The Department of Energy is not proposing a new refrigerator, washer or water heater standard in its latest appliance rulemaking. It is proposing to change the rulebook DOE uses before those standards are written.
The July 7 notice of proposed rulemaking would revise DOE’s “Process Rule,” the procedures and policies that guide how the agency develops energy conservation standards and test procedures for consumer products and certain commercial and industrial equipment. DOE says the proposal is intended to provide more certainty for affected stakeholders and to better inform the Secretary’s decision on whether to regulate and what standard level to select.
For the appliance trade, the proposal matters because it could shape the next generation of efficiency standards across categories such as refrigerators, clothes washers and dryers, dishwashers, room air conditioners, central air conditioners, heat pumps and water heaters. The immediate effect is procedural. The long-term effect could be fewer, slower or less stringent standards in cases where DOE determines the energy savings, consumer payback or manufacturing burdens do not clear the new tests.
The Process Rule Is the Rulebook Behind the Rules
DOE’s Process Rule dates to a 1995-96 effort to improve the way the agency develops appliance efficiency standards. The current rule is codified at 10 CFR part 430, subpart C, appendix A and describes the procedures, interpretations and policies DOE uses when setting new or amended standards and test procedures.
That makes it different from a product-specific rule. A refrigerator standard tells manufacturers what efficiency level future refrigerators must meet. A test procedure tells manufacturers and DOE how energy use is measured. The Process Rule determines how DOE gets there: when it seeks comments, what analyses it performs, how it weighs costs and benefits, and what evidence is needed before a standard moves forward.
DOE is proposing to make appendix A binding on the agency for certain actions, add a definition of “significant energy savings,” reinstate a comparative “walk up” analysis, include economic thresholds and return several sections to language from the 2020 Process Rule. Comments on the proposal are due Aug. 6, 2026.
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New Thresholds Could Change Which Standards Advance
The most consequential change may be DOE’s proposed definition of “significant energy savings.” DOE proposes that a standard would need to produce at least a 10 percent reduction in full-fuel-cycle energy use over 30 years or a 2-quad reduction in full-fuel-cycle energy use over 30 years.
DOE says a threshold at that level would have retained 91.5 percent of the energy savings from past standards while eliminating 35 percent of rulemakings, or 30 of 86 rulemakings, from moving forward under the proposed test. The agency argues that this would reduce burdens from incremental standards that deliver relatively small savings.
That is the central tradeoff. Manufacturers could face fewer redesign cycles, fewer compliance investments and less pressure to retool products for marginal efficiency gains. Consumers could see fewer rules that increase first cost. But efficiency advocates, utilities and some states are likely to focus on the other side of the ledger: the energy, water and bill savings that would not be captured if a rule fails the threshold.
The standard-by-standard impact will depend on the product. High-energy products such as water heaters or HVAC equipment may clear an absolute savings threshold even with a small percentage reduction. Lower-energy appliances may need to show a stronger percentage improvement to move ahead.
The ‘Walk Up’ Approach Reframes Stringency
DOE also wants to reinstate a comparative analysis it describes as a “walk up” approach. Instead of starting with the most stringent technically feasible level and walking down to a level DOE determines is economically justified, the proposal would move from the baseline toward progressively more stringent trial standard levels.
In plain terms, DOE is trying to make each step in efficiency stringency justify itself against the status quo and the next-lower option. The agency says this would more clearly show the added costs, benefits, operating savings and manufacturer impacts at each level.
The proposal also adds economic screens that could stop some standard levels from being selected. DOE proposes thresholds tied to a 10 percent increase in installed cost relative to the baseline, 20 percent of consumers projected to incur net costs, and a simple payback period of more than 50 percent of the average product lifetime.
For appliance manufacturers, those thresholds could become important planning tools. For retailers, they could affect future assortment, price ladders and timing for product transitions. For consumers, they could preserve more low-cost models in some categories but reduce the minimum efficiency floor that lowers operating costs over the life of an appliance.
Test Procedures and Reliability Move Up the Agenda
Test procedures are not technical side notes. They determine how products are measured, certified and compared. If a test procedure changes, the measured efficiency of a product can change even before the product itself changes.
DOE proposes to provide 180 days between a test procedure final rule and issuance of a standards proposal. Industry commenters have argued that manufacturers need that time to understand new tests, run equipment, assess lab setups and evaluate design consequences before commenting on a proposed standard.
The proposal also gives explicit attention to performance characteristics, including reliability, features, sizes, capacities and volumes. A standard level would not be proposed if interested parties establish that it is likely to make a covered product type or class unavailable in the United States with substantially the same performance characteristics as products generally available at the time.
That language matters for appliance ownership. Efficiency improvements can reduce utility bills, but the trade also tracks whether new requirements affect repair complexity, component costs, cycle times, drying performance, heating recovery, usable capacity or expected service life. DOE’s separate analytic-methods request for information asks for comment on the assumptions, models and methodologies used in standards analysis, including repair and installation cost assumptions, retirement and replacement modeling, baselines and consumer behavior.
What the Trade Should Watch
Manufacturers should watch whether DOE finalizes the proposed energy-savings and economic thresholds as written, revises them after comments, or adopts product-specific variations. Those choices could change how companies plan engineering budgets, compliance calendars and platform redesigns.
Retailers should watch product categories that are already sensitive to price and performance claims. A slower or narrower standards pipeline may reduce abrupt model turnover, but it also may create more complicated selling conversations if state policies, ENERGY STAR positioning and federal minimum standards move in different directions.
Consumers should watch total cost, not just sticker price. A looser standard-setting process may help preserve lower initial prices and more product configurations. It may also leave some households with higher energy or water bills over time if minimum efficiency levels rise more slowly.
- Cost: The proposal puts more emphasis on installed cost, consumer net cost and payback.
- Reliability and performance: DOE would more explicitly consider whether standards affect utility, features and product availability.
- Energy savings: Standards that do not meet the proposed full-fuel-cycle savings threshold could be harder to justify.
- Regulatory certainty: A more binding Process Rule could give industry clearer expectations, but the final rule and any legal challenges remain unresolved.
The Certainty Question
DOE frames the proposal as a way to improve transparency, affordability and certainty. The strongest case for the rule is that manufacturers, retailers and consumers benefit when standards are built on stable procedures, clear thresholds and full visibility into costs and benefits.
The strongest concern is that the same procedures could make some future efficiency updates harder to complete even when they would produce long-term operating savings. Appliance efficiency standards are always a balancing act among first cost, operating cost, product function, reliability, manufacturing investment, energy demand and consumer choice.
The proposed Process Rule would not settle those debates. It would change the machinery DOE uses to decide them.
