Mandatory Requirement Updated Guidance
Section 120.6(a)3D of the 2025 Energy Code requires fan-powered evaporators in refrigerated warehouses to meet minimum specific efficiency requirements and to demonstrate compliance with those requirements using the test procedures specified in Air-Conditioning, Heating and Refrigeration Institute (AHRI) Standard 420 (“AHRI 420”).
Several interested members of the public have submitted comments to the California Energy Commission (CEC) expressing concerns that requiring AHRI 420 testing procedures introduces significant costs. AHRI 420 testing has not been widely adopted, with only one manufacturer certifying its products under AHRI 420.
CEC staff investigated the issue and determined that the analysis supporting the mandatory specific efficiency requirements for fan-powered evaporators in refrigerated warehouses supports the use of AHRI 420 testing conditions. However, it does not support requiring AHRI 420 test procedures or AHRI 420 certification. The 2025 Energy Code Refrigeration Final CASE Team Report, which evaluates these systems, is available on the CEC website.
Based on the original analysis, CEC staff recommend that enforcement agencies exercise their enforcement discretion and refrain from allocating resources to enforce AHRI 420 certification requirements for fan‑powered evaporator specific efficiency under Section 120.6(a)3D.
Further Information
Questions about this guidance or the Building Energy Efficiency Standards in general may be directed to the Energy Code Hotline Submission Form.