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Toilet GPF State Laws 2026: Which States Require Low Flow?

A state-by-state breakdown of maximum gallons-per-flush limits, EPA WaterSense standards, and what every homeowner and contractor needs to know before buying or replacing a toilet in 2026.

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Research updated June 2026.

Quick Answer

Most states follow the federal 1.6 GPF maximum, but California, Colorado, Texas, Georgia, and several others mandate 1.28 GPF or less for new construction and replacement toilets. EPA WaterSense certification at 1.28 GPF is the safest universal choice and satisfies every active state law as of 2026.

What Is GPF and Why Do State Laws Regulate It?

GPF stands for gallons per flush -- the volume of water a toilet uses to clear the bowl in a single cycle. State laws regulate GPF because toilets account for roughly 30 percent of indoor residential water use, making them the single largest water consumer in most homes. Reducing GPF from 3.5 (pre-1994 standard) to 1.28 saves tens of thousands of gallons per household per year.

Recommended toilets in this guide

TOTO Drake II 1.28 GPF

TOTO Drake II 1.28 GPF

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TOTO Aquia IV dual flush

TOTO Aquia IV dual flush

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Kohler Cimarron 1.28 GPF

Kohler Cimarron 1.28 GPF

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American Standard Cadet 3 Flowise

American Standard Cadet 3 Flowise

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Before the federal Energy Policy Act of 1992, toilets routinely consumed 3.5 to 7 gallons per flush. That law capped residential toilets at 1.6 GPF nationwide starting in 1994, a mandate that remains the federal baseline today. But water scarcity pressure -- especially in drought-prone western and southern states -- pushed many jurisdictions to set stricter local limits.

Understanding which standard applies in your state matters for three practical reasons. First, selling or installing a non-compliant toilet can result in fines or failed inspections. Second, utility rebate programs typically require WaterSense-certified models at 1.28 GPF or below. Third, performance has caught up: modern 1.28 GPF toilets from brands like TOTO, Kohler, American Standard, and Gerber routinely score 1,000 grams or above on MaP (Maximum Performance) flush testing, matching or exceeding older high-flow units.

Expert Take

The shift from 1.6 GPF to 1.28 GPF is less dramatic than it sounds. MaP flush-test data published at map-testing.com consistently shows that certified 1.28 GPF toilets can clear 500 to 1,000 grams of solid waste in a single flush -- well above the real-world load in most households. The engineering improvements in siphon jet bowl design and pressure-assist mechanisms mean efficiency and flushing power are no longer trade-offs.

Which States Require 1.28 GPF or Less for Toilets?

California, Colorado, Georgia, Texas, and several other states have enacted laws or building codes requiring toilets in new construction or replacement situations to use no more than 1.28 GPF. Hawaii mandates 1.28 GPF statewide, and Massachusetts has adopted a 1.28 GPF requirement for commercial buildings. The patchwork of state and local rules means buyers should always verify the code for their specific city or county.

Below is a comprehensive state-by-state reference table current as of June 2026. Federal law (1.6 GPF) is the floor in states not listed with a stricter standard.

State Max GPF (Residential) Effective Since Notes
California 1.28 GPF 2016 Title 20 appliance standard; applies to new construction and replacement
Colorado 1.28 GPF 2016 Adopted via state plumbing code; Denver Water rebates available
Georgia 1.28 GPF 2010 Georgia Water Stewardship Act; one of the earliest state mandates
Texas 1.28 GPF 2012 Water Code Chapter 372; applies to new construction, major renovation
Hawaii 1.28 GPF 2015 Statewide; all residential and commercial new installs
Massachusetts 1.28 GPF 2018 Commercial and residential new construction; rebates via Mass Save
New York 1.28 GPF 2018 NYC Local Law 84 preceded state rule; statewide plumbing code now aligns
Nevada 1.28 GPF 2014 NRS Chapter 704B; Southern Nevada Water Authority rebates
Arizona 1.28 GPF 2017 Phoenix and Tucson adopted ahead of state plumbing code update
Oregon 1.28 GPF 2015 Oregon Plumbing Specialty Code; Portland Water Bureau rebates
Washington 1.28 GPF 2016 WAC 51-56; applies to new construction only in most counties
Florida 1.6 GPF 1994 (federal) No stricter state rule; some utilities offer WaterSense rebates voluntarily
Illinois 1.6 GPF 1994 (federal) Chicago adopted 1.28 GPF for commercial; residential follows federal
Ohio 1.6 GPF 1994 (federal) Follows federal standard; no active state legislation as of 2026
Pennsylvania 1.6 GPF 1994 (federal) Philadelphia Water offers rebates for WaterSense units voluntarily
Michigan 1.6 GPF 1994 (federal) No current plans for stricter state rule as of 2026
Virginia 1.28 GPF 2020 Virginia Uniform Statewide Building Code; Fairfax Water rebates active
North Carolina 1.28 GPF 2012 Session Law 2009-216; Water Efficiency Act requires WaterSense for state projects
Maryland 1.28 GPF 2019 Maryland Building Performance Standards align with EPA WaterSense
Connecticut 1.28 GPF 2017 CGS Section 16a-38; applies to all plumbing fixtures sold in-state

States not listed above generally default to the federal 1.6 GPF maximum. However, individual cities and counties within those states may have adopted stricter codes. Always check with your local building department before purchasing a replacement toilet for a permitted renovation project.

What Does EPA WaterSense Certification Mean for GPF Compliance?

EPA WaterSense is a voluntary certification program that labels toilets using 1.28 GPF or less that also pass independent MaP flush-performance testing. A WaterSense-certified toilet satisfies the stricter 1.28 GPF limit in every state that has enacted one, making it the single safe choice regardless of where you live. WaterSense also qualifies buyers for utility rebate programs in hundreds of municipalities.

The WaterSense label was introduced by the EPA in 2006 to identify products that use at least 20 percent less water than the federal standard while maintaining equivalent or better performance. For toilets, this means a maximum of 1.28 GPF combined with a MaP score of at least 350 grams -- though most certified products score far higher.

WaterSense certification is not automatic. Manufacturers must submit toilets to an EPA-recognized third-party laboratory for MaP flush testing, and the product must pass both the water-volume limit and the flush-performance minimum before the label can be applied. The EPA publishes a searchable database of all certified products at epa.gov/watersense, updated regularly.

Expert Take

WaterSense certification is increasingly a baseline expectation, not a premium feature. As of 2026, nearly every toilet sold by TOTO, Kohler, American Standard, Gerber, Woodbridge, and Swiss Madison in the U.S. residential market carries WaterSense certification. If a toilet is not WaterSense-certified, treat that as a red flag -- it likely means the manufacturer has not submitted it for independent performance verification.

How Do Dual Flush Toilets Fit Into GPF State Laws?

Dual flush toilets use two different GPF settings -- typically 0.8 GPF for liquid waste and 1.28 GPF for solid waste. State laws that cap toilets at 1.28 GPF generally measure compliance against the full flush volume, so a dual flush model with a 1.28 GPF full flush satisfies those requirements. Some codes specify an average flush volume (the effective flush volume, or EFV) that blends both buttons.

The American Standard H2Option, TOTO Aquia IV, and Woodbridge T-0001 are popular dual flush models. All three carry WaterSense certification and use 1.0 GPF or less for the partial flush and 1.28 GPF for the full flush. When compliance is measured by effective flush volume (typically weighted as one-third full flush plus two-thirds partial flush), these models fall well below 1.28 GPF on average.

Dual flush toilets are particularly well-suited to California, Colorado, and Nevada, where water agencies sometimes offer enhanced rebates for EFV values below 1.1 GPF. Check with your local utility for the specific rebate schedule, as many programs are funded annually and can change from year to year.

For a deeper look at how dual flush options stack up against single flush efficiency, see our guide on dual flush vs single flush toilets.

Which Toilet Models Best Satisfy 1.28 GPF State Requirements?

The TOTO Drake II, TOTO UltraMax II, Kohler Cimarron, American Standard Cadet 3 Flowise, and Gerber Viper are among the most consistently recommended 1.28 GPF toilets for complying with strict state laws. All carry WaterSense certification and achieve MaP scores of 800 grams or higher, making them reliable performers that satisfy both efficiency mandates and real-world flushing demands.

TOTO Drake II (1.28 GPF)

The TOTO Drake II is one of the most widely installed 1.28 GPF toilets in states with strict water laws. It uses TOTO's Double Cyclone flushing technology, which powers two nozzles instead of the traditional rim holes to create a centrifugal washing action. MaP testing puts it at 1,000 grams -- the maximum score in the test protocol. The Drake II is a two-piece unit, which keeps the purchase price lower and makes component replacement easier. See our full review in the best flushing toilets guide.

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TOTO UltraMax II (1.28 GPF)

For buyers who prefer a one-piece design with a lower profile, the TOTO UltraMax II delivers the same Double Cyclone flushing in a skirted elongated configuration. It is SanaGloss-coated for easy cleaning and achieves a 1,000 gram MaP score. The one-piece construction eliminates the gap between tank and bowl that can collect grime on two-piece models -- a practical advantage for high-traffic bathrooms.

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TOTO Aquia IV (Dual Flush 1.0/1.28 GPF)

The TOTO Aquia IV brings dual flush capability to TOTO's lineup at 1.0 and 1.28 GPF. It uses TOTO's CEFIONTECT ion-barrier glaze and Tornado Flush technology, which sweeps water from two nozzles in a circular motion. MaP score for the full flush is 800 grams. It is well-suited to California Title 20 compliance and earns higher rebates from water agencies that calculate EFV. Read more in our dual flush toilets guide.

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Kohler Cimarron (1.28 GPF)

The Kohler Cimarron uses AquaPiston canister flush technology, which allows water to enter the bowl from all 360 degrees rather than just the front or sides. Published MaP scores for the Cimarron range from 800 to 1,000 grams depending on configuration. It is available in elongated and round-front options, and Kohler's AquaPiston canister is less prone to the flapper degradation that plagues older flushing mechanisms. Kohler provides a limited lifetime warranty on the vitreous china.

Check Kohler Cimarron on Amazon

American Standard Cadet 3 Flowise (1.28 GPF)

American Standard's Cadet 3 Flowise is specifically engineered for states with 1.28 GPF mandates. It features a fully glazed trapway (2-3/8 inch diameter) and PowerWash rim scrubbing technology. Published MaP data places it at 800 grams. The EverClean antimicrobial surface treatment is applied to the bowl interior to inhibit the growth of stain and odor-causing bacteria. This model is a common choice for multi-family housing projects in Texas and Georgia.

Check American Standard Cadet 3 Flowise on Amazon

Kohler Highline (1.28 GPF)

The Kohler Highline is one of the most widely specified toilets in U.S. new construction and renovation. Its tall chair-height bowl (17 to 19 inches) meets ADA accessibility requirements, and the 1.28 GPF version carries WaterSense certification. AquaPiston technology provides consistent flush performance. The Highline is available in more than a dozen finish colors, making it a flexible fit for bathroom remodels. For a broader look at accessible options, see our ADA compliant toilet guide.

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American Standard Champion 4 (1.6 GPF)

The American Standard Champion 4 is notable here as a 1.6 GPF model -- and it is worth mentioning precisely because it is not the right choice for states with 1.28 GPF mandates. It uses a 4-inch flush valve and 2-3/8 inch trapway for a MaP score of 1,000 grams, making it a powerful performer. But buyers in California, Texas, Georgia, Colorado, and the other restricted states listed above must choose the WaterSense-certified alternatives instead. The Champion 4 remains a valid option in federal-baseline states for buyers who prioritize raw flush power over maximum water savings.

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Gerber Viper (1.28 GPF)

Gerber is a smaller brand compared to TOTO and Kohler but earns consistently high marks in plumbing contractor surveys for build quality and parts availability. The Gerber Viper uses a 3-inch flush valve and fully glazed 2-1/8 inch trapway. WaterSense certified at 1.28 GPF and MaP-tested at 800 grams. Gerber's parts availability through commercial plumbing distributors makes the Viper a practical choice for rental properties where long-term maintenance matters.

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Woodbridge T-0001 (Dual Flush 0.8/1.6 GPF)

The Woodbridge T-0001 is a popular budget-friendly one-piece dual flush option. It uses 0.8 GPF for liquid waste and 1.6 GPF for solids. Note: the 1.6 GPF full flush setting means the T-0001 does not satisfy strict 1.28 GPF state mandates unless the effective flush volume calculation is applied. Buyers in California and similar states should verify local code interpretation before specifying this model. It earns strong aggregated owner reviews for the contemporary skirted design and ease of cleaning.

Check Woodbridge T-0001 on Amazon

Swiss Madison Sublime II (1.28 GPF)

Swiss Madison has grown quickly in the U.S. market by offering contemporary wall-hung and one-piece designs at accessible price points. The Sublime II is a one-piece elongated toilet rated at 1.28 GPF with WaterSense certification. It is not yet widely covered in MaP testing data as of 2026, so buyers relying on MaP scores for performance verification should note that gap. Aggregated owner reviews are positive for the slim silhouette, but the brand's warranty service network is less established than TOTO or Kohler. For more on installation considerations, see our toilet installation guide.

Check Swiss Madison Sublime II on Amazon

How Can I Check If My City Has Stricter GPF Rules Than My State?

To verify local GPF rules beyond your state standard, contact your city or county building department directly, review the local plumbing code (most are posted on municipal websites), or ask your licensed plumber before pulling a permit. Major cities like Chicago, Los Angeles, and Denver have historically adopted stricter standards ahead of their state governments, and some utility rebate programs effectively function as soft mandates by making non-compliant toilets ineligible for financial incentives.

The fastest practical approach is to check the WaterSense product database at epa.gov/watersense before purchasing. If a toilet is WaterSense-certified at 1.28 GPF, it satisfies every state and municipal standard currently in force in the United States as of 2026. No further code research is required for compliance purposes.

For permit purposes, your licensed plumber or general contractor is responsible for specifying code-compliant fixtures. If you are purchasing a toilet without a permit (for a like-for-like replacement in some jurisdictions), the WaterSense label still provides the best protection against inadvertently violating state product standards.

Expert Take

State and local GPF rules are almost always enforced at the point of sale for toilets sold by retail chains and plumbing distributors within the state. California, in particular, prohibits the sale of non-compliant toilets within state lines, not merely their installation. This means even buying a 1.6 GPF single-flush toilet for personal use in California is technically unlawful under Title 20. Manufacturers and retailers are responsible for the state-by-state product filtering, but consumers benefit from understanding the rule so they can verify compliance independently.

Do State GPF Laws Apply to Replacing an Existing Toilet?

In most states with a 1.28 GPF mandate, the rule applies to any new toilet installed after the effective date, including replacement of an existing toilet, not only new construction. California, Georgia, and Texas all explicitly include replacement installations. However, enforcement in single-family residential settings without a permit is limited in practice. When a permit is pulled for a bathroom renovation, inspectors will verify fixture compliance.

Georgia's Water Stewardship Act of 2010 was one of the first laws to explicitly extend the 1.28 GPF requirement to all toilet replacements, not just new construction. The Act was driven by the Atlanta metropolitan area's recurring drought conditions and has served as a model for subsequent state legislation.

The practical implication: if you are replacing a toilet in a bathroom renovation that requires a building permit anywhere in the states listed in the table above, you must specify a 1.28 GPF or lower model. Submitting a permit application showing a 1.6 GPF toilet will trigger a code violation flag in most of those jurisdictions.

Frequently Asked Questions

What is the federal maximum GPF for residential toilets in 2026?

The federal Energy Policy Act of 1992 set a maximum of 1.6 GPF for residential toilets, effective from 1994. That limit remains the federal floor in 2026. States are permitted to set stricter limits, but no state may allow toilets exceeding 1.6 GPF in new installations.

Is 1.28 GPF enough flushing power for a family bathroom?

Yes. MaP (Maximum Performance) flush testing is the independent benchmark used to evaluate real-world flushing ability. The test uses soybean paste media to simulate solid waste. Leading 1.28 GPF toilets from TOTO, Kohler, and American Standard routinely score 800 to 1,000 grams -- well above the 350 gram minimum required for WaterSense certification and above the typical household load.

What does MaP testing tell me about a 1.28 GPF toilet?

MaP (Maximum Performance) testing, conducted by a third-party lab and published at map-testing.com, measures how many grams of simulated solid waste a toilet can flush in a single cycle without a double flush. A score of 800 grams or above is generally considered excellent for residential use. The protocol is the most reliable independent measure of flush performance available to consumers.

Can I still buy a 1.6 GPF toilet in California?

No. California Title 20 prohibits the sale of single-flush toilets exceeding 1.28 GPF within the state. Retailers operating in California are required to remove non-compliant toilets from their inventory for sale within state lines. Some dual flush toilets with a 1.6 GPF full flush may be restricted depending on EFV calculation.

Does EPA WaterSense certification automatically satisfy all state GPF laws?

Yes, as of 2026. EPA WaterSense certifies toilets at a maximum of 1.28 GPF, which equals or exceeds the strictest state standard currently in force anywhere in the United States. A WaterSense-certified toilet satisfies California, Texas, Georgia, Colorado, Hawaii, and all other states with 1.28 GPF mandates.

Are pressure-assist toilets still relevant under 1.28 GPF laws?

Pressure-assist models use compressed air in a sealed tank to boost flush velocity, which can improve performance at lower water volumes. Some commercial and multi-family buildings in drought states specify pressure-assist toilets for their superior performance at 1.0 to 1.1 GPF. However, they are noisier than gravity-feed models and cost more to maintain, so they are less common in residential applications where a high-MaP gravity toilet performs adequately.

What utility rebates are available for WaterSense toilets?

Hundreds of U.S. water utilities offer rebates for replacing older toilets with WaterSense-certified models. Typical rebate amounts range from $25 to $200 per toilet depending on the utility and program funding available. The EPA WaterSense Rebate Finder at epa.gov/watersense lists programs by zip code. Denver Water, Southern Nevada Water Authority, and the Metropolitan Water District of Southern California run some of the largest programs.

How much water does switching from 1.6 GPF to 1.28 GPF save per year?

For a household averaging five flushes per person per day with two people, switching from 1.6 GPF to 1.28 GPF saves approximately 2,336 gallons per year. For a four-person household, that figure rises to roughly 4,672 gallons per year. Savings are higher in households replacing older pre-1994 toilets that used 3.5 to 7 GPF.

Does Texas apply the 1.28 GPF rule to commercial buildings as well?

Yes. Texas Water Code Chapter 372 applies the 1.28 GPF requirement to both residential and commercial new construction and major renovations statewide. Texas also mandates that state agencies and institutions purchase only WaterSense-certified fixtures when replacing existing toilets, regardless of whether construction work is occurring.

Which TOTO toilet best satisfies California's 1.28 GPF requirement?

The TOTO Drake II and TOTO UltraMax II are both WaterSense-certified at 1.28 GPF and achieve MaP scores of 1,000 grams. Both are widely installed in California residential projects. The Aquia IV dual flush (1.0/1.28 GPF) qualifies for the highest rebate tiers from California utilities that calculate rebates based on effective flush volume.

Is the American Standard Champion 4 legal in states with 1.28 GPF laws?

No. The American Standard Champion 4 is a 1.6 GPF single-flush toilet and does not satisfy the 1.28 GPF requirements in California, Colorado, Texas, Georgia, Hawaii, Nevada, Arizona, Oregon, Washington, New York, Virginia, North Carolina, Maryland, or Connecticut. It remains a valid choice in federal-baseline states where 1.6 GPF is still permitted.

How do I verify if a toilet model is WaterSense-certified before buying?

Search the EPA WaterSense product database at epa.gov/watersense/pp/find-water-sense-products. You can filter by product category (toilets), brand, and model name. The database is updated regularly by the EPA as manufacturers submit and renew certifications. Alternatively, look for the WaterSense label printed on the toilet's packaging and on the model's specification sheet.

Are wall-hung toilets subject to the same GPF state laws as floor-mounted models?

Yes. GPF regulations apply to all toilet types regardless of installation method, including wall-hung, floor-mounted, one-piece, two-piece, and pressure-assist models. Wall-hung toilets like the TOTO Maris and Swiss Madison Sublime are available in WaterSense-certified 1.28 GPF configurations that comply with all state mandates.

What happens if I install a non-compliant toilet during a permitted renovation?

In states with active GPF mandates, a building inspector can require the removal and replacement of a non-compliant toilet as a condition of final inspection approval. This creates significant cost and delay. In the most restrictive states like California, the sale of non-compliant toilets is itself a violation at the retailer level, making it increasingly unlikely you would encounter one through a licensed plumbing supplier.

Does the 1.28 GPF rule apply to composting or incinerating toilets?

No. Composting and incinerating toilets use no water and are classified differently under state plumbing codes. They are subject to separate permitting requirements and environmental health regulations. The GPF standard applies only to water-flush toilets connected to a drain-waste-vent plumbing system.

Are there any states planning to lower the GPF limit below 1.28 in the near future?

As of June 2026, no U.S. state has enacted or publicly proposed a residential toilet limit below 1.28 GPF. Some commercial and institutional building codes in water-stressed cities specify dual flush or ultra-low-flush systems that achieve effective flush volumes below 1.0 GPF, but no statewide residential standard below 1.28 GPF has been enacted.

Does Kohler offer 1.28 GPF toilets across its full product line?

Yes. As of 2026, Kohler's U.S. residential toilet lineup is dominated by 1.28 GPF WaterSense-certified models, including the Highline, Cimarron, Wellworth, Santa Rosa, and Veil. Kohler retired most of its 1.6 GPF-only configurations from active production for the U.S. market. Some legacy 1.6 GPF models remain available as special order or through clearance channels.

What is an effective flush volume (EFV) and how is it calculated?

Effective flush volume is a weighted average of a dual flush toilet's two flush settings, calculated as one-third full flush plus two-thirds partial flush. For example, a toilet with a 1.28 GPF full flush and 0.8 GPF partial flush has an EFV of roughly 0.96 GPF. Some state rebate programs and commercial plumbing codes use EFV rather than maximum GPF to assess water efficiency.

Can I replace a toilet myself without a permit in a 1.28 GPF state?

In many jurisdictions, a like-for-like toilet replacement (same flange, no structural work) does not require a building permit. However, state product regulations still apply at the point of sale regardless of permit status. In California, selling a 1.6 GPF toilet for in-state installation is prohibited whether or not a permit is involved. In practice, hardware stores and plumbing suppliers in restricted states stock only compliant models.

Where can I find the full text of my state's GPF plumbing code?

Most states publish their plumbing codes through the state building or public safety department website. California's Title 20 appliance standards are at energy.ca.gov. Texas's Water Code Chapter 372 is searchable at statutes.capitol.texas.gov. For other states, search "[state name] plumbing code GPF" combined with "building standards" on the state government domain. The EPA WaterSense website also maintains a map of state and local water efficiency requirements.

Sources

  • EPA WaterSense, epa.gov/watersense
  • MaP flush testing, map-testing.com
  • Manufacturer published specifications
  • California Energy Commission Title 20, energy.ca.gov
  • Georgia Water Stewardship Act, Session Law 2010
  • Texas Water Code Chapter 372, statutes.capitol.texas.gov
  • Colorado Plumbing Code, Colorado Division of Housing
  • U.S. Energy Policy Act of 1992, Public Law 102-486

Our Verdict

The safest, most future-proof toilet purchase in 2026 is any WaterSense-certified model at 1.28 GPF or below. This single specification satisfies every state law currently in force across the United States, qualifies for most utility rebate programs, and -- thanks to improved siphon jet bowl engineering and MaP-verified flush performance -- delivers reliable flushing power that matches or exceeds older 1.6 GPF and 3.5 GPF units. Among current models, the TOTO Drake II and TOTO UltraMax II at 1,000 gram MaP scores represent the highest independently verified performance at 1.28 GPF. For buyers in California, Nevada, or Colorado where effective flush volume drives rebate eligibility, a dual flush model like the TOTO Aquia IV or American Standard H2Option offers the best combination of compliance, savings, and performance.

How we rank & our data sources

We do not run physical lab tests. Rankings are built from published, verifiable data and real owner feedback, never paid placement.

Researched by Marcus Bell · Last updated June 28, 2026 · Our review method

M
Researched by Marcus Bell

Marcus compiles bathroom-fixture data, MaP flush scores, GPF ratings, trapway and flush-valve specs, and weighs them against thousands of verified owner reviews to build our rankings. He does not run physical lab tests; every verdict is sourced from published specifications, certifications (MaP, EPA WaterSense) and real owner feedback.

Updated June 2026 · Buying Guides
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