We appreciate the work DOE has put into updating the test procedures for battery chargers. We believe the proposed updates to the test procedure are practical and appropriate for the rapidly transforming battery charger market. We strongly support DOE’s proposal to expand the scope of the test procedures to cover a wider variety of wireless chargers. Additionally, we believe that the proposed amendment to replace the unit energy consumption metric with three separate metrics for active mode, standby mode, and off mode will increase representativeness of the test procedure.