DOE's Decision Regarding Window Attachments and Rating, Certification and Labeling Programs

September 18, 2012

The Department recently reviewed Section 121 of the Energy Policy Act of 1992 (EPAct), which mandates that a "voluntary window rating program" to develop "energy rating and labels for windows and window systems" be developed by the National Fenestration Rating Council (NFRC). Pub. L. 102-486 § 121(a) (1992), codified at 42 U.S.C. § 6292 note.

DOE reviewed this section to determine if window attachments fell under the "voluntary rating program" developed by NFRC or whether another entity could develop ratings, certification and labeling systems for window attachments. The Department reviewed the statue, legislative history, technical data, and letters from the NFRC and the Window Covering Manufacturers Association.

Section 121 applies only to windows and window systems. However, window attachments are neither windows nor window systems. Therefore, the Department determined that EPAct Section 121 is inapplicable to window attachments.