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Why Can’t My Product Get a Label?

WaterSense banner headWaterSense receives many requests to develop specifications for products that aren't currently eligible for the WaterSense label. If your product isn't included on the products page, it isn't eligible for the WaterSense label. While EPA hopes to include more products in the future, each product category considered for the label undergoes certain procedures to identify, research, and finalize specifications.

What Factors does WaterSense Consider to Identify Product Categories?

EPA considers both technical and market factors when identifying product categories that are good candidates for the WaterSense product specification and labeling process. These evaluation factors include:

  • Potential for significant water savings on a national level.
  • Equal or superior product performance compared to conventional models.
  • State of technology development—product categories that rely on a single, proprietary technology will not be eligible for the label.
  • Assurance that the development of a specification will not lead to unintended or negative environmental or economic impacts
  • Ability to measure and verify water savings and performance.
  • Cost-effectiveness.

The Alliance for Water Efficiency provides information on national efficiency standards for fixtures and appliances and green specifications for indoor fixtures and appliances.  Visit the Resources section of their page on Standards and Codes for Water EfficiencyEXIT.

What is the Specification Development Process?

In developing a specification, EPA undertakes the following steps:

  • Conducts technical analysis and market research to evaluate water savings potential and environmental and economic impacts.
  • Announces intention to develop specification for a product to stakeholders, providing for input at the outset of the process.
  • Assesses existing test methods and determine the type of testing necessary for label consideration.
  • Releases draft product specifications for review and solicit input and comments from stakeholders and the general public. Stakeholder meetings and outreach are an integral part of this process.
  • Posts comments on the WaterSense Web site and revise the specification as necessary.
  • Announces final product specification.
  • Reviews existing specifications periodically to assess whether or not to update them.
  • Monitors the market to determine whether or not to develop specifications in new product areas.

What Data does WaterSense Need to Consider My Product?

EPA needs data to demonstrate that product categories meet the evaluation factors described above. If you think WaterSense should consider developing a specification for your product, you will need to send us data demonstrating water efficiency. Of greatest importance is how to measure and verify water savings for that product, and what constitutes "good" performance.

In some product categories, these data are readily available. For example, many plumbing products have defined test protocols and have been independently tested for efficiency and performance for a number of years, resulting in a large body of available data. On the contrary, other product categories have limited experience with independent testing and/or lack independent studies to demonstrate efficiency or performance.

The process of defining performance attributes and identifying protocols to test those attributes includes answering the following questions:

  • What performance attributes are important?
  • Are there defined testing methods?
  • Based on actual performance test data, do the testing methods produce consistent and reproducible results within an independent laboratory?

Once performance attributes are defined and a protocol is identified, performance levels must be set. This process includes answering the following questions based on performance test data and/or independent studies:

  • What is the existing range of product performance?
  • Are there any unintended or negative impacts caused by anticipated specification requirements?

If any of these questions cannot be answered, the data is insufficient for specification development. EPA is committed to working to fill such data gaps through research sponsored by interested parties.

If you can provide data or support development of data in these areas, please contact the WaterSense Helpline at (866) WTR-SENS (987-7367) or e-mail