2026-07-15 Comment response to the published Request for information

Summary: The China WTO/TBT National Notification & Enquiry Center opposes several aspects of the proposed energy conservation standards for distribution transformers. They recommend excluding large-capacity transformers (3,750 kVA and 5,000 kVA) from the scope due to reliability concerns, establishing a systematic exemption mechanism for space/weight constraints, providing alternative compliance pathways, and extending the transition period to 2030 to address supply chain strain.