The U.S. government’s Energy Star label is one of the most recognized environmental labels in North America. More than 77 percent of government purchasers and 70 percent of consumers recognize Energy Star and use it to buy energy-efficient products in more than 50 categories ranging from light bulbs to buildings.

What most professional purchasers and consumers do not realize, however, is that the Energy Star program does not test all products. Energy Star generally relies on manufacturers to police themselves and each other. As a result, not all Energy Star-labeled products meet the Energy Star standard.

Energy Star is a self-registration program. It is not a certification program, such as EcoLogo, GreenGuard, Green Seal and WaterSense. Rather than having an independent body determine whether a product meets the Energy Star standard, manufacturers get to decide for themselves.

Although manufacturers refuse to provide individual consumers with proof that products meet the Energy Star standard, government purchasers are much larger and more influential customers, so manufacturers are more likely to provide it if governments begin asking for it.

Energy Star overview

Launched in 1992 by the U.S. Environmental Protection Agency (EPA) and now jointly managed with the U.S. Department of Energy, the Energy Star program helps consumers identify energy-efficient products. By buying Energy Star-qualified products, consumers can reduce their energy use, their energy costs and their contributions to global warming.

Energy Star has become one of the most influential environmental labels in the world, with more than 2,000 participating manufacturers. The Energy Star program estimates it saved U.S. consumers $19 billion on their electric bills and reduced global warming pollution the equivalent of removing 29 million cars from the road.

As with any large, successful program, Energy Star faces a lot of public scrutiny. Recent reports by the EPA Office of Inspector General and the U.S. Government Accountability Office (GAO) have recommended strengthening or changing Energy Star’s practice of permitting manufacturers to claim a product meets Energy Star guidelines. EPA’s August 2007 report concluded that Energy Star “lacks a clear documented methodology governing products selected for verification tests and does not test for statistically valid results. Consequently, product efficiency and energy savings reported by manufacturers are, for the most part, unverified by EPA review.” A month later, GAO expressed similar concerns.

After independently testing several Energy Star refrigerators, an October 2008 Consumer Reports article revealed that some Energy Star-labeled refrigerators use significantly more electricity than the Energy Star standard permits. In fact, a refrigerator manufactured by LG used twice as much electricity as it claimed.

DOE acknowledged the need to reconsider the importance of having third-party verification of manufacturers’ claims to meet the Energy Star standard in a recent Wall Street Journal article.

Certification vs. registration programs

Manufacturers and suppliers claiming their products are Energy Star-certified are misleading their customers. Energy Star does not certify products.

An environmental certification program requires an independent third-party evaluation to determine whether a product actually meets an environmental standard. The third party tests the products or reviews existing test data conducted by independent laboratories and might even visit the manufacturing facility to ensure that a product passes the tests required to earn the environmental label.

Under a self-registration program, the manufacturer determines whether its product meets the standard. The manufacturer typically signs an agreement promising to tell the truth, but there is no independent verification required before the manufacturer can begin using the label.

When the Energy Star program began in 1992, the manufacturing community was understandably wary of permitting the government or other outside testing laboratories to test their products. Manufacturers were worried about government bureaucracy delaying their ability to make energy efficiency claims. They also feared the additional costs of testing products even though the tests should have been conducted before a manufacturer claimed to meet the Energy Star standard.

As a result, to gain the participation of a large number of manufacturers, the Energy Star program launched as a self-registration program. The government did not require manufacturers to provide proof that a product meets the Energy Star standard before they could begin using the Energy Star label on products.

The risks of allowing manufacturers to determine when their products meet the Energy Star standard are obvious. Energy efficiency, like other invisible environmental benefits, is difficult for the average purchaser to measure independently. Consumers are at the mercy of the information manufacturers choose to provide.

There are a variety of ways a product might falsely claim to be Energy Star qualified:

• An unscrupulous manufacturer might simply lie about a product’s ability to meet the Energy Star standard to increase sales.

• A manufacturer might “misinterpret” the testing requirements and falsely claim a product meets the Energy Star standard.

• A manufacturer might design a product to pass the Energy Star test but fail to meet the intention of the Energy Star program. A well-known appliance manufacturer, for example, has been accused of using advanced computer circuitry in its products to determine when the product is being tested to Energy Star protocols and to adjust to pass the test.

• A well-intentioned manufacturer might design a product that initially meets the Energy Star standard and then add product features that degrade the product’s energy efficiency later in the design process. Without the pressure to provide proof that the final product meets the standard, products might mistakenly claim to meet the Energy Star standard.

Role of professional purchasers

Professional purchasers, given their large purchasing volume, have the ability to require manufacturers and suppliers to provide information that they normally refuse to provide to average consumers. In the case of products claiming to meet Energy Star, purchasers can require proof of the energy efficiency claim.

Purchasers can request a variety of forms of proof:

• Ask companies to provide a statement signed by a company executive stating that the product when used under typical conditions will meet the Energy Star standard.
• Require that the company provide a copy of its Energy Star test protocols, a copy of test data for the product claiming to meet the Energy Star standard, and a signed statement by a company executive verifying the accuracy of the information provided.
• Require the company to have its Energy Star claim verified by an independent third-party.

Government purchasers also might require that companies provide public proof of their claims. Requiring manufacturers to post proof of their Energy Star and other environmental claims in a consistent format on a government or company website will force companies to be more careful with their energy efficiency and other environmental claims. Once posted on a website, the claims are available to public scrutiny, which increases the odds someone can discover any inaccurate information.

Purchasers know that specifying Energy Star-compliant products can help their organizations reduce electricity use, save money and lower global warming pollution compared to similar performing products. When suppliers threatened with losing business make an environmental claim, government purchasers should ask for proof. When developing contract language, purchasers should consider using language such as, “Products purchased under this contract must provide demonstrable proof of meeting the Energy Star standard. The Energy Star standard is available at www.energystar.gov.”

Energy Star is one of the world’s most important eco-labels. It helps save money and reduce global warming. It helps everyone buy better products. Let’s use our purchasing power to help Energy Star really shine. Ask for proof.

Scot Case has been researching and promoting responsible purchasing issues for 16 years. He is vice president of TerraChoice Environmental Marketing, which manages the EcoLogo program. scase@terrachoice.com or 610-779-3770.