On March 28, 2016, OHA denied an Application for Exception filed by Eaton Corporation (Eaton). In its Application, Eaton sought exception relief from the DOE’s distribution transformer efficiency standards, which became effective January 1, 2016. Eaton, headquartered in Dublin, Ireland, is a manufacturer of electric power systems. Due to malfunctions in its plants in late 2015, Eaton was unable to fully assemble, and certify with DOE, 28 distribution transformers before the new efficiency standards compliance date. Eaton requested exception relief for these distribution transformers, which met the old efficiency standards. OHA determined, however, that Eaton’s Application should be denied since any hardship, inequity, or undue burden created by these malfunctions did not occur because of the implementation of the new efficiency standards, but rather from Eaton’s own business decision to continue assembling nonconforming products close to the effective date of the new efficiency standards.