What is the enforcement mechanism for the standard? Is it up to the local inspectors to accept or challenge the circle “E” qualification?
DOE is responsible for enforcing Federal energy conservation standards, whether those standards were developed through a DOE rulemaking or prescribed by Congress. (42 U.S.C. 6303, 6304, 6316) DOE establishes specific enforcement regulations for each product covered by these standards, which may require manufacturers to file documents such as a compliance statement and a certification report. In a compliance statement, the manufacturer certifies its products meet all applicable regulatory requirements. In a certification report, the manufacturer provides product-specific information, such as the model number, energy consumption or efficiency, and other model-specific information that would enable DOE to determine which product class and standard the product is subject to and whether the product meets the standard. However, DOE has not yet finalized enforcement regulations for metal halide lamp ballasts. Until DOE finalizes such regulations, manufacturers will not be required to report a
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