Beginning October 1, 2018, portable electric spa manufacturers are required to certify each model as a standard spa, an inflatable spa, an exercise spa, or a combination spa.
Beginning June 1, 2019, portable electric spa manufacturers are required to use the new test procedure, meet the new performance standard, and label each spa unit displaying the energy performance.
Below is a list of frequently asked questions and guidance related to changes for portable electric spas.
If clarification is needed contact the Appliance Efficiency Program.
The effective dates are as follows:
October 1, 2018
Definitions and certification requirement updates (e.g., spa types, additional fileds to accommodate combination spas)
Units manufactured on or after June 1, 2019
- New test procedure
- New performance standard
- New label requirement
- New certification requirements (e.g., spa cover model number and manufacturer)
Test Lab Qualification
The new referenced test procedure, effective June 1, 2019, requires test labs be qualified by a certification body. This requirement ensures all test labs testing portable electric spas manufactured on or after June 1, 2019, are competent to perform the required test procedure. Details of the process are specified in Section 4.2 of ANSI/APSP/ICC-14 version 2014.
In general, the test lab must be ISO/IEC 17025 compliant and be further assessed by a certification body for qualification approval. Details of the process are specified in Section 4.2 of ANSI/APSP/ICC-14 version 2014. Test labs are not required to have ISO/IEC 17025 accreditation.
Test labs must also be approved by the CEC through an online application through the Modernized Appliance Efficiency Database System (MAEDbS). This is separate from the test lab’s qualification by a certification body. Test lab approval must occur before manufacturers or third party certifiers can submit data from that test lab to MAEDbS for an appliance. See Title 20, Section 1603(a) for test lab approval requirements
Test labs need to update to the new test method if they are testing models of portable electric spas that will be manufactured on or after June 1, 2019, and seek to certify those models to the CEC as compliant with the new standards. The approved test lab must use the new test method and be qualified by a certification body. Test labs may update their test method applicability by re-applying. The updated test lab application will be available prior to June 1, 2019.
Test lab approvals are valid until December 31st of each year and then expire. Test labs must apply annually for approval to the CEC. Test lab applications for the next certification year become available on November 1st each year.
The new test method provides more detailed instructions for general testing setup, provides specific instructions for testing exercise spas and combination spas (not currently provided in the current test method), and requires all testing laboratories to be qualified by an accredited certification body to ensure the testing facility, testing equipment, and personnel are able to perform the tests in the test procedure.
Exercise spas are operated at a much lower temperature than standard spas, but some exercise spas are equipped to function as a standard spa. Thus, the test procedure for exercise spas accommodates both exercise spas that have a maximum water temperature below 100 degrees Fahrenheit and those that have a maximum water temperature greater than or equal to 100 degrees Fahrenheit. Below the chart illustrates the difference between testing exercising spas, standard spas, and combination spas:
Each reservoir shall be powered on simultaneously and heated to the appropriate water temperature according to the test procedure, for the entire duration of the test.
On October 1, 2018, new data reporting requirement changes were made such as reporting the fill volume, the rated volume, and certifying each model as a standard spa, an inflatable spa, an exercise spa, or a combination spa. All portable electric spas certified before October 1, 2018, will remain in the active database until June 1, 2019, but the inputs for spa volume will be redirected to fill volume. These models may still be sold in California. If manufacturers update their certifications, they will be required to remove the listing from active database to the archive database (delete) and re-certify the model (add), instead of merely submitting a change.
All portable electric spas certified before June 1, 2019, will be archived. Spas manufactured on or after June 1, 2019, will be required to certify to the CEC to be sold or offered for sale in California.
Each reservoir of the combination spa shall separately meet the standby power performance standard to be sold or offered for sale in California. The various outcomes are:
- If the standard spa portion and an exercise spa portion both passes, the combination spa is compliant.
- If the standard spa portion passes and the exercise spa portion fails, the combination spa is not compliant.
- If the standard spa portion fails and the exercise spa portion passes, the combination spa is not compliant.
The current performance standard will still be applicable for inflatable spas manufactured before June 1, 2019.
All tested spa covers that allowed the portable electric spa to pass the standby power performance standard must be certified to the appliance efficiency database as separate listings to sell or offer for sale in California. This supports the requirement in Title 20 Section 1608(a) that any covered appliance may be sold or offered for sale in California only if “the unit has the same components, design characteristics, and all other features that affect energy or water consumption or energy or water efficiency, as applicable, as the units that were tested under Sections 1603 and 1604 and for which information was submitted under Section 1606(a).” Spa covers that have identical CEC data but different model numbers due to features unrelated to energy use (such as colors) can be certified with a single listing by using asterisks in the model number to represent characters that change as stated in Section 1606(a)(1)(C). Any cover (the manufacturer’s or a third party’s) that was not tested or tested but fails to meet the performance standard cannot be sold with the unit to the consumer.
Marking and Labeling
In addition to the marking requirements in Section 1607(b), requiring products to be physically marked with manufacturer name, brand name, or trademark; model number; and date of manufacture, all portable electric spas manufactured on or after June 1, 2019, shall be marked by the manufacturer with the label specified in Section 1607(d)(14)(B). The label shall be legible, and conspicuously displayed to the consumer.
If the spa has been tested with multiple spa covers, the label shall display the most recent performance data of the tested spa cover of the spa unit-cover combination that yielded the maximum normalized standby power test result obtained in accordance with Section 1605.3(g)(6)(B). The following illustrates an example for selecting the performance data to display for a spa with multiple spa cover combinations:
Yes, manufacturers may list other tested and certified spa covers, as shown below. The checkbox of the tested spa cover model number and corresponding spa cover manufacturer coinciding with the performance data shall be marked on the label.
The label specified in Section 1607(d)(14)(B) must only display the spa unit-cover combination that yielded the maximum normalized standby power test result obtained in accordance with Section 1605.3(g)(6)(B). The California appliance efficiency regulations do not restrict manufacturers from using other labels or marketing materials to display the energy use of each spa cover-unit combination.
For standard, exercise, and combination spas, the label shall be affixed on a readily visible location on the shell or skirt panel of the unit. For inflatable spas, the label shall be affixed on a readily visible location on the unit’s retail packaging.