The U.S. Department of Energy (DOE) has published a Notification of No Legal Effect, indicating that DOE’s energy conservation standards for manufactured housing, as established in May 2022, have no legal effect pursuant to section 301(d)(2)(B) of the ROAD Act.
Section 301(d)(2)(B) of the ROAD Act specifies that “[n]o energy efficiency standards for manufactured homes developed by any Federal agency shall have legal effect unless and until adopted by the Department of Housing and Urban Development pursuant to the consensus standards and regulatory development process described in . . . 42 U.S.C. 5403(a)(2)).” Section 301(d)(2)(C) of the ROAD Act requires the Department of Housing and Urban Development (“HUD”) to “adopt minimum energy efficiency standards for manufactured homes” within one year of enactment, and to update those standards every three years.
As of the date of this notification, no minimum energy efficiency standards meeting the requirements under section 301(d) of the ROAD Act have been adopted by HUD. Therefore, it is DOE’s position that the final rule published in the Federal Register on May 31, 2022, establishing energy conservation standards for manufactured housing has no legal effect pursuant to section 301(d)(2)(B) of the ROAD Act. The Department intends to initiate a rulemaking to conform DOE’s regulations for manufactured housing to account for the statutory changes adopted by the ROAD Act, and further notes that DOE will not enforce its energy conservation standards for manufactured housing as they have no legal effect under the ROAD Act.
Related Documents
Notification of Legal Effect - Federal Register, (September 18, 2026)
Notice of Intent - Federal Register, 86 FR 35773, (July 7, 2021)
- For additional information on the NEPA process please see the NEPA webpage at https://ecs-mh.evs.anl.gov/.
For the latest information on the planned timing of future DOE regulatory milestones, see the current Office of Management and Budget Unified Agenda of Regulatory and Deregulatory Actions. All planned dates are preliminary and subject to change.
Standards
Notification of Legal Effect - Federal Register, (September 18, 2026)
Request for Information - Federal Register, 90FR42544 (September 3, 2025)
Final Rule; Extension of Compliance Date for Tier 2 Homes - Federal Register 90FR28873 (July 2, 2025)
Notice of Proposed Rulemaking; Extension of Compliance Date - Federal Register, 90FR17230 (April 23, 2025)
Notice of Proposed Rulemaking; Enforcement Procedures - Federal Register, 88FR88844 (December 26,2023)
Final Rule; Extension of Compliance Date - Federal Register, 88FR34411 (May 30, 2023)
Notice of Proposed Rulemaking; Extension of Compliance Date - Federal Register, 88FR17745 (March 24, 2023)
Final Rule - Federal Register, 87FR32728 (May 31, 2022)
- Compare Redline
Environmental Impact Statement - Federal Register, 87FR2359 (January 14, 2022)
Notice of Data Availability - Federal Register, 86FR59042 (October 26, 2021)
Supplemental Notice of Proposed Rulemaking - Federal Register, 86FR47744 (August 26, 2021)
Notice of Proposed Rulemaking - Federal Register, 81 FR 39756 (June 17, 2016)
The manufactured housing energy conservation standard rulemaking docket EERE-2009-BT-BC-0021 contains all notices, public comments, public meeting transcripts, and supporting documents.
Public Meeting Information
There is no public meeting scheduled at this time.
Submitting Public Comments
The comment period is closed.
Test Procedure
Notice of Proposed Rulemaking - Federal Register, 81 FR 78733 (November 9, 2016)
The manufactured housing test procedure rulemaking docket EERE-2016-BT-TP-0032 contains all notices, public comments, public meeting transcripts, and supporting documents pertaining to this rulemaking.
Public Meeting Information
There is no meeting scheduled at this time.
Submitting Public Comments
The comment period is closed.
DOE has published a Notification of No Legal Effect, indicating that DOE’s energy conservation standards for manufactured housing, as established in May 2022, have no legal effect pursuant to section 301(d)(2)(B) of the ROAD Act.
There are currently no test procedures for manufactured housing.
Compliance
There are currently no compliance and enforcement procedures established for manufactured housing.
Waivers
For information on current test procedure waivers, see DOE’s waivers webpage.
For information about obtaining test procedure waivers, see 10 CFR 430.27.
Guidance and Frequently Asked Questions
For information on further guidance and answers to frequently asked questions on all covered products, see DOE’s Further Guidance database.
ENERGY STAR®
DOE supports the testing and verification of ENERGY STAR products in close collaboration with the Environmental Protection Agency.
Find tips and guidance for making your home, workplace, or vehicle more energy efficient visit EnergySavers.gov.
For more information related to this product, please email:
ApplianceStandardsQuestions@ee.doe.gov
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