Make Energy Star Compliance Testing Results Public, NRDC Urges EPA

The EPA should make public data from testing for Energy Star compliance, the Natural Resources Defense Council said in comments filed with the agency. Energy Star’s integrity has been called into question by investigations and media reports, the group said. The best way to “proactively build and maintain the integrity of the program is to have a robust off-the-shelf verification testing program that includes complete transparency of the program’s procedures and testing results,” NRDC said. The Consortium for Energy Efficiency (CEE) said the EPA should set rules that “balance program costs and maintain the value of the program’s integrity."

The EPA should share verification testing data with the Department of Energy and the FTC, NRDC said. Some products covered by Energy Star are also be subject to DOE energy standards or the FTC’s EnergyGuide labeling program, the group said. “It is conceivable that an Energy Star listed product would not only fail to meet Energy Star’s requirements but also be out of compliance with the DOE minimum energy performance standard and/or have inaccurate information reported for FTC EnergyGuide label.” Energy Star should also seek information from counterparts in other countries that do their own testing to “determine trends they are finding.” Lack of public access to test data “perpetuates stakeholder and media mistrust of the Energy Star program,” NRDC said.

Samples for testing should be collected directly from retail outlets by an independent entity, NRDC said. “This prevents the opportunity for manufacturers to ‘hand pick’ the samples to be tested.” Labs that conduct the testing should be independent and not owned or operated by the device makers, it said. “Accreditation by a certification body by itself is not a sufficient barrier to prevent a motivated manufacturer from producing biased or false test results."

The EPA’s efforts to protect Energy Star’s integrity and help consumers get the expected energy savings is laudable, but collecting test data from accredited labs before products are labeled “will impose significant costs and have marketing implications” for many product makers, the CEE said. The group, which represents U.S. and Canadian utilities and state energy officials, supports “reasonable requirements” that balance costs while maintaining Energy Star’s soundness, it said. “We also support sufficient phase in periods” particularly when specific industries have “insufficient testing and certification infrastructure,” it said.