Unnecessary Regulatory Burden
On March 7, 2011, the Department of Energy (DOE) published a final rule on certification and enforcement that disregards successful industry programs.

To comply with this final rule, manufacturers would have to expend enormous resources for product testing with no added benefit to consumers and no additional energy saved. DOE’s final rule would have manufacturers test each of the thousands of possible product combinations to establish product model efficiency ratings that the manufacturer can derive, based on tested models and engineering calculations.

A Trusted Resource for the DOE

For over 50 years, AHRI’s certification program for residential and commercial heating and air conditioning equipment has ensured that the efficiency rating claims of manufacturers are accurate and that products comply with applicable federal minimum efficiency standards. AHRI Certified® products are tested by a third-party laboratory and listed in the online Directory of Certified Product Performance. The Directory is updated daily and listings are sent directly to the Department of Energy. AHRI’s certification program obviates the need for new and burdensome government programs that would duplicate this successful industry program — a program that has been in place decades longer than federal and state efficiency standards.

AHRI has urged DOE to recognize the value of AHRI’s certification program to federal efficiency standards. DOE should focus on products that are either self-certified by a manufacturer or have no third-party voluntary industry certification program. We urge Congress to direct DOE to support the role of recognized and successful certification programs, such as the AHRI Certified program. This will help reduce the regulatory burden on manufacturers and testing costs for both the federal government and businesses alike.