The prescriptive path is the most widely used approach for commercial code compliance in the United States. Though easy to implement, prescriptive approaches do not typically discriminate between minimally compliant, high-performing and poorly performing HVAC system configurations. Hence, to meet aggressive energy and carbon reduction goals, it is clear that energy codes will need to transition from prescriptive to performance-based approaches, a transition that is riddled with several challenges. This paper discusses a new HVAC system-based performance approach (HVAC System Performance) which provides a simpler solution to HVAV system evaluation compared to whole building performance, while keeping tradeoffs limited to specific building systems. The Total System Performance Ratio (TSPR) is a metric for evaluation of overall system efficiency instead of individual component efficiency, a solution which could also eventually facilitate the transition to a 100% performance-based code structure. TSPR is a ratio that compares the annual heating and cooling load of a building to the annual energy consumed by the building’s HVAC system. A calculation software tool has been developed for determining a building’s TSPR. Already incorporated into the 2018 Washington State Energy Code, this approach is also being evaluated by ASHRAE Standard 90.l Project Committee and has the potential to provide a comprehensive performance-based approach for HVAC system evaluation and analysis.