5-C-i

APPENDIX 5-C. ENGINEERING QUESTIONNAIRES

TABLE OF CONTENTS

5-C.1 DESIGN FOR ENERGY IMPROVEMENT INFORMATION REQUEST 

FOR RESIDENTIAL CLOTHES WASHERS ...........................................................1

5-C.2 QUESTIONNAIRE TO EVALUATE THE PRODUCT CLASSES AND 

STANDARDS PROPOSED IN THE CONSENSUS AGREEMENT.......................14

5-C.3 INFORMATION REQUEST FOR COMPACT-SIZE PRODUCT CLASSES

FOR RESIDENTIAL CLOTHES WASHERS .........................................................22
5-C-1

APPENDIX 5-C. ENGINEERING QUESTIONNAIRES

5-C.1 DESIGN FOR ENERGY IMPROVEMENT INFORMATION 

REQUEST FOR RESIDENTIAL CLOTHES WASHERS

The United States Department of Energy (DOE) is currently reviewing energy 

conservation standards for residential clothes washers. DOE would like to confirm 

information on the incremental costs of increasing product efficiency by understanding 

the design options involved in the efficiency improvement. 

1. Market Share of Products You Sell

To help DOE discover manufacturer sub-groups and the relative importance of various 

product classes to specific manufacturers, please disaggregate your annual unit shipments 

for each product category as shown below. Please also indicate whether you purchase 

these products from other manufacturers (i.e. private label), and whether the factory that 

supplies the product is located in the United States.

Product Class % Private 

Label % Made in US 2008 Unit Shipments

Top-Loading, Compact

Top-Loading, Standard

Top-Loading, Semi-automatic

Front-Loading

Suds-Saving

• Are you aware of any top-loading semi-automatic or suds-saving units on the 

market?

2. Product Design Features

The following series of exhibits and questions address technical characteristics of key 

residential clothes washer components for both baseline and improved-efficiency 

products.

Baseline Clothes Washers

Which design features impacting energy use are generally incorporated into a “baseline” 

clothes washer (i.e. one that just meets existing modified energy factor (MEF) and water 

factor (WF) standards, if any) in the following product classes?

• Top-loading, Compact-size

• Top-loading, Standard-size
5-C-2

• Top-loading, Semi-automatic

• Front-loading

• Subs-Saving

Incremental Efficiency Levels

DOE proposed in the framework document to use efficiency levels based on the MEF and 

WF specifications prescribed by ENERGY STAR and the Consortium for Energy 

Efficiency (CEE)’s Super-Efficient Home Appliances Initiative, along with the maximum 

levels that are currently available in the market. For top-loading clothes washers, DOE 

did not include CEE Tier 3 as an efficiency level because the difference between the Tier 

3 criteria (2.20 MEF/4.50 WF) and the maximum available level (2.26 MEF/4.48 WF) 

was so small. For top-loading standard-size clothes washers, DOE proposed to add a 

level to fill the gap between the baseline and the ENERGY STAR criteria. For frontloading clothes washers, DOE proposes to add a level to fill the gap between the CEE 

Tier 3 criteria and the maximum available level. It will set these gap-fill levels at 

combinations of MEF and WF that are strongly represented in the California Energy 

Commission (CEC) appliance product directory.

For both top- and front-loading clothes washers, DOE recognizes that MEF and WF 

pairings may not simultaneously achieve max-tech levels. That is, a clothes washer with 

the highest possible MEF may not achieve the lowest possible WF. Similarly, a clothes 

washer with the lowest WF may not achieve the highest MEF. DOE considered several 

models in each product class to determine max-tech values that best represent optimal 

performance for products on the market. DOE did not suggest max-tech levels that 

represent a “hybrid” of the highest possible MEF and the lowest possible WF for each 

product class.

For top-loading compact-size clothes washers, DOE did not establish efficiency levels for 

analysis in previous rulemakings. Based on a review of the top-loading compact-size 

clothes washers in the CEC directory, which revealed little difference between the 

maximum available efficiency and the baseline DOE standard, DOE proposed to analyze 

one efficiency level above the baseline represented by the currently available maximum 

technology.

Table 1 through Table 3 shows the proposed efficiency levels for each product class.

• Are the proposed efficiency levels appropriate?

• Can you suggest an appropriate “max-tech” efficiency level? 

• Do you believe that the gap-fill efficiency levels defined by DOE for top-loading 

standard-sized and front-loading clothes washers are representative? If not, can 

you suggest appropriate gap-fill values? 

• If you believe the top-loading semiautomatic and suds-saving clothes washer 

product classes should be analyzed, can you suggest baseline, gap-fill, and maxtech efficiency levels for those product classes? 
5-C-3

Table 1: Efficiency Levels for Top-Loading Standard-Size Residential Clothes 

Washers

Level Efficiency Level Source

Efficiency Level

MEF WF

Baseline DOE Standard 1.26 9.50

1 Gap Fill 1.40 9.50

2 ENERGY STAR 1.72 8.00

3 CEE Tier 1 1.80 7.50

4 CEE Tier 2 2.00 6.00

5 Max Available 2.26 4.48

Table 2: Efficiency Levels for Top-Loading Compact-Size Residential Clothes 

Washers

Level Efficiency Level Source Efficiency Level

MEF WF

Baseline DOE Standard 0.65 18.40

1 Max Available 0.78 13.90

Table 3: Efficiency Levels for Front-Loading Residential Clothes Washers

Level Efficiency Level Source

Efficiency Level

MEF WF

Baseline ENERGY STAR 1.72 8.00

1 CEE Tier 1 1.80 7.50

2 CEE Tier 2 2.00 6.00

3 CEE Tier 3 2.20 4.50

4 Gap Fill 2.40 4.20

5 Max Available 2.89 3.36

• What design changes are generally required to convert a typical baseline toploading standard-sized clothes washer (1.26 MEF, 9.50 WF) to each incremental 

efficiency level up to the max available level (2.26 MEF, 4.48 WF)?

o What are the costs of the individual design options selected?

• What design changes are associated with converting a baseline top-loading 

compact-sized clothes washer (0.65 MEF, 18.40 WF) to the maximum available 

level (0.78 MEF, 13.90 WF)? 

o Are these design changes comparable for top-loading standard-sized 

clothes washers? 

o What are the costs of the individual design options selected? 
5-C-4

• What design changes are associated with converting a baseline front-loading 

clothes washer (1.72 MEF, 8.00 WF) to each incremental efficiency level up to 

the maximum available level (2.89 MEF, 3.36 WF)? 

o Are these design changes comparable for other product classes? 

o What are the costs of the individual design options selected? 

• Are the aggregated industry costs for each product class (highlighted in red in the 

Tables below) representative of your firm’s costs? Please indicate your firm’s 

costs for achieving the proposed efficiency levels in the Tables below. 

• Are there fundamental differences between required design changes that make the 

cost increment much higher for some product classes than others?

• Would you help DOE understand and estimate the conversion capital investments 

that would be necessary at each candidate standard level? What is the nature of 

the capital investments?

• What depreciation method would your company use to depreciate the conversion 

capital expenditures?

• Are installation costs a function of efficiency? Maintenance costs? Repair costs? 

If yes, would you please characterize this relationship by providing incremental 

installation, maintenance, and/or repair cost data? 

• Is there a relationship between MEF and WF? If yes, please characterize this 

relationship.
5-C-5

Table 4: Manufacturer Cost Data: Top-Loading – Compact and Standard

Product Class 

TopLoading –

Compact

Top-Loading – Standard

Efficiency Level 1 1 2 3 4 5

MEF 0.78 1.40 1.72 1.80 2.00 2.25

WF 13.90 9.50 8.00 7.50 6.00 4.45

Average Incremental Costs ($ Per Unit)*

Material

Labor

Overhead#

Minimum Incremental Costs ($ Per Unit)*

Material

Labor

Overhead#

Maximum Incremental Costs ($ Per Unit)*

Material

Labor

Overhead#

Conversion Capital Expenditures ($, Millions)

Building CAPX

Tooling/ Equipment 

CAPX

One-Time Product Conversion Expenses ($, Millions)

R&D

Marketing

# Depreciation on the conversion capital expenditure should NOT be included in the incremental overhead. 

* Incremental costs per unit should be reported relative to the baseline unit’s cost. The baseline unit complies with the federal standard for residential clothes washers and is equal 

to an MEF of 1.26 and WF of 9.50 for Top-Loading – Standard and an MEF of 0.65 for Top-Loading - Compact. The baseline WF of 18.40 for Top-Loading – Compact was 

selected based on a survey of clothes washers listed in the NRCan product database. 

Direct material – Costs of raw materials including scrap that can be traced to final or end products. Direct material costs do not include indirect material costs which are attributed to supplies that may 

be used in the production process but are not assigned to final products (e.g., lubricating oil for production machinery).

Direct labor – The earnings of workers who assemble parts into a finished good for operate machines in the production process. Direct labor includes the fringe benefits of direct laborers such as group 

health care, as well as overtime pay. Direct labor does not include indirect labor which is defined as the earnings of employees who do not work directly in assembling a product, such as supervisors, 

janitors, stockroom personnel, inspectors, and forklift operators.

Overhead – Factory overhead excluding depreciation. Factory overhead includes indirect labor, downtime, set-up costs, indirect material, expendable tools, maintenance, property taxes, insurance on 

assets, and utility costs. Factory overhead does not include selling, general, and administrative costs (SG&A); R&D; interest; or profit (accounted for by DOE separately).

Full Production Cost = Direct Material + Direct Labor + Overhead (factory) + Depreciation

Full Cost of Product = Full Production Cost + Non-production Costs (SG&A, R&D, interest, and profit)
5-C-6

Table 5: Manufacturer Cost Data: Front-Loading

Product Class  Front-Loading

Efficiency Level 1 2 3 4 5

MEF 1.80 2.00 2.20 2.40 2.89

WF 7.50 6.00 4.50 4.20 3.36

Average Incremental Costs ($ Per Unit)*

Material

Labor

Overhead#

Minimum Incremental Costs ($ Per Unit)*

Material

Labor

Overhead#

Maximum Incremental Costs ($ Per Unit)*

Material

Labor

Overhead#

Conversion Capital Expenditures ($, Millions)

Building CAPX

Tooling/ Equipment CAPX

One-Time Product Conversion Expenses ($, Millions)

R&D

Marketing

# Depreciation on the conversion capital expenditure should NOT be included in the incremental overhead. 

* Incremental costs per unit should be reported relative to the baseline unit’s cost. The baseline unit for the front-loading product class complies with the current ENERGY STAR 

level for residential clothes washers and is equal to an MEF of 1.72 and WF of 8.00.

Direct material – Costs of raw materials including scrap that can be traced to final or end products. Direct material costs do not include indirect material costs which are attributed to supplies that may 

be used in the production process but are not assigned to final products (e.g., lubricating oil for production machinery).

Direct labor – The earnings of workers who assemble parts into a finished good for operate machines in the production process. Direct labor includes the fringe benefits of direct laborers such as group 

health care, as well as overtime pay. Direct labor does not include indirect labor which is defined as the earnings of employees who do not work directly in assembling a product, such as supervisors, 

janitors, stockroom personnel, inspectors, and forklift operators.

Overhead – Factory overhead excluding depreciation. Factory overhead includes indirect labor, downtime, set-up costs, indirect material, expendable tools, maintenance, property taxes, insurance on 

assets, and utility costs. Factory overhead does not include selling, general, and administrative costs (SG&A); research and development (R&D); interest; or profit (accounted for by DOE separately).

Full Production Cost = Direct Material + Direct Labor + Overhead (factory) + Depreciation

Full Cost of Product = Full Production Cost + Non-production Costs (SG&A, R&D, interest, and profit)
5-C-7

DOE is requesting data on efficiency improvements and manufacturing costs associated 

with specific technology options. When providing data on efficiency improvements 

please indicate the improvements with respect to MEF and WF.

Control Systems

Adaptive Control Systems 

• Is there any room for further, significant energy efficiency improvement via adaptive 

control systems that adjust washer operation or conditions (i.e., wash temperature, 

cycle time, number of rinse cycles, spin speed, and other parameters) based on 

characteristics of the clothes load? If so, how much improvement can be achieved? 

What is the incremental manufacturing cost associated with adaptive control systems? 

What adaptive control sensor technologies do you use in your washers (e.g., sensors 

to measure the soil load, turbidity sensors to detect water quality, etc)?

• Do any of your clothes washers use a fuzzy logic to weigh laundry loads and regulate 

the length of the wash cycle, water level, number of rinses, and drying time? If so, 

how much efficiency improvement can be achieved? What would be the incremental 

manufacturing cost?

Automatic Fill Controls 

• What types of automatic fill control technologies do you incorporate in your frontload clothes washers? Top-load clothes washers? What are the incremental costs 

associated with these automatic fill control technologies? How much energy can be 

saved using this technology option? 

• Are there fundamental differences in the implementation of this technology option 

that make the cost increment much higher for some product classes than others? If so, 

please elaborate on these differences.

Improved Fill Control

• Is there any room for further significant energy efficiency improvement via improved 

fill control? For example, improving tolerances on existing wash-water fill sensing 

(pressure sensors or improving switch design) to avoid overfilling the wash tub? 

What would be the incremental manufacturing cost?

Other Control Issues

• Are you aware of any intellectual property or patent infringement issues that might 

affect your choice of adaptive control, automatic fill, or improved fill control 

technology?

• What is the incremental manufacturing cost of switching from electromechanical 

controls to electronic controls? Which technology options require electronic controls?

• Have you considered requiring a cold rinse and offering more warm or cold wash 

programs while reducing the number of hot wash cycle options in order to increase 

the MEF without affecting the WF per the DOE test procedure?
5-C-8

Advanced Agitation Concepts for Vertical-Axis Machines

• What types of advanced agitation technologies do you incorporate in your top-loading 

clothes washers (e.g., nutating plates, rotating disks, side-mount agitators)? How 

much efficiency improvement can be achieved with each type of advanced agitation 

technology? What is the incremental manufacturing cost compared to the standard 

agitator found in traditional top-loading machines?

Drum/Tub Upgrades 

Added Insulation

• Have you considered increased insulation as a design option? If so, what thicknesses 

and insulation materials have you considered? How much efficiency improvement 

can be achieved? What would be the incremental manufacturing cost?

Horizontal-Axis Design

• DOE’s review of research and literature shows that horizontal-axis machines use on 

average 40 percent less energy and 25 percent less water than traditional vertical-axis 

washers. Would you consider this accurate? If not, please suggest a more appropriate 

value.

• Are performance or consumer utilities limited by horizontal-axis designs?

Horizontal-Axis Design with Recirculation

• Have you considered horizontal-axis design with recirculation as a design option (i.e., 

using a pump to recirculate water and spray it into the drum)? How much efficiency 

improvement can be achieved with this design option? What would be the associated 

incremental manufacturing cost?

• Would this design option limit consumer utilities or performance?

Horizontal-Axis Design with Top-Loading Configuration

• Have you considered a horizontal-axis drum design that can be loaded from the top? 

Would you consider this to be a viable design option? Would a top-loading 

horizontal-axis washer have any inherent differences in performance compared to a 

traditional front-loading horizontal-axis washer? What would be the associated 

incremental manufacturing cost for this feature? 

Improved Horizontal-Axis Drum Design 

• Is there any room for further significant energy efficiency improvements via 

horizontal-axis drum design (i.e., to improve wash performance, reduce mass, and

increase spin speeds)? Have you considered drums featuring special paddles, drumwall textures, or similar enhancements? If so, how much efficiency improvement can 

be achieved? What would be the incremental manufacturing cost?
5-C-9

Reduced Thermal Mass

• Have you considered using a plastic wash tub specially designed to minimize the 

thermal mass that is heated by the water? If so, what specific materials have you 

considered? How much efficiency improvement can be achieved? Are there any 

advanced materials (plastics, composites, or others) that could be used to lower the 

thermal mass of the tub beyond the current practice? What would be the incremental 

manufacturing cost?

Tighter Tub Tolerance

• Have you considered tighter tub tolerances (i.e., reducing the annular volume between 

the inner wash basket and outer tub) as a means for improving efficiency? If so, how 

much efficiency improvement can be achieved? What is the incremental 

manufacturing cost?

• Are there other design considerations that are important in determining an appropriate 

clearance between basket and tub? If so, please elaborate.

Improved Water Extraction to Lower Remaining Moisture Content (RMC)

• Have you considered increasing the spin speed of the wash basket for the final spin 

cycle? What design changes would be required for this and what would be the 

incremental manufacturing cost? What would be the associated improvement in 

efficiency?

• Have you considered changing the direction of rotation to more evenly distribute 

clothes? If so, how much efficiency improvement can be achieved? What would be 

the incremental manufacturing cost?

• Have you considered longer spin cycles to lower the RMC? How much efficiency 

improvement can be achieved?

• How much efficiency improvement can be achieved through increasing the size or 

number of drainage holes in the washer drum? What would be the associated 

manufacturing cost?

• Based on DOE’s review of the CEC product database, front-loading washer RMC 

values range from 30 to 53 percent and top-loading washers RMC values range from 

35 to 61 percent. What RMC levels can be achieved with the above mentioned 

improved water extraction design changes? What RMC levels are achieved by your 

currently offered top-load clothes washers? Front-load clothes washers? 

• Does the size of the test load affect the RMC that can be achieved? If so, are you 

aware of any data showing this relationship?

Drum Motor Upgrades and Improvements 

• What types of drum motors do you currently employ in your clothes washers?
5-C-10

Increased Motor Efficiency

• Have you considered improved motor efficiency as a design option? If so, how much 

improvement can be achieved? What is the incremental manufacturing cost associated 

with improved motor efficiency?

• DOE’s review of literature and research indicates that replacing a split-phase motor 

with a capacitor-start motor may increase the efficiency of the motor by 10 percent. 

Would you consider this accurate?

• How much efficiency improvement can be achieved with permanent magnet motors? 

• What percentage of the overall energy consumption in a wash cycle is associated with 

the drum motor?

Direct-Drive Motors

• Do any of your top-loading or front-loading washers use a direct-drive motor? How 

much efficiency improvement can be achieved with this design option as compared to

the conventional motor/transmission system? Are the efficiency improvements 

different for each product class? 

• What type of motor would be used for this technology option (e.g., brushless directcurrent (BLDC) motor)? 

• How would a direct-drive system affect cleaning performance, cycle times, or spin 

speeds? 

• Are there larger standby power requirements for a direct-drive motor system? If so, 

how much? 

• What is the incremental manufacturing cost associated with a direct-drive motor? 

Spray Rinse or Similar Water-Reducing Rinse Technology

• Do your clothes washers currently incorporate spray rinse? How much efficiency 

improvement can be achieved through this design option? What is the incremental 

manufacturing cost?

• Do any of your clothes washers incorporate steam washing? How much efficiency 

improvement can be achieved through this design option? What is the incremental 

manufacturing cost?

• Do spray rinse and steam washing raise performance issues (e.g., reducing soil 

removal)?

Thermostatically Controlled Mixing Valves

• Have you considered thermostatically controlled water valves (TCWVs) as a design 

option to achieve energy savings by more accurately controlling inlet water 

temperature? How much efficiency improvement can be achieved? What is the 

incremental manufacturing cost? 

• Do adjustments to the water inlet temperatures raise performance issues (i.e., 

reducing soil removal with lower wash temperatures)?
5-C-11

• DOE believes that TCWV technology option has the potential to overstate the realworld energy savings, depending on the proximity of the water heater to the installed 

clothes washer and unheated water temperatures in different geographic locations and 

time of year. Are the benefits of TCWVs accurately captured by the test procedure? 

• Can efficiency improvements be achieved with non-thermostatically controlled water 

inlet systems, i.e., reducing the hot water energy use by reducing the warm water 

temperature using different hot and cold water ratios (40 percent hot and 60 percent 

cold as opposed to 50-50)? How much efficiency improvement can be achieved? Are 

there concerns with performance and consumer utility when adjusting the hot and 

cold water ratios?

Hot Water Circulation Loop

• Have you considered hot water circulation loop as a design option (i.e., using the hot 

water line running through a heat exchanger to heat cold water for use in a clothes 

washer)? How much efficiency improvement can be achieved? What is the 

incremental manufacturing cost associated with this design option?

Alternative Cleaning Processes

Plastic Particle Cleaning

• Have you considered plastic particle cleaning (i.e., tumble clothes with polymer 

granules which absorb dirt) as a design option? Has there been any attempt to 

commercialize this technology? DOE’s review of research and literature indicates that 

this technology would require 2 percent of the water used by a conventional clothes 

washer. Would you consider this accurate?

Bubble Action

• Have you considered an air-bubble feature as a design option (i.e. using air bubbles to 

more effectively deliver detergent to the surface of the clothing, while requiring less 

water than a typical wash cycle)? If so, what technology are you using to generate the 

bubbles? How much efficiency improvement can be achieved? What is the 

incremental manufacturing cost? 

Electrolytic Disassociation of Water

• Have you considered electrolytic disassociation of water as a design option (i.e., 

reducing hot water usage by substituting the electrolytic production of bleaching 

agents for the activation of bleaching chemical reactions in detergents by hot water)? 

How much efficiency improvement can be achieved? What is the incremental 

manufacturing cost?
5-C-12

Ozonated Laundering

• Would you consider ozonated laundering a viable design option? How much 

efficiency improvement can be achieved? What is the incremental manufacturing 

cost?

Smart Grid Technologies

• Have you considered smart grid technologies as a design option? If so, what specific 

capabilities would be enabled by the smart grid technology? Other than shifting 

energy usage away from peak power periods, could smart grid technology affect the 

overall energy efficiency of the clothes washer? How much efficiency improvement 

can be achieved? What is the incremental manufacturing cost?

Standby Power

• What are the consumer utilities associated with each type of display used in clothes 

washer? (For example, cycle/temperature selection, delay start time, cycle time, etc.)

• What types of display technologies do you use in your clothes washer product line? 

What are the standby power requirements for each display type assuming a 

comparable display (size and capability)?

• Are you aware of consumers demanding specific display types or is it other clothes 

washer features that attract them?

• What are the manufacturing costs associated with various display technologies?

• What drives the costs for each display technology?

• What would be the manufacturing costs associated with adding a feature to dim or 

turn off the displays? How much could this potentially decrease power consumption?

• What clothes washer features other than displays contribute to standby power, and 

what is the standby power requirement associated with each of them?

• Do any of your clothes washers incorporate switching power supplies? Is this a viable 

technology for reducing standby power in clothes washers? What is the incremental 

manufacturing cost of a switching power supply compared to a conventional linear 

power supply?

• Would you consider the following a viable design option for reducing standby power, 

and if so what would be the incremental manufacturing cost: a transformer-less power 

supply design, incorporated with a “soft” power pushbutton and triac to control power 

through the transformer, providing just enough power through the transformer-less 

power supply to maintain the microcontroller chip while the clothes washer is not 

powered on. When the power button is pressed, current would then be allowed to pass 

through the transformer of the conventional power supply to power the remainder of 

the control board.

• What other design options are available for reducing standby power consumption? 

What is the associated incremental manufacturing cost?
5-C-13

3. Test Procedure Issues

• How do you currently measure the capacity of your clothes washers? More 

specifically, at what level do you fill the washer with water for the DOE capacity 

measurement for top-loaders? What level do you fill the washer with water for frontloaders? Is the capacity measurement for the DOE energy test the same capacity used 

for marketing purposes? Would you suggest any changes to the current language for 

measuring capacity in the DOE energy test procedure? 

• Do you have any data showing the effects on RMC results using test cloth from 

different lots for a given clothes washer unit? Have you observed significant test-totest variation in MEF and WF measurements and RMC results as the test cloth ages 

(from 0 to 60 runs) for a given clothes washer unit? If so, how much is this variation? 

Do you have any test data showing this variation? Are there other test cloth issues 

that affect the measured test results that you are aware of? Would you recommend 

any changes to the test cloth specifications currently included in the DOE test 

procedure?

• Since the AHAM-2A detergent is no longer available, what detergent do you 

currently use to precondition the test cloths according to the DOE test procedure?

• The current DOE test procedure does not require the use of detergent during the 

energy test wash cycles. Do you believe the test procedure should be amended to 

require the use of detergent during the energy test wash cycles? If so, would you 

suggest using a powder or liquid detergent? Should DOE specify a specific brand of 

detergent to use to help ensure repeatability of test results? Would there be any 

concerns with the repeatability of test results using a liquid detergent?

• Do you have any consumer usage data showing the percentage of consumers that use 

powder detergent versus liquid detergent? 

• The current DOE test procedure does not provide specifications for the test load size 

for clothes washer capacities greater than 3.8 ft3

. Would a linear extrapolation of test 

load sizes for capacities greater than 3.8 ft3 be appropriate? If not, can you suggest 

appropriate test load sizes (minimum, average, and maximum) for capacities greater 

than 3.8 ft3? 

• Are you aware of any test procedures which account for adaptive controls (other than 

adaptive water fill control)?

• Are the temperature use factors specified by the current test procedure, which provide 

a weighted-average measurement of energy and water performance under the range of 

typical wash and rinse cycle temperature selections, representative of current 

consumer patterns and available wash cycles?

• Are there any clothes washer features currently available in the market that you 

believe should be incorporated into the test procedure? For example, should the test 

procedure incorporate steam cycles? Should the test procedure incorporate selfcleaning, deodorizing, or sanitizing cycles? Are there any other features that may 

impact the energy usage compared to a traditional wash and rinse cycle?

• Do you have any consumer usage data showing the percentage of consumers that use 

each type of wash cycle or advanced feature currently available in the market? 
5-C-14

5-C.2 QUESTIONNAIRE TO EVALUATE THE PRODUCT CLASSES AND 

STANDARDS PROPOSED IN THE CONSENSUS AGREEMENT

The Association of Home Appliance Manufacturers (AHAM) and the American Council 

for an Energy Efficient Economy (ACEEE) recently released a multi-product standards 

agreement (Consensus Agreement) that addressed negotiated standards for 

refrigerators/freezers, clothes washers, clothes dryers, room air conditioners, and 

dishwashers. For clothes washers, the Consensus Agreement proposes updated standards 

for top-loading standard and top-loading product classes, as well as splitting the existing 

front-loading product class into front-loading standard and front-loading compact clothes 

washers. DOE’s rulemaking process allows for a direct publication of a final rule if DOE 

concludes that standards proposed in the Consensus Agreement meet certain statutory 

criteria. In order to evaluate the product classes and standards proposed in the Consensus 

Agreement for residential clothes washers, DOE is requesting information on the topics 

in this questionnaire.

DOE is requesting information on the product classes in the table below. 

Baseline Efficiencies for Considered Product Classes

Product Class Product Class Description Baseline MEF

(ft3

/kWh/cycle)

Baseline 

Standby Power

(W)

Top-Loading, 

Standard

Top-loading with capacity 

greater than 1.6 ft3 1.26 0

Top-Loading, 

Compact

Top-loading with capacity 

less than 1.6 ft3 0.65 0

Front-Loading, 

Standard

Front-loading with capacity 

greater than 1.6 ft3 1.72 2.3

Front-Loading, 

Compact*

Front-loading with capacity 

less than 1.6 ft3 N/A N/A

*DOE is not aware of any compact front-loading clothes washers available on the market, and is especially 

interested in information on this product class to evaluate the proposed standard in the Consensus 

Agreement.

Any amended standards for clothes washers would be expressed in terms of the 

integrated modified energy factor (IMEF), as proposed in the test procedure NOPR 

published on September 21, 2010. 75 FR 57556. Based on the current definition, DOE 

expects IMEF to vary significantly from the current MEF metric. IMEF will account for 

standby and off mode energy consumption, as well as energy use from steam and selfcleaning cycles. The proposed test procedure also includes changes to the capacity 

measurement for top-loading washers, which will affect IMEF. The discussion below 

references efficiency levels in terms of MEF to avoid metrics unfamiliar to 

manufacturers.

1 KEY ISSUES

1.1 You previously indicated the following key issues in this rulemaking: [LIST KEY 

ISSUES] Do these remain key issues for your company in this rulemaking, and are 

there any additional key issues you believe DOE should consider in this 
5-C-15

rulemaking? 

2 ENGINEERING AND LIFE-CYCLE COST

2.1 Are the AHAM-supplied average incremental manufacturing costs at each 

efficiency level representative of costs your company incurs at each of these efficiency 

levels? Also, please indicate if the design options you previously stated for the given 

efficiency levels are still valid.

AHAM-Supplied Standard Top-Loading Incremental Costs

MEF

(ft3

/kWh/cycle)

AHAM Average 

Incremental Cost 

(materials, labor, OH)

Actual 

Incremental Cost 

(if different)

Description of Design Options

1.40 $3.08

1.72 $8.39 Electronics, load sensors, spray rinse, temperature 

sensors, modified agitators/baskets 

1.80 $13.02 Same as above

2.00 $23.99

Impeller, stainless baskets (higher spin speeds), 

better electronic controls/sensors, hung

suspension, lower water temperatures, longer 

cycles, variable motor drives

2.26 $59.25

Higher spin speeds, better load detection/flow 

meters, sophisticated drives, accelerometers, better 

suspension, longer cycles

AHAM-Supplied Standard Front-Loading Incremental Costs

MEF

(ft3

/kWh/cycle)

AHAM Average 

Incremental Cost 

(materials, labor, OH)

Actual 

Incremental Cost 

(if different)

Description of Design Options

1.80 $2.13

2.00 $6.09 Electronic UI

2.20 $15.73 Better damping/sensing systems, water level 

sensors paired with flow meters

2.40 $38.89

2.89 $72.13

2.2 At the time the Framework Document was published, the max-tech units had 

MEF ratings of 2.26 and 2.89 for top-loading and front-loading clothes washers 

respectively. DOE is now aware of top-loading clothes washers with a MEF of 2.57, and 

front-loading clothes washers with a MEF of 3.35. What design features and associated 

costs would be necessary to reach these efficiencies?

2.3 Do the design options and associated costs in the tables above also apply to the 

compact front- and top-loading product classes? 

2.4 Please comment on any issues related to the following proposed changes to the 

DOE clothes washer test procedure and how they may impact the design options used to 

reach higher efficiencies for each product class, as appropriate:
5-C-16

2.4.1 Standby and Off Mode Power

How would accounting for standby and off mode power impact the measured efficiencies 

of clothes washers? Would the inclusion of standby and off mode power affect the 

design options currently used to reach higher efficiencies?

2.4.2 Steam Wash Cycles

How would accounting for steam wash cycles affect the measured efficiency of clothes 

washers with this feature compared to the efficiency as measured using the existing test 

procedure? Is it appropriate to account for steam wash cycles in the measured efficiency 

of clothes washers? What percentage of your total shipments do clothes washers offering 

a steam wash cycle account for?

2.4.3 Self-Clean Cycles

How would including self-clean cycles affect the measured efficiency as compared to the 

current test procedure? What fraction of your total clothes washer shipments includes a 

pre-set self-clean cycle, and how frequently do you recommend consumers use such a 

cycle?

2.4.4 Use Factors

Will the proposed amendments to the use factors in the DOE test procedure significantly 

affect the measured efficiencies of any clothes washers? Are the proposed values 

consistent with actual consumer use? Can you provide any non-proprietary data related 

to consumer use of different cycles?

2.4.5 Capacity Measurement Method

Will the proposed capacity measurement method affect the design options you use to 

reach higher efficiencies?

2.4.6 Energy Test Cycle Definition

How will the changes to the energy test cycle definition change how your clothes washers 

are tested? Will this revised definition limit the design options available for reaching 

higher efficiencies?

3 CONVERSION COSTS

The MIA considers two types of conversion costs:

• Capital conversion costs are one-time investments in plant, property, and 

equipment (PPE) necessitated by an amended energy conservation standard. 

These may be incremental changes to existing PPE or the replacement of existing 

PPE. Included are expenditures on buildings, equipment, and tooling.

• Product conversion costs are costs related research, product development, testing, 

marketing and other costs for redesigning products necessitated by an amended 

energy conservation standard.
5-C-17

3.1 The tables below show the AHAM-submitted average capital conversion costs for 

a number of efficiency levels. Please indicate if your expected capital conversion costs 

vary from the AHAM-submitted estimate. In the description column, DOE is interested in 

understanding the kinds of changes that would need to be implemented to production 

lines and production facilities at each efficiency level. Where applicable, please quantify 

the number and cost of new production equipment, molds, etc. that would be required to 

implement the specified design changes. 

AHAM-Supplied Standard Top-Loading Capital Conversion Costs

MEF

(ft3

/kWh/cycle)

AHAM Average 

Capital Conversion 

Costs ($mm)

Actual Capital 

Conversion Cost 

(if different)

Description

1.40 $1.51

1.72 $34.98

1.80 $37.84

2.00 $41.76

2.26 $60.88

AHAM-Supplied Standard Front-Loading Capital Conversion Costs

MEF

(ft3

/kWh/cycle)

AHAM Average 

Capital Conversion 

Costs ($mm)

Actual Capital 

Conversion Cost 

(if different)

Description

1.80 $0.85

2.00 $0.86

2.20 $13.32

2.40 $19.46

2.89 $25.78

3.2 The tables below show the AHAM-submitted average product conversion costs 

for a number of efficiency levels. Please indicate if your expected product conversion 

costs vary from the AHAM-submitted estimate. In the description column, DOE is 

interested in understanding such expenses as product development, prototyping, testing, 

certification, and marketing. In the description column, please describe the assumptions 

behind the estimates provided. 

AHAM-Supplied Standard Top-Loading Product Conversion Costs

MEF

(ft3

/kWh/cycle)

AHAM Average 

Product Conversion 

Costs

Actual Product 

Conversion Cost 

(if different)

Description

1.40 $0.93

1.72 $1.43

1.80 $3.62

2.00 $7.95

2.26 $12.84
5-C-18

AHAM-Supplied Standard Front-Loading Product Conversion Costs

MEF

(ft3

/kWh/cycle)

AHAM Average 

Product Conversion 

Costs

Actual Product 

Conversion Cost 

(if different)

Description

1.80 $0.53

2.00 $0.53

2.20 $3.10

2.40 $5.91

2.89 $11.48

3.3 Are the capital and product conversion costs described above applicable to the 

compact product classes as well? Would the magnitude and nature of the conversion 

costs differ for the compact product classes?

3.4 Please provide additional qualitative information to help DOE understand the 

types and nature of your investments, including the plant and tooling changes and the 

product development effort required at different efficiency levels.

4 MARKUPS AND PROFITABILITY

DOE estimated the manufacturer production costs for the two standard product classes of 

residential clothes washers. DOE assumed the other two compact product classes would 

have similar baseline markup values. DOE defines manufacturer production cost as all 

direct costs associated with manufacturing a product: direct labor, direct materials, and 

overhead (which includes depreciation). The manufacturer markup is a multiplier applied 

to manufacturer production cost to cover non-production costs, such as SG&A and R&D, 

as well as profit. It does not reflect a “profit margin.” 

The manufacturer production cost multiplied by the manufacturer markup equals the 

manufacturer selling price. Manufacturer selling price is the price manufacturers charge 

their first customers, but does not include additional costs along the distribution channels. 

4.1 Please comment on the baseline markups DOE calculated as compared to your 

company’s baseline markups for the clothes washer product classes.

Residential Clothes Washer Baseline Manufacturer Markups by Product Class

Product Class Product Class Description

Estimated 

Baseline 

Markup

Manufacturer Comments 

or Revised Estimates

Top-Loading, 

Compact

Top-loading with capacity less than 

1.6 ft3 1.22

Top-Loading, 

Standard

Top-loading with capacity greater 

than 1.6 ft3 1.22

Front-Loading, 

Compact

Front-loading with capacity less than 

1.6 ft3 1.30

Front-Loading, 

Standard

Front-loading with capacity greater 

than 1.6 ft3 1.30
5-C-19

4.2 One of the possible scenarios DOE uses to model impacts on industry profitability 

is the impact of commoditization of premium products. Because the market disruption 

caused by standards can alter the pricing of premium products, DOE is interested in 

understanding if efficiency is a feature that earns a premium. Within each product class, 

do markups vary by efficiency level? If yes, please provide information about the 

markups at efficiencies above the baseline in the tables below. Would these markups also 

vary for compact product classes?

Estimated Standard Top-Loading Markups by Efficiency Level

MEF

(ft3

/kWh/cycle)

Estimated 

Markup Manufacturer Comments

1.40

1.72

1.80

2.00

2.26

Estimated Standard Front-Loading Markups by Efficiency Level

MEF

(ft3/kWh/cycle)

Estimated 

Markup Manufacturer Comments

1.80

2.00

2.20

2.40

2.89

4.3 Would you expect changes in your estimated profitability following an amended 

energy conservation standard? If so, please explain why. Can you suggest any scenarios 

that would model these expected changes?

5 FINANCIAL PARAMETERS

5.1 In order to accurately collect information about clothes washer manufacturing, 

please compare your financial parameters to the GRIM parameters tabulated below.
5-C-20

Financial Parameters for Residential Clothes Washer Manufacturing

GRIM Input Definition Industry 

Estimated

Value (%)

Your Actual (If 

Different from 

DOE’s 

Estimate)

Income Tax 

Rate

Corporate effective income tax paid (percentage of 

earnings before taxes, EBT) 34.3

Discount Rate

Weighted average cost of capital (inflationadjusted weighted average of corporate cost of 

debt and return on equity)

8.0

Working 

Capital

Current assets less current liabilities (percentage of 

revenues) 6.5

Net PPE Net plant property and equipment (percentage of 

revenues) 17.7

SG&A Selling, general, and administrative expenses 

(percentage of revenues) 11.3

R&D Research and development expenses (percentage 

of revenues) 2.2

Depreciation Amortization of fixed assets (percentage of 

revenues) 4.7

Capital 

Expenditures

Outlay of cash to acquire or improve capital assets 

(percentage of revenues, not including acquisition 

or sale of business units)

2.7

Cost of Goods 

Sold

Includes material, labor, overhead, and 

depreciation (percentage of revenues) 83.0

6 ADDITIONAL IMPACTS

6.1 You previously indicated the following regulatory burdens: changes in 

refrigerants, outcome of Copenhagen, building codes (green building programs and 

LEED), management over product life (take-back legislation), and RoHS regulations in 

California, Minnesota, and Canada. You additionally listed the DOE’s regulation of 

commercial clothes washers, clothes dryers, refrigerators and room air conditioners. Do 

these still represent regulatory burdens, and are there any additional regulatory burdens at 

this time? What costs do you anticipate incurring to meet these regulations?

6.2 The impact of amended energy conservation standards on employment is an 

important consideration in the rulemaking process. Where are your residential clothes 

washer facilities that produce products for the United States located? Please also provide 

employment levels and total washer shipments at each of these facilities.

6.3 At what efficiency levels would you consider relocating current domestic 

production abroad?

6.4 Are you aware of any small businesses, niche manufacturers, or component 

manufacturers for which amended energy conservation standards would have a severe 

impact? If so, why?

6.5 Have any of your US facilities qualified for grants available through the American 

Recovery and Reinvestment Act? Has your company reached the $75 million limit for 

efficient appliances under the Energy Improvement and Extension Act of 2008? How 
5-C-21

many shipments of washers qualifying for a $250 production tax credit under the Energy 

Improvement and Extension Act do you anticipate manufacturing in 2010?
5-C-22

5-C.3 INFORMATION REQUEST FOR COMPACT-SIZE PRODUCT 

CLASSES FOR RESIDENTIAL CLOTHES WASHERS

The United States Department of Energy (DOE) is currently reviewing energy 

conservation standards for residential clothes washers, including the standards proposed 

in the AHAM-ACEEE Multi-Product Standards Agreement (“Consensus Agreement”). 

In particular, DOE would like to understand the rationale for the proposed efficiency 

standards for the top-loading compact and front-loading compact product classes.

1. Consensus Agreement Standard Levels

Table 1 shows the proposed standards in the Consensus Agreement.

Table 6. AHAM-ACEEE Multi-Product Standards Agreement for Residential 

Clothes Washers 

Product Description

New Standard

Jan. 1, 2015

(MEF/WF)

New Standard

Jan. 1, 2018

(MEF/WF)

Top-Loading, Compact

(less than 1.6 cubic feet capacity) 1.26 / 14.0 1.81 / 11.6

Top-Loading, Standard 1.72 / 8.0 2.0 / 6.0

Front-Loading, Compact

(less than 1.6 cubic feet capacity) 1.72 / 8.0

Front-Loading, Standard 2.2 / 4.5

Table 2 compares the Consensus Agreement standards for the compact product classes to 

the current DOE standard, as well as the efficiency levels of compact top-loaders 

currently on the market.

Table 7. Efficiency Levels for Compact-Size Residential Clothes Washers

Efficiency Level Source

Efficiency Level

MEF WF

Top-Loading, Compact

DOE Standard 0.65 none

Level 1 (currently on the market) 0.78 13.9

Level 2 (currently on the market) 1.00 12.7

Consensus Agreement, 2015 1.26 14.0

Consensus Agreement, 2018 1.81 11.6

Front-Loading, Compact

DOE Standard 1.26 none

Consensus Agreement, 2015 1.72 8.0
5-C-23

Questions:

• Top-loading compact

o How were the standards for the top-loading compact product class 

established?

o What was the rationale for the tiered standards?

o Are you aware of any products on the market that meet the 2015 

standards? 2018 standards?

o Within the top-loading compact product class, what percentage market 

share do your company’s shipments represent?

o Do you foresee any potential changes in the competitive landscape for 

compact clothes washers due to the proposed standards?

• Front-loading compact

o How were the proposed standards for the front-loading compact product 

class established?

o Are you aware of any compact front-loaders on the market that meet the 

proposed standards? If not, do you foresee any entrants into this market in 

the future?
5-C-24

2. Design Options and Costs for Achieving Proposed Standard Levels

The inclusion of more stringent standards for top-loading compact and front-loading 

compact product classes in the Consensus Agreement implies that these standards are 

technologically achievable and economically justifiable. Because the proposed standards 

for the top-loading product class represent a significant improvement over current 

standards, DOE would like to better understand how these higher standard levels can be 

achieved. Table 3 shows the design options considered for standard-size top-loading 

clothes washers.

Table 8. Design Options for Standard-Size Top-Loading Clothes Washers

Design Options

Applicable to Compact 

Product Class?

More Advanced Controls

Adaptive fill control (more accurate pressure switches)

Temperature control (more accurate sensors)

Water inlet valves (more accurate flow control)

Electronic controls

Accelerometers

Motor Improvements

More efficient motor

Variable speed drive

Higher spin speeds

Basket/Drum Modifications

Basket shape modification

Stainless steel basket

Larger capacity

Stronger basket

Agitator modification

Reduced Water Consumption

Spray rinse

Recirculation pumps

Gray-water rinse

Structural Improvements

Better suspension system

Out-of-balance detection

Operational Design Options

Longer cycle times

Lower water temperatures
5-C-25

Questions:

• What design options are available for the compact product classes to meet the 

higher standard levels?

• What design options are most likely to be used to reach the proposed 2015 

standards? The 2018 standards?

• What are the average costs associated with meeting each incremental standard 

level? (See Table 4)

Table 9. Cost Associated with Meeting Each Incremental Efficiency Level

Efficiency Level Source

Efficiency Level Incremental Cost 

MEF WF ($/Unit)

Top-Loading, Compact

DOE Standard 0.65 none

Level 1 (currently on the market) 0.78 13.9

Level 2 (currently on the market) 1.00 12.7

Consensus Agreement, 2015 1.26 14.0

Consensus Agreement, 2018 1.81 11.6

Front-Loading, Compact

DOE Standard 1.26 none

Consensus Agreement, 2015 1.72 8.0

• Are there any significant differences between product types or platforms (e.g.

stacked washer/dryer vs. portable top-loading washer) that could affect the ability 

for a particular product type to achieve the proposed standard levels?

• Can the front-loading compact efficiency standards be achieved assuming similar 

design options as “nearly compact” front-loaders ranging from 1.6-2.4 cubic feet?
5-C-26

3. Consumer Utility

DOE would like to better understand the unique consumer utility offered by compact-size 

clothes washers.

Questions:

• Does the market continue to demand clothes washers with capacity less than 1.6 

cubic feet?

• Are the disparate compact top-loading products considered substitutes for each 

other? Or does each distinct product type satisfy a unique niche within the 

market? (e.g. stacked washer/dryer vs. portable top-loading washer)

• Would the proposed standards have any negative impacts on consumer utility of 

compact-size clothes washers?