Date: 2025-10-21 22:40:00
By Michael Ivanovich
In 2023, the U.S. Department of Energy (DOE) published a final rule1 establishing a federal test procedure for fans and blowers, including air-circulating fans (ACF) that are not ceiling fans (ceiling fans are covered by a separate test procedure2 updated by the DOE in 2022).3,4 After 12 long years, regulation had come to the U.S. market for commercial and industrial fans and blowers (CIFB) (also known as general fans and blowers [GFB]). Development of an accompanying energy-conservation standard was under way, with a final rule anticipated by the close of 2024.
The expectation was that, by this point in 2025, the final rule for the energy-conservation standard would have been published, commencing a five-year grace period during which the DOE would initiate and finalize rulemakings establishing compliance-filing (certification) and labeling requirements.
But that is not what happened. A draft energy-conservation standard was submitted to the Office of Information and Regulatory Affairs (OIRA) for final interagency review in late 2024 only to be withdrawn in early 2025. Subsequently, energy-performance, compliance-filing, and enforcement requirements are being left to the states to determine, with the possibility of diverging provisions.
What’s more, in May 2025, the DOE unexpectedly published nearly two dozen notices of proposed rulemaking (NOPR) seeking to withdraw products, including CIFB and ACF, from coverage under the Energy Policy and Conservation Act (EPCA), the legislation governing DOE appliance- and equipment-efficiency regulations. If the NOPR for CIFB and ACF becomes final, federal test procedures, definitions, and rating calculations/expressions that have been in effect since October 2023 will go away.
Meanwhile, model and state energy codes entered update cycles in 2024 and 2025 with proposals having been made to bring them up-to-date with the federal test procedure.
Where the industry finds itself with regard to CIFB and ACF (regulations for large-diameter ceiling fans [LDCF] are summarized in the sidebar “Ceiling-Fan Regulations and Codes”) and how it arrived there are the subject of this article. Also covered are energy-code updates Air Movement and Control Association (AMCA) International is working through with ASHRAE, the International Code Council (ICC), and several state energy offices.
Federal Regulations
For CIFB, the test procedure published in the Code of Federal Regulations (CFR) in May 2023:
- makes fan energy index (FEI) the metric for fan energy performance
- establishes a method of test mainly based on AMCA International standards
- sets forth rules for expressing FEI and other fan-performance parameters in printed and electronic literature for DOE jurisdictions (the United States and U.S. territories)
For ACF, the test procedure:
- makes cubic feet per minute per watt (cfm/W) the energy-performance metric
- establishes a method of test based on an AMCA International standard
- sets forth requirements for voluntary representations of energy efficiency
Both test procedures took effect in October 2023.
If fans and blowers are removed from the EPCA:
- California’s Title 20 appliance-efficiency regulation for fans will persist indefinitely. Note that ACF are exempt from the Title 20 regulation.
- Outside California, future state regulations (in addition to energy codes) may cover ACF.
- States will be free to use whatever metric and test procedure they desire for fan-efficiency regulations and be able to set their own minimum thresholds, labeling requirements, and enforcement provisions.
- State fan regulations, other than California, could be in effect as soon as 2027, as grace periods for state regulations typically are one year.
- State fan regulations could remain in effect for five years following publication of a federal energy-conservation standard because the DOE provides a five-year grace period when an appliance or equipment is federally regulated for the first time.
- Engineers, distributors, contractors, manufacturers, and others would have to learn about and comply with different flavors of the same requirements across states.
- Code officials, state attorneys, and regulatory agencies would have to learn to administer and enforce unique requirements on a state-by-state basis.
Even if fans and blowers remain covered under the EPCA, numbers 1, 2, 4, and 5 are likely.
Energy Codes
Model energy codes published by ASHRAE and the ICC are “adopted” by states and other jurisdictions in whole or in part, with provisions tailored to reflect local construction practices as well as environmental goals and other policy initiatives. States can adopt the current or an older version of a model energy code or create their own energy code from scratch (e.g., California’s Title 24 commercial energy code). What’s more, states can update their energy code on a regular cycle (usually every three years) or not at all.
Although model and state energy codes provide a measure of stability for fan-efficiency requirements, there is considerable variety among them. AMCA International researched the prevalence of “FEI” in projects across the United States in 2024 and found approximately 400 occurrences, which, given the California regulation and FEI having been in ANSI/ASHRAE/IES Standard 90.1, Energy Standard for Buildings Except Low-Rise Residential Buildings, since 2019 and the International Energy Conservation Code (IECC) since 2021, seems to indicate slow uptake. Also, substantial deviation already is being seen with regard to the structure of state code provisions, based on the NOPR for the federal energy-conservation standard still being public.
Updates to Model Energy Codes
By the time you are reading this, the 2025 edition of ANSI/ASHRAE/IES Standard 90.1 likely will be published. The 2025 edition will change the reference standard for calculating FEI ratings in DOE jurisdictions from ANSI/AMCA Standard 208, Calculation of the Fan Energy Index, to the DOE test procedure (CFR), with “hedge” wording in the event fans are removed from EPCA coverage, in which case the reference standard would revert back to ANSI/AMCA Standard 208. ANSI/ASHRAE/IES Standard 90.1-2025 will require ACF to be tested per the CFR or, in the event fans are removed from EPCA coverage, ANSI/AMCA Standard 230, Laboratory Methods of Testing Air Circulating Fans for Rating and Certification.
The same changes have been proposed for the 2027 IECC. A difference between ANSI/ASHRAE/IES Standard 90.1 and the IECC is language that effectively requires fans to be third-party-tested and fan ratings to be certified. The AMCA International Certified Ratings Program (CRP) qualifies for this requirement (to find fans with AMCA International-certified ratings, click here).
Meanwhile, several states continue to reference older (pre-2013) versions of model energy codes that do not have a fan-efficiency provision or reference ANSI/AMCA Standard 205, Energy Efficiency Classification for Fans, which uses the outdated (2013-2018) fan-efficiency-grade (FEG) metric.
Table 1 summarizes the status of baseline model energy codes for CIFB above 1 hp or 890 W electrical power. Note that other provisions of energy codes that relate to fans, such as fan power limits, are beyond the scope of this article.
State Energy Codes
In 2013, the DOE published a framework document effectively eliminating FEG from consideration as a suitable metric for a federal efficiency regulation for fans, citing FEG’s 15-percentage-point selection window and applicability to only peak total pressure. AMCA International, AMCA International member companies, and other stakeholders responded by developing FEI. By the time FEI was standardized in 2018, however, FEG was established in model and state energy codes via the 2013 edition of ANSI/ASHRAE/IES Standard 90.1 and the 2015 IECC (their updates, the 2016 edition of ANSI/ASHRAE/IES Standard 90.1 and the 2018 IECC, also use FEG). Today, FEG still appears in 17 states’ energy codes. Although publication of the federal test procedure made FEI the “law of the land,” at the current pace of updates, it will take these states years to transition to FEI.
Figure 1 shows states that use FEG vs. those that use FEI. States adopting the 2019 or a later edition of ANSI/ASHRAE/IES Standard 90.1 or the 2021 or a later edition of the IECC (FEI) are colored blue. Some home-rule states (Colorado, New Mexico, Hawaii) had sufficient dominance by major cities to be colored blue.
TABLE 1. Status of baseline model energy codes for CIFB.
Even if an energy code cites FEG requirements, manufacturers are required by federal law to rate fans using FEI, although they are permitted to publish “companion” FEG ratings. Generally, this is accomplished through fan-selection software, as FEI and FEG can be calculated using the same rating test data.
Table 2 shows states’ adoption of specific energy codes.
Air-Circulating Fans
You may be wondering why, all of a sudden, ACF are being regulated.
Long ago, an employee of a company producing a catalog for a manufacturer of ACF (axial fans in cages commonly seen in baseball dugouts, on plant floors, and in bus depots) wrote to DOE legal counsel asking if the DOE regulated ACF with ceiling-mounting kits as ceiling fans. Reading the then-definition of ceiling fan published in the CFR, the DOE legal counsel answered yes, thus, expanding the ceiling-fan regulation to fans not previously covered. The DOE eventually modified the definition of ceiling fan in a way that excluded ACF before later adding ACF to the rulemaking for CIFB.
Because the test procedure for CIFB does not apply to ACF, the DOE published a separate test procedure (based on ANSI/AMCA Standard 230) for ACF that required a separate energy-conservation standard, leading the DOE to have parallel rulemakings for CIFB and ACF. Unlike the CIFB test procedure, which requires a single sample, the ACF test procedure requires two samples of the same model, which effectively eliminated the vast majority of existing ACF performance ratings, meaning manufacturers were legally required to retest most, if not all, of their in-scope products by October 2023. With the draft energy-conservation standard for ACF withdrawn along with the draft energy-conservation standard for CIFB and coverage under the EPCA in question, ACF are in the same boat as CIFB. This is a shame because ACF performance ratings are notoriously inaccurate, as many manufacturers publish ratings based on tests to the 1999 edition of ANSI/AMCA Standard 230, which contains an error resulting in overstatements of airflow performance by a factor of 1.41 (square root of two). Even though AMCA International corrected the error in subsequent editions, many manufacturers continue to use the 1999 edition.
To help nudge ratings toward uniformity and conformance to the federal test procedure or, in the event ACF are withdrawn from coverage under the EPCA, the current edition of ANSI/AMCA Standard 230, AMCA International submitted change proposals to add ACF testing per the CFR to ANSI/ASHRAE/IES Standard 90.1, the IECC, and the Florida and Washington energy codes, with a minimum fan size of 200 W electrical input power. The 200 W is above the DOE minimum of 125 W and is meant to separate residential and commercial products. For the Florida and Washington energy codes, AMCA International’s proposals led to a minimum efficacy (cfm/W) based on fan diameter:
FIGURE 1. Fan-efficiency-metric adoption by state (based on Sept. 30, 2025, update of Table 1 at https://energycodes.gov/state-portal).
TABLE 2. Energy-code adoption by state.
where:
Effcirc = efficacy for ACF (cfm/W)
D = for unhoused fans, impeller diameter; for housed fans, the lesser of impeller diameter and equivalent diameter (inches)
Q = ACF airflow rate, determined by referenced test procedure at maximum fan speed (cubic feet per minute)
Equivalent diameter is the diameter of a circle with the same area as another geometric shape. For a rectangular cross-section with width a and height b, equivalent diameter is:
D= (4ab/Π)0.5
AMCA International’s change proposals are moving forward but with slight differences: ANSI/ASHRAE/IES Standard 90.1 neither has an efficiency requirement nor requires certification; the IECC does not have an efficiency requirement but requires certification (i.e., independent “testing and labeling”); the Florida energy code has a minimum efficiency requirement and requires certification; and the Washington energy code has a minimum efficiency requirement but does not require certification. ACF requirements are in neither the 2025 nor the 2023 editions of California Title 20 and California Title 24.
Conclusion
With this article, AMCA International seeks to help industry professionals track and comply with the variety of fan-efficiency metrics, standards, references, and requirements across federal, state, and municipal jurisdictions. From the beginning, AMCA International has collaborated with federal and state agencies, non-governmental organizations, other industry associations, and subject-matter experts toward practical, reasonable, and enforceable regulations for fans. AMCA International hopes the DOE retains EPCA coverage for fans and preserves the test procedures currently in effect, eventually publishing an energy-conservation standard providing uniform requirements across the states. In the interim, AMCA International will work with state agencies and other stakeholders to develop fan regulations that are consistent state by state.
References
- DOE. (2023, May 1). Energy conservation program: Test procedure for fans and blowers. Federal Register. Retrieved from https://bit.ly/DOE_CIFB
- DOE. (2022, August 16). Energy conservation program: Test procedure for ceiling fans. Federal Register. Retrieved from https://bit.ly/DOE_Ceiling_Fans
- Ivanovich, M. (2023). Dawn of a new era: The regulation of commercial and industrial fans and blowers. AMCA inmotion, pp. 2-10. Retrieved from https://url.td/AI23_Ivanovich
- Taber, C. (2023). U.S. regulations for air-circulating fans. AMCA inmotion, pp. 12-18. Retrieved from https://url.td/AI23_Taber
About the Author
Michael Ivanovich is senior director, advocacy and education, for Air Movement and Control Association (AMCA) International. In this role, he works with committees in North America, Asia, Europe, and the Middle East to develop strategies and programs that manifest the mission of the association “to advance the knowledge, growth, and integrity of the air-movement-and-control industry.”
Exceptions
Though there is much diversity among them, energy codes and regulations for commercial and industrial fans and blowers (CIFB) have one thing in common: exceptions that alter the scope of what is covered and what is not. An explanation of the exceptions could be a lengthy article in itself, so readers are referred to the 2023 edition of AMCA inmotion3,4 or encouraged to pay particular attention to the exceptions in whatever code or regulation they are concerned about.
Getting Fan Specifications Right
In the face of inconsistency and confusion concerning fan-efficiency requirements, here are tips for gaining confidence you will at least meet “law” or “code”:
- For California, confirm commercial- and industrial-fan models meet Title 24 commercial requirements (if required) and are compliant with Title 20 by being registered in the Modernized Appliance Efficiency Database System (MAEDbS).
- For energy codes, specify AMCA International-certified fans using this language: All [type] fans shall have a Fan Energy Index (FEI) rating not less than [1.00 for constant-speed fans or 0.95 for fans in variable-air-volume systems] and be licensed to bear the AMCA Certified Ratings Program seal for air performance [sound performance, if applicable] and Fan Energy Index.
- For air-circulating fans (ACF), require test reports showing models comply with federal-test-procedure requirements for ratings and two-sample testing. Such test reports must bear a post-Oct. 30, 2023, date to indicate conformance.
- Visit https://url.td/CRP_Directory to search for AMCA International-certified products by manufacturer, product type, or license type.
Ceiling-Fan Regulations and Codes
The U.S. Department of Energy (DOE) added large-diameter (blade span exceeding 7 ft [2.1.m]) ceiling fans (LDCF) to federal ceiling-fan regulations in 2017 and changed the metric to ceiling-fan energy index (CFEI) in 2020, setting minimum CFEI thresholds that took effect in 2021. As shown in Table 3, an updated test procedure was published in 2022 and took effect in 2023. A scheduled update of the energy standard that increased minimum CFEI requirements was written in 2024 but, like the draft energy-conservation standard for commercial and industrial fans and blowers (CIFB) and air-circulating fans (ACF), withdrawn in 2025. As a consequence, ceiling fans must continue to meet federal energy performance per the CFR of Jan. 21, 2020.
Meanwhile, CFEI was adopted for mechanical and energy codes beginning with the 2018 edition of the International Mechanical Code (IMC), the 2019 edition of ANSI/ASHRAE/IES Standard 90.1, and the 2021 edition of the International Energy Conservation Code (IECC). Minimum CFEI requirements were included in subsequent editions and updates have been proposed for upcoming editions. Table 3 summarizes those developments.
IMC, ANSI/ASHRAE/IES Standard 90.1, and IECC provisions for LDCF require certified CFEI ratings. To find AMCA International-certified ratings, click here. Under “Product Types,” click “Large Diameter Ceiling Fan.”
TABLE 3. Codes and standards for large-diameter ceiling fans.
Air Movement and Control Association International, Inc.