We are requesting stakeholder feedback on switchable wattage lighting under the Victorian Energy Upgrades program.
Your feedback on switchable wattage lighting products (product category 34)
18 December 2020
The issue involving products with switchable wattage setting
A key role of the commission is to safeguard the integrity of the VEU program by ensuring that valid abatement is claimed under the program. We have identified that some easily switchable lighting products create unacceptable risks to program integrity as these products can be, mistakenly or otherwise, switched in the field. The installation of these products means there is a heightened risk that a product may operate at a wattage value different from that being claimed. There can be a significant difference between the lower and upper wattage settings - typically 100 to 500 per cent difference.
Our position is that products that can be easily switched, for example from 50 watts to 10 watts are effectively 50 watt products. These products are tested at 50W but may have added functionality to reduce the wattage to 10 watts. While we recognise that there may be additional functionality, there are currently no mechanisms in the program that can accurately account for products with these added functions.
Given the above risk and lack of accurate mechanism, the commission considers the most appropriate and cost-effective option is to manage products of this nature at the product approval stage. This means only allowing new products easily switchable products to be registered at their highest wattage setting. This allows these easily switchable wattage lighting products to continue to be used in the program, however they will not receive the benefit of products operating at their lower wattage settings.
The current situation
Historically, applicants have submitted a small number of switchable wattage lighting products for approval under the program. Applicants had proposed the same product but used different model numbers based on the range of switchable wattages to effectively create separate products on the Register of Products. We had approved these products as separate products with different wattage settings as we understood them to be 'not easily switchable' – i.e. they could not be “switched outside of the factory”.
We have, in recent months, seen an increasing volume of this type of product being submitted for approval under the program, where there appears to be a continuing trend towards making the product 'easily switchable' i.e. the wattage setting could be easily 'switched outside of the factory'.
Our initial consultation – October 2020
In October 2020, we released a program update clarifying that for switchable wattage lighting products, we would approve newly submitted products only at the highest wattage setting. Therefore, since October 2020, we have only accepted new product applications for easily switchable wattage lighting products which are submitted for (and tested) at their highest wattage. We will reject product applications for lower wattage settings of these products, where they are identified as being easily switchable.
In the program update, we also proposed a transition period of one month (to 11 November 2020) for managing the small number of switchable wattage products which were approved before October 2020 and invited feedback from stakeholders on this proposed period. We received ten submissions which varied considerably in their feedback. The submissions ranged from not wanting any transition period, to wanting a 12-month period. The main reasons given for needing a transition period were to allow product manufacturers and accredited businesses to move the volume of stock held of these products and to complete existing and quoted work using these products.
The current consultation
Following our October consultation, we have identified that there are 'easily switchable' products (e.g. where wattage settings can be switched outside of the factory) and 'not easily switchable' products (e.g. where wattage settings are finalised at the factory).
We believe these products should be treated differently under the program.
An example of a 'not easily switchable' products is one with jumper settings or DIP switches set on an electronics board which are set in the factory and then sealed inside a housing which cannot be opened (without destroying product) or where opening would void the warranty (where the product has appropriate tamper-evident labels).
Based upon feedback from the initial consultation, we are now proposing that this transition period end on 31 March 2021. This is effectively a six-month transition which should allow participants to install stock held and complete current work orders.
We have proposed a transition period which reflects the ‘middle’ period of submissions made to our October consultation, which we believe balances the competing considerations made by stakeholders.
From 1 April 2021, we propose to remove all lower wattage settings of “easily switchable” wattage products from the Register of Products. We note that all of these products will still be able to be used in the program from this date but will only be awarded certificates based on their highest wattage setting. We propose that products that are deemed to be “not easily switchable” will not be affected.
We held a workshop on 17 December 2020 discussing the above issues. You can access the presentation slides, and will be able to access the recording of the workshop from our website next week.
Request for stakeholder feedback
We would like stakeholder feedback on:
- our current thinking on the definition of a product that is ‘not easily switchable’
- what evidence we should require from an applicant to prove that the product meets the definition of ‘not easily switchable’. For example, a statement made by the testing laboratory, confirming that a switchable wattage function is present in the product, but is not accessible without destroying the product, or voiding the warranty.
- our proposed transition period end date (approximately six months from early October 2020 to end of March 2021).
Please also include any comments you may have on our proposed distinction of treatment between easily switchable and not easily switchable products.
Please give reasoning for your responses along with any evidence or further justification where appropriate.
Please provide your feedback to us by close of business 31 January 2021 by email to: firstname.lastname@example.org
Where to get help
If you have any questions or feedback with respect to matters set out in this program update, please contact VEU support on (03) 9032 1310 or email@example.com