Since its start in 1992, the ENERGY STAR program has become one of the most significant consumer product rating programs in the United States. Shoppers have grown accustomed to looking for the blue ENERGY STAR symbol on a wide variety of electrical devices. In the last few years, ENERGY STAR status has also become a selling point for homes and office buildings, and the program’s standards have been adopted outside the United States. More than 4.5 billion ENERGY STAR-labeled products have been sold since 1993. The U.S. Environmental Protection Agency (EPA or the Agency) credits the voluntary program with saving over US$230 billion in energy bills and preventing more than 1.8 billion metric tons of greenhouse gas emissions. Until recently, the ENERGY STAR program seemed to be one of EPA’s least controversial programs, and one more likely to be a boon than a burden or a risk to manufacturers. In the last few years, however, stepped-up enforcement actions by both EPA and the U.S. Department of Energy (DOE) have presented increased risks for those who make and sell ENERGY STAR products. In addition, plaintiffs’ lawyers have pursued class actions on behalf of consumers who purchased appliances with allegedly misleading ENERGY STAR labels..