ENERGY 

EFFICIENCY

Better Coordination 

among Federal 

Programs Needed to 

Allocate Testing 

Resources

Report to the Committee on Energy and 

Natural Resources, U.S. Senate

March 2013

GAO-13-135

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-135, a report to the 

Committee on Energy and Natural Resources, 

U.S. Senate

March 2013

ENERGY EFFICIENCY

Better Coordination among Federal Programs 

Needed to Allocate Testing Resources

Why GAO Did This Study

The federal government has 

established three key programs to 

encourage energy efficiency in 

household appliances and consumer 

electronics sold in the United States: 

(1) federal minimum efficiency 

standards, led by DOE; (2) 

EnergyGuide, which requires product 

labeling and is led by the FTC; and (3) 

Energy Star, a voluntary labeling 

program led by EPA. 

Pub. L. No. 111-139 requires GAO to 

annually identify programs, agencies, 

offices, and initiatives with duplicative 

goals and activities. In response to this 

mandate, the objectives for this report 

are to: (1) examine these three 

programs’ approaches to improving the 

energy efficiency of household 

appliances and consumer electronics 

and the scope of products they cover, 

and (2) determine to what extent, if 

any, federal programs to foster energy 

efficiency for these products are 

fragmented, overlapping, or 

duplicative. GAO reviewed relevant 

legislation and program documents 

and spoke with staff at the agencies 

about each of the programs, and to 

stakeholders, including manufacturers.

What GAO Recommends

To limit the potential for duplication in 

the current Energy Star verification 

testing activities, GAO recommends 

that EPA take steps to better 

communicate to DOE the models 

selected for testing so DOE can avoid 

testing the same ones. DOE and EPA 

acknowledged the importance of 

coordination, but EPA disagreed with 

the draft recommendation, citing 

concerns it could be labor intensive to 

implement. GAO revised the 

recommendation to clarify EPA’s 

flexibility in implementing it.

What GAO Found

The three key federal energy efficiency programs––minimum energy efficiency 

standards led by the Department of Energy (DOE), EnergyGuide led by the 

Federal Trade Commission (FTC), and Energy Star led by the Environmental 

Protection Agency (EPA) with support from DOE—take different approaches to 

the shared goal of improving the energy efficiency of selected categories of 

household appliances and consumer electronics. The scope of products covered 

by these three programs also varies, and a number of products are covered by 

only one program, while others are covered by two or all three. Examples are as 

follows:

• Minimum energy efficiency standards establish a national minimum level of 

energy efficiency for selected categories of products and are designed to

eliminate the least efficient products from the marketplace. These standards 

currently apply to 33 categories of products, including refrigerators and 

dishwashers.

• EnergyGuide provides information displayed on a label attached to selected 

products that enables consumers to compare the estimated energy cost and 

energy consumption of different models within a given product category. 

EnergyGuide covers 16 such product categories, including televisions and 

dishwashers. 

• Energy Star identifies the most energy efficient models within a given 

category of products. Manufacturers of qualifying products can display an 

Energy Star label on their products that is widely recognized by buyers as an 

indication of energy efficiency. The program also encourages manufacturers 

to improve energy efficiency of some models so that those models qualify for 

the Energy Star label. Energy Star covers 37 such product categories, 

including televisions and washing machines. 

Federal programs to increase the energy efficiency of household appliances and 

consumer electronics are fragmented and overlapping, with one area of 

duplication. The programs are fragmented in that three federal agencies are 

addressing the same broad area of national need––improving energy efficiency. 

The programs are overlapping in that they target similar users—consumers. 

While fragmentation and overlap may result in duplication of resources, GAO 

found that these three programs are not broadly duplicative because they are not 

engaged in the same activities and do not provide the same services; however, 

GAO identified one duplicative activity within Energy Star. Specifically, GAO 

identified duplication in some testing activities undertaken to verify that products 

meet the criteria for carrying the Energy Star label. EPA and DOE each manage 

separate verification testing programs and, while the agencies coordinate to 

minimize duplication, GAO found 11 instances in which identical models had 

been tested twice in the same year—about 1 percent of the products tested. 

This duplication occurred because EPA does not communicate to DOE about 

some models that have been selected for testing until after the tests are 

complete; therefore, some models were tested twice while other models went 

untested. As a result, the agencies cannot ensure that scarce testing resources 

are maximized, either by eliminating unnecessary duplicative testing, or 

reallocating resources toward testing additional products.

View GAO-13-135. For more information, 

contact Frank Rusco at (202) 512-3841 or 

ruscof@gao.gov.
Page i GAO-13-135 Federal Energy Efficiency Programs

Letter 1 

Three Federal Programs Take Different Approaches to the Shared 

Goal of Improving Energy Efficiency and the Scope of Covered 

Products Varies 4

Federal Energy Efficiency Programs Are Fragmented and Overlap 

and Have One Area of Duplication 11

Conclusions 15

Recommendation for Executive Action 15

Agency Comments and Our Evaluation 15

Appendix I Comments from the Department of Energy 17

Appendix II Comments from the Environmental Protection Agency 19

Appendix III GAO Contact and Staff Acknowledgments 21

Figures

Figure 1: Information Three Key Federal Energy Efficiency 

Programs Provide to Consumers 7

Figure 2: Three Key Federal Energy Efficiency Programs’ Scope of 

Coverage Varies 9

Contents 
Page ii GAO-13-135 Federal Energy Efficiency Programs

Abbreviations

DOE Department of Energy

EIA Energy Information Administration

EPA Environmental Protection Agency

EPCA Energy Policy and Conservation Act of 1975

FTC Federal Trade Commission

kWh kilowatt-hour

MOU Memorandum of Understanding

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

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necessary if you wish to reproduce this material separately.
Page 1 GAO-13-135 Federal Energy Efficiency Programs

United States Government Accountability Office

Washington, DC 20548

March 28, 2013

The Honorable Ron Wyden

Chairman

The Honorable Lisa Murkowski

Ranking Member

Committee on Energy and Natural Resources

United States Senate

According to data from the Energy Information Administration (EIA),1

American households spent a total of nearly $230 billion on home energy 

expenditures in 2009––an average of about $2,024 per household. 

Energy to power household appliances––such as heating and cooling 

systems—and consumer electronics––such as televisions––represents a 

large portion of these expenditures. Increases in energy prices, paired 

with current economic conditions, have heightened consumers’ interest in 

making their households more energy efficient and reducing their energy 

consumption. In addition, most energy production results in the emission 

of pollutants and greenhouse gases such as carbon dioxide, which has 

been linked to global warming. As a result, reducing the consumption of 

energy can reduce the pollutants and greenhouse gases that are 

released into the environment.

The federal government has established the following three key programs 

to encourage energy efficiency in household appliances and consumer 

electronics, and to inform consumers about these products’ energy 

consumption:

1. The federal minimum efficiency standards program requires that 

certain products, such as residential appliances, commercial 

equipment, and lighting products, meet specified energy efficiency 

standards before they can be sold in the United States. The minimum 

efficiency standards were created under the Energy Policy and 

Conservation Act of 1975 (EPCA) to, among other things, encourage 

national energy conservation and increase energy efficiency.2 The 

 

1 EIA is a statistical agency within the Department of Energy that collects, analyzes, and 

disseminates independent information on energy issues.

2 Pub. L. No. 94-163, Title III, Part B, 89 Stat.871, 917-932 (1994), (codified as amended 

at 42 U.S.C. §§ 6291-6309).

 
 

Page 2 GAO-13-135 Federal Energy Efficiency Programs

U.S. Department of Energy (DOE) is responsible for establishing 

these standards and periodically revising them to achieve the 

maximum level of energy efficiency that is technically feasible and 

economically justified.

2. The EnergyGuide program requires manufacturers to label and clearly 

display the energy consumption and approximate annual energy costs 

of certain products. EnergyGuide was also created under EPCA. It is 

administered by the Federal Trade Commission (FTC) with assistance 

from DOE.3

3. The Energy Star program provides a way for manufacturers to help 

consumers identify, through the use of the distinctive blue Energy Star 

label, appliances and other products that deliver the same or better 

performance as comparable models while using less energy.

Participation in the program is voluntary. Energy Star was initiated in 

response to the Clean Air Act Amendments of 19904 and the Energy 

Policy Act of 19925 and, for many years, was jointly administered by 

the Environmental Protection Agency (EPA) and DOE. In 2009, the 

agencies signed an agreement making EPA the lead manager for the 

program and DOE the lead agency for developing testing procedures 

to verify that products meet Energy Star specifications.

GAO is required to conduct routine investigations to identify programs, 

agencies, offices, and initiatives with duplicative goals and activities within 

departments and governmentwide and report annually to Congress in 

accordance with Section 21 of Pub. L. No. 111-139. For the purposes of 

this report,

• fragmentation occurs when more than one federal agency, or more 

than one organization within an agency, is involved in the same broad 

area of national need;

• overlap occurs when programs have similar goals, devise similar 

strategies and activities to achieve those goals, or target similar users; 

and

 

3 Pub. L. No. 94-163, Title III, Part B, 89 Stat.871, 917-932 (1994), (codified as amended 

at 42 U.S.C. §§ 6291-6309).

4 Pub. L. No. 101-549, 104 Stat. 2399 (1990), (codified as amended at 42 U.S.C. §§ 7401-

7700).

5 Pub. L. No. 102-486, 106 Stat. 2776 (1992).
 

Page 3 GAO-13-135 Federal Energy Efficiency Programs

• duplication occurs when two or more agencies or programs engage in 

the same activities or provide the same services to the same 

beneficiaries.

As part of the work undertaken in response to this mandate, we identified 

these three federal energy efficiency programs as possible areas of 

fragmentation, overlap, or duplication. Our objectives for this report were 

to: (1) examine these three programs’ approaches to improving the 

energy efficiency of household appliances and consumer electronics and 

the scope of products they cover and (2) determine to what extent, if any, 

federal programs to foster energy efficiency in home appliances and 

consumer electronics are fragmented, overlapping, or duplicative.

To examine these three programs and the scope of products they cover, 

we reviewed relevant laws, regulations and agreements that specify the 

responsibilities and roles of each agency, including the 2009 

Memorandum of Understanding (MOU) between DOE and EPA. We also 

spoke with officials from each agency. For purposes of this report, we 

identified the number of product categories covered by each program 

slightly differently than each of the agencies overseeing them. There are 

three reasons why our categories and the agencies’ categories differ. 

First, we limited our scope to product categories of household appliances 

or consumer electronics and did not include commercial or industrial 

products. Second, we omitted product categories the agencies evaluate 

based only on water, rather than energy, use. Finally, because each 

agency uses different levels of specificity to describe product categories, 

we consolidated some categories into a larger, more inclusive category to 

allow us to compare across the agencies. For example, minimum 

standards cover many subcategories of incandescent lamps, and we 

generalized these products into one product category.

To determine the extent to which these three programs may be 

fragmented, overlapping, or duplicative, we examined agency 

documentation that sets forth the scope and purpose of each of these 

programs and compared the product categories covered by each of the 

three programs. In addition, we reviewed relevant laws such as the 

Energy Policy and Conservation Act of 1975, the Clean Air Act, the 

Energy Policy Act of 1992, and the Energy Policy Act of 2005, as well as 

DOE regulations that establish testing procedures for covered products.

The scope of our work included only household appliances and consumer 

electronics. We omitted products covered by these three programs that 

were primarily commercial, industrial, or building products. Additionally, 

we did not explore products such as urinals and showerheads that are 
 

Page 4 GAO-13-135 Federal Energy Efficiency Programs

covered by DOE’s minimum standards programs but only in terms of 

water use. Furthermore, for other products such as washing machines for 

which both energy and water efficiency is regulated, we considered only 

the energy efficiency component. We also reviewed the 2009 MOU 

between DOE and EPA regarding their joint administration of the Energy 

Star program. We spoke with officials from DOE, EPA, and FTC, as well 

as nonprofit and private sector stakeholders such as representatives from 

the American Council for an Energy-Efficient Economy and the Alliance to 

Save Energy. We also spoke with representatives from the private sector 

such as corporations that produce the household appliances and 

consumer electronics that must adhere to program guidelines.

We conducted this performance audit from February 2012 to March 2013 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

The three key federal energy efficiency programs we reviewed––

minimum energy efficiency standards, EnergyGuide, and Energy Star—

take different approaches to the shared goal of improving energy 

efficiency of selected categories of household appliances and consumer 

electronics. The scope of products that these three programs cover also 

varies.

The three key federal energy efficiency programs we reviewed take 

different approaches to improving energy efficiency as follows:

Federal minimum efficiency standards. Federal minimum efficiency 

standards for selected categories of household appliances and consumer 

electronics, among other things, are designed to eliminate the least 

efficient products from the market. Under EPCA, Congress required DOE 

to set minimum energy efficiency standards for manufacturers of specified 

categories of consumer products such as refrigerators, dishwashers, 

Three Federal 

Programs Take 

Different Approaches 

to the Shared Goal of 

Improving Energy 

Efficiency and the 

Scope of Covered 

Products Varies

Programs Take Different 

Approaches 
 

Page 5 GAO-13-135 Federal Energy Efficiency Programs

furnaces, and hot water heaters. Congress later amended the statute to 

include additional consumer product categories, as well as other 

categories.6 Manufacturers’ compliance with the standards is mandatory. 

The statute requires DOE to set and revise standards through the federal 

rulemaking process. This process calls for analyzing the technical and 

economic issues associated with setting energy efficiency standards for 

each category, proposing a standard through public notification, soliciting 

comments on the standard, revising the rule, and issuing the final rule. 

Most of the categories with deadlines require at least two rules—either to 

set an initial standard and later update it, or to update a congressionally 

set standard and then update it again about 5 years after the first 

deadline. DOE estimates that, from the inception of the federal minimum 

efficiency standards program in 1975 through 2005, consumer benefits 

from these standards amounted to about $64 billion. DOE projects that 

the standards will have saved consumers $241 billion by 2030 and $269 

billion by 2045.

EnergyGuide. EnergyGuide is designed to provide information displayed 

on a label attached to selected products that enables consumers to 

compare the estimated energy cost and energy consumption of different 

models within a given product category. EnergyGuide’s familiar yellow 

label has aided consumers for over 30 years in selecting household 

appliances and consumer electronics such as televisions and 

dishwashers by providing information on how much it will cost to run 

particular models per year and their level of energy consumption.7 EPCA 

requires DOE, in consultation with FTC, to study new product categories 

to determine whether they should be added to the EnergyGuide program 

 

6 The Energy Policy and Conservation Act of 1975, Pub. L. No. 94-163; as amended by 

the National Energy Conservation Policy Act, Pub. L. No. 95-619; the National Appliance 

Energy Conservation Act, Pub. L. No. 100-12 (1987); the National Appliance Energy 

Conservation Amendments of 1988, Pub. L. No. 100-357 (1988); the Energy Policy Act of 

1992, Pub. L. No. 102-486 (1992); the Energy Policy Act of 2005, Pub. L. No. 109-58 

(2005); and the Energy Independence and Security Act of 2007, Pub. L. No. 110-140. 

7 The law prohibits retailers from removing labels placed by manufacturers or making 

them illegible. In recent years, manufacturers have used adhesive backed labels adhered 

to appliances and so-called “hang tags” loosely attached to the interior or exterior of

appliances. The law also requires retailers to provide this information in catalogs offering 

products for sale. In 2000, FTC interpreted its authority over catalogs to encompass 

websites and required retailers to provide the same information on websites where 

consumers may purchase such products. In its August 2007 revisions to the rule, FTC, 

among other things, prohibited the use of hang tags on the exterior of appliances but 

continues to allow them on the inside.
 

Page 6 GAO-13-135 Federal Energy Efficiency Programs

and to report annually on the energy savings of the program. 

Manufacturers’ compliance with the standards is mandatory. FTC has the 

authority to add additional product categories if the commission 

determines that labeling for the product is likely to assist consumers in 

making purchasing decisions. The statute requires FTC to set and revise 

standards through the federal rulemaking process.

Energy Star. Energy Star is designed to identify the most energy efficient 

models––generally the top 25 percent–– within a given category of 

products without sacrificing performance. Manufacturers of qualified 

products can place the widely recognized Energy Star label on qualifying 

products as an indication of energy efficiency, which gives the 

manufacturer an incentive to improve energy efficiency. Participation is 

voluntary. EPA has reported that the additional incentive the Energy Star 

program provides as a marketing tool for manufacturers encourages 

efficiency beyond the level of federal minimum efficiency standards, 

further reducing energy consumption and the associated greenhouse gas 

emissions. According to EPA, as of 2012, Energy Star products had 

prevented more than 150 million metric tons of greenhouse gas 

emissions annually and reduced electricity consumption by more than 

200 billion kilowatt-hours (kWh) per year––a savings that offsets the need 

for more than 185 additional power plants.

Figure 1 provides an example of the different types of information 

conveyed to consumers for household appliances and consumer 

electronics by each of the three programs. Specifically, the figure 

illustrates a hypothetical case of two models of dishwasher, a product 

covered by all three programs. In the example, both dishwashers meet 

the federal minimum efficiency standards. However, the model on the left 

side of the figure qualifies for an Energy Star label––as noted by the 

Energy Star logo on the lower right corner of the Energy Guide label for 

that product––while the model on the right does not. The manufacturers 

of both models also publish an EnergyGuide label as shown in the figure 

and are compliant with the federal minimum energy efficiency standard.
 

Page 7 GAO-13-135 Federal Energy Efficiency Programs

Figure 1: Information Three Key Federal Energy Efficiency Programs Provide to Consumers

a

DOE has revised the standard for dishwashers to a maximum of 307 kWh/year; however, 

compliance with this standard is not required until May 30, 2013.

In 2011, the most recent year for which data are available, DOE’s budget 

for these programs was $42 million; EPA’s was $53.3 million; and FTC 
 

Page 8 GAO-13-135 Federal Energy Efficiency Programs

officials estimated that FTC spent about $215,000,8 for a total of about

$96 million to administer these programs.

The scope of products that the three federal energy efficiency programs 

cover varies. 9 Specifically,

• the minimum efficiency standards currently apply to 33 selected 

categories of household appliances and consumer electronics;

• EnergyGuide currently covers 16 such product categories; and

• Energy Star program––the broadest of the three programs––currently 

covers 37 such product categories.

Our analysis found that some products are covered by only one program, 

some by two programs, and some by all three. For example, of the 37 

product categories covered by Energy Star, 21 are covered only by 

Energy Star, 3 are covered by Energy Star and the federal minimum 

efficiency standards, and the remaining 13 are covered by all three 

programs. Figure 2 illustrates the coverage of product categories and the 

extent to which products are covered by one, two, or all three programs.

 

8 FTC officials told us they do not maintain separate line item budget data for its 

EnergyGuide activities but, at our request, the agency estimated its spending for fiscal 

year 2011. 

9 The number of product categories we identified differs slightly from the number of 

product categories each agency identifies as noted previously. 

The Scope of Products 

Covered Varies
 

Page 9 GAO-13-135 Federal Energy Efficiency Programs

Figure 2: Three Key Federal Energy Efficiency Programs’ Scope of Coverage Varies

Note: Because each agency uses different levels of specificity to describe product categories, we 

consolidated some categories into a larger, more inclusive category to allow us to compare across 

the agencies; therefore, the number of product categories we identify differs slightly from the number 

of product categories each agency identifies.

The three agencies have had varying histories expanding the product 

categories covered by each program, specifically, as follows:

• DOE has had a limited role in expanding the products covered by the 

minimum energy efficiency standards; rather, Congress has directed 

DOE to expand the products covered. The program has set standards 

for products such as clothes dryers and furnaces since the 1980s, and 

it has been expanded to include products such as ceiling fans and 

dehumidifiers. The scope of product categories covered under the 
 

Page 10 GAO-13-135 Federal Energy Efficiency Programs

federal minimum efficiency standards has largely been determined by 

statute and, while DOE has the authority to expand the scope of the 

program by adding new product categories and update standards for 

existing categories, it must go through a rulemaking process to do so. 

In 2007, we reported that DOE had faced difficulties meeting statutory 

deadlines for issuing standards, but it has recently made progress in 

improving its timeliness. 10

• FTC officials told us seven products have been added to EnergyGuide 

since 1980––including fluorescent lamps in the 1990s, ceiling fans in 

2007, and color televisions in 2011.11 In 2007 we noted, among other 

things, that DOE, in consultation with FTC, is required to study new 

products to determine if any products should be added to 

EnergyGuide.12 At that time, however, DOE staff could not identify any 

instance of such a study, and they told us that they had not completed 

one during the prior 10 years. We recommended that DOE, in 

consultation with FTC, regularly review product categories not 

currently covered to assess whether they should be included in the 

 

10 In January 2007, we reported that DOE had missed all 34 of the deadlines for 

rulemaking that had come due for the 20 product categories with deadlines that had 

passed. In addition, it had not revised standards for categories that had no deadlines but 

for which DOE is obligated to issue new rules. We recommended at that time that DOE 

take prudent steps to expedite its processes and, since then, DOE has sharply decreased 

the time to issue new rules. See GAO, Energy Efficiency: Long-standing Problems with 

DOE’s Program for Setting Efficiency Standards Continue to Result in Forgone Energy 

Savings, GAO-07-42 (Washington, D.C: Jan. 31, 2007).

11 Prior to 2007, FTC had limited authority to add products to EnergyGuide. In late 2007, 

Congress amended EPCA (42 U.S.C. §6294) to authorize the commission to prescribe 

labels for televisions and certain other consumer electronics, subject to specific 

provisions. 42 U.S.C. §6294(a)(2)(I). If DOE publishes applicable test procedures for 

those specified consumer electronics, the commission must issue disclosure requirements 

within 18 months of DOE’s publication. Absent those procedures, the EPCA amendments 

give the commission discretion to require disclosures if it identifies adequate non-DOE 

testing procedures and finds that disclosures will likely assist consumers in making 

purchasing decisions. Regardless of whether DOE test procedures exist, the commission

cannot require disclosures if those disclosures are not technically or economically 

feasible. 42 U.S.C. §6294(a)(2)(I)(iv). The amended law empowers the commission to 

consider other types of energy disclosures in lieu of traditional product labels for these 

consumer electronics. 42 U.S.C. §6294(a)(2)(I)(i). Finally, the amendments provide the 

commission with authority to require labeling or other disclosures for any other consumer 

product if the FTC determines such labeling is likely to assist consumers in making 

purchasing decisions. 

12 GAO, Energy Efficiency: Opportunities Exist for Federal Agencies to Better Inform 

Household Consumers, GAO-07-1162 (Washington, D.C.: Sept. 26, 2007).
 

Page 11 GAO-13-135 Federal Energy Efficiency Programs

EnergyGuide program. DOE and FTC took steps to implement this 

recommendation, including defining certain terms that would provide a 

basis for expanding product categories in the future. In addition, 

during the course of our current work, officials from FTC told us they 

take steps to consider new products, including soliciting suggestions 

from stakeholders during the rulemaking process, accepting petitions 

from interested parties, and coordinating with DOE and Energy Star 

officials. While FTC has not added any new products since 2011, 

officials told us that they routinely consider new product categories.

For example, the agency considered requiring an EnergyGuide label 

for personal computers but determined that variations in the 

components used to assemble computers and the lack of a standard 

testing procedure were barriers. Like the federal minimum efficiency 

standards, the scope of product categories covered under 

EnergyGuide has largely been determined by statute, and FTC must 

go through a rulemaking process to expand the scope of the program.

• EPA has expanded Energy Star from its initial coverage of computers 

and monitors to include many more product categories. For example, 

it added new products, such as residential heating and cooling 

equipment, then continued to add product categories through the 

1990s and 2000s—for example, clothes washers in 1997, ceiling fans 

in 2001, and water heaters in 2009—so that Energy Star now includes 

37 household appliance and consumer electronic product categories.

Because Energy Star is a voluntary program that does not engage in 

the same formal rulemaking process as the other two programs, it can 

add product categories more easily and has added many product 

categories.13

Federal programs to increase the energy efficiency of household 

appliances and consumer electronics are fragmented because more than 

one federal agency is involved in the same broad area of national need; 

they overlap because the three programs have similar goals and target 

similar users. The programs are not broadly duplicative because they are 

not engaged in the same activities and do not provide the same services, 

and the agencies coordinate on key decisions related to meeting their 

 

13 According to EPA documents, Energy Star product categories can be added where 

standards contribute to significant energy savings for products that fit consumer needs 

and are cost-effective over “a reasonable period of time.” 

Federal Energy 

Efficiency Programs 

Are Fragmented and 

Overlap and Have One 

Area of Duplication
 

Page 12 GAO-13-135 Federal Energy Efficiency Programs

common overarching goal of improving energy efficiency. However, we 

identified one duplicative activity within Energy Star program.

Fragmentation. Federal programs to improve energy efficiency for 

household appliances and consumer electronics are fragmented because 

three federal agencies are addressing the same broad area of national 

need—in this case, improving energy efficiency. In March 2011, we 

reported that fragmentation has the potential to result in duplication of 

resources.14 For example, fragmentation can lead to technical or 

administrative functions that could be shared among programs instead 

being managed separately by each agency. However, we have also 

reported that fragmentation is, by itself, not an indication that 

unnecessary duplication of efforts or activities exists. In the case of these 

three programs, each agency collects its own data on the products 

covered by its program,15 but we did not find evidence that the 

independent data collected by each agency adversely impact the 

effectiveness of these programs. Moreover, agency officials told us they 

are working to share data with one another. For example, FTC officials 

told us that they are formally working with DOE officials through the 

rulemaking process to create a single database that manufacturers will 

use to submit the information required for both agencies.

Overlap. Federal programs to foster energy efficiency for household 

appliances and consumer electronics overlap because the three 

programs have the shared goal of encouraging energy efficiency of 

household appliances and consumer electronics and target similar users, 

namely consumers of these products. However, we have reported in the 

past that overlapping programs may be aligned in a way that they are 

complementary. In the case of these three programs, we found that their 

differing approaches may have complementary functions—with the 

minimum efficiency standards setting a minimum level of efficiency for all 

products in a category, EnergyGuide providing specific information about 

estimated energy consumption and costs to help consumers select the 

product that best meets their need within this range, and Energy Star 

 

14 GAO, Opportunities to Reduce Potential Duplication in Government Programs, Save 

Tax Dollars, and Enhance Revenue, GAO-11-318SP (Washington, D.C.: Mar. 1, 2011).

15 For instance, each agency collects data on the annual energy use of refrigerators in 

terms of kWh per year.
 

Page 13 GAO-13-135 Federal Energy Efficiency Programs

identifying a group of the most energy efficient models––generally the top 

25 percent–– within a given category of products.

Duplication: The efforts of the three programs to improve energy 

efficiency for home appliances and consumer electronics are not broadly 

duplicative in that they are not engaged in the same activities or providing 

the same services; however, we identified one duplicative activity within 

the testing activities undertaken to support the Energy Star program. EPA 

officials told us that two levels of testing occur within the Energy Star 

program––qualification testing to determine if a product is eligible to 

display the Energy Star label and verification testing to confirm that 

products using the Energy Star label in the marketplace continue to meet 

Energy Star specifications. We identified some duplication in the 

verification testing activities. Specifically, DOE and EPA have separate 

verification testing efforts that, in themselves, are not duplicative, but we 

found some instances in which both agencies tested identical product 

models in the same year.

• DOE’s Energy Star verification testing activities were initiated in 2010 

and are funded and managed by the department, though the actual 

testing occurs at third-party laboratories. According to DOE officials, 

every 4 to 6 months, DOE typically selects for testing from 100 to 200 

different models across various product categories including 

household appliances and consumer electronics. DOE tests only 

Energy Star products that are also subject to federal minimum 

efficiency standards, allowing the agency to monitor compliance with 

both programs.

• EPA’s Energy Star verification testing activities were initiated in 2011 

and are funded by the program’s partners––primarily appliance and 

electronics manufacturers. The testing is conducted at EPArecognized laboratories, and the results are verified by EPArecognized certification bodies.16 At a minimum, EPA requires that the 

 

16 In 2010, EPA developed and instituted new testing procedures for products to qualify 

for Energy Star recognition. Under these procedures, there are EPA-recognized test 

laboratories and certification bodies that manage a manufacturer’s involvement in the 

program. All manufacturers that want to participate in the Energy Star program must have 

their products tested at EPA-recognized laboratories, and the results of these tests must 

be certified by an EPA-recognized certification body. According to EPA officials, this 

structure largely removes EPA from the testing and certification process, and installs it in 

more of an oversight and brand-management role. The new procedures took effect in 

January 2011.
 

Page 14 GAO-13-135 Federal Energy Efficiency Programs

certification bodies test 10 percent of the models within a product 

category each year (e.g., 10 percent of all computers) from all product 

categories for which they have certified results. EPA officials told us 

they select half of the models tested based on an approximation of 

which products are the highest selling. The certification bodies select 

the other half at random from among the products they have certified.

Officials from both DOE and EPA told us that they work closely to 

coordinate their efforts; however, we examined DOE and EPA verification 

testing data for a total of 1,238 tests during 2011 and a portion of 2012 

and found 11 instances–-about 1 percent of the products tested— in 

which identical models were tested in the same year under the testing 

done for EPA and DOE.17 In discussing this information with EPA and 

DOE officials, we determined that this duplication occurred because the 

two agencies do not fully coordinate and share information about the 

products they plan to test. In particular, EPA does not have information 

about the products its certification bodies select for testing; therefore, it 

cannot communicate this information to DOE before DOE selects 

products for testing. EPA officials told us that, in March 2012, they 

instituted a protocol through which they communicate to DOE twice yearly 

the results of the certification body testing to minimize the potential for 

duplication in their testing activities. EPA informs the certification bodies 

as to which products it has selected for testing, so no duplication should 

occur between the models EPA selects and the models the certification 

bodies select. However, the certification bodies do not inform EPA as to 

the models they select for testing until after that testing has taken place; 

therefore, EPA officials cannot share information with DOE about which 

models the certification bodies have tested until after the conclusion of 

the certification bodies’ testing. Without this information, DOE may 

continue to select the same models; therefore, some models may 

continue to be tested twice while other models go untested. As a result, 

the agencies cannot coordinate to ensure that scarce testing resources 

are maximized, either by eliminating unnecessary duplicative testing, or 

reallocating resources toward testing additional products.

 

17 DOE provided data on a total of 195 verification tests on household appliance or 

consumer electronics products––77 tests during 2011 and 118 tests as of January 2012. 

EPA’s verification testing data included a total of 1,043 verification tests that its recognized 

laboratories conducted on household appliance or consumer electronics products––686 

tests in 2011 and 357 as of June 2012.
 

Page 15 GAO-13-135 Federal Energy Efficiency Programs

Three key federal programs to foster energy efficiency in household 

appliances and consumer electronics––the federal minimum efficiency 

standards, the EnergyGuide product labeling program, and the Energy 

Star voluntary product labeling program––each perform valuable 

functions in improving energy efficiency. While these three programs are 

fragmented and overlap, the officials managing these programs have 

undertaken efforts to mitigate the potential consequences of 

fragmentation and overlap by collaborating to achieve their common 

overall goal of improving the energy efficiency of these products. Further, 

given the differing missions of the programs, we believe they are not 

broadly duplicative, and that the sum total of the three efforts provides 

more value than would any one of the three alone. Nonetheless, because 

EPA does not have timely information about the products that certification 

bodies have selected for testing, it cannot regularly communicate to DOE 

the models selected for testing to support the Energy Star program. As a 

result, the two agencies have tested identical models of some products in 

the same year. By not coordinating to identify and eliminate these 

duplicative activities, the agencies may be missing opportunities to better 

allocate testing resources, by either allowing more models to be tested or 

by simply eliminating unnecessary testing costs.

To limit the potential for duplication in the current Energy Star verification 

testing activities, we recommend that the Administrator of EPA develop a 

process that helps ensure that the Energy Star certification bodies 

communicate the models they randomly select for testing to EPA and 

DOE as quickly as possible so that DOE can avoid selecting the same 

models.

We provided a draft of this report to FTC, DOE, and EPA for comment. 

FTC provided no comments. We received written comments from DOE 

and EPA on the draft report, which are summarized below and 

reproduced in appendixes I and II, respectively. Both agencies 

acknowledged the importance of coordinating their verification testing 

activities. DOE neither agreed nor disagreed with our recommendation. 

EPA agreed with our findings but disagreed with our draft 

recommendation and stated that it was concerned that it would be labor 

intensive to collect information from the certification bodies. As an 

alternative to our recommendation, EPA proposed that it work with DOE

to develop a process to improve verification testing while minimizing 

burden but did not offer specific plans to better coordinate. We maintain 

that coordination must involve all of the entities charged with testing 

Conclusions 

Recommendation for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 16 GAO-13-135 Federal Energy Efficiency Programs

products, including the certification bodies. We modified the 

recommendation to clarify that EPA has flexibility to find an efficient 

process for the certification bodies to share the information. 

We are sending copies of this report to the Secretary of Energy, the 

Acting Administrator of the Environmental Protection Agency, the 

Chairman of the Federal Trade Commission, the appropriate 

congressional committees, and other interested parties. The report also is 

available at no charge on the GAO website at http://www.gao.gov. 

If you or your staff have questions about this report, please contact me at 

(202) 512-3841 or ruscof@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

listed in appendix III. 

Frank Rusco

Director, Natural Resources and Environment
Appendix I: Comments from the Department of 

Energy

Page 17 GAO-13-135 Federal Energy Efficiency Programs

Appendix I: Comments from the Department 

of Energy
Appendix I: Comments from the Department of 

Energy

Page 18 GAO-13-135 Federal Energy Efficiency Programs
Appendix II: Comments from the 

Environmental Protection Agency

Page 19 GAO-13-135 Federal Energy Efficiency Programs

Appendix II: Comments from the 

Environmental Protection Agency
Appendix II: Comments from the 

Environmental Protection Agency

Page 20 GAO-13-135 Federal Energy Efficiency Programs
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 21 GAO-13-135 Federal Energy Efficiency Programs

Franklin Rusco, (202) 512-3841 or ruscof@gao.gov

In addition to the individual named above, Jon Ludwigson, Assistant 

Director; Emily Norman; Alison O’Neill; Stuart Ryba; Karla Springer; and 

Barbara Timmerman made key contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(361390)
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