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Does an importer of a private-label charger have to certify it with the Department of Energy?

Not entirely.

Updated 3 min read

Does an importer of a private-label charger have to certify it with the Department of Energy?
The question

We import a USB charger from China and sell it under our own brand in the US. The factory says it is the factory’s job to handle energy rules. Is that right?

Main answer · Wecent Editorial Team

Short answer: Not entirely. Under US energy law the importer is treated as the manufacturer, so an importer of a covered product carries the same compliance duties as a domestic maker, including certifying covered models to the Department of Energy before selling them. Whether your charger is covered depends on its type. Ask the factory for test data and confirm coverage before importing.

The importer is the manufacturer

The Department of Energy states that under the Energy Policy and Conservation Act an importer is a manufacturer, held to the same standard as if it had built the product itself. The regulations define to manufacture as to manufacture, produce, assemble or import. That means a brand that imports a private-label charger cannot simply rely on the factory.

Which chargers are covered

The rules cover external power supplies, which convert household current to DC or lower-voltage AC to operate a consumer product, and battery chargers, which have their own standards. Direct-operation external power supplies made or imported on or after 10 February 2016 must meet Level VI efficiency and no-load limits and be marked under the efficiency marking protocol. Some products are excluded, so check the definition for your exact product type.

What an importer is expected to do

The Department of Energy’s importer questions list the key steps: 1. Check whether the product is covered and subject to a standard. 2. Make sure it was tested to the DOE test procedure. 3. Confirm that it meets the standard, by asking for test data. 4. Certify compliance to DOE before distributing the model in commerce. 5. Keep the test data that supports the certification.

What to ask the factory

  • Test reports for the DOE procedure, not only a safety report.
  • The efficiency mark that will be on the product, such as a Roman numeral.
  • Whether the model’s basic-model grouping matches how it will be certified.
  • Written confirmation that production matches the tested sample.

What to keep

Keep the test data, the certification record and the marking evidence for each model. The rules set how long records must be kept, so check with a compliance adviser.

Do not assume

A charger that passes a safety test may still not have energy test data. Raise the question at quotation, because a missing test is slow to fix.

Sources checked on 24 Oct 2026: U.S. Department of Energy: Importer Q&As; eCFR: 10 CFR 430.2 Definitions; eCFR: 10 CFR 430.32 Energy conservation standards.

Where this answer says to confirm with Wecent, the detail is not published on the product page and has to come from the datasheet or the factory. General facts come from the regulators, standards bodies or device makers named in the text.

Three more perspectives

Wecent Editorial Team · Purchasing perspective

Put DOE test data and marking into the purchase specification. It is easier to require before ordering than to chase afterwards.

Wecent Editorial Team · Compliance/QC perspective

Ask a US compliance adviser to confirm whether your exact model is a covered external power supply or battery charger.

Wecent Editorial Team · After-sales perspective

Keep the records with your product file. Retailers and authorities may ask for them long after the sale.

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