“The court recognized the problems that come with a patchwork of state regulations and gave a significant victory to manufacturers and consumers by ensuring that the principle of one federal regulation, not fifty separate state regulations, govern the manufacturing of federally covered HVACR products and equipment,” stated William G. Sutton, president of the Air-Conditioning and Refrigeration Institute (ARI).
ARI and the Association of Home Appliance Manufacturers (AHAM), the Gas Appliance Manufacturers Association (GAMA), and the National Electrical Manufacturers Association (NEMA) filed a complaint with the federal court seeking relief from regulations promulgated by the CEC regarding federally “covered products” and “covered equipment” that are preempted expressly by EPCA. The federally covered products affected by the CEC's regulations were air conditioners and heat pumps, package terminal air conditioners, water heaters, and furnaces, as well as other residential and commercial appliances.
The court found that the federal regulations were adopted to address the "situation where appliance manufacturers were confronted with the problem of a growing patchwork of differing state regulations which could increasingly complicate their design, production, and marketing plans. Regulations in a few populous states could as practical matters determine the product lines sold nationwide, even in states where no regulations existed."
In enjoining the CEC's regulations, the court found that "allowing each state to submit different pieces of information about their products opens the door to the creation of the precise situation that Congress sought to avoid in passing NAECA — subjecting manufacturers to a patchwork of potentially inconsistent state regulations.”
The energy efficiency of appliances is governed by EPCA as amended by the National Appliance Conservation Act of 1987 (NAECA) and the Energy Policy Act of 1992 (EPACT). NAECA contains efficiency standards, testing procedures, and labeling requirements, among other regulations, for certain residential appliances, referred to as "covered products." These include appliances such as refrigerators, room air conditioners, air conditioners and heat pumps, furnaces, water heaters, and fluorescent lamp ballasts. EPACT contains similar regulations for certain types of commercial and industrial equipment, referred to as "covered equipment." These include certain electric motors, packaged terminal air conditioners and heat pumps, storage water heaters, and instantaneous water heaters.
Publication date: 06/16/2003
