Appliance efficiency standards are regulations that mandate a minimum level of efficiency or a maximum amount of energy or water use for various household and commercial appliances, such as refrigerators, dishwashers, or laundry machines. Robust appliance efficiency standards, at both the federal and state levels, have an important role to play in the push toward a decarbonized future. At 2050 Partners, we understand that codes and standards are among the most cost-effective tools available to reduce greenhouse gas emissions, lower energy bills, and bolster grid resilience. 

Federal appliance standards cover many types of products and equipment, but states still play a large role in pushing appliance efficiency forward. In this three-part blog series, we will explore the past, present, and future of state appliance efficiency standards. This first installment dives into the history of state appliance efficiency standards, beginning with their roots in the 1970s. 

In the early 1970s, as California’s electric utilities were warning state legislators of an impending energy crisis, the Rand Corporation was contracted by the California State Assembly to evaluate California’s electrical grid and the anticipated crisis. Their final report, shared in 1973, concluded that California’s energy demand was growing so quickly that the state would need to double its electricity production every ten years to avoid blackouts.

 “If (as preferred by the utility companies) all new plants were to be placed on the coastline where ocean waters could be used cheaply for cooling, then by the year 2000 there would be 1200-MW power plants (nuclear or fossil-fuel) spaced every 8 miles, on the average, along the entire coastline.”
– Doctor, R.D., et al. 

Charles Warren, then a member of California’s assembly, acted immediately and initiated a series of hearings based on the findings in the Rand report. The hearings resulted in California’s Warren-Alquist State Energy Resources Conservation and Development Act (usually simplified to just “Warren-Alquist Act”), California Public Resources Code, section 25000 et seq. This landmark legislation, taking effect in 1975, established the California Energy Commission (CEC) to create state energy policy for forecasting energy consumption, siting new generation, and slowing the growth of energy demand. This legislation included the authority to set what would become the nation’s first energy efficiency standards for buildings and appliances. 

In 1977, the CEC adopted the first energy efficiency standards for appliances and equipment sold or offered for sale in California into Title 20 of the California Code of Regulations (The term “Title 20” is often used in the efficiency community as shorthand for California’s appliance standards). These early standards targeted common household appliances such as refrigerators, air conditioners, and water heaters. These standards not only improved appliance performance but also spurred technological innovation and set the stage for broader policy adoption at the federal level. 

Over the years, California continued to expand the scope of products with appliance standards and to revisit standards to achieve additional efficiency. Today, Title 20 includes efficiency requirements for a wide range of appliances, from computers to lighting products to commercial kitchen equipment. As we will discuss in more detail in the next installment of this series, the standards are updated periodically through a public rulemaking process, incorporating new technologies and market developments to ensure continued energy savings and emissions reductions. 

While California was leading the way at the state level, the federal government also began to take action to promote energy conservation. The Energy Policy and Conservation Act (EPCA) of 1975 established a national appliance efficiency program consisting of test procedures, energy labeling, and voluntary energy efficiency targets for consumer products. Although EPCA’s early efforts were largely voluntary, the act signaled growing recognition of the role that appliance efficiency could play in national energy policy. It also created the foundation for future mandatory standards, paving the way for more comprehensive legislation in the coming years. 

In response to California’s leadership and growing interest among other states, Congress passed the National Appliance Energy Conservation Act (NAECA) in 1987. This law established the first federal minimum efficiency standards for many household appliances, authorized the Department of Energy to update and enforce those standards, and preempted states from setting their own standards for covered products, with certain exceptions. Preemption ensures that all states benefit from minimum efficiency standards and avoids a patchwork of state standards that manufacturers were concerned would raise costs and complicate compliance. It also binds the country to an often slow and politically influenced process to update and add new standards and prevents states from adopting more stringent standards. The preemptive effect of federal standards remains a challenge for states considering implementing their own appliance standards programs. 

State standards play a key role both in meeting a state’s own climate and energy goals and in driving improvements to federal standards. States often serve as policy incubators, demonstrating the viability and benefits of new or amended standards for products not covered by federal rules. The ongoing threat of a patchwork of state standards continues to drive Congress and DOE to improve the federal appliance standards program, and many standards adopted by states since 2001 have subsequently been enacted federally. 

In fact, as a testament to the positive impacts of state and federal efficiency standards, a 2014 report from the Appliance Standards Awareness Project (ASAP) demonstrated that, between 1987 and 2010, household refrigerator prices declined by 35%, even as features were continually added and annual energy use dropped by 50%. 

While California blazed the trail, several other states played key roles in the evolution of appliance standards. Most other states adopted appliance standards through a legislative rather than administrative process. New York was among the first to follow California’s lead in the 1980s, adopting its own set of appliance standards that would later expand to include products not yet regulated federally. Massachusetts emerged as a policy innovator in the 2000s, pioneering state-level standards and contributing to regional efforts aimed at harmonizing policies across the Northeast. 

Additionally, national advocacy groups like ASAP analyzed and prepared “model standards” for appliances that states could adopt through legislation. Several states, including Oregon, Maryland, and New Hampshire, adopted these model standards in whole or in part. 

In the early 2000s, states including California, New York, and Massachusetts began adopting standards for products not yet covered by federal regulation, such as commercial ice makers, DVD players, and walk-in refrigerators. These efforts provided leverage for efficiency advocates to negotiate updates to federal legislation to expand the scope of DOE’s authority to adopt new standards, proving the complementary nature of state and federal roles in advancing energy efficiency standards. State standards have also encouraged further development of new technologies, such as in the case of California’s LED and Small Diameter Directional Lamps requirements, which went into effect in 2018 and pushed the market to develop high-quality LED lamps that would meet consumer expectations and support the phase out of legacy incandescent technology. 

Also in the early 2000s, California adopted a “backstop” standard by incorporating all then-effective federal standards and requiring them to take effect if federal standards were repealed. These “backstop” standards ensure that existing federal standards will remain in effect in the state. The Ninth Circuit Court of Appeals confirmed that the enforcement mechanisms necessary for these backstop standards – disclosure to the agency of test results and marking of appliances with manufacturer name and date of manufacture – are not preempted by federal law (Air Conditioning and Refrigeration Institute (ARI) vs CEC). Other states, such as Oregon and Hawaii, have since followed California’s lead in establishing backstops to federal standards. 

However, progress on state appliance standards has not always been straightforward. Beginning in 2002, CEC was involved in a long-standing and ultimately unsuccessful effort to obtain a waiver from federal preemption to establish its own state water-efficiency standards for residential clothes washers. Similarly, in 2009, Massachusetts submitted a petition for exemption from federal preemption so it could set its own fuel utilization efficiency standards for non-weatherized gas furnaces. DOE denied both waiver requests (unlawfully in California’s case), establishing a high bar for states to use the waiver pathway to set unique state standards for federally regulated appliances. 

With the likelihood of stalled progress on federal appliance standards over the next four years, state leadership is more vital than ever. States have the authority, the precedent, and the public support to enact and enforce standards that reduce energy use and promote sustainability. 

In our next post, we will explore the current status of state appliance standards – which states are leading, what products are being targeted, and how these policies are delivering measurable benefits. Then, in the third and final post, we will provide a roadmap for states that want to expand appliance standards programs or implement them for the first time. Stay tuned as we continue this important conversation. 

At 2050 Partners, we are committed to helping our clients leverage energy efficiency standards, building energy codes, and innovative policy strategies to drive decarbonization and energy equity. To learn more about our work and how we can support your organization, please contact us today.