Air Conditioner Test Procedure Enforcement Delay

Summary

The U.S. Department of Energy ("DOE") is finalizing a one- year delay of certain product-specific enforcement provisions related to the controls verification procedure established in a recently published final rule amending the test procedures for central air conditioners and heat pumps.

Compliance Requirements

1. #1

   On and after July 7, 2025, provisions in paragraphs (k)(1), (2) and (3) of § 429.134 shall apply; On and after July 7, 2026, provisions in paragraph (k)(4) of § 429.134 shall also apply; Manufacturers have 180 days before representations of energy use or efficiency have to be based on the new test procedure; Manufacturers, distributors, retailers, and private labelers may petition DOE for a compliance date extension of up to an additional 180 days; DOE may perform the CVP for any model certified as a variable capacity compressor system for the purposes of assessment or enforcement testing, including ICM models certified as variable capacity

   Deadline: 2025-07-07(July 7, 2025)

Market Impacts

• One-year delay of CVP enforcement provisions at 10 CFR 429.134(k)(4) from original July 7, 2025 date. CVP enforcement will not apply to units manufactured between July 7, 2025 and effective date of this rule.; Extended sell-through period for R-410A products before CVP enforcement takes effect, allowing manufacturers additional time to clear existing inventory; Delay in laboratory upgrades and certification processes needed to perform CVP testing, creating uncertainty in testing infrastructure development; CVP enforcement provisions will apply to all manufacturers, including foreign manufacturers, requiring compliance with variable-speed system verification; ICMs will be subject to CVP enforcement provisions when certifying variable capacity systems, despite requests for exclusion

Action Items

1. Delay CVP implementation planning

   Postpone all Controls Verification Procedure implementation activities until July 7, 2026, including testing equipment procurement, staff training, and procedure development

2. Maintain current test procedures

   Continue using appendix M1 test procedures for all product certification and energy efficiency reporting as specified in the January 2025 Final Rule effective July 7, 2025

3. Prepare for future CVP compliance

   Use the one-year delay period to conduct additional CVP testing, evaluate methodology, and prepare for full implementation by July 7, 2026

4. Continue other rule requirements

   Implement all other provisions of the January 2025 Final Rule not related to CVP enforcement, including updated test procedures and certification requirements effective July 7, 2025

Estimated Monetary Impact

Basis: The regulation delays CVP enforcement provisions but provides no specific monetary amounts. Comments mention CVP is 'time-consuming and costly' but no dollar figures. Estimates based on: 1) Comments stating CVP requires lab upgrades, product redesign, and additional testing time 2) Typical costs for HVAC testing procedures and compliance 3) No penalties specified in this delay rule 4) No explicit benefits mentioned beyond regulatory complianceConfidence: 40%

Validated Company Impacts