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Earthjustice, Appliance Standards Awareness Project, Natural Resources Defense Council - Comments in response to DOE solicitation of views on the implementation of test procedure waivers for large capacity clothes washers

Earthjustice, Appliance Standards Awareness Project, Natural Resources Defense Council - Comments in response to DOE solicitation of views on the implementation of test procedure waivers for large capacity clothes washers.

Groups believe manufacturers must receive a waiver before they may distribute in commerce products to which the required test procedure of the DOE cannot be applied. Test procedures for minor product changes should be sufficient - if test standards do not apply (for example, to large-capacity washers), then the change is significant enough to warrant withholding the product from the market until the manufacturer has obtained a waiver. EPCA and other DOE regulations require more strict test procedure requirements.