What: In a final rule published on March 6, 2023 (Final Rule), the U.S. Department of Energy (DOE) implemented the Room Size Coverage and integrated energy factor (IEF) rules. The Final Rule, effective December 23, 2023, established standard procedures by which manufacturers may measure and represent to consumers the effective room size coverage and IEF scores of their air cleaner products.
Why: On September 11, 2024, Dyson, Inc. petitioned the DOE to revoke the Final Rule because it:
- obligates manufacturers to make frequently inaccurate and misleading claims about the efficacy and efficiency with which their products operate,
- stifles innovation by manufacturers to develop products that operate better where it counts, in consumers’ homes, rather than in a highly stylized test chamber, and
- undermines energy-efficient consumer purchasing decisions in violation of the DOE’s broader mandate to properly regulate the energy efficiency of consumer products.
Dyson’s petition stated the Room Size Coverage and the IEF Rules should be revoked because they obligate manufacturers to express air cleaner room size coverage and IEF scores using clean air delivery rates (CADR) measured in reliance on the test procedure AHAM-AC-1-2020 (the “AHAM CADR Test”), incorporated by reference into the Final Rule. Dyson claimed the AHAM CADR Test suffers from severe flaws that result in CADRs that do not have real-world validity and, when used to calculate room size coverage and IEF scores, result in misleading information reaching consumers about the absolute and relative capabilities of different air cleaners to effectively and efficiently clean various-sized rooms. If the Final Rule is not revoked, Dyson Inc. requested that the DOE stay enforcement of the Final Rule pending a new notice and comment period regarding potential amendments to the Final Rule.
In a request for public comment published on April 30, 2025, the DOE seeks views on whether it should grant the petition and undertake a rulemaking to consider the proposal contained in the petition. The DOE welcomes comments on any aspect of the petition. By seeking comments on whether to grant this petition, the DOE takes no position at this time regarding the merits of the suggested rulemaking or the assertions in Dyson’s petition. Accordingly, the DOE is not revoking or staying enforcement of the provisions referenced in Dyson’s petition.
Action: Written comments and information are requested and will be accepted on or before May 30, 2025.
FEDERAL REGISTER NOTICE(S):
Energy Conservation Program: Notification of Petition for Rulemaking
CONTACT:
Shanerika Flemings
EMAIL:
TOPIC(S):
DOE
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