Over the past year, the Department of Energy (DOE) has issued a series of energy efficiency regulations impacting various home appliances including water heaters, gas stoves, ovens, clothes washers, refrigerators, and more. DOE cites that the new rules are necessary because inefficient appliances are significantly impacting consumers’ annual residential energy use and utility costs. As currently written, the proposed rules exclude consumer products designed solely for use in recreational vehicles and other mobile equipment.

The RV Industry Association is pleased that the recent proposed rules from the Department of Energy recognize that the RV industry is unique and exempt from the new energy conservation standards. We encourage the Department of Energy (DOE) to maintain this RV exemption in the final rule and any subsequent energy appliance standards. There are three instances where the statutory language clearly exempts motor vehicles and RVs from the new standards. 

  1. RVs are not consumer products. The new energy efficiency standards apply only to consumer products.  The consumer product safety title of Title 15 of the U.S. Code, which outlines the role of commerce and trade, defines consumer products (15 U.S.C. § 2052). Motor vehicles are specifically excluded from the consumer product definition under 15 U.S.C. § 2052(a)(5). 
  2. RVs are motor vehicles. Further to the first point, both motorized (self-propelled) and non-motorized RV trailers are considered motor vehicles under state and federal motor vehicle laws. They are designed to provide temporary living quarters for short-term camping use and comply with applicable motor vehicle regulations. RVs are recognized by all 50 states and the U.S. Department of Transportation as vehicles. Consequently, RVs fit squarely into the federal motor vehicle definition and as a result are not consumer products subject to the new appliance standards.
  3. RVs are specifically excluded from the Notice of Proposed Rulemaking (NPRM). In addition to RVs falling outside the consumer product definition as motor vehicles, RVs also fall outside the Title 42 definitions used to issue the new appliance standards. Title 42 grants the government the ability to take emergency action in numerous ways, and the NPRM pertains to Part A of Chapter 77 of Title 42 which is titled: “Energy Conservation Program for Consumer Products Other Than Automobiles”. Section 6292 of that title lists the products that are covered:

§ 6292. Coverage (a) In general. The following consumer products, excluding those consumer products designed solely for use in recreational vehicles and other mobile equipment, are covered products: 

(1) Refrigerators, refrigerator-freezers, and freezers which can be operated by alternating current electricity, excluding— (A) any type designed to be used without doors; and (B) any type which does not include a compressor and condenser unit as an integral part of the cabinet assembly; (2) Room air conditioners; (3) Central air conditioners and central air conditioning heat pumps; (4) Water heaters; (5) Furnaces; (6) Dishwashers; (7) Clothes washers; (8) Clothes dryers; (9) Direct heating equipment; (10) Kitchen ranges and ovens; (11) Pool heaters; 12) Television sets; (13) Fluorescent lamp ballasts; (14) General service fluorescent lamps, general service incandescent lamps, and incandescent reflector lamps.; (15) Showerheads, except safety shower showerheads; (16) Faucets; (17) Water closets.