Appliance Efficiency Standards

State action to develop and/or expand, enforce, and provide consumer education about appliance energy efficiency standards can provide additional energy cost savings to consumers and establishes an infrastructure for future state action.

Table Of Contents
  1. Why This Matters
  2. Policy Solution
  3. Model Policy Features
  4. Potential Limitations & Pitfalls
  5. Complementary Policies
  6. Additional Information
  7. Examples
  8. Resources
COMMUNITY BENEFITAffordability, Decarbonization
KEYWORDSDecarbonization, Efficiency
REGIONFederal, State
AFFORDABILITY STRATEGYResidential Decarbonization
OVERSIGHTU.S. Department of Energy, U.S. Environmental Protection Agency, State Energy Agencies
POLICY MECHANISMLegislation, Regulation

Why This Matters

Appliance efficiency standards, associated labeling programs, and enforcement are generally implemented at the federal level. Over 70 products, representing about 90% of home energy use, are governed by federal appliance and equipment standards set by the U.S. Department of Energy (DOE).1 Additionally, the federal ENERGY STAR program2 sets voluntary standards for higher-than-minimum efficiency appliances3 and provides consumer education about energy use and anticipated cost savings. The federal government is also responsible for enforcement of established standards. 

These programs now face a number of threats: 

  • Proposed legislation would authorize the U.S. Secretary of Energy to revise or revoke established standards and to set minimum energy saving requirements for any new standards.4 
  • The ENERGY STAR program remains at risk of being defunded or having its funding reduced,5 dismantled, and/or privatized.6 
  • Future enforcement of established standards is also uncertain.7 

Inaction in the development of new standards, weakening or revocation of existing standards, or  rollbacks related to enforcement or consumer education efforts through the ENERGY STAR program would all deprive consumers of effective strategies for lowering household energy costs.

Policy Solution

Although appliance energy efficiency standards are generally set and enforced at the federal level, states are authorized to develop and, as in the case of the California Energy Commission,8 enforce their own standards for products that have not yet been established at the federal level.9 In the past, such action at the state level has led to the products being incorporated into standards at the federal level.10 State action to develop and enforce energy efficiency standards for appliances and equipment for which no federal standards exist, enforce existing federal standards in the absence of federal enforcement,11 and/or to provide consumer education about appliance energy efficiency standards, similar to the ENERGY STAR program, can provide additional energy cost savings to consumers. Should the U.S. Department of Energy revoke established standards in the future, opportunities may also exist for states to step in to regulate those appliances and equipment.

Model Policy Features

Key features of state-level appliance efficiency standards include:

  • Authorization of state regulatory agencies to adopt—and enforce—additional standards through rulemaking, beyond those established by DOE.12
  • Standards governing the energy efficiency of appliances and equipment not currently regulated by the federal government.13 
  • Certification requirements specifying that affected manufacturers must attest to compliance of their products with state-established standards.14
  • Public violation reporting and/or audits (online or in-store) to ensure compliance beyond certification requirements.15
  • Labeling requirements for products regulated by the state notifying consumers of compliance with state standards.16
  • Consumer awareness and public engagement processes, including for manufacturers.17

Potential Limitations & Pitfalls

States are limited in their ability to set and enforce appliance energy efficiency standards; state-level standards can only be developed for products that are not already subject to federal energy efficiency standards. To date, the federal government has established standards for appliances and equipment accounting for 90% of residential energy use, as well as for much of commercial use. There is limited ability for states to make additional significant reductions in home energy use and associated cost savings through new standard development, assuming federal standards remain in place and are enforced.

Complementary Policies

Complementary policies that align with appliance efficiency standards include:

  • Efficient residential electrification to facilitate the shift to clean energy sources.
  • Rental efficiency standards that include the purchase and installation of energy-efficient appliances.
  • Refundable tax credits, rebates, and incentive programs at the state or federal levels to assist households in affording upgrades to more efficient appliances.

Additional Information

As of 2025, 20 states and the District of Columbia have adopted appliance energy efficiency standards for commercial and/or residential use.18

Examples

1. California Appliance Efficiency Regulations – California Code of Regulations – Title 20 Appliance Efficiency Regulations

Details:

  • Serves as a model for standard development in other states, as California’s program was the first of its kind and has led development of standards at the state level; many of these standards have subsequently been adopted at the federal level.19
  • Sets minimum efficiency standards for over 70 products.20
  • Has generated over $75 billion in electricity savings since 2013.21 
  • Includes robust outreach and educational resources for consumers and manufacturers.22
  • Continually assesses new opportunities for standard development through the pre-rulemaking process.23
  • Includes certification24 and compliance guidance.25

LIMITATIONS:

  • Although California enforces appliance efficiency standards through the Office of Compliance Assistance and Enforcement, compliance varies by product.26
  • Program administrative costs for the Appliance Efficiency Enforcement Subaccount of nearly $3 million, subject to state appropriations. (After increasing from $1.762 million in 2023–24 to $2.917 million in 2024–25, appropriations for 2025-26 are stable at 2024-25 levels.)27

2. Colorado Efficiency Standards for Appliances28

Details:

  • State standards developed for 22 products.29
  • Includes rules for testing, certification, labeling, and enforcement.30
  • Does not preempt more rigorous standards at the local level.31
  • Requires that products that are deregulated by the federal government are subject to the previously approved federal standard within Colorado, unless approval was revoked as the result of court action.32

LIMITATIONS:

  • Although Colorado’s legislation includes compliance provisions, rates of compliance are likely to be less than 100%, but are unknown.
  • Technical assistance is provided through a small program operated out of the Colorado Department of Public Health and Environment–the Small Business Assistance Program–and subject to state appropriations.33

Resources

Written: December 2025

  1. U.S. Department of Energy. Appliance and Equipment Standards Program. Accessed: November 26, 2025. ↩︎
  2. ENERGY STAR. About ENERGY STAR. Accessed: August 6, 2025. ↩︎
  3. ENERGY STAR. List of ENERGY STAR Energy Efficiency Products. Accessed: August 6, 2025. ↩︎
  4. Walton, R. (2025). Republicans take aim at DOE’s appliance efficiency program. Utility Dive. ↩︎
  5. Frazin, R. (2025). EPA says ‘no final decision’ has been made on whether to end Energy Star. The Hill. ↩︎
  6. Reilly, S. (2025). Zeldin sounds off on Energy Star, endangerment finding. E&E News by Politico. ↩︎
  7. deLaski, A. (2025). Appliance Standards Would Bring Inferior Products with Big Costs. American Council for an Energy-Efficient Economy. ↩︎
  8. California Energy Commission. Office of Compliance Assistance and Enforcement. Accessed: October 10, 2025. ↩︎
  9. U.S. Environmental Protection Agency, State Climate and Energy Program. (2015). EPA Energy and Environment Guide to Action: State Appliance Efficiency Standards. ↩︎
  10. Midwest Energy Efficiency Alliance. (2025). State Appliance Standards: The Best Energy Saving Policy You’ve Never Heard Of. ↩︎
  11. Eisenberg, D., Smith, S., and Hanel, N. (2025). California’s Energy Commission Reaches Costly Settlements Over Consumer Product Efficiency Standards. Beveridge & Diamond. ↩︎
  12. U.S. Environmental Protection Agency, State Climate and Energy Program. (2015). EPA Energy and Environment Guide to Action: State Appliance Efficiency Standards. ↩︎
  13. Appliance Standards Awareness Project and American Council for an Energy-Efficient Economy. Model Act for Establishing State Appliance and Equipment Energy and Water Efficiency Standards, updated October 2021. See also U.S. Environmental Protection Agency, State Climate and Energy Program. (2015). EPA Energy and Environment Guide to Action: State Appliance Efficiency Standards, Table 4.4.1. ↩︎
  14. Appliance Standards Awareness Project. (2021). Appliance Standards Questions and Answers: Appliance Standards Implementation. ↩︎
  15. Appliance Standards Awareness Project. (2021). Appliance Standards Questions and Answers: Appliance Standards Implementation. ↩︎
  16. Appliance Standards Awareness Project. (2021). Appliance Standards Questions and Answers: Appliance Standards Implementation. ↩︎
  17. U.S. Environmental Protection Agency, State Climate and Energy Program. (2015). EPA Energy and Environment Guide to Action: State Appliance Efficiency Standards. ↩︎
  18. State Climate Policy Dashboard. Buildings and Efficiency: Appliance Standards. Accessed: August 8, 2025. ↩︎
  19. U.S. Environmental Protection Agency, State Climate and Energy Program. (2015). EPA Energy and Environment Guide to Action: State Appliance Efficiency Standards. ↩︎
  20. State Climate Policy Dashboard. Buildings and Efficiency: Appliance Standards. Accessed: August 8, 2025. ↩︎
  21. U.S. Environmental Protection Agency, State Climate and Energy Program. (2015). EPA Energy and Environment Guide to Action: State Appliance Efficiency Standards. ↩︎
  22. California Energy Commission. Appliance Efficiency Program: Outreach and Education. Accessed: August 8, 2025. ↩︎
  23. California Energy Commission. Appliance Efficiency Proceedings-Title 20. Accessed: August 8, 2025. ↩︎
  24. California Energy Commission. Appliance Regulations Certification Assistance. Accessed: August 8, 2025. ↩︎
  25. California Energy Commission. Office of Compliance Assistance and Enforcement. Accessed: August   8, 2025. ↩︎
  26. Richter, C., Chase, A., Marvel, J., Cunningham, K., Wilkins, B.and McLain, L. (2016). Developing an Appliance Standards Compliance Improvement Program. ACEEE Summer Study on Energy Efficiency in Buildings, 5-5. ↩︎
  27. California 2025-2026 State Budget, Natural Resources Agency. Accessed: December 1, 2025. ↩︎
  28. Colorado Department of Public Health and Environment. Efficiency Standards for Appliances. Accessed: August 27, 2025. 
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  29. State Climate Policy Dashboard. Buildings and Efficiency: Appliance Standards. Accessed: August 8, 2025. ↩︎
  30. 2022 Colorado Code,Title 6, Article 7.5, § 6-7.5-109. Testing, Certification, Labeling, and Enforcement – Rules. ↩︎
  31. 2022 Colorado Code,Title 6, Article 7.5, § 6-7.5-103. Low-Efficiency Plumbing Fixtures. ↩︎
  32. 2022 Colorado Code,Title 6, Article 7.5, § 6-7.5-107. Protection Against Repeal of Federal Standards. See also Colorado Department of Public Health and Environment. Efficiency Standards for Appliances. Accessed: August 11, 2025. ↩︎
  33. Colorado Department of Public Health and Environment, Small Business Assistance Program. Accessed: December 1, 2025. The Air Pollution Control Division’s 2025-2026 budget can be viewed at: https://s3.us-west-2.amazonaws.com/beta.leg.colorado.gov/9010f5c88c36d06b651202e46979c784. ↩︎