Building Technologies Program

Office of Energy Efficiency and Renewable Energy

U.S. Department of Energy

November 14, 2008

Test Procedure for 

Microwave Ovens

NOPR Public Meeting

http://www1.eere.energy.gov/buildings/appliance_standards/residential/cookin

 EERE-2008-BT-TP-0011 COMMENT 06
Purpose of the Test Procedure NOPR Public Me

 Present the Department’s proposed test procedure for mic

ovens

 Seek comment from participants on the proposed test pro Discuss specific issues or questions related to the propos Discuss the next steps for the rulemaking

 EERE-2008-BT-TP-0011 COMMENT 06
Final

Rule

NOPR

 NOPR issued by DOE on October 1, 2008 NOPR Public Meeting today, November 14, 2008 Comments on NOPR from interested parties

• Transcript records oral comments from today’s public meet• Written comments (comment period closes December 31, 

 DOE reviews and considers all comments Final Rule Publication

• Final Rule is expected to be published no later than the Fin

the energy conservations standards rulemaking (March 20

Steps in the Microwave Oven Test Procedure Rule

 EERE-2008-BT-TP-0011 COMMENT 06
Test Procedure Overview and Issues

1. Products Covered by this Test Procedure Rulemaking2. Effective Date for the Test Procedure3. Measures of Energy Consumption4. Incorporating by Reference IEC Standard 62301 First Edition 200

Measuring Standby Mode and Off Mode power in Microwave Ove

5. Definitions of “Active Mode”, “Standby Mode”, and “Off Mode”6. Specifications for the Test Methods and Measurements for Micro

Standby Mode and Off Mode Testing

7. Technical Correction for the Microwave Oven Test Cooking Ener8. Compliance with Other EPCA Requirements

 EERE-2008-BT-TP-0011 COMMENT 06
 Workshop participants are invited to provide summary com

statements

 Participants are also invited to raise their issues on the Te

Procedure NOPR for discussion today

Comments and Issues from Participants

 EERE-2008-BT-TP-0011 COMMENT 06
Regulatory History

 The Energy Policy and Conservation Act (42 U.S.C. 6291 e

forth criteria and procedures for DOE’s adoption and amentest procedures for covered products.

 Test Procedure for Kitchen Ranges, Cooktops, Ovens, and 

Ovens, Final Rule. 62 FR 51976, October 3, 1997.

• Established test procedures for measuring the efficiency an

energy consumption of microwave ovens.

• Incorporated by reference IEC Standard 705-1998 and Am

1993, Methods for Measuring the Performance of MicrowaHouseholds and Similar Purposes.

• The test procedure currently does not provide for a measu

microwave oven standby- or off-mode energy consumption

 EERE-2008-BT-TP-0011 COMMENT 06
Regulatory History - Continued

 Energy Independence and Security Act of 2007 (EISA 2007

Amendments to EPCA

• Directs DOE to incorporate standby- and off-mode energy 

into its microwave oven test procedure by March 31, 2011. 

– DOE is accelerating the microwave oven test procedure schedule 

be used in energy conservation standards that are the subject of rulemaking, which has a scheduled final rule date of March 31, 20

• Directs DOE to integrate such energy consumption into the 

descriptor. If technically infeasible, DOE must prescribe a standby mode and off mode energy use test procedure if tefeasible.

• DOE must consider the most current versions of IEC Stand

and 62087.

– IEC Standard 62301, Household electrical appliances–Measurem

power, First Edition 2005-06

– IEC Standard 62087, Methods of measurement for the power con

audio, video and related equipment, First Edition 2002-03 [Not Re

 EERE-2008-BT-TP-0011 COMMENT 06
Test Procedure Overview

1. Products Covered by this Test Procedure Rulemaking2. Effective Date for the Test Procedure3. Measures of Energy Consumption4. Incorporating by Reference IEC Standard 62301 First Edition 200

Measuring Standby Mode and Off Mode power in Microwave Ove

5. Definitions of “Active Mode”, “Standby Mode”, and “Off Mode”6. Specifications for the Test Methods and Measurements for Micro

Standby Mode and Off Mode Testing

7. Technical Correction for the Microwave Oven Test Cooking Ener8. Compliance with Other EPCA Requirements

 EERE-2008-BT-TP-0011 COMMENT 06
Products Covered by this Test Procedure Rulem

 10 CFR 430.2 defines “microwave oven” as “a class of kitchen rang

ovens which is a household cooking appliance consisting of a com

designed to cook or heat food by means of microwave energy.”

 Proposed amendments cover all microwave ovens for which the pri

source of heating energy is electromagnetic (microwave) energy.

• Includes microwave ovens with and without thermal elements (desig

surface browning of food).

• Does not address combination ovens or microwave/conventional ran

 DOE will conduct a subsequent separate rulemaking to amend the 

conventional cooking products test procedure.

• DOE does not have standby mode or off mode power data to determ

changes would be required in the test procedures for those products

C

 EERE-2008-BT-TP-0011 COMMENT 06
Test Procedure Overview

1. Products Covered by this Test Procedure Rulemaking2. Effective Date for the Test Procedure3. Measures of Energy Consumption4. Incorporating by Reference IEC Standard 62301 First Edition 200

Measuring Standby Mode and Off Mode power in Microwave Ove

5. Definitions of “Active Mode”, “Standby Mode”, and “Off Mode”6. Specifications for the Test Methods and Measurements for Micro

Standby Mode and Off Mode Testing

7. Technical Correction for the Microwave Oven Test Cooking Ener8. Compliance with Other EPCA Requirements

 EERE-2008-BT-TP-0011 COMMENT 06
Effective Date for the Test Procedure

 DOE expects to publish the microwave oven test procedur

rule before publishing a final rule in the concurrent energy conservation standards rulemaking. 

 The effective date of the modified microwave oven test pro

would be three years after the test procedure final rule is pwhich is expected to be before the effective date of any apstandards.

 EERE-2008-BT-TP-0011 COMMENT 06
Test Procedure Overview

1. Products Covered by this Test Procedure Rulemaking2. Effective Date for the Test Procedure3. Measures of Energy Consumption4. Incorporating by Reference IEC Standard 62301 First Edition 200

Measuring Standby Mode and Off Mode power in Microwave Ove

5. Definitions of “Active Mode”, “Standby Mode”, and “Off Mode”6. Specifications for the Test Methods and Measurements for Micro

Standby Mode and Off Mode Testing

7. Technical Correction for the Microwave Oven Test Cooking Ener8. Compliance with Other EPCA Requirements

 EERE-2008-BT-TP-0011 COMMENT 06
Measures of Energy Consumption

 The DOE microwave oven test procedure provides for the calcula

several measures of energy consumption:

• Cooking efficiency• Energy factor (EF)• Annual energy consumption

 DOE’s microwave oven test procedure does not currently accoun

standby mode or off mode energy consumption.

 EPCA, as amended by EISA 2007, requires standby mode and off 

energy consumption to be “integrated into the overall energy effic

energy consumption, or other energy descriptor for each covered unless the Secretary determines that—

• (i) the current test procedures for a covered product already fully a

and incorporate standby mode and off mode energy consumption covered product; or 

• (ii) such an integrated test procedure is technically infeasible for a 

product, in which case the Secretary shall prescribe a separate staand off mode energy use test procedure for the covered product, ifeasible.” (42 U.S.C. 6296(gg)(2)(A))

 Although there are no current energy conservation standards for 

ovens, DOE’s rulemaking analyses have historically used EF as thconservation metric.

Measures of Ener

 EERE-2008-BT-TP-0011 COMMENT 06
Evaluating the Microwave Oven Energy Descr

 DOE evaluated the overall energy efficiency descriptor – E

determine whether it could be modified to include standby and off mode energy consumption.

 DOE sampled 32 microwave ovens, and AHAM independen

21 additional units. 

• Data from cooking tests showed a cooking efficiency range 

to 62 percent. 

• DOE was unable to correlate specific design options or oth

such as cavity size or output power with cooking efficiency

• The test data showed test-to-test variability of several EF p

points for a given microwave oven (i.e., where a given comdesign options could be assigned to a number of trial standdepending on the test results). 

Measures of Ener

 EERE-2008-BT-TP-0011 COMMENT 06
Evaluating the Microwave Oven Energy Descr

Measures of Ener

54%55%56%57%58%59%60%61%62%

600 700 800 900 1,000 1,100 1,200 1,300

Rated Output Power (W)

Efficiency (EF)

AHAM Standard MOTAHAM Inverter DriveDOE Standard MOTDOE Inverter Drive

 EERE-2008-BT-TP-0011 COMMENT 06
Evaluating the Microwave Oven Energy Descr

Measures of Ener

54555657585960616263

650 750 850 950 1,050 1,150 1,250

Measured Output Power (W)

Cooking Effciency (%)

54555657585960616263

600 700 800 900 

Measured Outpu

Cooking Efficiency (%)

AHAM EF Variability DOE EF Varia

 EERE-2008-BT-TP-0011 COMMENT 06
Evaluating the Microwave Oven Energy Descr

 The test procedure measures energy factor by heating 1 k

water 10 °C in a glass test vessel, with the microwave oven full power. 

 Manufacturers stated during interviews that the water used 

test procedure is not representative of an actual food load

 DOE believes that it is infeasible to specify a food load in t

procedure at this time, because it will require significant reand comments from stakeholders to understand what a representative food load is and how to ensure consistency properties from test to test.

Measures of Ener

 EERE-2008-BT-TP-0011 COMMENT 06
Combining Cooking Efficiency with Standby and Off 

Energy Use

 DOE explored whether it would be technically feasible to c

the energy efficiency during the cooking cycle (per-use) wstandby mode and off mode energy use (over time) to form metric. 

 DOE finds that an overall energy efficiency that combines 

values is representative of neither the energy efficiency of microwave oven for a very short period (as is the case witnor the efficiency of the microwave oven over an extended time.

Measures of Ener

EF measures heating of a water load over a period of seconds

Standby- and off-mode energy consumption is measured over a perioof multiple hours.

?+

 EERE-2008-BT-TP-0011 COMMENT 06
Combining Cooking Efficiency with Standby and Off 

Energy Use

 DOE notes that certain test procedures do combine a mea

cycle efficiency and standby energy use to derive an overaefficiency measure, which is a meaningful measure when:

• The difference in energy use between the primary function 

standby power is so large that the standby power has little the overall measure of energy efficiency; or

• The combined efficiency is based on energy use of the prim

energy function and standby power over the same period (annual or seasonal).

 However, microwave oven standby energy use is a signific

fraction of the overall energy use. 

 DOE believes it would be technically infeasible to incorpor

disparate and largely incompatible metrics of similar magn(EF and standby power) into a combined energy efficiency that produces a meaningful result.

Measures of Ener

 EERE-2008-BT-TP-0011 COMMENT 06
Separate Metrics for Energy Factor and Standby Po

 DOE believes that, although mathematically possible to co

energy consumption into a single metric encompassing ac(cooking), standby, and off modes, it is not technically feado so at this time for the following reasons:

• The high variability in the current cooking efficiency measu

from which the active mode EF and annual energy consumderived. 

• The significant contribution of standby power to overall mic

oven energy use.

 Inherent in a determination of technical feasibility under E

for a combined metric for active, standby, and off mode enconsumption is an expectation that the results would be meaningful.

 Therefore, DOE is proposing a separate metric to measure 

power.

Measures of Ener

 EERE-2008-BT-TP-0011 COMMENT 06
Request for Comment on the Energy Descrip

Measures of Ener

DOE seeks comment on the determination of the techninfeasibility of incorporating energy factor and standband off mode power into a single energy descriptor. (Is

 EERE-2008-BT-TP-0011 COMMENT 06
Test Procedure Overview

1. Products Covered by this Test Procedure Rulemaking2. Effective Date for the Test Procedure3. Measures of Energy Consumption4. Incorporating by Reference IEC Standard 62301 First Edition 200

Measuring Standby Mode and Off Mode power in Microwave Ove

5. Definitions of “Active Mode”, “Standby Mode”, and “Off Mode”6. Specifications for the Test Methods and Measurements for Micro

Standby Mode and Off Mode Testing

7. Technical Correction for the Microwave Oven Test Cooking Ener8. Compliance with Other EPCA Requirements

 EERE-2008-BT-TP-0011 COMMENT 06
Incorporating by Reference IEC Standard 62301 First Edition 

for Measuring Standby Mode and Off Mode power in Microwa

 DOE investigated test methods that could be incorporated for me

standby mode and off mode power in microwave ovens.

 EPCA, as amended by EISA 2007 requires that amendments to the 

procedure must take into consideration the most current version Standards 62301 and 62087. 

 DOE determined that IEC Standard 62087 does not cover microwa

and, therefore, was not considered.

 DOE conducted a test program to analyze the suitability of IEC St

62301 test conditions and procedures for incorporation into the Dmicrowave oven test procedure to measure standby mode power 

• Test data suggests that, with additional specifications for testing m

IEC Standard 62301 is indeed suitable for inclusion in the DOE teprocedure for that purpose. 

Incorporating IEC 

 EERE-2008-BT-TP-0011 COMMENT 06
Alternate Test Procedures

 DOE reviewed alternate test conditions and methods used in stan

test procedures used by countries considered to be international 

reducing standby power consumption.

• Japan’s Top Runner Program • Korea’s e-Standby Program

 DOE believes that IEC Standard 62301 provides a more represent

average standby power measurement because of the way it accou

variations in power consumption associated with clock time disp

 DOE also considered test procedures promoted by international s

programs. For example, the International Energy Agency (IEA) dethe “1-Watt Plan”:

• Targets reducing standby power internationally in electronic devic• Advocates that all countries adopt the same definition of standby 

test procedure (e.g., IEC 62301). 

Incorporating IEC 

 EERE-2008-BT-TP-0011 COMMENT 06
IEC Standard 62301

 DOE proposes to incorporate the same clauses from IEC S

62301 for measuring both standby mode and off mode powconsumption. 

 Section 4 clauses – provide conditions for: 

• Supply voltage waveform• Ambient room air temperature• Power measurement meter tolerances 

 Section 5 clauses:

• Clarify the measurement of standby mode for units with a s

duration higher power state before a lower power state

• Provide methods for measuring standby mode and off mod

when the power measurement is either stable or unstable (over a representative cycle).

Incorporating IEC 

 EERE-2008-BT-TP-0011 COMMENT 06
Request for Comment on the Incorporation of 

Standard 62301

Incorporating IEC 

DOE seeks comment on the adequacy of IEC Standard to measure standby mode and off mode power for micovens in general, and on the suitability of incorporatinspecified provisions into DOE regulations. (Issue #2)

 EERE-2008-BT-TP-0011 COMMENT 06
Test Procedure Overview

1. Products Covered by this Test Procedure Rulemaking2. Effective Date for the Test Procedure3. Measures of Energy Consumption4. Incorporating by Reference IEC Standard 62301 First Edition 200

Measuring Standby Mode and Off Mode power in Microwave Ove

5. Definitions of “Active Mode”, “Standby Mode”, and “Off Mode”6. Specifications for the Test Methods and Measurements for Micro

Standby Mode and Off Mode Testing

7. Technical Correction for the Microwave Oven Test Cooking Ener8. Compliance with Other EPCA Requirements

 EERE-2008-BT-TP-0011 COMMENT 06
Definition of Modes

 DOE plans to use the EPCA, as amended by EISA 2007, de

of “active mode,” “standby mode,” and “off mode.”

 “Active mode” is defined as “the condition in which an en

using product –

• (I) is connected to a main power source;• (II) has been activated; and• (III) provides 1 or more main functions.” (42 U.S.C. 6295(g

 DOE considers “main functions” for a microwave oven to 

operations in which the magnetron and/or thermal elemenenergized for at least a portion of the time for purposes of cooking, and/or defrosting the load.

Active Mode, Standby Mo

 EERE-2008-BT-TP-0011 COMMENT 06
Definition of Modes - Continued

 “Standby mode” is defined as “the condition in which an e

using product –

• (I) is connected to a main power source; and• (II) offers 1 or more of the following user-oriented or protec

functions:

– (aa) To facilitate the activation or deactivation of other functio

(including active mode) by remote switch (including remote cointernal sensor, or timer. 

– (bb) Continuous functions, including information or status disp

(including clocks) or sensor-based functions.” (42 U.S.C. 6295(gg)(1)(A)(iii))

 “Off mode” is defined as “the condition in which an energ

product –

• (I) is connected to a main power source; and• (II) is not providing any standby mode or active mode funct

U.S.C. 6295(gg)(1)(A)(ii))

Active Mode, Standby Mo

 EERE-2008-BT-TP-0011 COMMENT 06
Examples of Standby Mode and Off Mode

 A microwave oven with a continuously energized display o

sensor, or a microwave oven that automatically powers docertain energy-consuming components after a cooking cywaits to detect an event triggering re-energization of these components, would be considered capable of operation in mode but not off mode.

 A microwave oven that has electromechanical controls an

display, but consumes power while not in active mode, woconsidered capable of operation in off mode.

 If the microwave oven is equipped with a manual power on

switch, which completely cuts off power to the appliance (removes or interrupts all connections to the main power sthe same manner as unplugging the appliance), the microwwould not be in the off mode when the switch is in the “off

position.

Active Mode, Standby Mo

 EERE-2008-BT-TP-0011 COMMENT 06
Test Procedure Overview

1. Products Covered by this Test Procedure Rulemaking2. Effective Date for the Test Procedure3. Measures of Energy Consumption4. Incorporating by Reference IEC Standard 62301 First Edition 200

Measuring Standby Mode and Off Mode power in Microwave Ove

5. Definitions of “Active Mode”, “Standby Mode”, and “Off Mode”6. Specifications for the Test Methods and Measurements for Micro

Standby Mode and Off Mode Testing

7. Technical Correction for the Microwave Oven Test Cooking Ener8. Compliance with Other EPCA Requirements

 EERE-2008-BT-TP-0011 COMMENT 06
Specifications for the Test Methods and Measurements for M

Oven Standby Mode and Off Mode Testing

 IEC Standard 62301 has flexibility to measure standby and off mo

for most household electrical appliances. 

 IEC Standard 62301 does not specify closely the test method for m

the power consumption in cases in which the measured power is 

• Section 5.3.2 states that “[i]f the power varies over a cycle (i.e., a 

sequence of power states that occur over several minutes or hourperiod selected to average power or accumulate energy shall be ocomplete cycles in order to get a representative average value.”

 According to DOE testing of a microwave oven equipped with a 1

clock display, standby power use at different times during a 12-hocould vary by as much as 25 percent due to the variations in cloc

being displayed. 

Test Methods an

 EERE-2008-BT-TP-0011 COMMENT 06
Variation in Standby Power as a Function of Clock Disp

Test Methods an

1.15

1.2

1.25

1.3

1.35

1.4

1.45

1.5

5 7 9 11 13 15 17 19

Active Elements (LED)

Watts

 EERE-2008-BT-TP-0011 COMMENT 06
Specifications for the Test Methods and Measurements for M

Oven Standby Mode and Off Mode Testing

 Lack of specificity in IEC Standard 62301 about the test pe

could produce test results that are not comparable to thosobtained using other time periods, and that would not reprtrue standby power consumption of its microwave ovens

 DOE proposes to include a specification of the test period 

in which the power is not stable as “a 12-hour ± 30-second 

• Measures all possible configurations for a 12-hour clock.• Obviates the need for a specific starting time, which could 

ensured for microwave ovens that have an automatic powefeature.

Test Methods an

 EERE-2008-BT-TP-0011 COMMENT 06
Request for Comment on the Specifications of th

Measurements Test Cycle 

Test Methods an

DOE seeks comment on the proposed clarification to IStandard 62301, in which DOE would specify a test per12 hours ± 30 seconds for power measurements for microwave ovens for which the measured power is no(Issue #3)

 EERE-2008-BT-TP-0011 COMMENT 06
Test Procedure Overview

1. Products Covered by this Test Procedure Rulemaking2. Effective Date for the Test Procedure3. Measures of Energy Consumption4. Incorporating by Reference IEC Standard 62301 First Edition 200

Measuring Standby Mode and Off Mode power in Microwave Ove

5. Definitions of “Active Mode”, “Standby Mode”, and “Off Mode”6. Specifications for the Test Methods and Measurements for Micro

Standby Mode and Off Mode Testing

7. Technical Correction for the Microwave Oven Test Cooking Ener8. Compliance with Other EPCA Requirements

 EERE-2008-BT-TP-0011 COMMENT 06
Technical Correction for the Microwave Oven Test C

Energy Output

 The equation provided under section 4.4.1 of the current te

procedure for the calculation of the microwave oven test cenergy output, E

T, in watt-hours (Wh), contains a technica

• The equation currently calculates E

T in kWh instead of Wh

 The test cooking energy output is used to calculate annua

consumption in section 4.4.3, in which the units for E

T are 

to be Wh.

 In this NOPR, DOE proposes to change the value of the co

factor, K

e, in section 4.4.1 of 3,412 British thermal units (Bt

kWh to a value of 3.412 Btu per Wh, so that E

T is calculate

specified units of Wh.

Technical Correction for Cookin

 EERE-2008-BT-TP-0011 COMMENT 06
Request for Comment on Technical Correcti

DOE seeks comment on the proposed change to the conversion factor used in the calculation of microwave test cooking energy output in order to produce a value of Wh rather than kWh. (Issue #4)

Technical Correction for Cookin

 EERE-2008-BT-TP-0011 COMMENT 06
Test Procedure Overview

1. Products Covered by this Test Procedure Rulemaking2. Effective Date for the Test Procedure3. Measures of Energy Consumption4. Incorporating by Reference IEC Standard 62301 First Edition 200

Measuring Standby Mode and Off Mode power in Microwave Ove

5. Definitions of “Active Mode”, “Standby Mode”, and “Off Mode”6. Specifications for the Test Methods and Measurements for Micro

Standby Mode and Off Mode Testing

7. Technical Correction for the Microwave Oven Test Cooking Ener8. Compliance with Other EPCA Requirements

 EERE-2008-BT-TP-0011 COMMENT 06
Compliance with Other EPCA Requirement

 Section 323(b)(3) of EPCA requires that “[a]ny test procedures pr

amended under this section shall be reasonably designed to prodresults which measure energy efficiency, energy use . . . or estimoperating cost of a covered product during a representative averacycle or period of use . . . and shall not be unduly burdensome to (42 U.S.C. 6293(b)(3))

 IEC Standard 62301 is widely used and accepted internationally to 

power in standby and off mode.

 Based on testing and analysis, DOE has determined that the prop

amendments produce standby mode and off mode average poweconsumption measurements that represent an average use cycle cases in which the measured power is stable and unstable (i.e., vcycle).

 DOE does not believe this test procedure would be unduly burden

• The proposed test methods and equipment do not differ substantia

current DOE test procedure for measuring microwave oven cookin

• Manufacturers would not be required to make significant investme

facilities and equipment. 

Compliance with Other EPC

 EERE-2008-BT-TP-0011 COMMENT 06
How to Submit Comments...

 Public Meeting – oral comments will be captured in the transcript 

part of the public record.

 Written comments – NOPR comment period open until Decembe

Reference docket #: EERE-2008-BT-TP-0011 and/or RIN #: 1904

Email: MicroOven-2008-TP-0011@ee.doe.gov 

Mail: Mrs. Brenda Edwards

U.S. Department of EnergyBuilding Technologies Program1000 Independence Avenue, SW., Mailstop EE-2J

Washington, DC 20585-0121

Courier: Mrs. Brenda Edwards

U.S. Department of EnergyBuilding Technologies Program950 L'Enfant Plaza, 6th Floor

Washington, DC 20024Telephone: (202) 586-2945

 EERE-2008-BT-TP-0011 COMMENT 06