This is a draft document and does not represent a definitive view of the agency on the questions 

addressed. 

This and other guidance documents are accessible on the U.S. Department of Energy, Energy Efficiency 

& Renewable Energy web site at: http://www1.eere.energy.gov/guidance/default.aspx?pid=2&spid=1. 

Guidance Type: Conservation Standards, Enforcement 

Category: Commercial Equipment 

Product: Walk-in Cooler and Walk-in Freezers 

Guidance Version: DRAFT 

Issued: January 20, 2012 

Comment Period Closes: February 20, 2012 

Q: What are the relevant dates for compliance with the prescriptive requirements for walk-in coolers 

and walk-in freezers? For example: If a newly manufactured component of a walk-in cooler or walkin freezer is installed in a walk-in box manufactured prior to January 1, 2009, does it have to comply 

with the prescriptive requirements of 10 C.F.R. § 431.306? 

A: The following is a draft U.S. Department of Energy (DOE) guidance document regarding commercial 

walk-in coolers and walk-in freezers. This draft guidance document represents the Department’s 

interpretation of its existing regulations and is exempt from the notice and comment requirements of 

the Administrative Procedure Act. See 5 U.S.C. § 553(b)(A). Therefore, the Department is accepting 

comments and suggestions from the public until February 20, 2012. Comments and suggestions should 

be provided in WordPerfect, Microsoft Word, PDF, or text file format by sending an email to WICFEISA2007Guidance-2012-0001@ee.doe.gov. Please also include the docket number EERE-2012-BT-STD0001. At the end of the comment period, this draft guidance document may be adopted, revised or 

withdrawn. 

Earlier this year, DOE issued two rules that detailed a general approach with respect to the regulation of 

walk-in coolers and freezers (“WICFs” or “walk-ins”) -- the WICF test procedure final rule (76 Fed. Reg. 

21580 (April 15, 2011)) and the certification, compliance, and enforcement (CCE) final rule (76 Fed. Reg. 

12422 (March 7, 2011)). Because the statutory framework enacted by Congress established a series of 

component-based standards, DOE opted to follow this approach in regulating this equipment by 

establishing a test procedure that accounts for these component-specific standards. This approach 

effectively results in enforcement at the component level and requires component manufacturers to 

certify that the components they produce meet the applicable standard or standards. The CCE 

rulemaking further clarified that assemblers of walk-in systems are required to use only components 

that comply with the Federal standards. 76 FR 12422, 12444. 

In response to these rules, DOE has received a number of questions regarding how to apply the 

component-based approach when deciding which replacement components to install into WICF 

applications. Specifically, under what circumstances must WICF replacement components meet the 

applicable Federal standards? This guidance document addresses that question as it pertains solely to 

those requirements that have already been prescribed in EPCA as a result of amendments added by the 

Energy Independence and Security Act of 2007 (Pub. L. No. 110-140 (Dec. 19, 2007)) (EISA). These 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

requirements, which are currently in place and became effective as of January 1, 2009, are also found at 

10 CFR 431.306. DOE may amend this guidance in the future as needed. 

The guidelines presented below, which are consistent with the component-level approach established 

by Congress, include examples to illustrate their application. 

Guideline 1: All WICF components covered under EISA and manufactured on or after January 1, 2009, 

that are used in WICF applications must comply with the relevant EISA requirements. This includes WICF 

components that are assembled to make a newly constructed WICF and a WICF component that goes 

into an existing, previously installed WICF to replace a component. 

Example 1: A display door manufactured after January 1, 2009, and used in a walk-in cooler must comply 

with the relevant EISA requirements for a walk-in cooler display door no matter whether the display 

door is being installed in a new WICF or is a replacement for a display door in an existing WICF. (If the 

same or similar display door is used in an application other than a WICF, it does not have to meet the 

EISA requirements for WICF display doors.) 

Example 2: A WICF evaporator, manufactured prior to January 1, 2009, requires a replacement fan 

motor. If the replacement fan motor was manufactured after January 1, 2009 and is going to be used as 

a replacement for an existing WICF, it must be compliant with the WICF standard. Thus, the motor must 

be an ECM motor or a 3-phase motor. 

Guideline 2: WICF components covered by EISA and manufactured prior to January 1, 2009, that are
 

installed in WICFs manufactured prior to January 1, 2009, do not have to meet the relevant EISA
 

requirements.
 

Example: A WICF manufactured prior to January 1, 2009, needs a replacement door. The door may be
 

replaced from existing inventory consisting of replacement doors manufactured prior to January 1,
 

2009, and that door does not have to meet the EISA requirements for doors.
 

DOE believes this approach is permissible under the legal framework established by EISA and 

will not cause undue burden for the following reasons. First, DOE expects there to be a sufficient supply 

of WICF components to meet the demand for replacement components for WICFs manufactured after 

January 1, 2009. Component manufacturers are already producing compliant components as required 

under EISA, and supplying owners of pre-2009 WICFs with components as needed should not present 

any problems given the relatively small demand. 

DOE also believes customers will not be “stranded” – that is, unable to find replacement 

components for WICFs manufactured before January 1, 2009 – because existing products are available 

to meet the demand. For example, many motor manufacturers offer ECM motors as drop-in 

replacements for shaded pole and PSC fan motors that were installed in pre-2009 WICFs. For envelope 

components, which may be custom-made, DOE expects that in the majority of cases, manufacturers 

would be capable of supplying EISA-compliant components to replace non-EISA-compliant components 

that were manufactured before January 1, 2009. For example, if a cooler non-display door or panel 

made of 3 1⁄2 inches of expanded polystyrene foam fails, it can be replaced with a component made of 3 

1⁄2 inches of extruded polystyrene or polyurethane foam, which would meet the EISA R-value 

requirement. If a freezer display door with 2 panes of glass fails, it can be replaced with a 3-pane door. 

In a case where the component must be replaced with a component of different dimensions to meet the 

standard – for instance, if a 3-inch freezer panel would have to be replaced with a 4-inch panel – 

manufacturers and customers have several options. If the panels can be connected using the panel 

locking system, the difference in thickness can be made up with gasketing. The panel can also be 

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replaced with a 3-inch panel from inventory manufactured before January 1, 2009. Another option is to 

replace the panel with a used panel; used components are not covered under the EISA requirements, 

which only apply to new products. 

Finally, DOE believes manufacturers will not be left with a significant amount of inventory they 

cannot sell. Any components manufactured prior to January 1, 2009, can be used as replacement 

components in WICFs manufactured before January 1, 2009. DOE realizes that in the absence of 

comprehensive guidance, some manufacturers may have continued to produce replacement 

components for pre-2009 walk-ins that did not meet the EISA standards even after the January 1, 2009, 

compliance date. To address this concern, the guidelines presented in this document will not be applied 

retroactively to components made prior to the issuance of this guidance but on or after January 1, 2009. 

As a result, if a manufacturer in 2010 produced a panel that did not meet the required R-value as a 

replacement for a panel in a WICF manufactured prior to January 1, 2009, the manufacturer would not 

be penalized for producing a noncompliant component. DOE does not believe that any additional lead 

time is warranted. 

DOE believes the approach outlined in these guidelines will enable manufacturers to satisfy the 

EISA requirements without subjecting them or their customers to an undue burden. The approach 

ensures that all new equipment manufactured since January 1, 2009 – both complete WICFs and 

components thereof – comply with the EISA requirements while permitting components manufactured 

before January 1, 2009, or used components, to be used as replacement components in WICFs 

manufactured before January 1, 2009. Finally, this guidance is consistent with the component-level 

approach enacted by Congress through EISA and requires newly manufactured components to comply 

with the applicable standards regardless of whether they are used in a new installation or as 

replacement components for a previous installation. 

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