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Dept. of Energy comments regarding refrigerator rulemaking

January 15, 2010
Ms. Brenda Edwards
U.S. Department of Energy
Building Technologies Program
Mailstop EE–2J
1000 Independence Avenue, SW
Washington, DC 20585–0121
Re: Refrigerator-Freezers, and Freezers, EERE–2008–BT–STD–0012
Consumers Union of United States, Inc., publisher of Consumer Reports®, submits the following comments in response to the U.S. Department of Energy (“DOE”) in the above-referenced matter.
Consumers Union has been a long-time advocate of enforcing and improving Energy Guide and Energy Star labeling for appliances and electronics. During routine product testing, Consumers Union has discovered large discrepancies between the claims made in energy-usage labeling for several appliance models and the energy actually expended and has brought these matters to the attention of the Department of Energy. Some Consumers Union’s tests have been identical to those required under DOE testing protocols while other tests have diverged from the agency’s protocol in ways that we believe are more representative of how consumers actually use these appliances. In both cases, however, our results raise significant questions about the enforcement of the Energy Star program as well as casting doubt on whether certain appliances should in fact qualify.
Consumers rely on energy-usage labeling in choosing energy efficient products, but such labels are only effective if they are reliable and verifiable. Consumers Union advocates for third-party certification of compliance conducted by independent, accredited testing laboratories combined with DOE spot checking of Energy Star and Energy Guide manufacturer labels. However, even these measures will not protect consumers from misleading Energy Guide and Energy Star labels if the test procedures do not accurately reflect true energy use in consumers’ homes. Indeed, our tests have suggested that some manufacturers may have engineered their products to “recognize” the DOE test protocol and perform in ways that save energy during the testing procedure, but are unlikely to be duplicated once in a consumer’s home where such conditions will rarely pertain. Below are the key findings from our test results and our recommendations for preventing manufacturers from “building to the test.”
For the complete comments, click here (PDF format).