[mindslight]

I think the term "gaming" was overstating the point relative to my argument. What I see is that the previous regulations got a lot of the low hanging fruit, and now there aren't really big gains to be had like that.

I actually don't think companies will go backwards on improvements they've already adopted. The mechanism I see is a reluctance to spend design time on changing things (ie keep selling the same old shit), rather than pure cost optimization with newer technologies costing more.

I'd say a big cause of the problem here is the handwavey nature of regulations focusing on "high level" goals like efficiency and expecting that engineers can magically find it somewhere [0], rather than more direct things like "all appliance motors that consume more than 5% of the energy used by the appliance must be brushless ECM"

[0] similarly, see the repeated calls for magical encryption backdoors that don't weaken security