SUPPLEMENTARY INFORMATION: 

Table of Contents

I. Introduction

A. Authority

B. Scope and History of Rulemakings for Distribution Transformers

C. Presidential Determination

II. Request for Information and Comments

III. Submission of Comments

IV. Approval of the Office of the Secretary

I. Introduction

The following section briefly discusses the background underlying this request for information (“RFI”) concerning the effect of Federal energy conservation standards on the distribution transformers market.

A. Authority

The Energy Policy and Conservation Act (“EPCA”) ^[1] authorizes DOE to regulate the energy efficiency of a number of consumer products and certain industrial equipment. (42 U.S.C. 6291-6317, as codified) Title III, Part C of EPCA ^[2] added by Public Law 95-619, Title IV, section 441(a), established the Energy Conservation Program for Certain Industrial Equipment, which sets forth a variety of provisions designed to improve energy efficiency. (42 U.S.C. 6311-6317) The Energy Policy Act of 1992, Public Law 102-486, amended EPCA and directed DOE to prescribe energy conservation standards for those distribution transformers for which DOE determined such standards ( printed page 35904) would be technologically feasible, economically justified, and would result in significant energy savings. (42 U.S.C. 6317(a)) The Energy Policy Act of 2005, Public Law 109-58, amended EPCA to establish energy conservation standards for low-voltage dry-type (“LVDT”) distribution transformers. (42 U.S.C. 6295(y))

EPCA further provides that, not later than six years after the issuance of any final rule establishing or amending a standard, DOE must publish either a notice of determination that standards for the product do not need to be amended, or a NOPR including new proposed energy conservation standards (proceeding to a final rule, as appropriate). (42 U.S.C. 6316(a); 42 U.S.C. 6295(m)(1))

B. Scope and History of Rulemakings for Distribution Transformers

This RFI relates to distribution transformers as defined in 10 CFR 431.192.^[3] DOE prescribed the currently applicable energy conservation standards for distribution transformers manufactured on or after January 1, 2016, in a final rule published on April 18, 2013. 78 FR 23336 (“April 2013 Final Rule”). DOE published a final rule on April 22, 2024, that adopted amended energy conservation standards for distribution transformers manufactured on or after April 23, 2029. 89 FR 29834 (“April 2024 Final Rule”).

C. Presidential Determination

On April 20, 2026, President Trump issued Presidential Determination No. 2026-10, pursuant to Section 303 of the Defense Production Act of 1950, as amended (“DPA”) (50 U.S.C. 4533), that found that grid infrastructure and its associated upstream supply chains, including transformers, transmission lines and conductors, substations, high-voltage circuit breakers, power control electronics, protective relay systems, capacitor banks, electrical core steel, and related raw material and manufacturing tools, are industrial resources, materials, or critical technology items essential to national defense. Presidential Determination No. 2026-10 of April 20, 2026, Presidential Determination Pursuant to Section 303 of the Defense Production Act of 1950, as Amended, on Grid Infrastructure, Equipment, and Supply Chain Capacity,91 FR 21931 (Apr. 23, 2026) (“Presidential Determination”). The Presidential Determination, consistent with Executive Order 14156 of January 20, 2025, Declaring a National Energy Emergency,^[4] also found that without Presidential action, U.S. industry cannot reasonably be expected to provide these capabilities in a timely manner due to limited domestic production capacity, extended procurement timelines, foreign supply dependence, and insufficient capital investment. Also, the Presidential Determination found that purchases, purchase commitments, financial support for the development of production capabilities, or other action pursuant to Section 303 of the DPA are the most cost-effective, expedient, and practical alternative methods for meeting this need.

The Presidential Determination directed the Secretary of Energy to implement the determination, including making necessary purchases, commitments, and financial instruments, to expand domestic capability to develop, manufacture, and deploy grid infrastructure and supporting industrial supply chains. Transformers and electrical core steel are expressly identified as covered industrial resources under that determination.

These national security findings are directly relevant to DOE's administration of energy conservation standards for distribution transformers, adopted in the April 2024 Final Rule. For certain equipment classes, DOE estimated that compliance with the adopted efficiency levels would be met by transitioning to amorphous-core transformer designs, which rely on material and manufacturing processes distinct from those used for grain-oriented electrical steel (“GOES”) core transformers that constitute the majority of current market production. 78 FR 29834, 30011.

II. Request for Information and Comments

In this RFI, DOE seeks data and information relevant to understanding how the energy conservation standards for distribution transformers adopted in the April 2024 Final Rule interact with U.S. domestic manufacturing capacity, supply chain resilience, and the National defense considerations identified in the Presidential Determination. DOE also seeks suggestions on what actions it could take to implement the Presidential Determination and what actions it could take to expand domestic capability to develop, manufacture, and deploy more distribution transformers in the near term to meet the nation's energy demand to ensure United States defense readiness, economic strength, and energy independence.

Additionally, DOE also requests information on whether the standards adopted in the April 2024 Final Rule result in special hardship, inequity, or unfair distribution of burdens to manufacturers, utilities, consumers, or other end-users.

Where possible, DOE requests and encourages that respondents provide quantitative estimates and describe the assumptions.

Information on how to submit comments, data, and other information, including Confidential Business Information (CBI), is provided in section III of this document.

In this section, DOE identifies specific issues for which it seeks comment, data, and other information.

Issue 1: DOE requests information regarding whether, and how, the national security considerations identified in the Presidential Determination—including limited domestic production capacity, foreign supply dependence and extended procurement timelines—are impacted by the April 2024 Final Rule. Specifically, DOE seeks information on (a) whether compliance with the adopted standards would require or increase reliance on foreign-sourced amorphous steel or other materials or components that raise national security concerns; (b) whether the adopted standards could reduce domestic production capacity for raw GOES, GOES cores, or GOES-core transformers, and if so, what effects that reduction would have on the resilience of U.S. grid infrastructure supply chains; and (c) any other interactions between the adopted standards and the national defense findings in the Presidential Determination that DOE should consider.

Issue 2: In the April 2024 Final Rule, DOE acknowledged ongoing supply chain challenges associated with distribution transformers ( e.g., a single domestic manufacturer of GOES and a single domestic manufacturer of amorphous alloy, trade uncertainties, limited capacity of lower-loss GOES, limited global capacity of amorphous ( printed page 35905) alloy, labor shortages) and the broader electric grid ( e.g., substantial load growth increasing demand for all grid components, increasing product lead times). 89 FR 29834, 29866. DOE requests information regarding whether, and for whom, the adopted standards may result in special hardship, inequity, or an unfair distribution of burdens ( e.g., manufacturers, utilities or cooperatives, particular regions, or consumers of particular transformer types and sizes). DOE specifically requests information on whether smaller or resource-constrained entities would face greater compliance challenges, including due to scale economies, input access, or financing constraints, and whether such impacts vary systematically by firm size or operational scale. DOE requests information on the mechanisms driving such impacts (including material availability, production constraints, and procurement practices) and any potential flexibilities or alternative approaches that DOE should consider, consistent with applicable laws (such as EPCA, DPA, and other relevant authorities related to trade, taxation, and financing), to address demonstrated impacts—especially those to smaller entities. DOE also requests data regarding impacts on end users, including any changes in equipment costs, installation costs, procurement lead times, and reliability or service outcomes that could affect ratepayers or other customers.

Issue 3: DOE requests information and data regarding investments to develop, manufacture, and deploy more distribution transformers made since publication of the April 2024 Final Rule ( e.g., general or specific sunk costs such as capital equipment purchases, facility expansions, workforce changes, equipment redesign activities, and supplier development). DOE requests that, to the extent practicable, respondents distinguish between investments made primarily to meet the adopted energy conservation standards and investments made primarily to expand production capacity or otherwise respond to broader grid-driven demand growth.

Issue 4: DOE emphasized in the April 2024 Final Rule that distribution transformers are critical grid infrastructure and that maintaining and strengthening national manufacturing capacity, including for key inputs such as electrical steel, is an important consideration as the U.S. works to expand and modernize the electric grid. DOE requests information regarding how the distribution transformer supply chain (including lead times, order backlogs, inventory practices, supplier qualification timelines, and the availability and cost of key components and materials) has been affected and is anticipated to be affected since publication of the April 2024 Final Rule. DOE requests that, to the extent practicable, respondents distinguish between any expected impacts resulting from the standards promulgated by the April 2024 Final Rule ( e.g., challenges with sourcing certain low-loss GOES, challenges with sourcing amorphous alloy, any stranded assets based on the April 2024 Final Rule, any labor challenges based on the April 2024 Final Rule) versus other factors contributing to the current supply chain shortages experienced by the distribution transformer market ( e.g., broader demand growth driven by electrification, data centers, etc.).

Issue 5: DOE requests information on the conditions under which the distribution transformer, electrical steel, or related components industry could expand production capacity to meet current and projected demand. Specifically, DOE seeks information on the regulatory certainty and the extent to which the current or anticipated regulatory requirements affect investment planning, capital allocation, and the willingness of firms to expand production capacity; lead times for capacity expansion including typical lead times to increase production capacity for distribution transformers and key inputs; the primary drivers of lead time for capacity expansion ( e.g., capital equipment procurement, facility construction, workforce development, etc.); constraints on expansion including any key bottlenecks that limit the ability to expand production; investment conditions including the specific market conditions, transformer prices, contract structures, demand visibility, and risk-sharing that allow for distribution transformer expansion; and the relative competitiveness of domestic manufacturing as compared to imported transformers or transformer components and how that influences investment decisions.

Issue 6: DOE requests information on the price levels or market conditions under which expanding domestic production of distribution transformers and key inputs becomes an economically viable investment. DOE also seeks information on how those conditions compare to the price, availability, and delivery timelines of imported transformers or transformer components serving the U.S. market, including the extent to which imports influence investment decisions. DOE also requests responses regarding the driving factors for transformer investment decisions including the relative importance of current spot prices, demand projections, and the presence of long-term purchasing contracts.

Issue 7: DOE requests information regarding any changes since publication of the April 2024 Final Rule to domestic production of distribution transformers or related components serving the U.S. market. DOE also requests information on changes in sourcing practices, including increased importation of completed transformers or subassemblies ( e.g., cores, core/coil assemblies, windings, tanks, or other components) and any changes in the location of final assembly. Where possible, DOE requests and encourages that respondents provide quantitative estimates and describe the assumptions.

Issue 8: DOE requests information regarding any changes to the price, quality, specifications, and available capacity of GOES serving the U.S. distribution transformer market, including any changes in the percentage of domestically produced GOES used in U.S.-sold distribution transformers. DOE also requests data on how domestically produced GOES supply compares with global GOES supply with respect to price, quality, available capacity, specifications, and delivery timelines. DOE requests data on how the price, quality, specification, capacity and suppliers of GOES vary between markets ( e.g., the liquid-immersed distribution transformer market, low-voltage dry-type distribution transformer market, medium-voltage dry-type distribution transformer market, large-power transformer market). Where possible, DOE requests and encourages that respondents provide quantitative estimates and describe the assumptions.

Issue 9: DOE requests information regarding any changes to the price, quality, specifications, qualification timelines, and available capacity of amorphous alloy serving the U.S. distribution transformer market, including any changes in the percentage of domestically produced amorphous alloy used in U.S.-sold distribution transformers. DOE also requests data on how domestically produced amorphous steel supply compares with global supply with respect to price, quality, capacity, delivery timelines, and contracting practices. Where possible, DOE requests and encourages that respondents provide quantitative estimates and describe the assumptions.

Issue 10: DOE requests information regarding the availability, lead times, and constraints associated with ( printed page 35906) manufacturing distribution transformer cores (including core cutting, winding, stacking, annealing, and related equipment), and the extent to which core manufacturing capacity (domestic and global) may limit the ability of manufacturers to meet the adopted standards. DOE requests data regarding any differences in core sourcing practices between distribution transformer cores made of GOES versus amorphous alloy as well as between markets ( e.g., the liquid-immersed distribution transformer market, low-voltage dry-type distribution transformer market, medium-voltage dry-type distribution transformer market, large-power transformer market).

Issue 11: DOE requests information on domestic-content considerations for distribution transformers and key inputs (including GOES and amorphous alloy). DOE requests data on any major supply chain risks, the feasibility of increasing domestic content over time, and any barriers to doing so ( e.g., certification requirements, supplier qualification, metallurgical specifications, or trade and logistics constraints).

Issue 12: DOE requests information regarding the extent to which amorphous alloy use is expected to be “additive” to existing GOES distribution transformer production ( i.e., added for certain basic models while most production continues to use GOES) versus requiring conversion or replacement of existing GOES distribution transformer production equipment. DOE requests information on expected ramp rates, equipment needs, and any constraints on scaling amorphous-core distribution transformer production over the compliance period.

Issue 13: DOE requests information regarding how private sector distribution transformer investments (including investments driven by the adopted standards) complement ( i.e., new facilities that manufacture distribution transformers along with multiple grid components and share resources), compete with ( i.e., investments made in meeting efficiency standards that otherwise would be made in expanding capacity of other grid components), or displace other grid-related investments (including other transformers, transmission lines and conductors, substations, high-voltage circuit breakers, power control electronics, protective relay systems, capacitor banks, electrical core steel, and related raw material and manufacturing tools). DOE requests information and data on shared constraints ( e.g., skilled labor, electrical steel and other magnetic materials, and capital equipment) and whether these constraints affect investment timing or prioritization.

Issue 14: In light of the Presidential Determination and the findings that grid-infrastructure supply chains are essential to national defense, DOE requests information regarding the defense-readiness, economic strength, and energy independence implications of the standards adopted in the April 2024 Final Rule, including in relation to Federal purchase commitments and financial support actions under Section 303 of the DPA. Specifically, DOE requests information on whether the adopted standards could reduce the ability of the U.S. transformer industry to surge production in response to a national emergency, natural disaster, or other disruption requiring rapid grid restoration; the extent to which compliance with the adopted standards would increase U.S. reliance on foreign sources; whether compliance would affect the domestic electrical steel industry's production volumes, pricing, and long-term viability in ways that could impair national defense readiness; and any recommendations for how DOE could structure regulatory flexibilities, in accordance with applicable law, to support the national defense priorities identified in the Presidential Determination.

Issue 15: DOE requests information regarding how the interaction between the April 2024 Final Rule and the national defense considerations identified in the Presidential Determination—including Federal purchase commitments, financial support actions under Section 303 of the DPA, and priority-rated orders under the DPA ^[5] —affects smaller utility purchasers of distribution transformers, including rural electric cooperatives, municipal and public power utilities, and small investor-owned utilities not on critical project tracks. Specifically, DOE seeks information on changes in procurement lead times and order priority experienced by such purchasers, including any existing evidence of displacement in manufacturer order queues.

Issue 16: DOE requests information regarding price effects and changes in contract terms offered to the smaller utility purchasers, including minimum order quantities, no-substitute or specification-substitution clauses, payment and deposit terms, escalation provisions, and the availability of multi-year framework agreements since publication of the April 2024 Final Rule. Where possible, DOE requests and encourages that respondents provide quantitative estimates and describe the assumptions.

Issue 17: DOE also seeks suggestions on what actions are needed, consistent with applicable law, to implement the Presidential Determination and what actions are needed in the near term to expand domestic capability to develop, manufacture, and deploy more distribution transformers to meet the nation's energy demand to ensure United States defense readiness, economic strength, and energy independence.

III. Submission of Responses

DOE invites all interested parties to submit in writing by the date specified in the DATES section of this document, information on matters addressed in this document and on other matters relevant to distribution transformers.

Submitting responses via www.regulations.gov. The www.regulations.gov web page requires you to provide your name and contact information. Your contact information will be viewable to DOE Building Technologies Office staff only. Your contact information will not be publicly viewable except for your first and last names, organization name (if any), and submitter representative name (if any). If your response is not processed properly because of technical difficulties, DOE will use this information to contact you. If DOE cannot read your response due to technical difficulties and cannot contact you for clarification, DOE may not be able to consider your response.

However, your contact information will be publicly viewable if you include it in the response or in any documents attached to your response. Any information that you do not want to be publicly viewable should not be included in your response, nor in any document attached to your response. If this instruction is followed, persons viewing responses will see only first and last names, organization names, correspondence containing information, and any documents submitted with the responses.

Do not submit to www.regulations.gov information for which disclosure is restricted by statute, such as trade secrets and commercial or financial information (hereinafter referred to as Confidential Business Information (“CBI”)). Responses submitted through www.regulations.gov cannot be claimed ( printed page 35907) as CBI. Responses received through the website will waive any CBI claims for the information submitted. For information on submitting CBI, see the Confidential Business Information section.

DOE processes submissions made through www.regulations.gov before posting. Normally, responses will be posted within a few days of being submitted. However, if large volumes of responses are being processed simultaneously, your response may not be viewable for up to several weeks. Please keep the tracking number that www.regulations.gov provides after you have successfully uploaded your response.

Submitting responses via email, hand delivery/courier, or postal mail. Responses and documents submitted via email, hand delivery/courier, or postal mail also will be posted to www.regulations.gov. If you do not want your personal contact information to be publicly viewable, do not include it in your response or any accompanying documents. Instead, provide your contact information on a cover letter. Include your first and last names, email address, telephone number, and optional mailing address. The cover letter will not be publicly viewable as long as it does not include any information responsive to the request for information.

Include contact information each time you submit data, documents, and other information to DOE. If you submit via postal mail or hand delivery/courier, please provide all items on a CD, if feasible, in which case it is not necessary to submit printed copies. No faxes will be accepted.

Data, and other information submitted to DOE electronically should be provided in PDF (preferred), Microsoft Word or Excel, WordPerfect, or text (ASCII) file format. Provide documents that are not secured, written in English and free of any defects or viruses. Documents should not contain special characters or any form of encryption and, if possible, they should carry the electronic signature of the author.

Campaign form letters. Please submit campaign form letters by the originating organization in batches of between 50 to 500 form letters per PDF or as one form letter with a list of supporters' names compiled into one or more PDFs. This reduces processing and posting time.

Confidential Business Information. Pursuant to 10 CFR 1004.11, any person submitting information that he or she believes to be confidential and exempt by law from public disclosure should submit via email two well-marked copies: one copy of the document marked confidential including all the information believed to be confidential, and one copy of the document marked “non-confidential” with the information believed to be confidential deleted. DOE will make its own determination about the confidential status of the information and treat it according to its determination. Persons seeking to submit confidential information through alternative means are encouraged to contact DOE for additional guidance.

It is DOE's policy that all responses may be included in the public docket, without change and as received, including any personal information provided in the responses (except information deemed to be exempt from public disclosure).

DOE considers public participation to be a very important part of the process for developing energy conservation standards. DOE actively encourages the participation and interaction of the public during the comment period in this process. Interactions with and between members of the public provide a balanced discussion of the issues and assist DOE. Anyone who wishes to be added to the DOE mailing list to receive future notices and information about this process or would like to request a public meeting should contact Appliance and Equipment Standards Program staff at (202) 287-1445 or via email at ApplianceStandardsQuestions@ee.doe.gov.

IV. Approval of the Office of the Secretary

The Secretary of Energy has approved publication of this request for information.

Signing Authority

This document of the Department of Energy was signed on June 10, 2026, by Audrey Robertson, Assistant Secretary (EERE) for Critical Minerals and Energy Innovation, pursuant to delegated authority from the Secretary of Energy. That document with the original signature and date is maintained by DOE. For administrative purposes only, and in compliance with requirements of the Office of the Federal Register, the undersigned DOE Federal Register Liaison Officer has been authorized to sign and submit the document in electronic format for publication, as an official document of the Department of Energy. This administrative process in no way alters the legal effect of this document upon publication in the Federal Register .

91 FR 35903