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FREQUENTLY ASKED QUESTIONS – CERTIFICATION

CONSUMER PRODUCTS

UPDATED JANUARY 29, 2010 

Manufacturers and/or private labelers who have not submitted a certification report and 

compliance statement for the products identified in Question 1 are in violation of Federal 

regulations and are subject to enforcement, including civil penalties and injunctive action 

to prohibit distribution of covered products in commerce in the United States. You 

should submit the required documents immediately in order to limit potential civil 

penalties. 

The information provided below is intended to help companies understand their 

responsibilities under the energy efficiency/water conservation regulations, with respect 

to the requirement to certify compliance with the regulations. It is not intended to create 

or remove any rights or duties, nor is it intended to affect any other aspect of EPCA or 

DOE regulations. You should consult 10 CFR 430.62, and other sections cited below 

for complete information.

1) Who is required to submit a certification report and compliance statement?

 Which products are subject to these certification requirements?

 What is a manufacturer?

 What is a private labeler?

 Are fluorescent lamp ballasts subject to these reporting requirements?

2) What is the purpose of these reporting requirements?

3) What information is required to be included in the certification report?

4) What information is required to be included in the compliance statement? 

5) May I have a third party submit my certification report and compliance 

statement?

 I am a third party representative. What do I need to submit?

6) How do I submit the required information?

7) What if I have never filed a certification report or compliance statement?

8) Do international companies need to report?

9) I participate in the ENERGY STAR program. Do I still need to submit 

certification reports and compliance statements?

10) I manufacture/import/label general service fluorescent lamps and/ or 

incandescent reflector lamps. What information should I provide?

 Where can I get a list of NVLAP test laboratories?

 How do I certify new models since I do not have 12-month test data?

11) I heard manufacturers will be required to submit certification reports and 

compliance statements for products that had not been subject to the certification 

requirements before. Is that true?

 What additional consumer products will be subject to the certification 

requirements?

 When is my certification report and compliance statement due?

 What information must I submit?
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1) Who is required to submit a certification report and compliance statement? 

Both manufacturers and private labelers of some covered consumer products are required 

to submit certification reports and compliance statements. 

 Which products are subject to these certification requirements? 

(1) Central air conditioners 

(2) Central air conditioning heat pumps 

(3) Clothes washers 

(4) Clothes dryers 

(5) Direct heating equipment 

(6) Dishwashers 

(7) Faucets 

(8) Furnaces 

(9) General service fluorescent lamps 

(10) Incandescent reflector lamps 

(11) Pool heaters 

(12) Refrigerators, refrigerator-freezers, and freezers 

(13) Room air conditioners 

(14) Showerheads 

(15) Urinals 

(16) Water closets 

(17) Water heaters 

As of July 6, 2010: 

(18) Ceiling fans 

(19) Ceiling fan light kits with sockets for medium screw base lamps or pin-based 

fluorescent lamps 

(20) Ceiling fan light kits with sockets other than medium screw base lamps or 

pin-based fluorescent lamps 

(21) Compact fluorescent lamps (Medium base) 

(22) Dehumidifiers 

(23) External power supplies (Class A only), including switch-selectable singlevoltage voltage external power supplies 

(24) Torchieres 

 What is a manufacturer? 

For purposes of the certification requirements, any person who manufactures, 

produces, assembles, or imports a consumer product is a “manufacturer.” 

 What is a private labeler? 
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A “private labeler” is the owner of a brand or trademark on the label of a 

consumer product which bears a private label. A product is considered to “bear a 

private label” if the product or its container is labeled with the brand or trademark 

of a person other than the manufacturer and the manufacturer’s brand or 

trademark is not on the product or container. 

In other words, a private labeler is a company that sells consumer products under 

its name, but does not produce them. 

 Are fluorescent lamp ballasts subject to these reporting requirements? 

Fluorescent lamp ballasts are not currently subject to the reporting requirements. 

2) What is the purpose of these reporting requirements? 

A certification report provides information to DOE to help us verify a manufacturer’s (or 

private labeler’s) compliance with the applicable energy efficiency or water conservation 

standard and helps us develop information regarding the products in the marketplace. A 

manufacturer must provide a certification report for each basic model. A certification 

report should be filed every time a new basic model is introduced. In addition, a 

manufacturer is required to report when production of a basic model has ceased and is no 

longer being distributed. 

A compliance statement is the actual certification by the manufacturer or private labeler 

that its basic models comply with the applicable standards; that it performed the required 

testing in conformance with the specified testing procedures; that the information it 

reported in its certification report(s) is true, accurate and complete; and that it is aware of 

the penalties it faces for noncompliance and/or making false statements. 

3) What information is required to be included in the certification report? 

In general, the certification report must include, for each basic model: 

 the product type 

 the product class (please see 10 CFR 430.32 for more information on the product 

classes) – be sure product classes are identified exactly as specified in 430.32

 the manufacturer’s name 

 the private labeler’s name(s) (if applicable) 

 the manufacturer’s model number(s). 

In addition, each covered product requires specific additional information. Refer to 

10 CFR 430.62(a)(4)(i)-(xxii) for greater detail, including the form in which 

measurements should be presented. An abbreviated summary follows: 

 Central air conditioners—seasonal energy efficiency ratio; model number of 

ducted air mover (if applicable) 
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 Central air conditioning heat pumps—seasonal energy efficiency ratio; heating 

seasonal performance factor; model number of ducted air mover (if applicable) 

 Clothes washers—energy factor; capacity 

 Clothes dryers—energy factor; voltage 

 Direct heating equipment—annual fuel utilization efficiency; capacity 

 Dishwashers—energy factor 

 Faucets—maximum water use for each faucet; or maximum water use for each 

flow control mechanism with a listing of accompanied faucets by model number 

 Furnaces—annual fuel utilization efficiency 

 General service fluorescent lamps—testing lab’s NVLAP identification number 

or other NVLAP-approved accreditation identification; production date codes; 12-

month average lamp efficacy; lamp wattage; 12-month average Color Rendering 

Index 

 Incandescent reflector lamps—testing lab’s NVLAP identification number or 

other NVLAP-approved accreditation identification; production date codes; 12-

month average lamp efficacy; lamp wattage 

 Pool heaters—thermal efficiency 

 Refrigerators, refrigerator-freezers, and freezers—annual energy use; total 

adjusted volume 

 Room air conditioners—energy efficiency ratio; capacity 

 Showerheads—maximum water use; list of accompanied showerheads by model 

numbers 

 Urinals—maximum water use 

 Water closets—maximum water use 

 Water heaters—energy factor; rated storage volume 

As of July 6, 2010: 

 Ceiling fans—model number

 Ceiling fan light kits with sockets for medium screw base lamps or pin-based 

fluorescent lamps—efficacy

 Ceiling fan light kits with sockets other than medium screw base lamps or pinbased fluorescent lamps—model number

 Medium base compact fluorescent lamps—minimum initial efficacy; lumen 

maintenance at 1,000 hours; lumen maintenance at 40 percent of rated life; rapid 

cycle stress test; lamp life

 Dehumidifiers—energy factor; capacity

 Class A external power supplies—active mode efficiency percentage; no-load 

mode power consumption; nameplate output power; if missing from nameplate, 

output current of highest- and lowest-voltage models within design family 

 Class A switch-selectable single-voltage voltage external power supplies—

average active mode efficiency percentage; no-load mode power consumption at 

lowest and highest selectable output voltage; nameplate output power; if missing 

from nameplate, output current

 Torchieres—model number 
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4) What information is required to be included in the compliance statement? 

For consumer products, the compliance statement must contain all the information and be 

filed in the format set forth in Appendix A to Subpart F of Part 430. Please refer to that 

appendix to see the format for the statement. The compliance statement must certify: 

 The basic model complies with the applicable energy conservation or water 

conservation standard. 

 All required testing has been conducted in accordance with the test requirements 

in Subpart B of Part 430. 

 All information in the certification report is true, accurate, and complete. 

 The manufacturer/private labeler submitting the certification report is aware of the 

penalties associated with violation of the Act, including the penalties for 

knowingly filing a false statement to the government. 

Please note that the compliance statement MUST be signed. 

5) May I have a third party submit my certification report and compliance 

statement? 

You may elect to use a third party to submit the certification report, in accordance with 

430.62(e). However, you may not use a third party to submit your compliance statement. 

If a third party submits a certification report on your behalf, you should submit a 

compliance statement in accordance with 430.62(a) that states that the information 

reported in the certification report submitted on [date] (or covering [x] models) by [name 

of your third party representative] is true, accurate and complete. 

 I am a third party representative. What do I need to submit? 

You must submit all the information required on a certification report (see Question 3 

above). You must also include the name(s) of the manufacturers or private labelers who 

authorized you to submit their certification report(s) on their behalf. 

6) How do I submit the required information? 

Please use certified mail and submit to: 

Appliance Standards Program (EE-2J) 

U.S. Department of Energy 

1000 Independence Ave., SW 

Washington, DC 20585-0121 

7) What if I have never filed a certification report or compliance statement? 

You should file a certification report for each basic model that is currently in production 

and/or in distribution. 
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8) Do international companies need to report? 

Yes, if your company imports and sells covered products in the United States, you must 

comply with 10 CFR Part 430. Any person who imports a covered product is considered 

a “manufacturer” under Part 430. Covered products that are not in compliance may be 

refused admission into the customs territory of the United States. DOE will pursue 

enforcement actions against foreign manufacturers who distribute covered products in the 

United States and who fail to comply with the applicable regulations. 

9) I participate in the ENERGY STAR program. Do I still need to submit 

certification reports and compliance statements? 

Yes, you still need to submit certification reports and compliance statements to DOE 

under part 430. ENERGY STAR is a voluntary program managed by the EPA. A 

product listed in the ENERGY STAR program obviously should meet the minimum 

federal standards. The requirements to submit certification reports and compliance 

statements are separate, however, and you must file these documents with DOE to fulfill 

your obligations under part 430. 

10) I manufacture/import/label general service fluorescent lamps and/ or 

incandescent reflector lamps. What information should I provide?

The certification report for general service fluorescent lamps and incandescent reflector 

lamps should include 

 The testing laboratory’s National Voluntary Laboratory Accreditation Program 

(NVLAP) identification number or other NVLAP-approved accreditation 

identification; 

 Production date codes (and accompanying decoding scheme); 

 12-month average lamp efficacy in lumens per watt; 

 Lamp wattage; and 

 For general service fluorescent lamps only, 12-month average Color Rendering 

Index. 

 Where can I get a list of NVLAP test laboratories? 

A list of laboratories accredited to perform energy efficiency testing for lighting products 

is available online at http://ts.nist.gov/Standards/scopes/eelit.htm. 

 How do I certify new models since I do not have 12-month test data? 

The regulations provide different certification procedures for new models of general 

service fluorescent lamps and incandescent reflector lamps. See 430.62(b)(2) for detailed 

instructions. 
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11) I heard manufacturers will be required to submit certification reports and 

compliance statements for products that had not been subject to the certification 

requirements before. Is that true?

Yes. On January 5, 2010, DOE published a final rule that adopted certification 

requirements for 6 additional consumer product types. 

 What additional consumer products will be subject to the certification 

requirements? 

(1) Ceiling fans 

(2) Ceiling fan light kits 

(3) Medium base compact fluorescent lamps 

(4) Dehumidifiers 

(5) External power supplies, Class A 

(6) Torchieres 

 When is my certification report and compliance statement due? 

You must submit your certification report and compliance statement no later than July 6, 

2010. 

 What information must I submit? 

See Question 3 and Question 4 above.