The current certification, compliance and enforcement regulations for Commercial Refrigeration Equipment (CRE) “simply makes no sense”. The regulations define the basic model as any product that has a different energy use or efficiency level. It does not allow for modeling the performance of our equipment. Our equipment is customized per order and by mixing and matching different combinations we have 118,000 basic models. The requirement to test two models to get an average energy level increases the number of tests to 236,000. At an average test cost of $3,000, our total costs will be over $700,000,000. The rule needs to be redone.