“Even though it recognized that a need existed to ensure that products provided promised savings, the Department had not developed a consistent, comprehensive testing program for all of its ENERGY STAR product categories. While it required manufacturers of three product categories, including solid state lighting, compact fluorescent lighting, and windows to use an independent testing service to demonstrate compliance with ENERGY STAR specifications, the Department allowed manufacturers of five other product categories to self-certify compliance. This included specifications for such high energy consumption appliances as refrigerators/freezers, clothes washers, dishwashers, water heaters, and room air conditioners.”
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