The point of standards and standardised evaluations is to come up with a measurement methodology which is consistent across units tested and testing sessions.
The Energy Star Test Procedures for refrigerators and freezers is defined in this document:
Refrigerators and freezers are tested unloaded. Which suggests that the Energy Star programme should report a less efficient energy usage as compared with normal loading of a refrigerator/freezer, which will reduce air exchange and the need to re-cool air.
The Energy Star Test Procedures for refrigerators and freezers is defined in this document:
<https://www.energystar.gov/sites/default/files/specs/ENERGY%...> [PDF]
Refrigerators and freezers are tested unloaded. Which suggests that the Energy Star programme should report a less efficient energy usage as compared with normal loading of a refrigerator/freezer, which will reduce air exchange and the need to re-cool air.