From the article:
Most dishwashers on the market are already well below the federal standard of 5 gallons, with most using 3.5 gallons per cycle or less.
Dishwashers are not the only appliances Biden's DOE has set its sights on, however, as the regulator is also considering crackdowns on washers, dryers and refrigerators that manufacturers say could reduce performance.
A bureaucrat is incapable of acknowledging human behavior. When any appliance (dishwasher, washer, dryer) does not do the job up to consumer's satisfaction, consumers simply run the cycle again. If new appliances don't deliver results given the new standards for energy efficiency, the end result will be more energy used; not less.