Is there a grace period for manufacturers to promote products as ENERGY STAR certified after a criteria revision renders them no longer certified?

Continued association of the ENERGY STAR mark with a product no longer certified as ENERGY STAR is a violation of the ENERGY STAR partnership agreement signed between the brand owner and EPA and is a violation of federal trademark law. This applies to physical labels on units, as well as documents and online references related to the product. The specification revision process contemplates and provides a reasonable "sell through" period between the last permissible product certification date and the effective date of a new specification during which time units manufactured and labeled under the previous specification may be sold. That period also allows ample time for labeled units to clear U.S. ports, where relevant. The EPA works with the U.S. Customs and Border Patrol to monitor label use at U.S. ports of entry, and actively monitors the use of the ENERGY STAR mark in online advertising and sales to maintain the integrity of the brand.