The Energy Department says its 2022 energy-efficiency standards for manufactured homes now have 'no legal effect' and will not be enforced. A July housing law moved that job to HUD, which has one year to set standards and has not yet.
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In a one-page notice published September 18, the Department of Energy said its May 31, 2022 final rule setting energy conservation standards for manufactured homes 'has no legal effect' and that it 'will not enforce' them. The reason is the 21st Century ROAD to Housing Act, signed July 11, 2026, which says no federal energy-efficiency standard for manufactured homes has legal effect until the Department of Housing and Urban Development adopts it through its own consensus process. The law gives HUD one year, to July 2027, to adopt minimum standards and requires updates every three years. HUD has adopted none yet. DOE says it will write a rule to conform its regulations. The notice gives no estimate of the effect on home prices or energy bills and has no comment period.
In 2022 the Energy Department set energy-efficiency standards for manufactured
homes. On September 18 it said those standards no longer count.
DOE will not enforce its energy conservation standards for manufactured housing as they have no legal effect under the ROAD Act.
Why
On July 11, 2026 the 21st Century ROAD to Housing Act became law. As DOE quotes
it, the law says "[n]o energy efficiency standards for manufactured homes developed
by any Federal agency shall have legal effect unless and until adopted by the
Department of Housing and Urban Development" through HUD's consensus standards
process.
The law also gives HUD one year, to July 2027, to "adopt minimum energy
efficiency standards for manufactured homes," and requires updates every three
years. DOE's notice: "As of the date of this notification, no minimum energy
efficiency standards meeting the requirements under section 301(d) of the ROAD Act
have been adopted by HUD."
What the 2022 standards were
From earlier documents in the same docket: the 2022 rule based its standards on the
2021 International Energy Conservation Code, with a less demanding tier for
single-section homes. Its compliance date was pushed back twice, in 2023 and 2025,
the second time until after DOE published final enforcement procedures. Those
procedures were proposed in December 2023. The docket shows no final version.
What happens next
DOE "intends to initiate a rulemaking to conform DOE's regulations" to the law,
with no timeline given.
HUD has until July 2027 to adopt standards of its own.
Nothing is open for comment on this notice.
What the notice does not say
What this means for the price of a home or its energy bills. It gives no figures.
Whether any manufacturer built homes to the 2022 standards.
