Each manufacturer, before distributing in commerce in the United States a covered product or equipment subject to an applicable energy conservation standard, must test each basic model according to DOE test procedures and submit a certification report to DOE certifying that the basic model meets the applicable energy conservation standard.
These frequently asked questions and answers provide assistance to U.S. manufacturers regarding compliance with DOE's energy conservation standards. The FAQs on this page are designed to help a U.S. manufacturer identify key issues to consider to ensure compliance with the energy conservation standards for consumer products and commercial and industrial equipment. In the Q&As on this page, the term "manufacturer" is used to refer to the party that produces, builds, or assembles the product, but not the importer. Separate importer-specific Q&As are available.
Is the product I am manufacturing “covered”?
See the list of covered products and equipment. For more specific information, consult the relevant definitions in 10 CFR Parts 430 (consumer products) and 431 (commercial and industrial equipment). You should also note whether the covered product is subject to an energy conservation standard. Some types of covered equipment will become subject to standards in the future but may not be subject to standards at this time.
If the product is covered and subject to conservation standards, has it been tested in accordance with the DOE test procedure?
The relevant test procedure is identified in 10 CFR Part 430 or 431. For most products, DOE does not require a test facility to meet specific requirements. (See, e.g., 10 CFR 430.25 for some exceptions.) So, a manufacturer may test on it own or may choose to work with a third party laboratory to complete testing. However, the manufacturer is ultimately responsible for ensuring that the testing was conducted in complete accordance with the applicable DOE test procedure. Note that non-DOE test procedures may generate different results.
Except in very limited circumstances, DOE requires a minimum sample size of two units. Consult the certification provisions in 10 CFR Part 429, Subpart B, to determine how many units you need to test or whether you may be permitted to use an alternative method of determining efficiency (AEDM).
If the product has been tested, does it meet the applicable standard?
The applicable standards are listed in 10 CFR 430.32 or in 10 CFR Part 431. Determine whether a product can be certified as compliant by applying the product-specific certification requirements in 10 CFR Part 429, Subpart B; the certification statistics are typically found in paragraph (a) of the product-specific section. Manufacturers are required to maintain test data underlying a certification of compliance. 10 CFR 429.71.
You should review your test data before certifying that the product/equipment is compliant. You should also be sure to apply the applicable certification statistics to determine your certified ratings. A manufacturer may also wish to consider: Were the test results from prototypes or units coming off the manufacturing line? Does my routine or random sampling of units produce consistent results? You, the manufacturer, are responsible for the compliance with the energy conservation standards of the products you distribute in commerce in the U.S.
If the product meets the standard, have you, the manufacturer, certified the compliance of the product to DOE?
After you have tested a sample of a sufficient size to ensure that the product you are manufacturing meets the standard, you must certify to DOE that the product has been tested and meets the standard. DOE provides templates for certification reports, which you can fill out and submit electronically through DOE's Compliance Certification Management System. The following questions and answers explain more about manufacturer certifications of compliance.
What is a certification report?
DOE provides preformatted, standardized, product-specific Excel templates. Complete the applicable template(s) for the type(s) of product or equipment you manufacture. Each template has an “Input” tab for model-specific information and a “Certification” tab for company/contact information as well as the legal certification that the listed basic models comply with all applicable energy conservation standards. When complete, upload the completed templates to your new CCMS account.
Who is going to submit the report?
If you are going to submit a certification report, you first need a CCMS account. Complete and submit a user registration form by scanning and e-mailing a signed copy to firstname.lastname@example.org. Once the form is received, DOE’s contractor will contact the user to complete the registration process.
If you are going to authorize a third party to submit a certification report, you first need to complete a third-party authorization form. Either you or your third-party submitter may submit the completed third-party authorization form. You do not need a CCMS account; however, your third-party submitter will need to complete a user registration form to get an account, if it does not already have one. Your third-party submitter will complete the appropriate template(s) for the products you manufacture and will upload the completed templates using its CCMS account. The manufacturer is ultimately responsible for providing valid certifications prior to distribution in commerce in the U.S. Thus, if a third party submits certification reports on your behalf, you may want to ask to see the report(s) that it has submitted.
Does listing on DOE's public database mean DOE has "approved" my product for distribution in the U.S.?
No. Certifications are submitted through the Compliance Certification Management System (CCMS) system. Although DOE provides limited information from manufacturers’ certification reports on its public database, DOE does not make any representations or warranties about the accuracy of the information. In other words, DOE is not providing “approval” by posting model information on the public database. When a manufacturer submits a certification report through CCMS, the system automatically sends out an email confirmation of the submittal, which is the submitter's proof of having submitted the certification report to the Department. The regulatory requirement to submit reports is fulfilled upon submission of a certification report that complies with the requirements of 10 CFR Part 429 - not upon posting on DOE’s public database.