To sell most appliances, electronics, plumbing fixtures, or lighting products in California, the manufacturer has to complete CEC testing for appliances under Title 20 of the California Code of Regulations before the product ships. That means having the unit tested to the method the California Energy Commission specifies, filing the results in the Modernized Appliance Efficiency Database System (MAEDbS), and getting the Executive Director’s approval. Selling a covered product that hasn’t cleared this process exposes the manufacturer to administrative penalties of up to $2,500 per violation, and each unsold-but-offered unit can count separately.
Is Your Product Covered
Title 20 Section 1601 lists the product categories subject to the appliance efficiency regulations. The list runs past 50 categories and covers everything from refrigerators, dishwashers, and clothes washers to showerheads, faucets, and toilets; from central and room air conditioners to water heaters and pool heaters; from lamps, ballasts, and luminaires to computers, monitors, and televisions; from electric motors and pool pumps to battery charger systems, external power supplies, and portable spas.1Cornell Law School. California Code of Regulations Tit. 20, 1601 – Scope
Two exemptions apply across the board: products sold wholesale in California for final retail sale outside the state, and products designed and sold exclusively for recreational vehicles or other mobile equipment. Individual categories carry their own carve-outs (electric vehicle chargers, certain medical devices, refrigerators over 39 cubic feet, and others), so check the exemption language for your specific product before assuming it is or isn’t covered. If a product seems too niche to be regulated, that’s not a safe assumption. Review Section 1601 directly.
Which Test Method Applies
Section 1604 tells you which test method to use. For products the federal government already regulates under the Energy Policy and Conservation Act, Title 20 typically incorporates the federal test procedures in 10 C.F.R. Part 430 or Part 431. For products California regulates on its own, Section 1604 designates a California-specific protocol or references an industry standard such as an ANSI or ASHRAE method.2Cornell Law School. California Code of Regulations Tit. 20, 1604 – Test Methods for Specific Appliances
Identify the correct method before testing begins. If more than one method is available for your product, you’ll need to identify which one you used when you file, and the lab has to apply it exactly as written.
Who Can Do the Testing
Title 20 gives manufacturers two routes.
Approved Industry Certification Programs
The first route is participation in an approved industry certification program. These are typically run by manufacturer trade associations. To be approved by the CEC’s Executive Director, a program must be accredited by ANSI or ISO (or hold an equivalent approval), maintain a publicly accessible listing of energy performance data updated at least every six months, verify the data manufacturers submit to it, and flag any appliances that meet the federal standard but fall short of California’s.3Cornell Law School. California Code of Regulations Tit. 20, 1603 – Testing: All Appliances
Direct Laboratory Testing
The second route is testing at a laboratory individually approved by the Executive Director. To be approved, the lab must have conducted tests under the applicable test method within the previous 12 months, agree to interpret and apply that method exactly as written, keep its equipment properly calibrated, and retain copies of all test reports for products still in commercial production.3Cornell Law School. California Code of Regulations Tit. 20, 1603 – Testing: All Appliances
A lab applies for approval by submitting a Test Laboratory Application through MAEDbS. Each appliance type and each test method needs its own approval. Approval expires at the end of the calendar year and has to be renewed annually. Approved labs appear in the MAEDbS company search directory, which is where a manufacturer confirms that a prospective lab actually holds current approval for the specific product and method involved.
Filing the Results in MAEDbS
Once testing is complete, the manufacturer files an electronic statement with the Executive Director through MAEDbS for each appliance sold or offered for sale in California. The filing must include three things:4Cornell Law School. California Code of Regulations Tit. 20, 1606 – Filing by Manufacturers; Listing of Appliances in the MAEDbS
- Manufacturer identification: company name, address, phone, email, the person responsible for the filing, and the person signing the declaration.
- Testing information: a statement that the product was tested under Sections 1603 and 1604, identification of which method was used when more than one applies, and the name and address of the testing laboratory.
- Performance data: the product-specific metrics listed in Section 1606’s Table X for that category, which may include annual energy use, cooling capacity, water consumption, or other efficiency measurements.
Getting Access to MAEDbS
Before you can file, you need an account. Register the company on the MAEDbS portal, select the applicable company type (manufacturer, third-party certifier, or test laboratory), and create user credentials. After email validation, CEC staff review and approve the account. Assign an External System Admin to manage the account and users, and External Staff to handle the actual certification submissions.5California Energy Commission. MAEDbS General Instructions
Each submission can carry up to 1,000 data entries. A manufacturer can also delegate filing to a third-party certifier, but the certifier has to submit and receive approval of a third-party certifier application before that delegation takes effect.
Review and Approval
After you submit, the Executive Director determines whether the statement is complete and accurate and whether the appliance actually meets the efficiency standards in Sections 1605.1, 1605.2, and 1605.3. The regulation gives the Executive Director 30 days to inform the manufacturer of the determination. Missing that deadline does not count as automatic approval.4Cornell Law School. California Code of Regulations Tit. 20, 1606 – Filing by Manufacturers; Listing of Appliances in the MAEDbS
If the submission is incomplete, the Executive Director returns it through MAEDbS with an explanation of the defects and a request for corrected information. Common problems include mismatched test methods, missing Table X performance fields, and incorrect manufacturer identification. Once the filing clears, the product appears in the public MAEDbS database and can be sold in California.
Marking the Product
Getting listed in MAEDbS is not the end of it. Section 1607 requires that every covered appliance permanently, legibly, and conspicuously display the manufacturer’s name or brand, the model number, and the date of manufacture (at least year and month) in an accessible location on the unit.6Cornell Law School. California Code of Regulations Tit. 20, 1607 – Marking of Appliances
Some categories get more flexibility. Plumbing fixtures and fittings may carry the information on the unit or its packaging. Lamps and spray sprinkler bodies may use the unit, the individual package, or the packaging of a multi-unit group. If the date of manufacture is coded in a way an ordinary person wouldn’t understand, the manufacturer has to provide the code to the CEC on request.
Federally regulated consumer products carry the additional FTC EnergyGuide labeling or other markings required by 16 C.F.R. Part 305. Federally regulated commercial and industrial equipment has to be permanently marked with the energy performance information called out in Section 1607’s Table Y.
What Happens If You Skip or Fail Testing
The CEC’s Office of Compliance Assistance and Enforcement watches the market. If the Executive Director finds a product being sold in California without a MAEDbS listing, the response can include testing the product at the manufacturer’s expense, issuing a Notice of Violation, negotiating a settlement, or initiating administrative proceedings.7Cornell Law School. California Code of Regulations Tit. 20, 1608 – Compliance, Enforcement, and General Administrative Matters
Products already listed can still be pulled. The CEC can request test reports for any listed product, and if the manufacturer doesn’t produce the report on time, the Executive Director may remove the listing, which makes further sale illegal. If a submitted test report shows the product doesn’t meet the applicable standard, the Executive Director removes the listing after 10 days’ electronic notice to the manufacturer’s designated contact.
California Public Resources Code Section 25402.11 authorizes administrative civil penalties of up to $2,500 per violation. The CEC can also refer the matter to the Attorney General, who may seek the same $2,500 per-violation penalty in court along with injunctive relief. In setting the amount, the commission weighs the seriousness of the violation, how many violations occurred and over what period, whether the conduct was willful, the violator’s financial resources, and consumer harm from wasted energy.8California Legislative Information. California Code, Public Resources Code – PRC 25402.11 Because each unit sold without proper certification can be treated as a separate violation, exposure scales with distribution.