Constitution Index · H.J.Res. 75 · 2025-03-10

Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of Energy Efficiency and Renewable Energy, Department of Energy relating to "Energy Conservation Program: Energy Conservation Standards for Commercial Refrigerators, Freezers, and Refrigerator-Freezers".

Latest official status (2025-05-09): Became Public Law No: 119-9.

Official source ↗

Constitutional grade

A

Constitutional

HJRES 75, enacted as Public Law 119-9, repeals a 2025 Department of Energy efficiency mandate for commercial refrigeration. The SI grade is A because Congress used lawful oversight power to reduce federal overreach, infringe no Bill of Rights protection, restore individual and state choice, and take no property without process.

Article I, Section 8, Clause 18 Article I, Section 7 Article I, Section 8, Clause 3 Amendment IX Amendment X Amendment V

SI-generated grade · passed automated checks (real Constitution citation, language rules) · not individually reviewed by a person · methodology · Report an error: hello@valuesforamerica.com

The five checks

Enumerated powers · passes

Congress acts within explicit authority: Article I, Section 8, Clause 18 Necessary and Proper Clause combined with oversight of executive rulemaking, and Article I, Section 7 presentment and bicameralism procedures as implemented by the Congressional Review Act at 5 U.S.C. chapter 8. Disapproving an agency rule that stretched Article I, Section 8, Clause 3 Commerce Clause authority over intrastate appliance design restores enumerated limits rather than exceeding them.

Bill of Rights · passes

Nullifying a commercial appliance efficiency mandate removes rather than imposes a restriction on 1st, 2nd, 4th, 5th, 6th, 7th, 8th and 9th Amendment interests. No speech, religion, press, arms, search, self-incrimination, trial, jury, or punishment provision is infringed. The action supports Tenth Amendment reserved powers by withdrawing federal regulation of intrastate commercial equipment choices.

Individual liberty · passes

The SI analysis finds this expands sovereignty over person, property, labor and enterprise. Manufacturers, grocers, restaurants and owners regain liberty of contract and use of property to select cost-effective refrigeration without proving freedom to the government. No compelling justification for the federal mandate was sustained by Congress, so the burden principle favors repeal.

Decentralization · passes

The SI review finds this disapproval decentralizes: (1) individuals and businesses can choose refrigeration equipment efficiency without federal compulsion; (2) local communities have no need for federal standards; (3) states can set their own efficiency or consumer-protection policies under their police powers; (4) it does not consolidate upward, it reverses upward consolidation and restores the Tenth Amendment minimum-level principle.

Due process and takings · passes

No procedural or substantive due process violation under the Fifth Amendment Due Process Clause. Notice was given through Congressional Review Act procedures in Article I, Section 7 presentment and bicameralism, signed as Public Law 119-9. No property is taken; compliance costs and retrofits required by the 2025 rule are lifted, so no Fifth Amendment Takings Clause just-compensation issue arises.

Provenance

Grade ID
212
Rubric version
vfa-constitutional-grade/1.0
Graded
2026-10-08 10:48 UTC
Engine
primary SI engine
Source fetched
2026-10-08 09:43 UTC
Source SHA-256
dcc5c61c5962223f1b75f83add69c23c50711a9454d026d662599e24613e7425
Checks
si-editorial-standard/1.0: real Constitution citation, language rules

Version history · never overwritten

GradeGradedRubric Source hashStatus
A · #212 2026-10-08 vfa-constitutional-grade/1.0 dcc5c61c5962 current

Cite this

Values for America. “Constitutional grade: H.J.Res. 75, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of Energy Efficiency and Renewable Energy, Department of Energy relating to "Energy Conservation Program: Energy Conservation Standards for Commercial Refrigerators, Freezers, and Refrigerator-Freezers"..” VFA Constitution Index, grade 212 (rubric vfa-constitutional-grade/1.0), graded October 8, 2026. https://www.valuesforamerica.com/constitution-index/grades/212. Accessed 2026-10-19.

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