Table V-7 on http://energycodeace.com/download/26420/file_path/fieldList/T20%20Computers%20FS-2019-070219-3.pdf http://energycodeace.com/download/26420/file_pat

Table V-7 on http://energycodeace.com/download/26420/file_path/fieldList/T20%20Computers%20FS-2019-070219-3.pdf http://energycodeace.com/download/26420/file_path/fieldList/... has details based on the "expandability score" which limits desktop to 50-75 kWh/year. The issue seems to be that the devices don't have low-power modes that meet the criteria for annual idle power usage. However "If the model is shipped at the purchaser’s request with either a limited capability operating system or without an operating system, or if the model is not capable of having an operating system, the model is not required to comply with the power management requirements of Section 1605.3(v)(5)(B)." So it should be possible to buy the system without an OS from an appropriate provider.