CFA and NCLC File Comments at DOE on Proposal to Change Interim Test Procedure Waiver Process

Consumer Federation of America and the National Consumer Law Center submitted comments to the Department of Energy expressing concern about its  proposal to change the interim test procedure waiver process.  The groups stressed that the proposal could  give foreign companies the ability to avoid full compliance and potentially gain advantage over American companies that may be more inclined to comply since DOE proposes that  test procedure interim waivers be automatically ‘deemed granted’ for a product if no agency action is taken after the initial 30 business days and with no public notice that this is occurring – thus leaving competing, more compliant manufacturers and other affected parties in the dark and putting consumers at risk for buying a non-compliant, less efficient product. DOE Comments on Interim Waiver Process Final