On July 7, 2026, the Department of Energy (DOE) published a notice of proposed rulemaking (NOPR) proposing substantial revisions to DOE’s “Process Rule,” which governs the process DOE uses to develop energy conservation standards and test procedures for consumer products and commercial/industrial equipment pursuant to the Energy Policy and Conservation Act (EPCA). If finalized, the proposal would significantly alter how DOE develops and evaluates new and amended energy conservation standards, with important implications for manufacturers, importers, and distributors of products subject to DOE’s energy efficiency regulations.
The proposal is explicitly framed as an effort to curb appliance and equipment efficiency mandates that DOE believes raises product costs and restricts consumer choice. As discussed below, the NOPR would restore many features of DOE’s 2020 Process Rule, reverse portions of later revisions, and add new procedural and substantive constraints that would make it more
