DOE About to Make an Appliance Efficiency Testing Error

If you wanted to improve the test scores of a high school math class, one way to do it would be to let the students write their own tests. The scores would certainly increase, but the thing you actually care about—knowledge of math—would not. Unfortunately, the Department of Energy (DOE) is on the verge of making a similar error.

A recently proposed “update” to DOE’s Appliance and Equipment Standards Program—which is saving consumers billions of dollars annually on their utility bills while reducing the harmful air pollution from generating energy to run their appliances and equipment—would allow manufacturers to write their own tests for measuring the energy use of their products with minimal oversight from DOE or other interested parties.

These tests might not make for thrilling reading, but they’re incredibly important. They determine how the energy efficiency of electronics, appliances, and equipment is measured, and every product with an efficiency standard has a corresponding test. Some tests might make certain products look significantly more or less efficient than they are. That’s part of why it’s so important to get these tests right.

The testing change is part of a broad suite of modifications DOE is proposing to its “Process Rule” that would make it more difficult to administer the program and give too much power to corporations at the expense of consumers and the environment.

What is the Process Rule and why does it matter?

My colleague Lauren Urbanek has written a more detailed explanation of the Process Rule, but here’s a quick summary.

The Process Rule is a non-binding regulation that guides how DOE administers its Appliance and Equipment Standards Program. Currently, it’s a good balance between offering stakeholders the predictability to plan for future standards while allowing DOE to respond to unforeseeable issues that might crop up.

Unfortunately, DOE’s proposed changes would make it harder to update standards, unnecessarily reducing benefits to consumers and the environment.

Among other issues, the proposal would greatly increase the likelihood that DOE simply accepts an industry-written test procedure without modification. But in order to get these tests right, there must be input from all stakeholders, not just industry.

What is the program and why do tests matter?

The Appliance and Equipment Standards Program sets minimum energy (or water, depending on the product) efficiency standards for a wide variety of electronics, appliances, and equipment. It has enjoyed widespread, bipartisan support in its over 40-year history. Approximately 90 percent of the energy consumed in the typical U.S. household is by products that are part of the program, including  water heaters, air conditioners, appliances, and light bulbs. These standards save households, on average, $500 per year. By DOE’s own estimate, the program has avoided over 3 billion tons of carbon dioxide and is on track to reduce our nation’s energy bills by $2 trillion.

But what do we mean by “energy efficiency”? At the most basic level it’s a measure of how much useful “stuff” you get out of an appliance divided by how much energy you spend to get it. The “stuff” in question depends on the product. For a refrigerator, for example, the useful “stuff” is a fridge full of cold air, and you want to know how much energy you have to use to produce it.

It is comparatively easy to develop a test for some products. Take light bulbs (a product facing its own rollback, as my colleague Noah Horowitz has written). It’s pretty straightforward for DOE engineers to measure how much light comes out (the useful “stuff”) as well as how much electrical energy was consumed to get it. 

Other products aren’t so simple. Take a clothes dryer. Although it’s still fairly easy to measure how much energy is consumed, the useful “stuff” is a load of dry clothes. In order to ensure that you get the same answer every time you test a particular model of clothes dryer, you need to use the same kind of load every time. Unfortunately, DOE’s test method is flawed. The test load is a set of thin 50 percent cotton/50 percent polyester handkerchief-like cloth instead of more common items like blue jeans, cotton socks, and towels. By using a load that excludes common, harder-to-dry items, the official DOE test method results in gross underreporting of a dryer’s true energy use and drying time. 

That’s why getting the test method correct is so important. If the test doesn’t accurately represent the way appliances are used in the real world, we can’t know which products are truly more efficient. Consumers won’t have the information they need to choose the most efficient products. (DOE’s tests are also used for qualifying for ENERGY STAR®, which grants a blue and white label to the most efficient products on the market.) Companies have known about the problems with some of these tests for years, but rather than work together to fix them, many prefer to ace the broken test they already know.

In the case of clothes dryers, the test procedure has been broken for some time. Unfortunately, this is far from the only product where there have been problems. Some manufacturers have exploited a flaw in the test for measuring the energy use of new TVs and have used software to artificially inflate their efficiency scores.  Despite this well-documented issue, almost three years later the industry still hasn’t fixed these flaws or adapted the method to properly account for new, ultra-high-definition TVs.


At a time when DOE has already missed 16 legal deadlines for updating standards for a wide range of products it’s unfortunate that it has been spending time developing proposals that will harm the program. NRDC will be submitting comments on the proposed Process Rule revisions, and we hope that DOE will substantially revise or totally withdraw its proposal. The public can submit comments here by May 6.

If you’re concerned about these changes, here’s what you can do to help. Visit to learn more about the threats to this program and contact your members of Congress to let them know you’re concerned. These tests are too important to allow DOE to get a failing grade.

About the Authors

Joe Vukovich

Energy Efficiency Advocate, Climate & Clean Energy program
Blog Post

It will soon be more difficult and cumbersome to set strong standards for the appliances and electronics in our homes and businesses, if the Trump administration’s Department of Energy has their way.

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