This old question again but with a new twist: As a project in China, all my project IT equipment checks out as EnergyStar due to using Dell and HP equipment. The only thing not compliant are the refrigerators. However, we have selected China Energy Efficiency Grade 1 (highest efficiency rating) fridges.

I took the annual energy consumption of these refrigerators and compared it to the refrigerator EnergyStar standard (which is based on 20% reduction of USA federal standard NAECA). The calculation shows that my refrigerators are significantly below the Energystar max electricity use limit for a product of this class and size.

While I can show equivalency to EnergyStar this way, at the end of the day these products are still not EnergyStar certified. There is also no equivalent product in the US market. Do you think this method will work?