By Ray McGowan

Non NFRC certified commercial window energy ratings are frequently submitted for energy code compliance.  Documents submitted making reference to NFRC 100 and NFRC 200, which can vary widely, may be submitted as evidence of energy code compliance and but they may not meet the NFRC 100 and/or 200 requirements the reasons described below.

If a submitted document references the NFRC 100, it may not comply since NFRC 100, section 4.1.1 (compliance, product line simulation and testing) mandates each product line must have an associated validation test.  For products rated using CMAST, section 5.9.4 requires each framing product line to have an associated validation test.    A code compliance document referencing NFRC 100 and/or 200, without the required associated product line validation test, does not fully comply with NFRC 100 and should not be accepted as proof of energy code compliance.  The same is true of a CMAST bid report unless it is using approved framing components, not those in the design stage, which then have a validation test associated with the framing product line.

National energy code documents, such as the International Energy Conservation Code (IECC), CA Title 24, and ASHRAE 90.1, require window energy performance be determined according to NFRC 100 and NFRC 200. Without the required validation testing, NFRC 100 and 200 requirements are not satisfied. 

Therefore, NFRC advises the industry any non-validated NFRC 100 (U-factor) referencing report or document may not be fully NFRC 100 and 200 compliant and may not satisfy the IECC, CA Title 24, and ASHRAE 90.1 code requirements for NFRC 100 and 200.  These documents should not be used for energy code compliance without  the required validation testing documentation for the associated product line (or using approved framing components in CMAST). Please contact NFRC with questions on any energy code document where this may apply.

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