APGA Weighs in on Cooking Products Test Procedure Petition

By Stuart Saulters posted 05-25-2023 12:53 PM

On May 19, APGA submitted comments to the Department of Energy (DOE) in response to a petition requesting changes to the agency's test procedures for gas cooking products. 
Recall that DOE finalized a new test procedure for gas cooking products last year.  During the notice and comment period, APGA raised concerns about the ;ack of repeatability of the new test procedure.  Without a repeatable test procedure, appliance manufacturers may have issues ensuring that their appliances are cleared to be sold in the U.S.  To help address concerns with the final test procedure, the Association of Home Appliance Manufacturers (AHAM), the trade association that represents manufacturers of cooking products, petitioned the agency in January 2023 to make several changes to the test procedure.  However, DOE did not publish notice of the petition until after the comment period opened and closed for the agency's rulemaking impacting gas cooking products' minimum efficiency standards, during which APGA also raised concerns about the test procedure for gas-fired cooking appliances.
Through the comments, APGA supported portions of the petition while continuing to raise concerns about how the test procedures appear to be inherently biased against gas cooking products.  APGA will continue to engage in this rulemaking and others impacting appliance efficiency test procedures, as they are the critical underpinning for compliance with minimum efficiency standards.  APGA jointly submitted the comments with the American Gas Association (AGA), the National Propane Gas Association (NPGA), and Spire.
A copy of the comments is available here.
For questions on this article, please contact Stuart Saulters of APGA staff by phone at 202-802-0493 or by email at