DOE Reliance on Third-Party Certification Programs

AHRI’s certification programs for residential and commercial heating and air conditioning equipment have worked well for over 50 years to ensure that the efficiency rating claims of manufacturers are accurate and that products comply with applicable federal minimum efficiency standards.

Manufacturers’ efficiency rating claims are verified through random testing by an independent laboratory and participation in AHRI’s certification programs is open to all manufacturers whether or not they are AHRI members. Manufacturers whose products fail verification testing are assessed significant penalties and must rerate their products. AHRI Certified products are listed on our website, updated daily, and sent directly to the Department  of Energy. AHRI’s certification programs obviate 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.

HVACR and water heating products are “applied” products.

Different from traditional home appliances (e.g. clothes washers, dishwashers and microwave ovens) which are simply plugged in, HVACR products are complex, and their application is customized to the individual customer’s needs. As such, HVACR and water heating products require experienced technicians — such as NATE certified technicians to properly install and ensure that they operate effectively and efficiently. However, DOE has insisted on categorizing and testing our members’ products as simple “plugand- operate” equipment instead of as complex and permanent components of a building. HVACR and water heating products are not the same as residential home appliances, and therefore should not be tested using the same procedure.

On March 7, 2011, 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.<

AHRI has urged DOE to recognize the value of AHRI’s certification program to federal efficiency standards.

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

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