The 2025 Energy Code includes mandatory minimum efficiency requirements for variable refrigerant flow (VRF) air conditioners and heat pumps in Table 110.2-F and Table 110.2-G. The Integrated Energy Efficiency Ratio (IEER) and Energy Efficiency Ratio (EER) efficiency metrics are based on the AHRI 1230 test procedure. In 2023, the AHRI 1230 test procedure was updated resulting in changes to IEER and EER efficiency ratings. Additionally, the U.S. Department of Energy (DOE) adopted new minimum IEER efficiency requirements based on the updated AHRI 1230 testing procedure. These DOE minimum IEER efficiency requirements went into effect on January 1, 2024. The updated AHRI 1230 test procedure and DOE minimum IEER efficiency requirements no longer align with the minimum efficiency requirements identified for VRF equipment with cooling capacity greater than or equal to 65,000 Btu/h in Table 110.2-F and Table 110.2-G of the 2025 Energy Code.
The California Energy Commission (CEC) advises the following:
- Enforcement agencies should enforce updated federal minimum efficiency requirements for IEER for all VRF equipment with cooling capacity greater than or equal to 65,000 Btu/h, see 10 CFR 431.97(g)(2).
- Enforcement agencies are not required to enforce EER minimum efficiencies identified in Table 110.2-F and Table 110.2-G for all VRF equipment with cooling capacity greater than or equal to 65,000 Btu/h.
This follows recommendations included in the December 16, 2024 Regulatory Advisory for VRF Minimum Efficiency Requirements for the 2022 Energy Code.