Appliance and Equipment Efficiency Standards
Overview
Crowell & Moring’s energy team has significant experience with matters involving the U.S. Department of Energy’s (DOE) appliance conservation standards as well as the Energy Star program. We have been active in compliance, enforcement, policymaking, and other advisory matters spanning multiple presidential administrations, and we regularly advise manufacturers, importers, private labelers, and other stakeholders on the Energy Policy and Conservation Act (EPCA) and state-level programs, including those administered by the California Energy Commission (CEC). Our team is particularly adept at resolving matters that require counsel to be in command of technical issues, and to work extensively and productively with your legal, business, engineering, and technical teams. We have advised on and negotiated successful resolutions of enforcement cases on behalf of numerous clients spanning diverse consumer, commercial, and industrial products and are unique in being one of the only firms to have administratively litigated EPCA-related decisions from the DOE’s Office of Hearings and Appeals (OHA).
Contact
Insights
Firm News | 7 min read | 06.04.26
Crowell & Moring Secures Top Rankings in Chambers USA 2026
Washington – June 4, 2026: Crowell & Moring earned 92 individual rankings for 81 attorneys, as well as 48 national and statewide practice area rankings, in the Chambers USA 2026 guide. The Chambers guide ranks the country’s top law firms and lawyers through in-depth research, client interviews, and feedback from attorneys at peer firms.
Client Alert | 3 min read | 01.26.23
Appliance Manufacturers and Importers Should Prepare for Increased DOE Enforcement Activity in 2023
Publication | 03.15.19
Blog Post | 02.21.19
EPCA Compliance: What Appliance Manufacturers (and Importers) Need to Know
Representative Matters
- Prepared written comments for Fortune 500 company on DOE’s proposed energy conservation standards for multiple residential products.
- Advise major international appliance manufacture on compliance and enforcement under the Energy Star program.
- Represented covered product manufacturer on the novel application of DOE's enforcement authority for the Backstop Rule for General Service Lamps.
- Represented a covered product manufacturer in self-reporting a DOE compliance violation and in all phases of the subsequent DOE enforcement proceeding and settlement process, resulting in a favorable client outcome and a significant reduction from the proposed penalty to the penalty paid.
- Advised a global technology manufacturer on novel compliance issues related to an Internet-connected consumer appliance, including obtaining a beneficial private letter ruling from DOE for the client ahead of the global launch of their product.
- Counseled a covered product manufacturer through a DOE enforcement proceeding resulting from a DOE-initiated enforcement investigation of the manufacturer’s product, including conducting an internal investigation concerning the manufacturer’s historical production and testing processes. Ultimately reached a favorable outcome for the client in settlement, securing a significantly smaller penalty than initially proposed by the agency.
- Represented three covered product manufacturers in separate but parallel proceedings to pursue interpretation of a DOE compliance standard for external power supplies (EPSs), including through staff outreach, OHA proceedings and, ultimately, appeals to the Federal Energy Regulatory Commission (FERC) to challenge the OHA outcomes. All three matters were resolved through settlement during the FERC proceedings, resulting in the issuance of new DOE guidance for EPSs that reflected our clients' input.
- Advised a global manufacturer and importer of covered products on multiple novel compliance issues related to Internet-connected devices and diverse issues related to EPSs and battery chargers, including proactive outreach to DOE policy staff.
- Advised diverse manufacturers and importers throughout all phases of the EPCA rulemaking process for multiple products, including DOE staff outreach, development of comments, and outreach to other impacted companies.
- Represented a covered product manufacturer regarding a novel product category throughout all phases of CEC rulemaking, including challenges to the Codes and Standards Enhancement process, outreach to CEC staff, coordination and collaboration with aligned stakeholders and, at times, contentious informational sessions with CEC staff and other stakeholders, ultimately reaching the most satisfactory available outcome for the client.
Contact
Insights
Firm News | 7 min read | 06.04.26
Crowell & Moring Secures Top Rankings in Chambers USA 2026
Washington – June 4, 2026: Crowell & Moring earned 92 individual rankings for 81 attorneys, as well as 48 national and statewide practice area rankings, in the Chambers USA 2026 guide. The Chambers guide ranks the country’s top law firms and lawyers through in-depth research, client interviews, and feedback from attorneys at peer firms.
Client Alert | 3 min read | 01.26.23
Appliance Manufacturers and Importers Should Prepare for Increased DOE Enforcement Activity in 2023
Publication | 03.15.19
Blog Post | 02.21.19
EPCA Compliance: What Appliance Manufacturers (and Importers) Need to Know
Insights
EPCA Compliance: What Appliance Manufacturers (and Importers) Need to Know
|02.21.19
Crowell & Moring's Retail & Consumer Products Law Observer
Professionals
Insights
Firm News | 7 min read | 06.04.26
Crowell & Moring Secures Top Rankings in Chambers USA 2026
Washington – June 4, 2026: Crowell & Moring earned 92 individual rankings for 81 attorneys, as well as 48 national and statewide practice area rankings, in the Chambers USA 2026 guide. The Chambers guide ranks the country’s top law firms and lawyers through in-depth research, client interviews, and feedback from attorneys at peer firms.
Client Alert | 3 min read | 01.26.23
Appliance Manufacturers and Importers Should Prepare for Increased DOE Enforcement Activity in 2023
Publication | 03.15.19
Blog Post | 02.21.19
EPCA Compliance: What Appliance Manufacturers (and Importers) Need to Know





