A U.S. District Court for the Eastern District of California U.S. has issued a permanent injunction enjoining the California Energy Resources
Conservation and Development Commission (CEC) from enforcing its appliance marking, information filing, and compliance regulations on equipment including central air-conditioners and heat pumps that are covered by the federal Energy
Policy and Conservation Act (EPCA).
In a decision issued June 13, "the court recognized the problems that come with
a patchwork of state regulations and gave a significant victory to manufacturers
and consumers by ensuring that the principal of one federal regulation not fifty
separate state regulations govern the manufacturing of federally covered HVACR
products and equipment," according to William G. Sutton, president of the
Air-Conditioning and Refrigeration Institute (ARI).
ARI and the Association of Home Appliance Manufacturers (AHAM), the Gas
Appliance Manufacturers Association (GAMA), and the National Electrical
Manufacturers Association (NEMA) filed a complaint with the federal court
seeking relief from regulations promulgated by the CEC regarding federally
"covered products" and "covered equipment" that are preempted expressly by EPCA.
The federally covered products affected by the CEC's regulations were air-conditioners and heat pumps, package terminal air-conditioners, water heaters, and furnaces, as well as other residential and commercial appliances.
The court found that the federal regulations were adopted to address the
"situation where appliance manufacturers were confronted with the problem of a
growing patchwork of differing state regulations which could increasingly
complicate their design, production and marketing plans. Regulations in a few
populous states could as practical matters determine the product lines sold
nationwide, even in states where no regulations existed."
In enjoining the CEC's regulations, the court found that "allowing each state to
submit different pieces of information about their products opens the door to
the creation of the precise situation that Congress sought to avoid in passing
NAECA – subjecting manufacturers to a patchwork of potentially inconsistent
The energy efficiency of appliances is governed by EPCA as amended by the
National Appliance Conservation Act of 1987 (NAECA) and the Energy Policy Act of
1992 (EPACT). NAECA contains efficiency standards, testing procedures, and
labeling requirements, among other regulations, for certain residential
appliances, referred to as "covered products." These include appliances such as
refrigerators, room air-conditioners, air-conditioners and heat pumps, furnaces,
water heaters, and fluorescent lamp ballasts. EPACT contains similar
regulations for certain types of commercial and industrial equipment, referred
to as "covered equipment." These include certain electric motors, packaged
terminal air-conditioners and heat pumps, storage water heaters, and
instantaneous water heaters.
Equipment specifiers in California and around the country can search ARI’s
electronic database for performance ratings on thousands of pieces of air-conditioning equipment at www.ariprimenet.org.
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