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One Year Later: California Title 20 Fan-Efficiency Regulations

April 29, 2025, marks one year since the California Energy Commission (CEC) rolled out provisions for commercial and industrial fans and blowers (CIFB) under Title 20 appliance-efficiency regulations. These regulations now require that in-scope fans and blowers be marked with their operational boundaries, highlighting when they achieve a Fan Energy Index (FEI) of 1.00 or higher.

This post will break down the key points of Title 20, clarify complex provisions, and provide resources for manufacturers, distributors, and engineers to stay compliant.

Background: Key Milestones in the Journey to Compliance

The CEC began its rulemaking in 2017 after the U.S. Department of Energy (DOE) put a pause on its own regulations. The Title 20 requirements were officially adopted on November 16, 2022, with an initial compliance deadline set for November 16, 2023. However, to align with the federal test procedures, the CEC extended the deadline to April 29, 2024. This meant that all in-scope products manufactured on or after that date had to comply with the Title 20 standards.

Since the regulation took effect, 110,000 fan models have been filed in the Modernized Appliance Efficiency Database System (MAEDbS) by thirty-three manufacturers.

Nuances of Compliance: What You Need to Know

California Title 20 Table D-3 references the general fan test procedure (Appendix A), not the specific procedure for ACFs (Appendix B), effectively excluding ACFs from coverage. Title 20 also explicitly exempts air curtains, transport refrigeration fans, and embedded HVAC fans, going beyond DOE’s 10 CFR 431.174(a)(3) by excluding even those embedded fans that DOE implicitly includes.

Duty Points Where FEI > 1.00: What Does It Mean for Manufacturers?

Title 20 does not mandate that fans operate with an FEI of 1.00 or higher at all times. Rather, manufacturers must provide ratings for fans at three bounding duty points that include the maximum fan speed, maximum fan pressure, and maximum fan airflow where the FEI meets or exceeds 1.00.

For more in-depth details, you can refer to Annex H of the ANSI/AMCA Standard 214-21, which outlines how to calculate FEI for fans and blowers.

Compliance: Testing, Marking, and Certification

Fan manufacturers, sellers, and system designers must ensure compliance by submitting products for testing in accordance with the federal CIFB test procedure, marking the products per Title 20 guidelines, and certifying them in MAEDbS. The key requirements include:

• Permanent Labeling: Fans must have a permanent label that includes:
• Manufacturer name, model number, and manufacture date
• Fan-performance boundaries showing the FEI threshold of 1.00 or higher
• The type of pressure (static or total) for which the fan was rated
• MAEDbS Certification: Manufacturers must create a MAEDbS account and submit compliance data through the database, including key parameters and formats specified in Title 20.

Scope: What’s Covered and What’s Not

Title 20 (Section 1602[d]) defines CIFB as rotary-bladed machines that convert electrical or mechanical power into air power, with energy outputs limited to 25 kilojoules per kilogram of air. In practical terms, this includes fan types such as:

• Axial inline fan
• Axial panel fan
• Centrifugal power-roof-ventilator exhaust fan
• Centrifugal power-roof-ventilator supply fan
• Axial power-roof-ventilator fan
• Axial supply fan
• Centrifugal housed fan
• Centrifugal inline fan
• Centrifugal unhoused fan (includes fans designed for use in a fan array with partition walls separating them from other fans in the array)
• Radial housed fan

However, certain fan types are excluded, including:

• Radial housed unshrouded fans with a blade diameter at tip of less than 30 in. or a blade width of less than 3 in.
• Safety fans (e.g., those for explosive atmospheres)
• Induced-flow fans
• Jet fans
• Cross-flow fans
• Fans manufactured exclusively to be powered by an internal-combustion engine
• Fans that create a vacuum of 30 in. wg or greater
• Fans designed and marketed to operate at or above 482°f (250°c)
• Fans and blowers embedded in the equipment listed in paragraph (a)(3) of 10 cfr section 431.174 
• Fans and blowers embedded in equipment other than the equipment listed in paragraph (a)(3) of 10 cfr section 431.174 that (a) are available only as part of a manufactured assembly that includes functions other than air movement or as a replacement part for such an assembly and (b) are not subject to federal efficiency standards

Resources for Compliance

For more information about Title 20 and to access valuable resources, check out Energy Code Ace’s tools, training, and FAQs. To find Title 20-compliant fans, use the MAEDbS Quick Search tool on the California Energy Commission’s website.

Representing Your Interests

Michael Ivanovich is the Senior Director, Global Affairs, at AMCA International. The AMCA advocacy team actively collaborates with government agencies, policymakers, and industry leaders to shape fair, effective policies that benefit manufacturers and support industry growth. Learn more about our initiatives.