In December 2016 Innovation, Science and Economic Development Canada (ISEDC) proposed an update, under the Information Technology Equipment (including Digital Apparatus) Limits and Methods of Measurement indicating that external thermostats are subject to the requirements of the standard known as ICES-03, Issue 6.
HRAI members, specifically thermostat manufacturers, were taken by surprise with this news, having not been consulted prior to the release of this update. HRAI members have discussed how best to prepare themselves to comply with the standard specific to conducted emissions of external thermostats. The majority of (if not all) thermostats meet the standard for radiated emissions; there appears to be little evidence that thermostats actually create any disruptive conducted emissions. Despite any apparent evidence the Ministry is targeting a host of potential equipment that may cause interference by giving off conducted emissions.
HRAI members met with representatives from ISEDC to express their concerns. The Ministry has since issued a notice on January 12, 2017 extending the transition period applicable to external thermostats for compliance with the requirement under the standard ICES-003 until January 1, 2018.
HRAI has responded noting that this date does not give manufacturers adequate time to comply with this requirement given the size of the market in Canada for external thermostats. Electro Federation Canada also supported HRAI’s position.
HRAI Manufacturers concluded that the earliest date that they could comply is April 30, 2019 based on the date of manufacture. This date would allow time to run development, testing, compliance, sourcing, quality assurance and other activities before going to market. This timeline is also outside of the heating season.
Members also strongly recommended that the compliance date be based on the “date of manufacturer” as versus the current approach of ensuring that these thermostats sold, offered for sale, imported, distributed or leased are compliant.
A response from the Ministry is forthcoming by the end of February.
For more information contact Caroline Czajko at HRAI, e-mail: cczajko@hrai.ca