Title 20 appliance-efficiency guidance does not replace other product or installation requirements.
WarmlyYours recorded California Energy Commission guidance dated August 16, 2024 stating that the towel warmer presented in that inquiry did not fall into a regulated appliance category under Title 20 Appliance Efficiency Regulations, and therefore did not require Title 20 certification.
That recorded response is limited to Title 20 and the product described. It is not a blanket statement that every towel warmer or combination appliance meets all California requirements, and it does not replace electrical safety listings, installation instructions or applicable building rules.
The CEC’s current public guidance explains the classification test: check the appliance types in Section 1601 and the definitions in Section 1602. Only products within a regulated category require the associated Title 20 compliance/certification. A product with additional functions must be assessed by its actual characteristics.
Source: the dated CEC response recorded by WarmlyYours and CEC’s current explanation of regulated products and certification.