California leads the way in air filter regulations: TITLE 20

Created by Yasar Kiyak | |   HVAC & Air Purifier

California, as always, leads the way in sustainability. Increasing the energy efficiency of products is considered one of the pillars of sustainable energy policy. And air filter energy efficiency regulation is right about this policy. If one sells (or offers for sale) air filter products in California, the state’s Appliance Efficiency Regulations (Title 20) should be taken into consideration. In this article, I would like to discuss the bullet points of air filter labeling requirements in California in light of Title 20.

What is TITLE 20?

California wants to be as energy efficient as possible, like every state. But California is serious about it. According to California’s primary energy policy, the California Energy Commission (CEC) can adopt rules and regulations, as necessary such as reducing the inefficient consumption of energy and water by prescribing efficiency standards and other cost-effective measures. These regulations include energy consumption marking for appliances that may save a significant amount of energy or water statewide.

Title 20 contains the state’s minimum efficiency requirements for energy and water use in regulated appliances. These appliances include but are not limited to, water heaters, furnaces, heat pumps, air conditioners, refrigerators, pumps, lamps and ballasts, computers, spray sprinkler bodies, air filters, and showerheads. As you see, Title 20 applies more than just air filters, but since filtration is my expertise, that is what I am diving into.

Who’s Responsible?

Manufacturers are responsible for certifying air filters in the California Energy Commission’s Modernized Appliance Efficiency Database System (MAEDbS). This acts as the manufacturer’s statement that it has properly met all relevant conditions, including testing, and marking products. However, everyone in the sales chain, including manufacturers, wholesalers, retailers, contractors, distributors, and importers is accountable for ensuring regulated products are listed in the MAEDbS before selling them or offering them for sale in California, including online sales.

Why We Should Care?

Per Section 1609 of Title 20, any person involved with the manufacture, distribution, and sale of noncompliant appliances may be subject to administrative fines of up to $2,500 for each non-compliant unit of the appliance that was sold or offered for sale. In other words, if a regulated item is not listed in the Title 20 database, it cannot be sold in the state of California. Title 20 is policed by the CEC, California Justice Department, and enforced at the point of sale. A violation can be found as part of a complaint and/or during a random inspection.

What does Title 20 compliance mean?

To verify the products, you are selling are compliant, a search in MAEDbS can be made. Companies should not be selling their products in California unless they are listed on the database. In other words, if the product is in the database, it the product can be legally sold in California.

When Title 20 will be effective for air filters?

On April 4th, CAC proposed amending appliance efficiency regulations for residential air filters. On Apr 7th, the Office of Administrative Law approved regulatory action which becomes effective on July 1st, 2024. Let’s look at the air filter section deeper.

What kind of air filters are in scope?

According to the air filter definition in the regulation, the following air filters are in scope: a disposable or reusable air cleaning device with filter media encased in a frame of nominal depth of no greater than six inches in residential ducted systems.

What should air filter manufacturers do?

Each manufacturer shall electronically file with MAEDbS a statement for each air filter that is sold or offered for sale in California. Following information is needed: filter dimensions, face area of tested air filter, test procedure used (ANSI/ASHRAE 52.2-2017), face velocity utilized for the test procedure, MERV rating, particle size efficiency for 0.3 to 1 micron (percentage), 1 to 3 micron and 3-10 micron, air flow rates in different rates, max air flowrate value, resistance to airflow rate at different airflow rates, and dust holding capacity. It is pretty much the full test report of the ASHRAE 52.2 test.

How should manufacturers mark air filters?

On or after July 1st, 2024, each air filter should be marked permanently on the edge of the filter itself with the following information: PSE, resistance to different airflow rates, MERV rating, and such marking should be visible through any retail packaging.

Closing remarks:

According to CEC, it is the first of its kind since there are no existing comparable federal regulations about the marking requirements for air filters. While it is a statewide regulation, its impact might be federal. Let me explain: Firstly, other states can follow similar air filter marking regulations. Secondly, what if a Californian buys an air filter online? Eventually, air filters can end up in California even though they are shipped from other states or sold online. So, everyone in the supply chain including retailers and filter manufacturers should consider this possibility. Please note that this regulation only applies to residential air filters for ducted systems.

It seems a great initiative for the energy efficiency of air filters. End users can compare the resistance values at a given MERV-rated filter from different manufacturers. With the information in the database, the right filter can be selected per the ducted forced-air heating or cooling system. Max-rated airflow value can be valuable in this choice. Moreover, end users can see how efficient their filters are for submicron particles. This could be quite useful for mitigating the infectious aerosols. Just to let you know that this regulation is not an efficiency standard.

To follow the air filter marking regulation, CEC has calculated a $0.03 incremental cost per filter, which is reasonable. I already came across some residential air filters that have such markings in North Carolina, even though it is not required to do so here. It proves that the manufacturers have already started implementing not only in California but also in other states. So, it should not be surprising to see more companies follow this trend until July 1st, 2024.


About the author:

Yasar Kiyak, Ph.D. is the R&D Manager at Gessner Filtration, a MATIV Brand. He is also a USPTO registered patent agent. He received his bachelor's and master’s degrees in Textile Engineering from Istanbul Technical University and a Ph.D. degree in Fiber and Polymer Science from NC State University. During his graduate studies, Yasar specialized in nonwovens for filtration applications. He is an innovator with a strong background in the fiber and filtration industries. Yasar can be reached at yasar.kiyak(at)