DOE Adopts Environmentalist-Recommended Energy Efficiency Guidelines for Refrigerators

On January 17, 2024, the Department of Energy (DOE) issued a paired direct final rule and notice of proposed rulemaking (NPRM) that adopt updated energy conservation standards for refrigerators and freezers. This rulemaking falls under the Energy Policy and Conservation Act (EPCA), which prescribes energy conservation standards for various consumer products and certain commercial and industrial equipment. EPCA requires DOE to periodically determine whether more stringent standards would be technologically feasible and economically justified, and would result in significant energy savings. The direct final rule and notice of proposed rulemaking propose the same set of standards; the direct final rule will go into effect on May 16, 2024, if not withdrawn in response to comments. If the direct final rule is withdrawn, DOE will proceed with the rulemaking process under the NPRM.

As part of this proposed rulemaking, DOE analyzed the benefits and burdens of 6 trial standard levels (TSLs) of efficiency. In the context of this rulemaking governing refrigerators and freezers, efficiency standards are expressed in terms of kilo-watt hours per year. The scenarios explored by DOE range from TSL 6, the maximum technologically feasible energy efficiency, which would require most products to contain vacuum-insulated panels and variable-speed compressors, to TSL 1, the least rigorous standard.

DOE's direct final rule adopts TSL 4, a standard that was recommended to DOE by the Association of Home Appliance Manufacturers and a coalition led by the Appliance Standards Awareness Project, which includes environmental organizations like Earthjustice and the National Resources Defense Council. This standard is expected to result in cumulative emission reductions (between 2029 and 2058) of 101 million metric tons of carbon dioxide,186 thousand tons of nitrogen oxides, 0.22 tons of mercury, and 846.5 thousand tons of tons of methane and 0.99 thousand tons of nitrous oxide.