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.
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
- Congress.gov: HJRES 75 summary · fetched 2026-10-08 · official page ↗
Version history · never overwritten
| Grade | Graded | Rubric | Source hash | Status |
|---|---|---|---|---|
| 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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