Energy Star Requirements in Federal Procurement

Energy Star requirements in federal procurement are statutory mandates under the Energy Policy Act that require federal agencies to purchase energy-efficient products certified under the EPA Energy Star program or meeting Federal Energy Management Program (FEMP) efficiency designations.

What are Energy Star Requirements in Federal Procurement?

The Energy Policy Act of 2005 (42 U.S.C. § 8259b) requires federal agencies to purchase products that are Energy Star-certified (for consumer and commercial products where an Energy Star specification exists) or that meet FEMP's designated energy efficiency requirements (for commercial products not covered by Energy Star). FAR 23.203 implements this requirement.

Covered products include:

• Commercial office equipment (computers, monitors, printers, copiers, servers).
• Appliances (refrigerators, dishwashers, water heaters).
• Lighting products (LEDs, exit signs, torchieres).
• Commercial HVAC equipment (chillers, boilers, packaged units).
• Building envelope products (windows, doors, insulation).
• Industrial equipment and motors.

The requirement applies when the Energy Star or FEMP-designated product is available and meets the agency's performance and quantity needs at a reasonable price. Contracting officers may not waive the requirement merely because a non-compliant product is cheaper; a genuine technical incompatibility or unavailability is required.

FAR 52.223-15 (Energy Efficiency in Energy-Consuming Products) implements the requirement at the contract level. Solicitations for covered products must include this clause, and contractors must certify that delivered products meet the applicable standards.

Why Energy Star Requirements matter for government contractors

Product suppliers must verify that their federal catalog items carry current Energy Star certification or FEMP designation before listing them for federal purchase. Selling non-certified products to federal agencies on contracts that include FAR 52.223-15 constitutes a contract compliance failure. IT resellers, office equipment suppliers, lighting companies, and appliance distributors face the highest exposure.

Example

An IT equipment reseller holds a GSA Multiple Award Schedule contract covering desktop computers, laptops, and monitors. FAR 52.223-15 is included in the MAS contract. Before adding new product lines to the federal catalog, the reseller verifies that each item appears on EPA's Energy Star certified products list at energystar.gov. One server model the reseller intended to list has not yet received Energy Star for Servers certification. The reseller excludes that model from federal sales until certification is obtained, then adds it to the catalog with the certification letter on file.

Frequently Asked Questions

What is the difference between Energy Star and FEMP requirements?

Energy Star is an EPA-administered labeling program covering a defined set of product categories where Energy Star specifications have been established. FEMP sets efficiency requirements for commercial products that do not have Energy Star specifications but where the federal government is a significant purchaser. Together, they cover most energy-consuming federal procurement categories. When an Energy Star specification exists for a product type, Energy Star certification is the standard; when no Energy Star specification exists, FEMP's recommended efficiency level applies.

Do Energy Star requirements apply to construction contracts?

Energy Star requirements apply to building materials, equipment, and systems installed in federal facilities. Federal construction contracts include provisions requiring Energy Star-certified or FEMP-compliant equipment for HVAC, lighting, plumbing, and other building systems. The Federal Buildings Personnel Training Act also requires that building operators be familiar with energy management requirements.

Can an agency waive Energy Star requirements?

An agency may waive the Energy Star requirement when the required products are not available at a reasonable price, are not available in sufficient quantity, or do not meet the agency's technical requirements. The waiver must be documented. FAR 23.203(b) specifies the waiver process. Blanket waivers are generally not permitted; waivers must be specific to the product and the acquisition.

How does a contractor verify current Energy Star certification status?

The EPA maintains a searchable database of certified products at energystar.gov/productfinder. Certification status can change when a product model is discontinued or when the manufacturer does not recertify under a new Energy Star specification version. Contractors should check product status at the time of each purchase and maintain documentation of certified status for contract compliance.