ES-i

EXECUTIVE SUMMARY

TABLE OF CONTENTS

ES.1 OVERVIEW OF PRELIMINARY ANALYSIS ACTIVITIES..........................................1

ES.2 OVERVIEW OF THE PRELIMINARY ANALYSIS AND THE TECHNICAL 

SUPPORT DOCUMENT ....................................................................................................3

ES.3 KEY RESULTS OF THE ANALYSIS ...............................................................................4

ES.3.1 Market and Technology Assessment .............................................................................4

ES.3.2 Screening Analysis.........................................................................................................6

ES.3.3 Engineering Analysis.....................................................................................................6

ES.3.4 Markups to Determine Product Price...........................................................................15

ES.3.5 Energy Use Analysis....................................................................................................16

ES.3.6 Life-Cycle Cost and Payback Period Analysis............................................................19

ES.3.7 Shipments Analysis......................................................................................................27

ES.3.8 National Impact Analysis.............................................................................................28

ES.3.9 Preliminary Manufacturer Impact Analysis.................................................................33

ES.4 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT..............................................33

ES.4.1 Non-Compressor Refrigerator Storage Temperatures.................................................33

ES.4.2 Non-Compressor Refrigerator Standard Adjustment Factor .......................................34

ES.4.3 Hybrid Refrigeration Product Classes .........................................................................34

ES.4.4 Stocks, Shipments, and Lifetimes of Miscellaneous Refrigeration Products..............35

ES.4.5 Energy Use of Non-Compressor Cooled Cabinets and Refrigerators .........................35

ES.4.6 Energy Use and Market Shares of Ice Makers.............................................................35

ES.4.7 Vapor Compression in Small Cooled Cabinets ...........................................................36

ES.4.8 Relationship between Volume and Efficiency in Thermoelectric Refrigeration 

Products........................................................................................................................36

ES.4.9 Vacuum-Insulated Panels (VIPs) for Cellar Compartments or Cooled Cabinets........36

LIST OF TABLES

Table ES.3.1 Product Classes for Miscellaneous Refrigeration Products.....................................5

Table ES.3.2 Cooled Cabinet Efficiency Levels...........................................................................7

Incremental MSP Results for 6 ft3 Table ES.3.3 Cooled Cabinet..................................................8

Incremental MSP Results for 2 ft3 Table ES.3.4 Cooled Cabinet..................................................9

Table ES.3.5 Non-Compressor Refrigerator Efficiency Levels..................................................10

Table ES.3.6 Incremental MSP Results for Non-Compressor Refrigerator................................10

Table ES.3.7 Portable Ice Makers Efficiency Levels..................................................................11

Table ES.3.8 Cooled-Storage Ice Makers Efficiency Levels......................................................12

Table ES.3.9 Uncooled-Storage Ice Makers Efficiency Levels..................................................12

Table ES.3.10 Incremental MSP Results for Portable Ice Makers................................................12

Table ES.3.11 Incremental MSP Results for Cooled-Storage Ice Makers....................................13

Table ES.3.12 Incremental MSP Results for Uncooled-Storage Ice Makers................................13
ES-ii

Table ES.3.13 Hybrid Refrigeration Product Design Changes .....................................................15

Table ES.3.14 Markups for Miscellaneous Refrigeration Products..............................................16

Table ES.3.15 Cooled Cabinets: Average Annual Energy Use by Efficiency Level....................17

Table ES.3.16 Non-Compressor Refrigerators: Average Annual Energy Use by 

Efficiency Level.....................................................................................................18

Table ES.3.17 Ice Makers: Average Annual Energy Use by Efficiency Level.............................18

Table ES.3.18 Hybrid Products: Average Annual Energy Use by Efficiency Level ....................19

Table ES.3.19 Average LCC and PBP Results for Product Class CC, Cooled Cabinet ...............21

Table ES.3.20 Average LCC Savings Relative to the Base Case Efficiency Distribution 

for Product Class CC, Cooled Cabinet ..................................................................22

Table ES.3.21 Average LCC and PBP Results for Product Class NCR, Non-Compressor 

Refrigerator............................................................................................................23

Table ES.3.22 Average LCC Savings Relative to the Base Case Efficiency Distribution 

for Product Class NCR, Non-Compressor Refrigerator ........................................23

Table ES.3.23 Average LCC and PBP Results for Product Class IM-P, Portable Ice 

Maker.....................................................................................................................24

Table ES.3.24 Average LCC Savings Relative to the Base Case Efficiency Distribution 

for Product Class IM-P, Portable Ice Maker..........................................................24

Table ES.3.25 Average LCC and PBP Results for Product Class IM-C, Non-Portable 

Cooled Storage Ice Maker .....................................................................................25

Table ES.3.26 Average LCC Savings Relative to the Base Case Efficiency Distribution 

for Product Class IM-C, Non-Portable Cooled Storage Ice Maker .......................25

Table ES.3.27 Average LCC and PBP Results for Product Class IM-U, Non-Portable 

Uncooled Storage Ice Maker .................................................................................26

Table ES.3.28 Average LCC Savings Relative to the Base Case Efficiency Distribution 

for Product Class IM-U, Non-Portable Uncooled Storage Ice Maker...................26

Table ES.3.29 Cooled Cabinets: Cumulative NES Full-Fuel Cycle Results (quads)....................29

Table ES.3.30 Non-Compressor Refrigerators Cumulative NES Full-Fuel Cycle Results 

(quads)....................................................................................................................29

Table ES.3.31 Ice Makers: Cumulative NES Full-Fuel Cycle Results (quads) ............................30

Table ES.3.32 Hybrid Refrigeration Products: Cumulative NES Fuel Full-Fuel Cycle 

Results (quads).......................................................................................................30

Table ES.3.33 Cumulative Net Present Value of Consumer Benefits for Cooled Cabinets, 

in Billion 2013$ .....................................................................................................31

Table ES.3.34 Cumulative Net Present Value of Consumer Benefits for Non-Compressor 

Refrigerators, in Billion 2013$ ..............................................................................31

Table ES.3.35 Cumulative Net Present Value of Consumer Benefits for Ice Makers, 3-

Percent Discount Rate............................................................................................32

Note: Blank cells represent non-existent efficiency levels (i.e., higher than max-tech) for 

the specific classes. ................................................................................................32

Table ES.3.36 Cumulative Net Present Value of Consumer Benefits for Ice Makers, 7-

Percent Discount Rate............................................................................................32
ES-iii

LIST OF FIGURES

Figure ES.1.1 Flow Diagram of Analyses for the Miscellaneous Refrigeration Products 

Rulemaking Process.................................................................................................2

Figure ES.3.1 Cooled Cabinets Shipments Forecasts for the Base Case and Considered 

Efficiency Levels...................................................................................................27
ES-1

EXECUTIVE SUMMARY

ES.1 OVERVIEW OF PRELIMINARY ANALYSIS ACTIVITIES

The Energy Policy and Conservation Act of 1975 (EPCA), as amended, requires the U.S. 

Department of Energy (DOE) to establish energy conservation standards that are technologically 

feasible and economically justified, and would achieve the maximum improvement in energy 

efficiency. See 42 U.S.C. 6295(o)(3)(B) This executive summary provides an overview of the 

activities associated with the preliminary analysis that DOE conducted as part of the current 

rulemaking to set energy conservation standards for miscellaneous refrigeration products. The 

executive summary describes the preliminary analysis activities and summarizes key results from 

DOE’s preliminary analyses. Additionally, the executive summary delineates issues identified 

during the analyses about which DOE seeks comments from interested parties. These issues are 

also highlighted in the public meeting presentation.

Figure ES.1.1 presents a summary of the DOE rulemaking phases and the key analyses 

that constitute each phase. The rulemaking process typically begins with a framework document, 

which is followed by a preliminary analysis. DOE then publishes and seeks comment on a notice 

of proposed rulemaking (NOPR). After considering these comments and other relevant data and 

information, DOE publishes a final rule establishing any new or amended standards. The figure 

presents the major analyses in each phase in rectangular boxes. Core analyses for the rulemaking 

are lined in the center column of the figure, providing a logical sequence that DOE follows in 

carrying out the rulemaking process. Inputs to the analyses are shown with arrows pointing 

toward their respective analysis boxes, and outputs are shown with arrows directed away from 

their respective analysis boxes. Many outputs also form inputs for the downstream analyses. 

DOE obtains data for the inputs from various sources including, but not limited to, technical 

publications, market-survey reports, trade publications, interested parties’ comments, industry 

experts and consultants, interagency guidance, and interactions with end users and the 

manufacturers. Key outputs from the analyses form the basis for setting the new energy 

conservation standards.
ES-2

Figure ES.1.1 Flow Diagram of Analyses for the Miscellaneous Refrigeration 

Products Rulemaking Process
ES-3

ES.2 OVERVIEW OF THE PRELIMINARY ANALYSIS AND THE TECHNICAL 

SUPPORT DOCUMENT 

For the preliminary analysis, DOE publishes a notice of public meeting (NOPM) in the 

Federal Register, which announces the availability of the preliminary technical support 

document (TSD), the date and place of the public meeting, and presentation materials interested 

parties may review before the public meeting. In addition, the NOPM highlights the major 

analyses DOE developed in the preliminary analysis stage. 

The preliminary TSD describes each preliminary analysis in detail, providing detailed 

descriptions of inputs, sources, methodologies, and results. Chapter 2 of the preliminary TSD 

provides an overview of each preliminary analysis, the comments received in response to the 

analytical approaches DOE described in the framework document, and DOE’s responses to those 

comments. The following chapters of the preliminary TSD address the analyses performed for 

the preliminary analysis stage.

• Chapter 3: The market and technology assessment (MTA) characterizes the relevant 

product markets and technology options, including prototype designs.

• Chapter 4: The screening analysis reviews each technology option uncovered in the MTA 

to determine whether it is: technologically feasible; practicable to manufacture, install, 

and service; likely to adversely affect product utility or product availability; or likely to 

have adverse impacts on health and safety.

• Chapter 5: The engineering analysis develops cost-efficiency relationships that show a 

manufacturer’s cost of achieving increased efficiency. DOE uses manufacturer markups 

to convert manufacturer production cost (MPC) to manufacturer selling price (MSP).

• Chapter 6: The markups analysis converts the MSP derived from the engineering analysis 

to consumer equipment prices based on distribution chain markups.

• Chapter 7: The energy use analysis determines the annual energy consumption of the 

products under consideration.

• Chapter 8: The life-cycle cost (LCC) and payback period (PBP) analysis calculates, at the 

consumer level, the discounted savings in operating costs throughout the estimated 

average life of the covered product, compared to any increase in the product’s installed 

cost likely to result directly from the imposition of a given standard.

• Chapter 9: The shipments analysis forecasts shipments of products, which are then used 

to calculate the national impacts of standards on energy consumption, the net present 

value (NPV) of consumer costs and savings, and future manufacturer cash flows.

• Chapter 10: The national impact analysis (NIA) assesses the cumulative national energy 

savings (NES) from standards and the NPV of consumer costs and savings associated 

with standards at different efficiency levels.

• Chapter 12: The preliminary manufacturer impact analysis (MIA) assesses the potential 

impacts of energy conservation standards on manufacturers, such as effects on 
ES-4

expenditures for capital conversion, profitability, shipments, and research and 

development costs.

The remaining chapters of the preliminary TSD address the analyses to be performed for 

the NOPR stage:

• Chapter 11: The consumer subgroup analysis evaluates the effects of potential energy 

conservation standards on various national subgroups of the population.

• Chapter 13: The emissions analysis discusses the effects of potential energy conservation 

standards on various airborne emissions of electric utilities. 

• Chapter 14: Monetization of emissions reductions benefits considers the estimated 

monetary benefits likely to result from reduced emissions of carbon dioxide and nitrogen 

oxides expected to result from the standards. 

• Chapter 15: The utility impact analysis examines impacts of potential energy 

conservation standards on the generation capacity of electric utilities.

• Chapter 16: The employment impact analysis examines the effects of potential energy 

conservation standards on national employment.

• Chapter 17: A regulatory impact analysis examines the national impacts of nonregulatory alternatives to mandatory energy conservation standards.

ES.3 KEY RESULTS OF THE ANALYSIS 

The following sections describe in detail the key analyses DOE performed in support of 

the preliminary analysis for miscellaneous refrigeration products.

ES.3.1 Market and Technology Assessment

When initiating an analysis of potential energy conservation standards for appliances, 

DOE develops information for the products and characterizes the market and industry structure, 

evaluating both current and historical information. This activity assesses industries and products 

both quantitatively and qualitatively, based on publicly available information. 

When evaluating and establishing energy conservation standards, DOE generally divides 

covered products into product classes by the type of energy used or by capacity or other 

performance-related features that affect efficiency. Different energy conservation standards may 

apply to different product classes. (42 U.S.C. 6295(q)) In this current effort, DOE plans to 

consider the possible regulation of product classes for four distinct types of miscellaneous 

refrigeration products: cooled cabinets (i.e., products including wine chillers that are composed 

entirely of compartments that operate above 39 °F); ice makers; non-compressor refrigerators;

and hybrid refrigerators, refrigerator-freezers, and freezers (i.e., products that include 

compartments that operate above 39 °F, such as wine storage compartments, in products that 

otherwise perform the functions of refrigerators, refrigerator-freezers, or freezers). Table ES.3.1
ES-5

describes the product classes being considered for miscellaneous refrigeration products in this 

rulemaking. The four product classes listed for hybrid refrigeration products only represent the 

classes for which DOE is aware of existing hybrid products; however, DOE is considering an 

approach that would consider corresponding hybrid product classes for all 40 existing product 

classes for conventional refrigerators, refrigerator-freezers, and freezers.

Table ES.3.1 Product Classes for Miscellaneous Refrigeration Products

Product Type Product 

Class Product Class Description

Cooled Cabinets CC All cooled cabinets

Non-Compressor 

Refrigerators NCR All non-compressor refrigerators

Ice Makers

IM-P Portable ice makers

IM-C Cooled-storage ice makers

IM-U Uncooled-storage ice makers

Hybrid 

Refrigeration 

Products

H-3A-BI Built-in standard-sized* hybrid all-refrigerators with 

automatic defrost

H-9I-BI Built-in standard-sized hybrid freezers with automatic defrost 

and an automatic icemaker

H-11A Compact* hybrid all-refrigerators with manual defrost

H-13A Compact hybrid all-refrigerators with automatic defrost

* Note: “Compact” products are defined as having a total compartment volume of less than 7.75 cubic feet; for 

compartment sizes larger than this, the term “standard-sized” is used.

For the miscellaneous refrigeration products that are the topic of this rulemaking, DOE 

addressed as part of the market assessment: (1) manufacturer market share and characteristics, 

(2) existing regulatory and non-regulatory initiatives for improving product efficiency, and (3) 

trends in product characteristics and retail markets. The information gathered for this assessment 

provided data and resource materials that were used throughout this analysis.

DOE reviewed literature and interviewed manufacturers to develop an overall 

understanding of the miscellaneous refrigeration product market in the United States. Industry 

publications, including trade journals, and literature from manufacturers, government agencies, 

and trade organizations comprised the bulk of the information examined by DOE. This 

information included: (1) manufacturer identities and individual manufacturer market shares; (2) 

shipments by product type; (3) product information; and (4) industry trends. Chapter 3 of the 

preliminary TSD describes the market analysis and the information gathered from DOE’s 

research.

DOE typically uses information about existing and past technology options and prototype 

designs to determine which technologies and combinations of technologies manufacturers use to 

attain higher performance levels. In consultation with interested parties, DOE developed a list of 

technologies to be considered. The lists were developed from trade publications, technical 

papers, and manufacturer literature and through consultation with manufacturers of components 
ES-6

and systems. Because existing products contain many technologies for improving product 

efficiency, a review of product literature and direct examination of purchased products provided 

additional information. The identified technologies include all those examined to date that DOE 

believes are technologically feasible.

ES.3.2 Screening Analysis

DOE develops an initial list of options for enhancing efficiency from the technology 

assessment described previously. The screening analysis (chapter 4) examines whether identified 

technologies (1) are technologically feasible; (2) are practicable to manufacture, install, and 

service; (3) have an adverse impact on product utility or availability; or (4) have adverse impacts 

on health and safety. If the technology option is not technologically feasible, or is not practicable 

to manufacture, install, and service on a scale consistent with the shipment projections predicted 

to occur by the time of the standard, DOE will not consider that technology option further.

Similarly, if the technology would result in adverse impacts on product utility or availability, or 

would have adverse impacts on health and safety, DOE will not consider that technology option 

further. In the subsequent engineering analysis, DOE further examines the technology options 

that it did not remove from consideration in the screening analysis.

ES.3.3 Engineering Analysis

The engineering analysis (chapter 5) establishes the relationship between the costs of 

manufacturing miscellaneous refrigeration products and their efficiencies. This relationship 

serves as the basis for calculating costs and benefits of modified product designs for consumers, 

manufacturers, and the Nation. Chapter 5 describes the product classes DOE analyzed, the 

representative baseline units, the efficiency levels DOE considered, the methodology DOE used 

to develop the manufacturing production cost model, and the cost-efficiency results.

ES.3.3.1 Cooled Cabinets

DOE adopted a combined efficiency level/design option/reverse engineering approach to 

developing cost-efficiency curves for cooled cabinets. DOE established efficiency levels defined 

as a percentage of baseline energy consumption. DOE’s analysis is based on the efficiency 

improvements associated with groups of design options. Also, DOE developed manufacturing 

cost models based on the reverse engineering of products to support the calculation of the 

incremental costs associated with efficiency improvements.

Because there are no current Federal energy conservation standards for cooled cabinets, 

DOE selected a baseline efficiency level consistent with the least-efficient product evaluated for

its analysis, a thermoelectric cooled cabinet of 2 ft3 capacity. DOE designated energy use of its 

efficiency levels as percentages of the equivalent energy use associated with a cooled cabinet 

that is minimally compliant with the wine chiller energy conservation standards established by 

the California Energy Commission (CEC) in its Title 20 Appliance Efficiency Regulations. The 

CEC regulations permit a maximum allowable annual energy consumption level based on a 

product’s interior volume. Manufacturers have stated that the CEC and Natural Resources 

Canada (NRCan) standards effectively set the standard level for products sold in the United 
ES-7

States. (see, for example, U-Line, No. 14 at p. 1) DOE used this level in developing a set of 

efficiency levels to examine as part of the preliminary analysis. (DOE notes that the CECequivalent efficiency level is equal to the CEC standard, adjusted to account for the fact that 

DOE’s proposed test procedure includes a usage adjustment factor that differs from the factor 

used in the CEC test procedure.)

DOE tested and conducted reverse-engineering inspections for eight vapor-compression 

wine chillers and three thermoelectric wine chillers for its cooled cabinet analysis. As described 

in chapter 3 of this TSD, DOE is considering an approach that would combine vaporcompression and non-compressor cooled cabinets into the same product class.

As discussed further in chapter 5 of this TSD, DOE generated cost-efficiency curves 

separately for 2 ft3 and 6 ft3 cooled cabinets. Because DOE is not aware of any non-compressor 

cooled cabinets significantly larger than 2 ft3

, the 6 ft3 analysis does not consider efficiency 

levels associated with non-compressor refrigeration technology. These separate analyses for 

products having different characteristics but belonging to the same product class provides 

broader insights regarding the overall cost-effectiveness of different efficiency levels. The 

economic analyses described in subsequent chapters were based on the assumption that both 

product types would meet the same efficiency level, expressed as a percentage of the CECequivalent energy use. Because of the current efficiency levels of non-compressor (i.e.,

thermoelectric) refrigeration technology, DOE assumed for the analysis that current 

thermoelectric products would need to be converted to vapor-compression technology to attain 

the higher efficiency levels that DOE considered in the analysis. 

DOE analyzed efficiency levels (ELs) that spanned the range of energy consumption 

observed from all available data, as described further in Chapter 5 of this TSD. The lowest 

efficiency level observed, which DOE called EL 0, was 267 percent of the CEC-equivalent 

energy consumption. The highest efficiency level that DOE considered – EL 11 – was 32 percent 

of CEC-equivalent energy consumption. The range of efficiency levels that DOE considered in 

its analysis is presented in Table ES.3.2. As evidenced by this table, EL 4 represents the CECequivalent efficiency level.

Table ES.3.2 Cooled Cabinet Efficiency Levels

Efficiency Level Percent of CEC-Equivalent Energy Consumption

EL 0 267%

EL 1 200%

EL 2 160%

EL 3 130%

EL 4 (CEC-equivalent) 100%

EL 5 90%

EL 6 80%

EL 7 70%

EL 8 60%

EL 9 50%

EL 10 40%

EL 11 (Max-Tech) 32%
ES-8

EL 11 represents the maximum-technology (max-tech) level for cooled cabinets, which 

DOE evaluated through energy modeling and comparison with available maximum-efficiency

products, as described in detail in chapter 5 of this TSD. The energy model for the max-tech 

level was based on the use of all of the design options applicable to cooled cabinets. While this 

product configuration has not likely been tested as a prototype, all of the individual design 

options have been incorporated in available refrigeration products, although some, (e.g., vacuum 

insulated panels) may not have been incorporated in commercialized cooled cabinets. The maxtech efficiency level for cooled cabinets is higher than that of the most-efficient products

currently available (i.e., max-available). The costs of the max-tech efficiency level design 

options are also quite high, as they are based on extensive use of high-cost design options as well 

as all applicable lower-cost design options

DOE developed the cost-efficiency curve for 6 ft3 cooled cabinets based on three vaporcompression test units, using reverse-engineering to determine the costs of improving product 

efficiency using various screened-in design options. DOE selected 6 ft3 as a representative 

volume because it is the size that best represents the full capacity and efficiency range of vaporcompression wine chillers and a wide variety of models. These three 6 ft3 units represented 

baseline, medium-efficiency, and max-available efficiency levels and provided separate data 

points to generate the cost curve for this capacity. DOE also calculated the max-tech efficiency 

level for this curve by applying additional design options to the max-available design. Because 

there are no non-compressor cooled cabinets of this capacity available on the market, DOE did 

not analyze the full range of efficiency levels for this capacity—the evaluation spanned from the 

CEC-equivalent efficiency level (100 percent – EL4) to max tech (32 percent of the CECequivalent level). For the 2 ft3 cooled cabinet capacity, DOE evaluated the full range of 

efficiency levels, because products of this size may utilize thermoelectric or absorption 

refrigeration technology, as well as vapor compression. Chapter 5 provides a more detailed 

description of the engineering analysis for cooled cabinets. The incremental MSPs are presented 

for 6 ft3 cooled cabinets in Table ES.3.3 and for 2 ft3 cooled cabinets in Table ES.3.4.

Incremental MSP Results for 6 ft3 Table ES.3.3 Cooled Cabinet

Efficiency Level

(percent of CEC-Equivalent 

energy use)

Total Added MSP

EL 0 (267%) NA

EL 1 (200%) NA

EL 2 (160%) NA

EL 3 (130%) NA

EL 4 (CEC Equivalent) $0

EL 5 (90%) $15

EL 6 (80%) $26

EL 7 (70%) $41

EL 8 (60%) $59

EL 9 (50%) $78

EL 10 (40%) $170

EL 11 (32% – Max-Tech) $258
ES-9

Incremental MSP Results for 2 ft3 Table ES.3.4 Cooled Cabinet

Efficiency Level

(percent of CEC-equivalent 

energy use)

Total Added MSP

EL 0 (267%) $0

EL 1 (200%) $26

EL 2 (160% $42

EL 3 (130%) $54

EL 4 (100% – CEC Equivalent) $66

EL 5 (90%) $70

EL 6 (80%) $88

EL 7 (70%) $107

EL 8 (60%) $122

EL 9 (50%) $137

EL 10 (40%) $207

EL 11 (32% – Max-Tech) $275

ES.3.3.2 Non-Compressor Refrigerators

As with cooled cabinets, DOE also adopted a combined efficiency level/design 

option/reverse engineering approach to developing cost-efficiency curves for non-compressor 

refrigerators. Using DOE’s proposed test procedure, DOE tested, and then reverse engineered,

five models of thermoelectric refrigerators (NCR-1), and one absorption-based refrigerator 

(NCR-2). The proposed test procedure would test products in a 90 °F ambient temperature 

condition and is otherwise similar to the DOE test procedure for refrigerators that is detailed in 

10 CFR 430, subpart B, appendix A. However, none of the tested products attained the 39 °F 

standardized temperature during testing. Hence, consistent with the test procedure proposal, for 

each of these products, the energy use measurements are based on a test conducted with the 

temperature controls in the coldest available setting. Because there are no current Federal, state, 

or industry energy conservation standards for non-compressor refrigerators, and because they 

have no established test procedure, there is no established baseline efficiency level for these 

products. Therefore, DOE selected both baseline and max-available efficiency levels based on 

the test data. DOE also calculated the energy use reduction associated with a max-tech efficiency 

level using vacuum insulated panel insulation applied to the max-available design. DOE 

analyzed the efficiency levels presented in Table ES.3.5.
ES-10

Table ES.3.5 Non-Compressor Refrigerator Efficiency Levels

Efficiency Level Percent of Baseline 

Energy Consumption

EL0 (Baseline) 100%

EL1 95%

EL2 90%

EL3 85%

EL4 80%

EL5 75%

EL6 70%

EL7 65%

EL8 (Max-Tech) 64%

DOE developed cost-efficiency relationships for non-compressor refrigerators based 

primarily on the cost differences associated with the different design option combinations of the 

models that it tested. In addition, DOE calculated the energy use reduction associated with 

insulation-based design options for an intermediate efficiency level and a max-tech efficiency 

level. The incremental MSP costs for non-compressor refrigerators are presented in Table 

ES.3.6.

Table ES.3.6 Incremental MSP Results for Non-Compressor Refrigerator 

Efficiency Level (percent of 

baseline energy use) Total Added MSP

EL0 (100% – Baseline) $0

EL 1 (95%) $0.3

EL 2 (90%) $0.5

EL 3 (85%) $0.8

EL 4 (80%) $10

EL 5 (75%) $17

EL 6 (70%) $17

EL 7 (65%) $27

EL 8 (64% – Max-Tech) $36

As mentioned above, the proposed test procedure for non-compressor refrigerators that 

DOE is considering would require testing in a 90 °F ambient temperature condition, but that 

many of these products cannot maintain the 39 °F standardized fresh food compartment 

temperature when operating in such conditions. As explained in the test procedure notice, DOE 

proposed these test conditions because products marketed as refrigerators are expected to 

maintain safe food storage conditions under the thermal loads that are simulated by the 90 °F 

ambient condition. However, when considering standards, rather than allow products to more 

easily meet the potential standard by having refrigeration capacity insufficient to maintain a 

desired compartment temperature, DOE is considering permitting the allowable standard level to 

adjust in a manner proportional to the deviation of the measured compartment temperature from 

the standardized temperature.
ES-11

ES.3.3.3 Ice Makers 

To analyze ice makers, DOE utilized the efficiency-level approach, which calculates the 

relative costs of achieving increases in energy efficiency levels without regard to the particular 

design options used to achieve such increases.

DOE tested and reverse engineered two ice makers in each of the three product classes

currently under consideration: portable ice makers (IM-P), cooled-storage ice makers (IM-C), 

and uncooled-storage ice makers (IM-U). These six units were tested using the ice maker test 

procedure proposed by DOE in the Test Procedure NOPR, which would require measuring the 

energy use associated with producing 4 pounds of ice per day and with storing ice in its bin. The 

proposed test uses a 72 °F ambient temperature condition. For cooled-storage ice makers, the 

“ice storage energy” is the energy required to maintain bin temperatures below freezing. For 

portable and uncooled-storage ice makers, ice storage energy is the energy required to replace ice 

that melts. 

Because there are no current Federal, state, or industry energy conservation standards for 

ice makers, and because they have no established test procedure, there is no established baseline 

efficiency level for these products. Therefore, DOE developed its analysis based on the results

noted above, selecting both baseline and maximum-efficiency units for each class based on the 

data. 

DOE analyzed incremental efficiency levels that spanned the range of energy 

consumption observed from all available test data. The efficiency levels that DOE considered in 

its ice maker analysis are presented in Table ES.3.7 through Table ES.3.9 below.

Table ES.3.7 Portable Ice Makers Efficiency Levels

Efficiency Level Energy Consumption 

(kWh/year)

Percent of Baseline Energy 

Consumption

EL 0 (Baseline) 256 100%

EL 1 230 90%

EL 2 205 80%

EL 3 179 70%

EL 4 154 60%

EL 5 128 50%

EL 6 102 40%

EL 7 (Max-Available) 89 35%
ES-12

Table ES.3.8 Cooled-Storage Ice Makers Efficiency Levels

Efficiency Level Energy Consumption 

(kWh/year)

Percent of Baseline Energy 

Consumption

EL 0 (Baseline) 552 100%

EL 1 524 95%

EL 2 497 90%

EL 3 469 85%

EL 4 442 80%

EL 5 414 75%

EL 6 (Max-Available) 408 74%

Table ES.3.9 Uncooled-Storage Ice Makers Efficiency Levels

Efficiency Level Energy Consumption 

(kWh/year)

Percent of Baseline Energy 

Consumption

EL 0 (Baseline) 1,075 100%

EL 1 1,021 95%

EL 2 968 90%

EL 3 914 85%

EL 4 860 80%

EL 5 806 75%

EL 6 753 70%

EL 7 699 65%

EL 8 (Max-Available) 677 63%

DOE developed cost-efficiency relationships for all three product classes of ice makers 

under consideration based on the cost difference associated with the relative design option 

combinations of the least-efficient (baseline) and most-efficient (max-available) models that it 

tested in each class. The incremental MSP costs for all three ice maker product classes are 

presented in Table ES.3.10 through Table ES.3.12 below.

Table ES.3.10 Incremental MSP Results for Portable Ice Makers 

Efficiency Level (percent of baseline energy use) Total Added MSP

EL 0 (100% – Baseline) $0

EL 1 (90%) $1.30

EL 2 (80%) $2.59

EL 3 (70%) $3.89

EL 4 (60%) $5.18

EL 5 (50%) $6.48

EL 6 (40%) $7.78

EL 7 (35% – Max-Available) $8.43
ES-13

Table ES.3.11 Incremental MSP Results for Cooled-Storage Ice Makers 

Efficiency Level (percent of baseline energy use) Total Added MSP

EL 0 (100% – Baseline) $0

EL 1 (95%) $3

EL 2 (90%) $6

EL 3 (85%) $9

EL 4 (80%) $12

EL 5 (75%) $14

EL 6 (74% – Max-Available) $16

Table ES.3.12 Incremental MSP Results for Uncooled-Storage Ice Makers 

Efficiency Level (percent of baseline energy use) Total Added MSP

EL 0 (100% – Baseline) $0

EL 1 (95%) $3

EL 2 (90%) $7

EL 3 (85%) $10

EL 4 (80%) $14

EL 5 (75%) $17

EL 6 (70%) $21

EL 7 (65%) $23

EL 8 (63% – Max-Available) $26

ES.3.3.1 Hybrid Refrigeration Products

Hybrid refrigeration products are similar in design, construction, and operation to the 

refrigerators, refrigerator-freezers, and freezer that are already covered and subject to Federal 

energy conservation standards, often using identical components. The key difference is that 

hybrid products include a compartment operated at warmer temperatures that comprises at least 

half of the refrigerated volume. Because of the very limited number of known hybrid 

refrigeration products, and their similarities with conventional refrigerators, refrigerator-freezers, 

and freezers, DOE considered whether the 2014 energy conservation standards for conventional 

refrigeration products could be applied to hybrid products. 

DOE analyzed a hybrid refrigerator combining a fresh food compartment and a cellar 

compartment. The analysis considered numerous product configurations based on a selection 

from a range of options for key features: 

• Compact and standard-size products.

• Hybrids with cellar compartments comprising 50 percent and 75 percent of 

refrigerated volume.

• Glass doors covering the cellar compartment, both compartments, neither 

compartment, or for compact products, a single glass door covering both 

compartments.
ES-14

DOE considered a range of design details, including the following:

• 1.5-inch and 2-inch thick insulation.

• Glass packs for the glass doors involving baseline, medium-technology, and 

maximum-technology designs. The baseline glass pack was dual-pane air-filled; the 

medium-tech glass pack was dual-pane with argon fill and low-emissivity coating; 

and the max-tech glass pack was triple-pane with krypton fill and low-emissivity 

coating.

• Compressors of different efficiencies: nominal EER levels of 2.1 Btu/W-h and 

“higher-EER” 2.4 Btu/W-h for compact products, 3.7 Btu/W-h and “higher-EER” 4.4

Btu/W-h for standard-size products.

All of these design options, other than the maximum-technology glass, are commonly 

used for hybrid and wine chiller products.

Table ES.3.13, summarizes the analysis, showing the design options required for 

compliance with the standard for different product configurations. In some cases, two sets of 

compliant design option combinations are presented. The results show that all anticipated 

product configurations can be designed to achieve the evaluated standard level, and that nearly 

all configurations can meet it without use of max-tech glass packs. Even the one configuration 

evaluated requiring use of a max-tech glass pack could, given other design options considered in 

the analysis as listed above, comply with the applicable 2014 standard using a higher-EER 

compressor. This configuration is not one that DOE is aware of being currently available on the 

market, i.e., a hybrid refrigerator using glass doors for both the fresh food and cellar 

compartments. The analysis is discussed in greater detail in chapter 5.
ES-15

Table ES.3.13 Hybrid Refrigeration Product Design Changes 

Product Configuration Design Options Needed for Compliance 

Size Cellar 

Volume 

(%)

Doors

Fresh 

Food

Cellar

Thicker InsulationFresh Food MediumTech GlassFresh Food MaxTech GlassCellar Medium-Tech GlassCellar Max-Tech GlassHigher-EERCompressor

Compact 50% Solid Glass X X

X

Glass Glass X X X X

X X X

Single Glass Door

Covering Both 

Compartments

X X X X

X X X

75% Solid Glass X X

X X

Glass Glass X X X

Single Glass Door

Covering Both 

Compartments

X X X

Standard 50% Solid Glass X X X

X X

Glass Glass X X X X

75% Solid Glass X X X

X X

Glass Glass X X X X

X X X

ES.3.4 Markups to Determine Product Price

The markups analysis (chapter 6) develops appropriate markups in the distribution chain 

to convert the estimates of MSP derived in the engineering analysis to customer purchase prices. 

In developing markups, DOE determined the distribution channels for miscellaneous 

refrigeration products and the markup associated with each party in the distribution channel. 

DOE found that an overwhelming majority of residential appliances are sold through retail 

outlets. DOE is not aware of any other distribution channel that plays a significant role for 

miscellaneous refrigeration products, leading DOE to tentatively conclude that all miscellaneous 

refrigeration products are purchased by consumers from retail outlets.
ES-16

DOE developed separate markups for baseline products (baseline markups) and for the 

cost increase associated with improvements required to produce more-efficient products 

(incremental markups). DOE also added sales tax to the estimated retail prices. Table ES.3.14

summarizes the markups developed for miscellaneous refrigeration products.

Table ES.3.14 Markups for Miscellaneous Refrigeration Products 

Markup Product Baseline Incremental

Manufacturer

Vapor-compression 

cooled cabinets (CC-1) 1.26

Thermoelectric cooled 

cabinets (CC-2) 1.22

All non-compressor 

refrigerators 1.22

All ice makers 1.23

All hybrid products 1.26

Retailer All 1.36 1.11

Sales Tax All 1.071

ES.3.5 Energy Use Analysis

The energy use analysis provides the basis for estimating the energy savings from higher 

efficiency appliances used in the LCC and subsequent analyses. The DOE test procedure 

provides standardized results that can serve as the basis for comparing the performance of 

different appliances used under the same conditions, but actual usage in the field may differ from 

usage estimated by the test procedure. 

To determine the distribution of energy use for miscellaneous refrigeration products, 

DOE used a combination of laboratory testing, field measurements, and reported energy use 

from public databases and manufacturers’ websites. The energy use of cooled cabinets was 

calculated as a linear function of volume, using online survey data to provide distributions of 

internal volumes. 

DOE assumed cooled cabinets, non-compressor refrigerators, and hybrid products would 

be in constant use. For ice makers, DOE assumed a usage rate of 4 pounds of ice per day, plus 

ice storage where appropriate. For portable ice makers (IM-P), DOE applied a 50-percent usage 

factor to account for the expectation that these units would not be plugged in for the entire year.

For other ice makers (IM-C and IM-U), DOE assumed products would be in constant use. These 

usage rates are based on the proposed test procedure.

Table ES.3.15 through Table ES.3.18 show the results of the energy use analysis for 

cooled cabinets, non-compressor refrigerators, ice makers and hybrid refrigeration product 

classes at each considered efficiency level. For cooled cabinets, these tables present results for 
ES-17

only a single example with a volume of 2.0 ft3, but the energy use was calculated across a range 

of volumes. Chapter 7 provides more details on the methods, data, and assumptions used for the 

energy use analysis.

Table ES.3.15 Cooled Cabinets: Average Annual Energy Use by Efficiency Level

Efficiency 

level

CC: Cooled Cabinet

(2.0 ft3)

Percent of Baseline 

Energy Consumption

Energy Consumption 

(kWh/year)

EL0 267% 660

EL1 200% 494

EL2 160% 395

EL3 130% 321

EL4 100% 247

EL5 90% 222

EL6 80% 198

EL7 70% 173

EL8 60% 148

EL9 50% 124

EL10 40% 99

EL11 32% 79
ES-18

Table ES.3.16 Non-Compressor Refrigerators: Average Annual Energy Use by 

Efficiency Level

Efficiency 

level

NCR: Non-Compressor Refrigerators 

(1.7 ft3)

Percent of Baseline 

Energy Consumption

Energy Consumption 

(kWh/year)

EL0 100% 672

EL1 95% 638

EL2 90% 605

EL3 85% 571

EL4 80% 538

EL5 75% 504

EL6 70% 470

EL7 65% 437

EL8 64% 430

Table ES.3.17 Ice Makers: Average Annual Energy Use by Efficiency Level

Efficiency 

level

IM-P:

Portable

IM-C:

Non-portable,

cooled storage

IM-U:

Non-portable, uncooled 

storage

Percent of 

Baseline 

Energy Use

Energy Use

(kWh/year)

Percent of 

Baseline 

Energy Use

Energy Use

(kWh/year)

Percent of 

Baseline 

Energy Use

Energy Use

(kWh/year)

EL0 100% 256 100% 552 100% 1075

EL1 90% 230 95% 524 95% 1021

EL2 80% 205 90% 497 90% 968

EL3 70% 179 85% 469 85% 914

EL4 60% 154 80% 442 80% 860

EL5 50% 128 75% 414 75% 806

EL6 40% 102 74% 411 70% 753

EL7 35% 89 65% 699

EL8 63% 672

Note: Blank cells represent non-existent efficiency levels (i.e., higher than max-tech) for the specific classes.
ES-19

Table ES.3.18 Hybrid Products: Average Annual Energy Use by Efficiency Level

Efficiency 

Level

H-3A-BI: StandardSize, Built-In Hybrid 

All-Refrigerator with 

Automatic Defrost

(13.4 ft3)

H-11A:

Compact Hybrid AllRefrigerator with 

Manual Defrost

(4.5 ft3

)

H-13A:

Compact Hybrid AllRefrigerator with 

Automatic Defrost

(5.7 ft3

)

H-9I-BI:

Standard-Size, BuiltIn Hybrid Freezer 

with Automatic 

Defrost

(15.7 ft3)*

Percent of 

2014 

Standard

Energy Use

Energy 

Use

(kWh

/year)

Percent of 

2014 

Standard

Energy Use

Energy 

Use

(kWh

/year)

Percent of 

2014 

Standard

Energy Use

Energy 

Use

(kWh

/year)

Percent of 

2014 

Standard

Energy Use

Energy 

Use

(kWh

/year)

EL0 160% 538 160% 407 160% 499 100% 500

EL1 130% 437 130% 331 130% 405 95% 475

EL2 100% 336 100% 254 100% 312 90% 450

EL3 90% 302 90% 229 90% 280 85% 425

EL4 85% 282 80% 204 80% 249 80% 400

EL5 70% 178 70% 218

EL6 60% 153 60% 187

EL7 55% 140 55% 171

* Adjusted volume = cooled cabinet volume + 1.73 times freezer volume

Note: Blank cells represent non-existent efficiency levels (i.e., higher than max-tech) for the specific classes.

ES.3.6 Life-Cycle Cost and Payback Period Analysis 

New energy conservation standards for products change consumer operating expenses, 

which usually decrease, and consumer prices, which may increase. DOE analyzed the net effect 

of new standards on consumers by evaluating the LCC using the cost-efficiency relationship 

derived in the engineering analysis, as well as the energy costs derived from the energy use 

analysis. Inputs to the LCC calculation included the installed cost to the consumer (purchase 

price plus installation cost), operating costs (primarily energy expenses), the lifetime of the 

appliance, and a discount rate.

Because the installed cost of a product typically increases while operating cost typically 

decreases in response to new standards, there is a point in time during the life of products having 

higher-than-baseline efficiency at which the net operating-cost benefit (in dollars) since the time 

of purchase is equal to the incremental first cost of purchasing the higher efficiency product. The 

length of time required for products to reach this cost-equivalence point is known as the PBP.

DOE conducted the LCC and PBP analyses using values that reflect utilization of the 

products in the field. DOE utilized data from online surveys to develop household samples for 

each product class (or, for cooled cabinets and non-compressor refrigerators, product 

subcategory), composed of households that owned that type of product. Data from these surveys
ES-20

provided information on household demographics, product characteristics, product volume for 

cooled cabinets, as well as purchase, installation, maintenance, and repair costs.

DOE used data from the Energy Information Administration (EIA) to derive average 

annual electricity prices for each State and the District of Columbia. DOE then assigned an 

appropriate price to each household in the sample, depending on its location. To project future 

prices, DOE multiplied these prices by the forecast of annual average price changes in EIA’s 

AEO 2014.

DOE did not find any lifetime estimates for miscellaneous refrigeration products in the 

relevant literature so it used data from online surveys to estimate the distribution of cooled 

cabinets and non-compressor refrigerators in the field. DOE used these data to estimate the 

survival function of these appliances, which DOE assumed has the form of a cumulative Weibull 

distribution. The analysis yielded an average lifetime of 4.3 years for cooled cabinets and noncompressor refrigerators. For hybrid products, DOE assumed the lifetimes would be the same as 

those of their non-hybrid equivalents, which DOE calculated in the previous rulemaking for 

refrigerators, refrigerator-freezers, and freezers, the Final Rule for which was published on 

September 15, 2011 (76 FR 57516). These average lifetimes are 17.4 years for standard-sized 

built-in hybrid all-refrigerators (H-3A-BI), 22.3 years for standard-sized built-in hybrid freezers

(H-9I-BI), and 5.6 years for compact hybrid all-refrigerators (H-11A and H-13A). For ice 

makers, DOE assumed the lifetime would be similar to the lifetime of compact freezers in the 

previous Final Rule (76 FR 57516), with an average of 8.0 years.

To estimate the share of consumers who would be affected by a standard at a particular 

efficiency level, DOE’s LCC analysis considered the projected distribution (i.e., market shares) 

of product efficiencies that consumers purchase under the base case (i.e., the case without new 

energy efficiency standards). For cooled cabinets, DOE used data available from the CEC, 

NRCan, and manufacturer websites, in combination with online surveys and DOE’s own testing 

and field measurements, to estimate the efficiency distributions in recent years for each of the 

products. For non-compressor refrigerators, DOE used results from online surveys and testing to 

estimate the efficiency distributions. For ice makers, DOE tested two units from each product 

class. DOE assumed for each product class that half of all products had an efficiency level 

equivalent to the lower energy consumption product, and half had an efficiency level equivalent 

to the higher energy consumption product. For hybrid products DOE used data available from 

manufacturers to determine the energy use of each product, and then determined the base case 

efficiency distribution relative to the 2014 refrigerator-freezer standards for appropriate product 

classes. DOE assumed that the market shares of the efficiency levels in future years will be 

roughly the same as the shares in 2012.

Using the projected distribution of product efficiencies for each product class, DOE 

randomly assigned specific product efficiency levels to each sample household. If a household 

was assigned a product efficiency that is greater than or equal to the efficiency of the standard 

level under consideration, the LCC savings calculation would show that this household is not 

impacted by that standard level. 
ES-21

Table ES.3.19 through Table ES.3.28 show the results of the LCC and PBP analyses for 

cooled cabinets, non-compressor refrigerators and ice maker product classes at each considered 

energy efficiency level. The average lifetime operating cost presented in the tables is a 

discounted value. Figures presented in chapter 8 show the range of LCC savings and PBPs for all 

of the efficiency levels considered for each product class. 

Chapter 8 provides more details on the methods, data, and assumptions used for the LCC 

and PBP analyses.

Table ES.3.19 Average LCC and PBP Results for Product Class CC, Cooled Cabinet

EL

Percent of Baseline 

Energy 

Consumption

Average Costs 

(2013$) Simple 

Payback 

Period

(years)

Average 

Lifetime 

Installed (years)

Cost

First Year’s 

Operating 

Cost

Lifetime 

Operating 

Cost

LCC

0 267 292 86 357 649 --- 4.3

1 200 318 65 269 587 1.2 4.3

2 160 334 53 217 551 1.2 4.3

3 130 346 43 177 524 1.2 4.3

4 100 358 34 138 496 1.2 4.3

5 90 365 30 125 490 1.3 4.3

6 80 385 27 112 497 1.6 4.3

7 70 407 24 99 506 1.8 4.3

8 60 425 21 86 511 2.0 4.3

9 50 443 18 73 516 2.2 4.3

10 40 531 15 60 591 3.3 4.3

11 32 615 12 49 664 4.3 4.3

Note: The results for each EL are calculated assuming that all consumers use products with that 

efficiency level. The PBP is measured relative to the baseline product.
ES-22

Table ES.3.20 Average LCC Savings Relative to the Base Case Efficiency Distribution 

for Product Class CC, Cooled Cabinet

EL

Percent of 

Baseline Energy 

Consumption

Percent of Consumers 

that Experience a Net 

Cost

Average Life-Cycle Cost 

Savings*

(2013$)

0 267 0 0

1 200 0 3

2 160 0 9

3 130 0 19

4 100 0 33

5 90 2 39

6 80 22 32

7 70 44 23

8 60 51 18

9 50 58 13

10 40 87 -61

11 32 95 -135

* The calculation includes consumers with zero LCC savings (no impact).
ES-23

Table ES.3.21 Average LCC and PBP Results for Product Class NCR, Non-Compressor

Refrigerator

EL

Percent of Baseline 

Energy 

Consumption

Average Costs 

(2013$) Simple 

Payback 

Period

(years)

Average 

Lifetime 

Installed (years)

Cost

First Year’s 

Operating 

Cost

Lifetime 

Operating 

Cost

LCC

0 100 165 98 393 558 --- 4.3

1 95 165 93 374 539 0.1 4.3

2 90 165 88 355 520 0.1 4.3

3 85 166 84 336 502 0.1 4.3

4 80 177 79 317 494 0.7 4.3

5 75 185 74 298 483 0.9 4.3

6 70 185 70 279 464 0.7 4.3

7 65 197 65 260 457 1.0 4.3

8 64 207 64 256 463 1.3 4.3

Note: The results for each EL are calculated assuming that all consumers use products with that 

efficiency level. The PBP is measured relative to the baseline product.

Table ES.3.22 Average LCC Savings Relative to the Base Case Efficiency Distribution 

for Product Class NCR, Non-Compressor Refrigerator

EL

Percent of 

Baseline Energy 

Consumption

Percent of Consumers 

that Experience a Net 

Cost

Average Life-Cycle 

Cost Savings*

(2013$)

0 100 0 0

1 95 0 17

2 90 0 36

3 85 0 54

4 80 0 62

5 75 0 73

6 70 0 92

7 65 0 99

8 64 0 93

* The calculation includes consumers with zero LCC savings (no impact).
ES-24

Table ES.3.23 Average LCC and PBP Results for Product Class IM-P, Portable Ice 

Maker

EL

Percent of Baseline 

Energy 

Consumption

Average Costs 

(2013$) Simple 

Payback 

Period

(years)

Average 

Lifetime 

Installed (years)

Cost

First Year’s 

Operating 

Cost

Lifetime 

Operating 

Cost

LCC

0 100 207 37 233 440 --- 8.0

1 90 208 34 211 419 0.5 8.0

2 80 210 30 190 399 0.5 8.0

3 70 211 27 168 379 0.5 8.0

4 60 213 23 146 359 0.5 8.0

5 50 214 20 124 339 0.5 8.0

6 40 216 17 103 319 0.5 8.0

7 35 217 15 91 308 0.5 8.0

Note: The results for each EL are calculated assuming that all consumers use products with that 

efficiency level. The PBP is measured relative to the baseline product.

Table ES.3.24 Average LCC Savings Relative to the Base Case Efficiency Distribution 

for Product Class IM-P, Portable Ice Maker

EL

Percent of 

Baseline Energy 

Consumption

Percent of Consumers 

that Experience a Net 

Cost

Average Life-Cycle 

Cost Savings*

(2013$)

0 100 0 0

1 90 0 10

2 80 0 20

3 70 0 30

4 60 0 40

5 50 0 50

6 40 0 60

7 35 0 66

* The calculation includes consumers with zero LCC savings (no impact).
ES-25

Table ES.3.25 Average LCC and PBP Results for Product Class IM-C, Non-Portable 

Cooled Storage Ice Maker

EL

Percent of Baseline 

Energy 

Consumption

Average Costs 

(2013$) Simple 

Payback 

Period

(years)

Average 

Lifetime 

Installed (years)

Cost

First Year’s 

Operating 

Cost

Lifetime 

Operating 

Cost

LCC

0 100 1,109 84 538 1,647 --- 8.0

1 95 1,113 80 516 1,628 1.1 8.0

2 90 1,116 77 493 1,610 1.1 8.0

3 85 1,120 73 471 1,591 1.1 8.0

4 80 1,124 70 448 1,572 1.1 8.0

5 75 1,128 66 426 1,553 1.1 8.0

6 74 1,128 66 423 1,551 1.1 8.0

Note: The results for each EL are calculated assuming that all consumers use products with that 

efficiency level. The PBP is measured relative to the baseline product.

Table ES.3.26 Average LCC Savings Relative to the Base Case Efficiency Distribution 

for Product Class IM-C, Non-Portable Cooled Storage Ice Maker

EL

Percent of 

Baseline Energy 

Consumption

Percent of Consumers 

that Experience a Net 

Cost

Average Life-Cycle 

Cost Savings*

(2013$)

0 100 0 0

1 95 0 9

2 90 0 19

3 85 0 28

4 80 0 38

5 75 0 47

6 74 0 48

* The calculation includes consumers with zero LCC savings (no impact).
ES-26

Table ES.3.27 Average LCC and PBP Results for Product Class IM-U, Non-Portable 

Uncooled Storage Ice Maker

EL

Percent of Baseline 

Energy 

Consumption

Average Costs 

(2013$) Simple 

Payback 

Period

(years)

Average 

Lifetime 

Installed (years)

Cost

First Year’s 

Operating 

Cost

Lifetime 

Operating 

Cost

LCC

0 100 1,103 150 965 2,068 --- 8.0

1 95 1,107 143 921 2,028 0.6 8.0

2 90 1,111 137 877 1,988 0.6 8.0

3 85 1,115 130 833 1,949 0.6 8.0

4 80 1,120 123 789 1,909 0.6 8.0

5 75 1,124 116 746 1,869 0.6 8.0

6 70 1,128 109 702 1,829 0.6 8.0

7 65 1,132 103 658 1,790 0.6 8.0

8 63 1,134 99 636 1,770 0.6 8.0

Note: The results for each EL are calculated assuming that all consumers use products with that 

efficiency level. The PBP is measured relative to the baseline product.

Table ES.3.28 Average LCC Savings Relative to the Base Case Efficiency Distribution 

for Product Class IM-U, Non-Portable Uncooled Storage Ice Maker

EL

Percent of Baseline 

Energy 

Consumption

Percent of Consumers 

that Experience a Net 

Cost

Average Life-Cycle 

Cost Savings*

(2013$)

0 100 0 0

1 95 0 20

2 90 0 40

3 85 0 60

4 80 0 79

5 75 0 99

6 70 0 119

7 65 0 139

8 63 0 149

* The calculation includes consumers with zero LCC savings (no impact).
ES-27

ES.3.7 Shipments Analysis

Shipment forecasts are needed to calculate for each product being considered the national 

impacts of standards on energy use, NPV, and future manufacturer cash flows. DOE found that 

very limited data were available on miscellaneous refrigeration product shipments. To estimate

the shipments, DOE used the results of a study based upon online surveys to determine the total 

stock in 2012 and then used the lifetime function to determine the proportion of new shipments 

that made up the total stock.1 DOE assumed that the household saturation rate determined in 

2012 would remain the same going forward and, therefore, used AEO 2014 housing starts 

projections to determine future total stock and future shipments. DOE split the shipments into 

market segments for new households, replacements, and, in the case of NCR-2 (i.e., absorption 

refrigerators), shipments to hotels. Chapter 9 of the TSD provides additional detail on the 

shipments analysis.

Figure ES.3.1 illustrates the total forecasted shipments for cooled cabinets in the base 

case and at the considered efficiency levels. DOE estimated that the increased product prices at 

higher efficiency levels would cause a slight decrease in cooled cabinet shipments. Due to the 

cost-efficiency relationships for non-compressor refrigerators, hybrid products, and ice makers, 

DOE does not expect future shipments of these products to be affected by standards.

Figure ES.3.1 Cooled Cabinets Shipments Forecasts for the Base 

Case and Considered Efficiency Levels

0

0.5

1

1.5

2

2.5

3

3.5

4

4.5

5

Shipments (millions)

Base Case

EL1

EL2

EL3

EL4

EL5

EL6

EL7

EL8

EL9

EL10

EL11
ES-28

ES.3.8 National Impact Analysis

The NIA estimates the following national impacts from possible efficiency levels for 

miscellaneous refrigeration products: (1) national energy savings (NES), (2) monetary value of 

the energy savings due to standards, (3) increased total installed costs of the considered products 

due to standards, and (4) the NPV of energy savings (difference between value of energy savings 

and increased total installed costs). DOE prepared a spreadsheet model to forecast energy 

savings and national consumer economic costs and savings resulting from new standards. 

A key component of DOE’s estimates of NES and NPV is the trend in energy efficiency 

forecasted for the base case (without new standards) and each of the standards cases (with new 

standards). DOE did not forecast any change in the base-case efficiency distributions over the 

forecast period. In determining standards-case efficiency distributions, DOE used a “roll-up” 

scenario to establish the distribution of efficiencies for the year that the new standards are 

assumed to become effective (i.e., 2021) and subsequent years. DOE assumed that product 

efficiencies in the base case that did not meet the standard level under consideration would “roll 

up” to meet the new standard level in 2021. 

Chapter 10 provides additional details on this and other aspects of the NIA analysis.

ES.3.8.1 National Energy Savings 

DOE calculated annual NES as the difference between national energy consumption in 

the base case (without new efficiency standards) and under each efficiency level. DOE expressed 

NES based on full-fuel cycle values. To do this, DOE first estimated energy consumption and 

savings based on site energy. DOE then converted site energy values to full-fuel cycle values by 

using factors that account for (a) the losses in transmission, distribution and generation of 

electricity, and (b) the energy consumed by extracting, processing and distributing primary fuels. 

Cumulative energy savings are the sum of the annual NES over the period in which products 

shipped in 2021-2050 are in operation. 

The NES results shown in Table ES.3.29 through Table ES.3.32 are shown as full-fuel 

cycle energy savings in quadrillion British thermal units (i.e., quads).
ES-29

Table ES.3.29 Cooled Cabinets: Cumulative NES Full-Fuel Cycle Results (quads)

Efficiency 

Level

Cooled Cabinet

CC

1 0.052

2 0.139

3 0.292

4 0.518

5 0.618

6 0.730

7 0.852

8 0.976

9 1.102

10 1.199

11 1.266

Table ES.3.30 Non-Compressor Refrigerators Cumulative NES Full-Fuel Cycle Results

(quads)

Efficiency Level

Non-Compressor 

Refrigerator

NCR

1 0.063

2 0.134

3 0.204

4 0.275

5 0.346

6 0.416

7 0.487

8 0.501
ES-30

Table ES.3.31 Ice Makers: Cumulative NES Full-Fuel Cycle Results (quads)

Efficiency Level

Portable Ice Maker Non-Portable Ice 

Maker, cooled storage

Non-Portable Ice 

Maker, uncooled 

storage

IM-P IM-C IM-U

1 0.012 0.001 0.008

2 0.024 0.003 0.017

3 0.036 0.004 0.025

4 0.048 0.006 0.033

5 0.059 0.007 0.042

6 0.071 0.008 0.050

7 0.077 0.058

8 0.062

Note: Blank cells represent non-existent efficiency levels (i.e., higher than max-tech) for the specific classes.

Table ES.3.32 Hybrid Refrigeration Products: Cumulative NES Fuel Full-Fuel Cycle

Results (quads)

Efficiency 

Level

Standard-Size 

Built-In Hybrid 

All-Refrigerator

Compact Hybrid 

All-Refrigerator

with Manual 

Defrost

Compact Hybrid 

All-Refrigerator 

with Automatic 

Defrost

Standard-Size 

Built-In Hybrid 

Freezer

H-3A-BI H-11A H-13A H-9I-BI

1 0.019 0.003 0.014 0.000

2 0.043 0.010 0.048 0.000

3 0.051 0.012 0.059 0.000

4 0.055 0.015 0.071 0.001

5 0.017 0.082

6 0.019 0.093

7 0.020 0.099

Note: Blank cells represent non-existent efficiency levels (i.e., higher than max-tech) for the specific classes.

ES.3.8.2 Net Present Value 

DOE calculated net monetary savings each year as the difference between total savings in 

operating costs and increases in total equipment costs in the base case and standards cases. DOE 

only included cooled cabinets, non-compressor refrigerators, and ice makers in the NPV 

analysis, because there is no cost efficiency curve available at this time to generate robust 

incremental cost estimations for hybrid refrigeration products at different efficiency levels. DOE 

calculated savings over the life of the products purchased in the forecast period. The NPV is the 

difference between the present value of operating cost savings and the present value of increased 

total installed costs. In accordance with guidance provided by the Office of Management and 

Budget (OMB) to Federal agencies on regulatory analysis, DOE used discount rates of 7 percent 

and 3 percent to discount future costs and savings to the present. 
ES-31

The NPV results by product are shown in Table ES.3.33 throughES.3.36. A negative 

NPV indicates that the costs of a standard at a given efficiency level exceed the savings.

Table ES.3.33 Cumulative Net Present Value of Consumer Benefits for Cooled Cabinets, 

in Billion 2013$

Table ES.3.34 Cumulative Net Present Value of Consumer Benefits for NonCompressor Refrigerators, in Billion 2013$

Efficiency 

Level Discount Rate

3 Percent 7 Percent

1 0.470 0.208

2 0.997 0.441

3 1.525 0.675

4 1.779 0.775

5 2.125 0.920

6 2.649 1.151

7 2.891 1.245

8 2.759 1.175

Efficiency 

Level Discount Rate

3 Percent 7 Percent

1 0.278 0.118

2 0.743 0.315

3 1.559 0.661

4 2.762 1.171

5 3.278 1.388

6 3.026 1.226

7 2.629 0.989

8 2.485 0.875

9 2.337 0.758

10 -1.953 -1.367

11 -5.985 -3.345
ES-32

Table ES.3.35 Cumulative Net Present Value of Consumer Benefits for Ice Makers, 3-

Percent Discount Rate

Efficiency Level

Portable Ice Maker Non-Portable Ice 

Maker, cooled storage

Non-Portable Ice 

Maker, uncooled 

storage

IM-P IM-C IM-U

billion 2013 dollars

1 0.082 0.009 0.056

2 0.163 0.018 0.111

3 0.245 0.027 0.167

4 0.327 0.036 0.222

5 0.408 0.044 0.278

6 0.490 0.045 0.334

7 0.533 0.389

8 0.417

Note: Blank cells represent non-existent efficiency levels (i.e., higher than max-tech) for the specific classes.

Table ES.3.36 Cumulative Net Present Value of Consumer Benefits for Ice Makers, 7-

Percent Discount Rate

Efficiency Level

Portable Ice Maker Non-Portable Ice 

Maker, cooled storage

Non-Portable Ice 

Maker, uncooled 

storage

IM-P IM-C IM-U

billion 2013 dollars

1 0.036 0.004 0.024

2 0.072 0.008 0.049

3 0.107 0.012 0.073

4 0.143 0.015 0.097

5 0.179 0.019 0.122

6 0.215 0.020 0.146

7 0.234 0.170

8 0.182

Note: Blank cells represent non-existent efficiency levels (i.e., higher than max-tech) for the specific classes.
ES-33

ES.3.9 Preliminary Manufacturer Impact Analysis

DOE conducts the MIA in three phases and further tailors the analytical framework based 

on comments received from interested parties. In Phase 1, DOE creates an industry profile to 

characterize the industry and conducts preliminary manufacturer interviews to identify important 

issues that require special consideration. The preliminary analysis TSD presents the results of the 

Phase 1 analysis. In Phase 2, DOE prepares an industry cash-flow model and an interview 

questionnaire to guide subsequent discussions. In Phase 3, DOE interviews manufacturers, and 

assesses the impacts of new or amended energy conservation standards both quantitatively and 

qualitatively. The NOPR TSD presents the results of Phase 2 and Phase 3 analyses.

The preliminary MIA identified potential impacts to manufacturers of refrigeration 

products through interviews with a representative subset of manufacturers in the refrigeration 

products industry. Chapter 12 of the preliminary TSD includes details on the key issues 

identified by DOE during the preliminary MIA.

To summarize, DOE identified the following key areas of impact for manufacturers of 

refrigeration products:

• Timing of new standards relative to the 2014 energy conservation standard for 

refrigerators, refrigerator-freezers, and freezers;

• Impact on shipments and profitability;

• Impact on product mix;

• Cumulative regulatory burden;

• Capital and product conversion costs; 

• Product innovation and consumer utility; and

• Impact on small businesses.

ES.4 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT

DOE is interested in receiving comments on all aspects of this preliminary analysis. DOE 

especially invites comments or data to improve DOE’s analysis, including data or information 

that will respond to the following questions or concerns that were raised in response to the 

framework document and in preparation of the preliminary TSD. 

ES.4.1 Non-Compressor Refrigerator Storage Temperatures

DOE has observed through testing that non-compressor refrigerators are typically unable 

to achieve storage temperatures of 39 °F or below in its proposed ambient test condition of 90 

°F.

• Do any non-compressor refrigerators—thermoelectric or absorption—exist that can maintain 

storage temperatures of 39 °F or below in ambient temperatures of 90 °F?
ES-34

ES.4.2 Non-Compressor Refrigerator Standard Adjustment Factor

As mentioned in chapter 2 of this TSD, DOE is not aware of refrigerators using 

refrigeration technologies other than vapor compression that can maintain 39 °F storage 

temperatures when operating in the 90 °F ambient conditions used for refrigerator testing. To 

address this issue, DOE may consider accounting for this limitation when developing standards 

for these product types. This approach may compensate for the fact that such products would 

effectively be rated at a condition that theoretically should require less energy use than operation 

at the standardized temperature. This standard adjustment factor, depicted in Equation 1, would 

adjust the maximum allowable energy use downward so that the standard’s stringency would 

increase as the product’s coldest temperature increases. 

Equation 1

Standard Adjustment Factor = (90 °F – TTest_Cold)/ (90 °F – 39 °F)

Where: TTest_Cold indicates the fresh food compartment temperature achieved by a noncompressor refrigerator in the cold setting during an energy test. When a group of units of 

the same model are tested, e.g., for certification purposes, this value would be the average 

measured for the group.

DOE used this standard adjustment factor to develop its efficiency levels for noncompressor refrigerators, as described in chapter 5 of this TSD.

• How should, if at all, DOE address the different nature of non-compressor-based 

refrigeration products in the context of their inability to reach and maintain storage 

temperatures of 39 °F or lower under the conditions detailed in DOE’s proposed test 

procedure conditions?

ES.4.3 Hybrid Refrigeration Product Classes

For hybrid refrigeration products, DOE is considering creating product classes based on 

all existing product classes for refrigerators, refrigerator-freezers, and freezers that will apply to 

products manufactured on or after September 15, 2014, as currently found at 10 CFR 430.32(a). 

DOE proposes to assign hybrid products to these 40 product classes based on their storage 

volume, compartment temperature ranges, defrost type, ice service, and built-in status. The 

hybrid refrigeration products identified by DOE thus far would fall into one of four product 

classes: H-3A-BI, comprising built-in standard-sized hybrid all-refrigerators with automatic 

defrost; H-9I-BI, comprising built-in standard-sized hybrid freezers with automatic defrost and 

an automatic icemaker; H-11A, comprising compact hybrid all-refrigerators with manual defrost; 

and H-13A, comprising compact hybrid all-refrigerators with automatic defrost. However, 

additional hybrid products identified by DOE in the future could potentially fall into any of the 

40 product classes under consideration.

• Are there hybrid refrigeration products currently on the market that would not be well 

represented by one of the existing product classes for refrigerators, refrigerator-freezers, and 
ES-35

freezers? Should DOE allow separate product classes for built-in hybrid refrigeration 

products?

ES.4.4 Stocks, Shipments, and Lifetimes of Miscellaneous Refrigeration Products

DOE based its analysis on the results of a study that relied on online surveys1 to estimate 

stocks, shipments, and lifetimes of cooled cabinets, non-compressor refrigerators, ice makers, 

and hybrid refrigeration products. However, for cooled cabinets, shipments estimates from other 

sources (AHAM, NPD Group, and Natural Resources Canada) were lower than those derived 

from survey data, in some cases by a significant factor. DOE also lacked data on the historical 

shipments of non-compressor refrigerators, ice makers, and hybrid refrigeration products, as well 

as projected future shipments of any miscellaneous refrigeration products. Consequently, DOE’s 

estimates were based on trends derived from the 2011 Final Rule on Refrigerators, RefrigeratorFreezers and Freezers. DOE is interested in obtaining additional data on historical, current, and 

projected future stocks and shipments of miscellaneous refrigeration product, as well as lifetime 

estimates, to help refine its estimates.

• Are additional data available on the historical, current, and projected future stocks, shipments 

and lifetimes of cooled cabinets, non-compressor refrigerators, ice makers, and hybrid 

refrigeration products?

ES.4.5 Energy Use of Non-Compressor Cooled Cabinets and Refrigerators

DOE relied on limited energy use data from laboratory testing, field measurements, and 

manufacturer websites to estimate the annual energy use of non-compressor (thermoelectric 

and/or absorption cooling) cooled cabinets and refrigerators. Manufacturer website data, in 

particular, were unclear regarding the test conditions under which such measurements were 

made. Additional data on the estimated annual field energy consumption of non-compressor

cooled cabinets and refrigerators would help DOE to refine its estimates of the efficiency 

distributions of products currently on the market.

• Are additional data available on the estimated annual field energy use of non-compressor

(thermoelectric and/or absorption cooling) cooled cabinets and refrigerators? If so, what 

specific topics or categories of data should DOE include and collect as part of its overall 

analysis?

ES.4.6 Energy Use and Market Shares of Ice Makers

DOE was not able to test more than two ice maker products per product class, and as a 

result its engineering cost-efficiency estimates were very limited. DOE had no data on the

efficiency market share distribution of ice makers and made the assumption that half of the 

products on the market were at the lower efficiency level, and half were at the higher efficiency 

level. Moreover, while DOE was able to estimate from survey data that about 70 percent of ice 

makers were portable (IM-P), very limited information was available on the market share split 

between cooled and uncooled non-portable ice makers (IM-C and IM-U, respectively). 
ES-36

Additional data on the energy consumption and market shares of all ice makers would help DOE 

to refine its estimates, which could have implications on energy use and potential savings.

• Are additional data, if any, available on the energy consumption and market shares of ice 

makers? If no such data are available, how should DOE begin to collect or develop these 

data? In lieu of that, what data could DOE use to help approximate the energy consumption 

and market shares of these products? 

ES.4.7 Vapor Compression in Small Cooled Cabinets

Vapor-compression refrigeration systems are generally significantly more efficient than 

thermoelectric refrigeration systems. However, as discussed in chapter 5 of this TSD, the 

efficiency of compressors commonly used for refrigeration products drops off significantly 

below capacities of 300 Btu/hour. Therefore, it may not be efficient or feasible to switch from 

thermoelectric to vapor-compression technology in cooled cabinets below a certain size. 

• What additional data, if any, are available on the feasibility of using vapor compression for 

cooled cabinets above or below a particular size or capacity threshold? DOE encourages the 

public to provide these types of data, to the extent they are available, including, but not 

limited to, studies, test results, and field reports. 

ES.4.8 Relationship between Volume and Efficiency in Thermoelectric Refrigeration 

Products

DOE found during testing that the efficiency of thermoelectric cooled cabinets increased 

significantly as product volume decreased and, consequently, seeks to improve its understanding 

of how efficiency is related to size or bottle capacity.

• DOE requests information and any available data on the relationship between volume and 

efficiency in thermoelectric refrigeration products.

ES.4.9 Vacuum-Insulated Panels (VIPs) for Cellar Compartments or Cooled Cabinets

In prior discussions with manufacturers, DOE learned that different manufacturers had 

varying experiences in integrating VIPs to refrigeration products. The energy efficiency

improvement reported by manufacturers ranged roughly from 0 to 100 percent of the levels 

predicted by the models described in the engineering analysis. DOE used a performance 

degradation factor of 50 percent in its analysis to account for this variation in experience. 

However, DOE notes that none of this manufacturer feedback specifically addressed cooled 

cabinets, and that manufacturers indicated that VIPs provide less performance enhancement for 

fresh food compartments than they do for freezer compartments. Consequently, this limited

information obtained by DOE regarding VIPs may not apply to those compartments that are 

maintained at 55 °F.

DOE requests information and any available data on the thermal performance of cellar 

compartments or cooled cabinets using vacuum insulated panels.
ES-37

 1 Greenblatt, J. B., S. J. Young, H.-C. Yang, T. Long, B. Beraki, S. Price, S. Pratt, H. Willem, L.-B. Desroches, and 

S. M. Donovan (2013). “U.S. Residential Miscellaneous Refrigeration Products: Results from Amazon Mechanical 

Turk Surveys,” Lawrence Berkeley National Laboratory, LBNL-6537E, November.