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SMART Energy Efficiency Standards Act would eliminate installation deadlines 


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Senator Joni Ernst (R-IA) has introduced S. 4892, the SMART Energy Efficiency Standards Act. The bill targets a long-standing problem with the Department of Energy’s (DOE) regional energy efficiency standards for HVAC equipment. 

Right now, some regional efficiency standards for furnaces, central air conditioners, and heat pumps are enforced based on the date of installation. The SMART Energy Efficiency Standards Act would change that compliance date to the date of manufacture. The bill revives legislation previously introduced in the House by Congressman Bob Latta (R-OH) and Congresswoman Debbie Lesko (R-AZ). 

“There’s no reason heating and cooling equipment should be treated differently from virtually every other product,” said Ernst. “My bill uses the date it is manufactured to provide a fair, predictable standard that helps distributors, gives contractors certainty, and keeps equipment available for American families.” 

This legislation is likely to be considered in the context of modernizing the Energy Policy and Conservation Act and removing installation deadlines is part of ACCA’s EPCA platform. Please take action in support of this and other energy policy priorities: 

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Moving compliance to the date of manufacture 

Under current law, compliance with some regional standards depends on the date equipment is installed. A furnace or air conditioner can meet every DOE requirement when it leaves the factory and still become illegal to install once a new standard takes effect, even though nothing about the unit itself has changed. 

4892 would amend the Energy Independence and Security Act of 2007 to base compliance on the date of manufacture instead. That means any HVAC product that meets DOE requirements when it leaves the factory could be sold and installed without an arbitrary deadline hanging over it.

How installation date compliance hurts HVAC contractors 

These HVAC equipment standards are the only DOE energy efficiency standards that use the date of installation as the compliance deadline. Every other DOE standard holds the manufacturer accountable at the factory door. 

Installation date compliance leaves distributors holding equipment they legally purchased but can no longer sell for installation once a new standard takes effect. Contractors feel the same squeeze when a job slips past the deadline, and the equipment already on the truck becomes a compliance problem. The added costs and delays eventually land on homeowners. 

Contractors saw this firsthand during the 2023 transition to new regional air conditioner standards. Businesses in the South and Southwest raced to install compliant inventory before the deadline or risked getting stuck with equipment they could no longer legally install. 

HVAC industry coalition backs the bill 

ACCA joined the Air-Conditioning, Heating, & Refrigeration Institute (AHRI), Heating, Air-conditioning & Refrigeration Distributors International (HARDI), and the Plumbing-Heating-Cooling Contractors—National Association (PHCC) in a coalition letter of support to Senator Ernst. 

“Under current law, compliance with regional energy efficiency standards is based on the date equipment is installed rather than the date it is manufactured,” the coalition wrote. “This creates unnecessary complexity throughout the HVAC supply chain by effectively causing otherwise fully compliant equipment to expire after it has been legally manufactured, purchased, and distributed.” 

A date-of-manufacture standard, the coalition wrote, “places compliance responsibility where it belongs — with the manufacturer — and ensures that every product entering the distribution chain complies with applicable Department of Energy requirements.” 

“The SMART Energy Efficiency Standards Act will provide business certainty throughout the HVAC supply chain, reduce unnecessary costs and complexity, and ensure a more orderly transition to future energy efficiency standards,” the letter concluded. 

A smoother transition for the HVAC supply chain 

Under the bill, a unit that complies when it ships would stay legal to sell and install for as long as it sits on a distributor’s shelf. New standards would phase in the same way they do for every other DOE-regulated product, with factories switching over to the new requirements and older stock selling through on its own timeline. 

Earlier House versions of the bill stalled in committee. Senator Ernst’s introduction gives the fix a fresh start in the Senate, and ACCA’s government relations team is tracking S. 4892 as it moves through committee. 


Posted In: Energy Policy, Government, Top Priorities

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