WMA Regulatory Affairs Update – July 2025
- Jessica Ferris
- Aug 1
- 6 min read
June saw important regulatory activity at the state level: the Florida Building Commission’s Technical Advisory Committees met in Gainesville to hear proposed code modifications for the 9th Edition (2026) of the Florida Building Code; and Colorado approved much needed changes to the state's recent legislation on performance requirements for windows, doors, and skylights.
Florida Building Code Technical Advisory Committee Meetings The Technical Advisory Committees (TACs) for the Florida Building Code (FBC) met during the week of June 23 to review proposed public code change modifications and comments to the 8th Edition (2023) of the FBC.
While WMA did not submit any code modifications, the Regulatory Affairs and Standards Development Committee (RASDC) reviewed several structural-related proposals aimed at removing the overhang exception for doors. This exception, found in Section 1709.5.1 of the building code and Section R609.3 of the residential code, currently states that “door assemblies installed where the overhang (OH) ratio is equal to or more than 1 need not be tested for water infiltration….” The RASDC voted to oppose the removal of this exception, citing concerns that doing so would effectively eliminate the option for side-hinged doors to be tested and labeled solely to ASTM E330 or WMA 100—structural standards for design pressure ratings. The committee noted that eliminating this option would essentially subject the entire state of Florida to High Velocity Hurricane Zone (HVHZ) standards. Additionally, the change could create ADA accessibility issues and force a significant number of inswing doors to be installed as outswing.
In April, WMA submitted written comments in opposition to the proposed modifications through the Florida Building Commission’s website.
During the Structural TAC meeting on June 24, the proponent, the Insurance Institute for Business and Home Safety (IBHS), requested that the TAC deny the modifications, because they plan to collaborate with the Fenestration and Glazing Industry Alliance (FGIA) to revise the language and reintroduce it during the October Structural TAC meeting. WMA’s Director of Regulatory Affairs and Standards Development was there to voice opposition to the modifications as per WMA’s written comments and formally requested that WMA be included in revision discussions as well.
There will be a second 45-day comment period beginning August 25, where these modifications as revised will be posted. The Structural TAC meets again in early October to hear the modifications with comments submitted. Depending on how these revised modifications shape up, WMA may or may not be in support. At this juncture, the proponent seems determined to require water infiltration testing of all exterior doors installed in Florida.
Colorado Finalizes Window, Door, and Skylight Thermal Performance Requirements Following a public hearing on June 21, 2025, the Colorado Department of Public Health and Environment (CDPHE) finalized revisions to the state's performance requirements for windows, doors, and skylights.
Background: House Bill 23-1161, enacted in June 2023, required that all residential windows, doors, and skylights sold in Colorado after January 1, 2026, meet the Northern Climate Zone criteria of the ENERGY STAR program (Version 7.0). In 2024, the Colorado General Assembly adopted SB24-214, which granted the Executive Director of the CDPHE the option to evaluate and adopt an alternative standard for residential windows, doors, and skylights if the Executive Director, in consultation with the Colorado Energy Office (CEO), determined that the ENERGY STAR requirements could not reasonably be met.
The CEO conducted an analysis, which was released earlier this year, and found the ENERGY STAR criteria to be “unreasonable” and concluded that “the standard cannot be met by manufacturers without imposing too high of a financial burden on the majority of Colorado households. The standard would also significantly reduce consumer options for doors” since solid wood doors do not meet ENERGY STAR requirements, according to the May 13, 2025, Request for Rulemaking Hearing to Adopt 5 CCR 1004-2 Water and Efficiency Standards Regulation, concerning Proposed Alternative Standard to the Standard Established in C.R.S. § 6-7.5-105(5)(j) for Residential Windows, Doors and Skylights.
In its analysis, the CEO recommended more practical performance levels aligned with the 2024 International Energy Conservation Code (IECC).
Current Status: At the June 21st hearing, the CEO’s recommendation was approved and will take effect January 1, 2026. The requirements for the alternative standard are as follows:
Windows: U-factor ≤ 0.30
Skylights: U-factor ≤ 0.50
Residential doors with >½-lite glazing: U-factor ≤ 0.30
Opaque and ≤½-lite doors: Exempt from U-factor requirements
The CEO analysis also recommended no solar heat gain coefficient (SHGC) limitations so that homeowners and homebuilders can decide if they wish to take advantage of passive solar heating in their home with a higher SHGC or prefer to prevent potential overheating in warm months with a lower rating. This too was approved.
WMA Response: There was supposed to be a public comment period regarding the CEO’s recommendation prior to finalization, but that did not occur. However, in anticipation, WMA prepared a public comment in support of the CEO’s recommendation (please see comment below):
World Millwork Alliance (WMA) appreciates the opportunity to provide comments regarding the Colorado Energy Office’s (CEO) recent recommendation concerning energy efficiency requirements for windows, doors, and skylights sold in Colorado.
WMA supports the CEO’s conclusion that mandating ENERGY STAR certification for all fenestration products is unreasonable. We endorse the CEO’s alternative recommendation to adopt the U-factor requirements specified in the residential prescriptive table of the 2024 International Energy Conservation Code (IECC) as a more effective and conventional approach.
CEO-Recommended U-Factor Requirements:
Residential windows: U-factor ≤ 0.30
Residential skylights: U-factor ≤ 0.50
Residential doors (>½-lite): U-factor ≤ 0.30
Opaque and ≤½-lite residential doors: Exempt from U-factor requirements
Concerns with House Bill 23-1161 Signed into law on June 1, 2023, House Bill 23-1161 mandates that, beginning January 2026, all windows, doors, and skylights installed in residential structures of three stories or fewer must be certified under the ENERGY STAR program for the Northern climate zone. WMA respectfully opposes this requirement for the following reasons:
1. Misapplication of the ENERGY STAR Program The ENERGY STAR program is designed as a voluntary labeling initiative, not as a regulatory standard. It serves to recognize products that exceed baseline efficiency criteria. ENERGY STAR periodically revises its specifications to maintain differentiation between standard and high performance products. Mandating compliance through legislation effectively transforms a voluntary program into a code requirement, which is inconsistent with its original intent and undermines its integrity.
2. Adverse Impact on Availability and Cost
Shipping and altitude challenges: Colorado’s elevation presents logistical challenges for transporting high-performance insulating glass units (IGUs). To mitigate altitude-induced pressure changes, manufacturers must use capillary tubes or breather tubes, which can cause Argon gas to escape—reducing thermal performance and affecting compliance with ENERGY STAR U-factor thresholds.
Increased costs for consumers: ENERGY STAR-certified fenestration products generally come at a higher upfront cost. When broader envelope performance is not accounted for, these additional expenses may not yield proportional energy savings, placing an unnecessary financial burden on homeowners and builders.
3. Exclusion of a Large Industry Segment ENERGY STAR participation is limited:
Currently, only 129 businesses are listed as ENERGY STAR participants for windows, doors, and skylights.
By comparison, just the Wood Door & Window Manufacturing industry alone in the U.S. comprises 894 businesses (IBISWorld). A significant share of manufacturers would be effectively barred from selling in Colorado under this mandate.
4. Flawed Enforcement Strategy The enforcement plan for HB 23-1161 relies on:
Spot checks of major retailers and distributors
Anonymous reports and complaints, leading to monetary penalties
This approach creates enforcement gaps, particularly as homeowners can purchase noncompliant products from out-of-state suppliers, bypassing the regulation entirely. It also places undue compliance burdens on legitimate businesses, while offering limited oversight during actual construction.
Conclusion WMA urges Colorado to adopt the 2024 IECC U-factor requirements as a reasonable, practical, and inclusive alternative to ENERGY STAR certification. This approach:
Aligns with national energy code practices
Ensures consistent enforcement through local building inspectors
Preserves consumer choice and affordability
Maintains a fair and competitive market for all manufacturers
Furthermore, with the U.S. Environmental Protection Agency considering the phase-out of the ENERGY STAR program, relying on its certification for regulatory enforcement may prove unsustainable.
Thank you for considering these comments on the WMA Regulatory Affairs Update – July 2025. WMA remains committed to working collaboratively to support energy-efficient building practices that are also economically and practically sound.
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