More good news from DOE/EPA last week: the agencies intend to beef up testing of products using the ENERGY STAR label. ENERGY STAR is an important labeling program used to help consumers identify the more energy efficient models within a product category. The ENERGY STAR requirements are often used by utility, state and federal rebate programs to encourage production and purchase of the most efficient products available.
The ENERGY STAR program is a manufacturer self certification program. This means manufacturers are select the samples and in some cases use their own testing laboratory to develop the test data needed to qualify for the ENERGY STAR label. Given this arrangement, there is a potential for mischief. On several recent occasions ENERGY STAR qualified models failed to meet the ENERGY STAR requirements.
Until now, ENERGY STAR has done very little to verify that the products are performing as promised. To ensure consumers are getting the energy and operating cost savings they expect when they purchase ENERGY STAR labeled products, EPA and DOE need to ramp up their verification testing and enforcement program.
The good news is that last week, DOE and EPA announced that they will be increasing the level of attention they pay to testing and enforcement. For a start, DOE is doing some of its own testing with samples purchased directly from retail. They have already made clear they are willing to act on this information. They will be following that up with a more comprehensive testing program.
In order to make sure the testing works, DOE and EPA should make sure the testing is independent, transparent, and strategically targeted:
- Independence: product selection and testing should not be controlled by manufacturers. Independent selection and testing will ensure that the models tested are representative of the models sold and that the testing is not biased by those who have a stake in the results.
- Transparency: testing, collection and implication of failure protocols should all be publicly available, as should detailed test results. There is nothing secret about energy consumption. Public data will make sure failing products are exposed; build the credibility of the program; and help other jurisdictions prioritize their testing.
- Strategic targeting: testing should be wide spread, but prioritized based on products/manufacturers that have had compliance troubles; energy savings implications; information from stakeholders and manufacturers; and data-sharing between agencies.