These are:

• Consider using having stricture requirements for larger rice cookers, using the same size banding (by power rating) as used by several countries.

• Consider including other non-cooking modes in the requirements, specifically the keep warm function and no-load standby mode (as used in e.g. China).

Ideally, in making any of changes it would be prudent to have discussion with neighbouring countries on their revision plans, and also consult with various stakeholders.


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.

• Minimise market disruption & costs.

5.1 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 new requirement 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 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.

5.1.1 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.

• From 12 months before the effective date, suppliers may voluntarily register products according to the new TCVN requirements and display the new label.

Figure 6 illustrates these arrangements for a labelling transition.

Figure 6: Grandfathering and transitional arrangements for the introduction of revised labelling requirements

For example, if the new MEPS and labelling requirements for rice cookers 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 VEESL REVIEW OF VIETNAMESE ELECTRIC RICE COOKER STANDARDS, AUGUST 2014 18

6 Conclusions and recommendations Based on the analysis above, some conclusions and recommendations can be made for amending the Vietnamese regulations for rice cookers.

6.1 Conclusions The main conclusions that can be drawn from the analysis presented in this report are:

• There is no agreed international testing procedure for rice cookers, though many aspects of the test procedure are similar across countries in the region.

• The currently required time of four minutes of cooking is too short to provide a sufficiently accurate and reliable estimate of cooking efficiency.

• There is a spread of efficiency of rice cookers on the Vietnam market, so no major change in the label performance requirements is necessary at this stage, although this should continue to be monitored.

• The performance requirements currently do not make distinction on the size (or power) of the rice cooker, whereas most other countries have stricture requirements for large rice cookers. Including a similar requirement would mean a slight increase in the MEPS requirements for the larger products.

• Some neighbouring countries include non-cooking modes in their requirements, specifically the keep-warm and the standby mode.

These findings suggest that there is an opportunity to:

• Amend the test procedure, specifically to revise the start test temperatures (to 23oC ± 2oC), and to include a longer test time or larger temperature rise.

• Include size (power) in the performance requirements, which could mean slightly higher MEPS values for larger products.

• Consider including standby and keep warm mode in the performance requirements.

6.2 Recommendations In making the following recommendations an important step is that any proposed changes to the regulations is done in discussion and consultation with various stakeholders, including neighbouring countries which may also be considering changing their regulations. Aligning performance requirements will make it simpler, and also cheaper, for the supplier to meet any new requirements.

6.2.1 Testing requirements The main proposed change to the test is to increase the temperature rise in the test. The recommendation is to ensure a temperature rise to 90oC, rather than a four minute cooking time. This should mean a more accurate and repeatable estimate of cooking efficiency is made.

To align it with other countries in the region, it is also recommended to alter the start test temperature is to 23oC ± 2oC. This is a minor change, and should not result in any significant change in the measured energy performance of the products under test.

6.2.2 Performance requirements The current market shows a good spread of efficiency of products on the market, so no significant change in performance requirements is recommended. However, we do recommend that size is included in the performance requirements and that the bins are aligned with neighbouring countries, as shown in Table 10.


Table 10: Proposed new MEPS requirements

Rated Power, P (Watt) Minimum heat efficiency (%)

P< 400 80 400 <P <= 600 81 600 < P <= 800 82 800 < P <=1000 83

1000 < P <= 2000 84

Using the energy efficiency index (K) to set the labelling requirements should remain, as in Table 1. However, with the higher MEPS requirements for larger rice cookers, the efficiency requirements for each label grade will also be higher for the larger rice cookers. The proposed efficiency thresholds for the label grades are shown in Table 11. Higher MEPS and a scaling of 1.2 for Grade 5 (as shown in earlier Table 1) implies an efficiency of over 100%, so for the current proposal the maximum efficiency is capped to 98% (in bold in Table 11).

Table 11: Proposed efficiency thresholds for MEPS and label requirements

Rated Power, P (Watt) Minimum heat efficiency (%) Grade 1 Grade 2 Grade 3 Grade 4 Grade 5

P< 400 80 80 84 88 92 96 400 <P <= 600 81 81 85.05 89.1 93.15 97.2 600 < P <= 800 82 82 86.1 90.2 94.3 98 800 < P <=1000 83 83 87.15 91.3 95.45 98

1000 < P <= 2000 84 84 88.2 92.4 96.6 98 The likely impact of such a revision to MEPS, based on the currently registered products, can be seen in Figure 7 (where the red line is the new MEPS level and the green line represents the grade 5 label).

Figure 7: Impact of revised MEPS on registered products (March 2014 database)


It should be noted that if the testing method is changed (as recommended), this should not alter the measured efficiency of models but it will make the results more accurate. This could mean that some of the existing declared values may need to be adjusted.

6.2.3 Standby and keep warm modes Without further evidence it is not clear if the keep warm function and standby is an issue for rice cookers in Vietnam, such that it needs to be addressed through product-specific regulation.

These operating modes will only be an issue if the products on the market have relatively high power requirements (say >1-2 Watts for standby mode) and if they are used in these operating mode for significant lengths of time in Vietnam. If no information can be found, and there is a strong desire to include standby and/or keep warm functions, we would suggest an interim step. Before recommending any additional regulation, we would recommend a short research project to:

• Find out the likely standby (low) power demand of these products. Ideally desk-based but, if necessary, to measure the standby and keep warm power demand of some rice cookers on the market.

• Find out the approximate use of these products in these two operating mode. If there is no existing research, this could be done through simple householder interviews on their typical/average use of rice cookers. The alternative, which would be more accurate though more expensive, would be to undertake in-situ trials.

• If these are important aspects, we would recommend that the performance requirements match the Chinese standards initially.

6.2.4 Next steps The proposed next steps should be to:

• Review if the keep warm and standby mode is an issue for rice cookers in Vietnam.

• Propose and agree changes to the test methodology for rice cookers.

• Review any proposed performance requirements with relevant stakeholders, and amend as necessary.

• Once these steps are complete, make a signal to the market of the intended change to the regulations in advance, and then change the regulations. (Section 5 has further details on how to handle this).


7 Potential improvements to the regulations In addition to the changes in the performance requirements there is one minor suggested change for the current test procedure:

• To calculate the cooking efficiency use the average of all four tests, not just the final three currently listed. This will provide a more robust average for the efficiency calculation. Note this this may be an error in the English translation. (Clause 5.2.3)

8 References DoI (2014) Survey of Energy Efficiency Labelling of Appliances in Vietnam. A report by VEESL. March 2014.

Evans, C and Lane, K (2014) Laboratory capacity and verification testing report. Prepared for the Vietnam Energy Efficiency Standards and Labelling (VEESL) Program, funded by the Department of Industry (Australia).

Liu, W; van Phan, L, and Arjadi, H (2012) TWG Feasibility Study Report on Enhancing Regional Harmonization for the BRESL Products: Rice Cookers. A UNDP/GEF funded-report under the Barrier Removal to the cost-effective development and implementation of energy efficiency standards and labelling project. October 2012.

VEESL (2013) A Guide to Re-grading Energy Performance Labels. Produced by VEESL in 2013.


Review of Vietnamese Rice Cooker Standards · Review of Vietnamese Rice Cooker ... the test procedure are similar across countries in the region. ... methods make the results of the

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