On October 22, 2026, ANRE opened consultation on draft amendments concerning gas and electric water heaters. The proposal revises the Energy Conservation Act enforcement framework and manufacturer performance criteria, including methods for evaluating energy use across gas, heat-pump, electric-resistance, fuel-cell and hybrid technologies.

The draft is intended to support efficiency and non-fossil-energy objectives and may require future product-data and design planning changes. Comments close on November 20, 2026 and no final compliance date has yet been established by the consultation notice.

Impact

Impact assessment: Medium.

Key reasons: The proposal could materially change the metrics, calculation methods and manufacturer performance planning for multiple water-heater technologies, but final criteria and implementation timing remain pending.

Who is affected?

Manufacturers and importers of residential water heaters, component suppliers, test laboratories, energy-efficiency teams, Japanese distributors and organizations responsible for product performance data.

Conclusion:

Identify in-scope models, compare current test and calculation methods with the draft criteria, estimate portfolio effects and submit comments by November 20. Do not change declarations or compliance claims until final rules and transition provisions are published.