States are Turning the Voluntary Energy Star Program into a De Facto Standard

By Tim O’Connor
Associate Editor and
Communications Manager

With Congress divided and unable to agree on many kinds of legislation, environmental groups have shifted their strategy to imposing new regulations and energy standards at the state level. In some cases, this is leading to a patchwork of stricter requirements that foodservice equipment and supplies dealers and manufacturers are forced to navigate.

The most recent regulatory trend in commercial products is aligning state energy and water consumption requirements with Energy Star standards. This effectively turns the voluntary Energy Star program, a symbol of government-verified energy efficiency, into a mandatory minimum standard for commercial foodservice equipment in many parts of the country. To date, 14 states and Washington D.C. have approved new standards that match various levels of Energy Star requirements. The latest state to do so is New York, which updated its new appliance standards as part of a revision to its building codes in 2022. The new law impacts what products can be legally sold, rented, leased and installed in the Empire State and the affected equipment includes commercial dishwashers, fryers, hot holding cabinets, ovens, and steam cookers.

Equipment manufactured after June 26, 2023, that does not meet Energy Star V2.0 standards (V2.2 for ovens and V1.2 for steam cookers) is now prohibited in the state. However, equipment produced before that date is still allowed, meaning that existing dealer inventory should not be impacted.

A spokesperson from the New York State Energy Research and Development Authority (NYSERDA), the agency enforcing the codes, said the decision to adopt Energy Star standards was made to keep New York current with similar moves in other states. “New York State standards align with other states that promulgated minimum efficiency standards for products and appliances not pre-empted by the federal government,” the spokesperson said.

The tendency for states to follow each other in adopting these kinds of regulations is no surprise to Charlie Souhrada, CFSP, vice president, regulatory and technical affairs, North American Association of Food Equipment Manufacturers (NAFEM). Souhrada has been following the effort to turn Energy Star into a de facto requirement at the state level for several years. In 2019, he was among the group of business advocates who argued before Colorado’s legislature against a bill that required commercial dishwashers, fryers and steam cookers to meet Energy Star requirements.

The Colorado law, like those that have since followed, used the Energy Star program in a way it was never intended, Souhrada explained. Since its beginnings in 1992, Energy Star has been a success story of public-private partnerships and continues to have wide support among manufacturers. The program is administered by the Environmental Protection Agency (EPA) and has saved 5 trillion kilowatt-hours of electricity, achieved 4 billion metric tons of greenhouse gas reductions and saved $500 billion in energy costs over more than 30 years. In fact, NAFEM actually helped to bring Energy Star to the foodservice equipment sector in 2002 and is planning to celebrate 20 years of that partnership with the EPA later this year.

Its voluntary nature is core to Energy Star’s mission, as certain product categories and customer requirements are simply incompatible with the standard. “By requiring foodservice equipment to use Energy Star is painting our members into a corner,” Souhrada said. “Most of these regulations are written so it’s the minimum Energy Star standard, which is all well and good, but the perception that’s created is that all appliances should have Energy Star. In some cases, it just isn’t a possibility. It isn’t available to them.”

Still, Souhrada understands why states are using Energy Star as a reference point. The program is well-understood by manufacturers and the label inspires trust with the public. “Energy Star is a known entity,” Souhrada said. “It’s an easy way to provide credibility or legitimacy to a regulation.”

A spokesperson from NYSERDA confirmed that familiarity was an important factor in New York State’s decision to match Energy Star. “New York’s product standards align with current or past versions of Energy Star specifications because these products have significant market penetration, proven performance and manufacturer familiarity, making compliance easier for all parties.”

By turning Energy Star into a minimum threshold, states risk undermining the public-private partnership that has made it such a success for three decades. Instead of morphing into a requirement, Souhrada said there is ample opportunity for Energy Star to continue pushing for greater energy and water consumption reductions through its volunteer status.

“We’re looking at ways to continue to strengthen the program with component testing that would verify Energy Star,” Souhrada said. “We continue to work on ways to keep the program strong. Manufacturers are firmly behind it and that’s part of the reason why we’re pushing back on the states and saying, ‘Hey, this is not in keeping with the intent of the original program.’”

What Dealers Can Do
The states that have enacted these more rigorous standards typically exempt previously manufactured equipment from the requirements, however, there are no options for manufacturers to seek an exemption for a current product line that might still be in production past the enforcement date. That can leave dealers and operators with fewer equipment options.

“In some cases, the operator might be looking for an economical piece of equipment to get their installation up and running or to fulfill an immediate need,” Souhrada said. “Specifying a certain type of energy requirement for some of these applications does not necessarily suit what the operator might need.”

The state-by-state nature of the standards also means that manufacturers and dealers have yet another mishmash of regulations to navigate. “It is more difficult for small businesses to try to keep up with or monitor all these state-by-state regulations because they simply don’t have the resources,” Souhrada added.

Fortunately, there are some tools that can help. The State Appliance Standards Database (SASD) is a resource developed by the Northeast Energy Efficiency Partnerships (NEEP) to help businesses identify compliant products. As of September, the database had nearly 49,000 products listed that can be checked against the standards for 11 states and Washington, D.C. The website,, also provides information on the scope and requirements of state standards, guides for how manufacturers can verify products and fact sheets for distributors. For dealers operating on the West Coast, California maintains its own separate website, the Modernized Appliance Efficiency Database System (MAEDbS) — found at — to verify against the state’s standards, which are often the most strict in the country.

To avoid violations, dealers are encouraged to check their products against the SASD. Anything certified in the database is considered to be in compliance. If a product being sold is not listed in the database, the SASD recommends that dealers contact the manufacturer and ask them to submit their product data.

Ultimately, that puts the onus on dealers to ensure that anything sold or leased meets standards in each customer’s market. If a dealer sells a non-compliant item, it can lead to financial penalties. “They are held responsible for knowing what the state regulations are,” Souhrada noted.