Air Conditioning & Refrigeration Institute v. Energy Resources Conservation & Development Commission

This case presents the question of whether federal law preempts California’s appliance regulations requiring appliance manufacturers to submit data about their appliances to California’s Energy Resources Conservation and Development Commission (“Commission”), mark their appliances with basic information such as brand name and energy performance, and be subjected to related compliance and enforcement rules. We conclude that fed eral law does not preempt California’s regulations. We therefore reverse the district court’s decision finding the regulations preempted and permanently enjoining the Commission from enforcing these regulations, vacate the injunction, and remand.

I

California boasts an extensive and laudable appliance efficiency program. As part of California’s program, the Commission has, since 1977, required manufacturers to submit data to it. The data collected by the Commission pursuant to section 1606 of Title 20 of the California Code of Regulations is maintained in an electronic database, which contains information on over 135,000 appliance models. The Commission’s database provided the foundation of information for the Environmental Protection Agency’s Energy Star…