A conservation standard and a test procedure answer different market questions. DOE's October 28, 2016 direct final rule set standards for miscellaneous refrigeration products. Its July 18 rule established product coverage, definitions and testing procedures for certain classes. The first addresses required performance; the second supplies a framework for measuring energy use. Treating them as interchangeable hides an important part of product comparison. [2016-24759][2016-14389]

The July rule described devices including wine chillers and beverage coolers, whose compartments can operate warmer than typical refrigerator compartments. Its procedures followed the same general methodology as existing refrigerator, refrigerator-freezer and freezer tests. That common approach is a reason to examine the basis of energy-use representations, not proof that all products have the same consumption or that unlike categories are directly comparable. [2016-14389]

For buyers and sellers, our reading is that a comparison needs the right category and measurement basis before a standard can make it informative. Neither rule demonstrates that a particular model is the cheapest to operate, that a supplier has gained market share, or that competition has improved. Those are commercial outcomes requiring evidence beyond the publication of a regulatory method. [2016-24759][2016-14389]

The October standards had an October 28, 2019 compliance date. The direct final rule's stated February 27, 2017 effectiveness was conditional on the adverse-comment process: comments due February 15 could lead to withdrawal if DOE found a reasonable basis. The two retained documents come from the same DOE policy chain. They explain the intended rules for this product group, not independently tested savings or a settled future market response. [2016-24759][2016-14389]

Source documents

  1. Energy Conservation Program: Energy Conservation Standards for Miscellaneous Refrigeration Productshttps://www.govinfo.gov/content/pkg/FR-2016-10-28/html/2016-24759.htm
  2. Final Coverage Determination; Test Procedures for Miscellaneous Refrigeration Productshttps://www.govinfo.gov/content/pkg/FR-2016-07-18/html/2016-14389.htm