Energy Department shelves its manufactured-home efficiency rule

The Energy Department said Friday that its 2022 energy-efficiency standards for manufactured homes have “no legal effect” and that it will not enforce them ^[1]. The reason is the 21st Century ROAD to Housing Act, which hands that rulemaking to HUD ^{[1, 2]}.

Why it matters: Manufactured homes make up about one in 10 new houses, Canary Media reported, and their buyers have a median household income of about $40,000, according to ACEEE ^{[5, 6]}. The DOE rule set the tradeoff those buyers would face: a higher sticker price in exchange for lower utility bills. That decision now waits on HUD ^{[1, 2]}.

By the numbers

• $660 and $4,222: DOE’s 2022 estimates of the average added purchase price for single-section and multi-section homes, in 2020 dollars ^[3].
• $177 and $475: The estimated first-year energy savings for those two home types, for simple paybacks of 3.7 and 8.9 years ^[3].
• 1994: The last time HUD updated the energy rules manufacturers build to today, ACEEE says ^[5].
• About 100,000: New manufactured homes built each year, per ACEEE ^[5].
• 6.95%: Freddie Mac’s 30-year fixed average on Sept. 17, a day after the Fed raised its target range to 3.75% to 4% ^{[7, 8]}.

How did we get here? Congress told DOE in 2007 to write efficiency standards for manufactured homes, and DOE issued them on May 31, 2022, based on the 2021 International Energy Conservation Code ^{[3, 5]}. The rule had two tiers. Single-section homes got a lighter thermal-envelope standard capped at less than $750 in added cost, while multi-section homes got the full code levels ^[3]. Compliance was set for May 31, 2023 ^[3].

It never arrived. DOE pushed the date back in 2023, then in July 2025 moved the multi-section deadline to 180 days after it publishes final enforcement procedures; single-section homes were already tied to 60 days after those procedures ^[4]. DOE never published them, and the 2025 rule says DOE was weighing “appropriate next steps” ^{[4, 5]}. HUD and USDA have also retreated this year from a separate energy code for site-built homes they finance, as this wire reported in August.

What the new law says: The ROAD to Housing Act, H.R. 6644, became law on July 11 ^[2]. Section 301(d)(2)(B) reads: “No 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 the consensus process in the 1974 manufactured housing law ^[2]. HUD must adopt minimum standards within one year of enactment and update them at least every three years ^[2].

DOE’s notice, signed Sept. 16, applies the plain reading: HUD has adopted no such standards, so the 2022 rule is inert ^[1]. DOE says it will start a rulemaking to conform its regulations to the statute ^[1].

What it means for buyers and owners

• No new efficiency requirement for now. Homes coming off factory lines remain subject to the HUD code, not the DOE tiers ^{[1, 5]}.
• A cost the buyer won’t see, and a bill they will. The DOE rule’s added purchase price is gone for now, along with the utility savings DOE projected ^{[1, 3]}.
• More designs may qualify. The same section of the law lets a manufactured home be built “with or without a permanent chassis” and has HUD set labels and standards for chassis-free homes ^[2]. ACEEE says the law also widens financing options for buyers ^[5].
• Borrowing costs are a separate squeeze. The 15-year fixed averaged 6.26% this week ^[7].

What’s next: HUD’s one-year clock runs from the law’s July 11 enactment, and DOE’s conforming rulemaking has no published date ^{[1, 2]}.

The other side: The fight over this rule predates the new law. In comments DOE summarized last year, the Manufactured Housing Institute urged it to withdraw the 2022 rule entirely and redo its cost-benefit analysis with HUD, and the Manufactured Housing Association for Regulatory Reform argued the standards hurt affordable homeownership for lower- and moderate-income buyers ^[4]. Fourteen efficiency, housing and environmental groups countered that delay would lock those same families into higher utility bills, and noted that the largest manufacturer had already switched all 39 of its U.S. factories to Zero Energy Ready Homes ^[4]. DOE itself wrote that the rule’s net benefits “require additional upfront costs paid by homeowners, which can also have a significant impact on housing affordability” ^[4].

The law split the difference. Canary Media reported that the House had passed a bill in January to lock in the decades-old standards, that the Senate pushed to keep an update, and that the final bill cleared the House with 32 “no” votes ^[6]. ACEEE’s Mark Kresowik told Canary Media that updated HUD standards “should lower the cost to live inside a manufactured home” ^[6]. Whether HUD’s standards land near DOE’s 2022 tiers, above them or below them is still open ^{[1, 2]}.