1

This is a draft document and does not represent a definitive view of the agency on the questions 

addressed.

This and other guidance documents are accessible on the U.S. Department of Energy, Energy Efficiency 

& Renewable Energy web site at: http://www1.eere.energy.gov/guidance/default.aspx?pid=2&spid=1.

Guidance Type: Certification and CCMS, Test Procedures, Enforcement, Definitions and Scope of 

Coverage

Category: Plumbing Products

Product: Faucets

Guidance Version: DRAFT

Issued: May 22, 2014

Comment Period Ends: June 23, 2014

The following is a draft U.S. Department of Energy (DOE or the Department) guidance document 

regarding the test procedure for faucets. This draft guidance document represents the Department’s 

interpretation of its existing regulations and is exempt from the notice and comment requirements of 

the Administrative Procedure Act. See 5 U.S.C. § 553(b)(A). Nonetheless, the Department is accepting 

comments and suggestions from the public until June 23, 2014. Comments and suggestions should be 

provided in WordPerfect, Microsoft Word, PDF, or text file format by sending an email to

FaucetGuidance2014GUID0023@ee.doe.gov. Please also include the docket number EERE-2014-BTGUID-0023. At the end of the comment period, this draft guidance document may be adopted, revised, 

or withdrawn.

Q: The third-party test laboratory that performs faucet testing for my company typically uses a 

standard faucet body (or other test device) containing the same flow-restricting device (such as an 

aerator or flow-restricting insert) used in all of my faucet designs. Does the test data obtained from 

this test fulfill the testing requirement for all of my faucet designs?

A. DOE requires that a manufacturer test each of its basic models of a covered product to determine its 

compliance prior to distribution in commerce of that covered product by the manufacturer. A basic 

model is defined in 10 CFR 430.2 as all units of a given type of covered product (or class thereof) 

manufactured by one manufacturer, having the same primary energy source, and which have essentially 

identical electrical, physical, and functional (or hydraulic) characteristics that affect energy consumption, 

energy efficiency, water consumption, or water efficiency; and, with respect to faucets, have similar

flow control mechanism attached to or installed within the fixture fittings, or similar water-passage 

design features that use the same path of water in the highest flow mode. A manufacturer, however,

may group all individual models that contain a similar flow-restricting device into a single basic model so 

that only units of one basic model of faucet must be tested. See 10 C.F.R. §§ 429.11 and 429.28 and 10 

C.F.R. § 430.2 (basic model definition for faucets). 

Even if the flow-restricting device itself is solely responsible for determining the water consumption of a 

given model of faucet, because the covered product is the faucet and not the flow-restricting insert, a 

given faucet can only be defined as the same basic model as another if both faucets not only use a

similar flow-restricting insert, but are also manufactured by the same manufacturer. Thus, the use of a 

“standard” faucet body or other test device in a test does not constitute a test of a manufacturer’s basic 
2

model unless the “standard” faucet body was manufactured by the same manufacturer and otherwise 

conforms to the definition of a basic model.

This FAQ may also be of interest:

http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/replacement-aeratortests_faq_2014-05-22.pdf