ISSUED: FEBRUARY 10, 2011 

The following is a U.S. Department of Energy (DOE) guidance document that provides further 

clarification on the definitions, test procedures, and product classes applicable to residential 

refrigeration products to aid manufacturers in determining whether a given basic model is 

covered by DOE’s regulations. This guidance document represents the Department’s 

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

requirements of the Administrative Procedure Act. See 5 U.S.C. § 553(b)(A). 

Q: What types of refrigerated wine storage products and/or hybrid wine storage products (i.e., 

products combining wine storage, fresh food, and/or freezer compartments) are covered under 

DOE’s regulations? 

A: For the purpose of this guidance, a wine storage compartment is a compartment that is not 

designed to be capable of storage temperature less than 39  ̊F. At this time, wine storage 

products, defined for these purposes as refrigeration products comprised exclusively of wine 

storage compartments, are not covered under DOE’s regulations. See 75 FR 78810 (December 

16, 2010). DOE has received several inquiries about the applicability of DOE’s definitions to 

hybrid products that combine wine storage compartments with fresh food and/or freezer 

compartments. Consequently, DOE is clarifying through this guidance that such hybrid products 

may fall within the current definitions of electric refrigerator1 and electric refrigerator-freezer2 . 

A wine storage compartment of any size added to what would otherwise be an electric 

refrigerator does not change the product’s status as an electric refrigerator and does not exempt 

it from coverage. The same outcome applies for any electric refrigerator-freezer -- i.e. adding a 

wine cooler compartment to an electric refrigerator-freezer would not exempt that product’s 

coverage as an electric refrigerator-freezer. 

However, products that include a wine storage compartment but are otherwise freezers do not 

meet the freezer3 definition if the wine storage compartment comprises a majority of the total 

1 Electric refrigerator means a cabinet designed for the refrigerated storage of food, designed to be capable of

achieving storage temperatures above 32 °F (0 °C) and below 39 °F (3.9 °C), and having a source of refrigeration

requiring single phase, alternating current electric energy input only. An electric refrigerator may include a

compartment for the freezing and storage of food at temperatures below 32°F (0 °C), but does not provide a

separate low temperature compartment designed for the freezing and storage of food at temperatures below 8 °F

(‐13.3 °C). 10 CFR 430.2. 2 Electric refrigerator‐freezer means a cabinet which consists of two or more compartments with at least one of

the compartments designed for the refrigerated storage of food and designed to be capable of achieving storage

temperatures above 32 °F (0 °C) and below 39 °F (3.9 °C), and with at least one of the compartments designed for

the freezing and storage of food at temperatures below 8 °F (‐13.3 °C) which may be adjusted by the user to a

temperature of 0 °F (‐17.8 °C) or below. The source of refrigeration requires single phase, alternating current

electric energy input only. 10 CFR 430.2. 3 Freezer means a cabinet designed as a unit for the freezing and storage of food at temperatures of 0 °F. or below,

and having a source of refrigeration requiring single phase, alternating current electric energy input only. 10 CFR

430.2.
storage volume of that product. As an example, the product addressed by the Liebherr waiver 

that recently terminated, which had over 50% of its volume dedicated as a wine cooler, is not a 

freezer under the current regulatory definition. See 75 FR 78810, 78817 (Dec. 16, 2010). 

DOE recognizes the potential disparity in treatment among these hybrid products. As DOE 

indicated earlier during its related rulemaking activities for refrigeration products, the 

Department plans to engage in a future rulemaking to more comprehensively address these types 

of products. See 75 FR 29824, 29827 (May 27, 2010). 

DOE notes that there are many different groups of wine storage, fresh food, and freezer 

compartments that could be combined in a given refrigeration product. The different types of 

compartments distinguished by the standards include the following: 

•	 Freezer (“long-term”): a freezer compartment capable of 0  ̊F storage temperature. These 

compartments are typically found in refrigerator-freezers or freezers. 

•	 Freezer (“short-term”): a freezer compartment larger than 0.5 cubic feet in volume 

capable of storage temperatures less than 32  ̊F but normally not less than 8  ̊F. These 

compartments are generally found in refrigerators other than all-refrigerators. 

•	 Freezer (“ice only”): a freezer compartment of 0.5 cubic feet capacity or less capable of 

storage temperatures less than 32  ̊F but normally not less than 8  ̊F. These compartments 

may be found in all-refrigerators. 

•	 Fresh food compartment: a compartment capable of storage temperatures less than 39  ̊F, 

generally not controllable to temperatures less than 32  ̊F. 

•	 “Wine storage” compartment: a compartment not capable of 39  ̊F storage temperature 

that provides warmer temperatures than 39  ̊F. Generally such compartments are designed 

for storage of wine. 

While DOE has not defined all of these terms in its regulations, DOE understands they are 

commonly used within the refrigeration industry (see, for example, product definitions for basic 

refrigerator and all-refrigerator in AHAM HRF-1-2008, sections 3.1.1 and 3.1.2) and is using 

them to provide additional clarity in this guidance document. In particular, these terms are 

helpful when mapping the basic models on the market today to DOE’s regulatory definitions and 

product classes for determining scope of coverage. 

Table 1 below shows several possible combinations of compartments that could be present in a 

refrigerated product. The table identifies the product definitions that apply to each distinct 

combination of compartments. For example, a product incorporating a “short term” freezer 

compartment and a fresh food compartment (the fifth compartment combination identified 

below) is a refrigerator other than an all-refrigerator. 

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Table 1: Product Definitions Applicable to Different Compartment Combinations in a 

Product 

Compartment Types 

Freezer 

(“long 

term”) 

Freezer 

(“short 

term”) 

Freezer 

(“ice 

only”) 

Fresh 

Food 

“Wine 

Storage” 

Product Types 

COVERED PRODUCT COMBINATIONS 

All-Refrigerator 9

9 9

9 9

9 9 9

Refrigerator other 

than an AllRefrigerator 

9 9

9 9 9

RefrigeratorFreezer 

9 9

9 9 9

Freezer 9

EXAMPLES OF CURRENTLY UNCOVERED PRODUCT 

COMBINATIONS 

Wine Storage only 9

Wine Storage with 

“long term” freezer 

9 9

Wine Storage with 

“short term” 

freezer 

9 9

Note: All-refrigerators with “ice-only” freezer compartments may have just one such 

compartment. DOE is not aware of the existence of such products with more than one “ice-only” 

freezer compartment and has not made a determination of the product type definition applicable 

for such a combination. 

Some of the compartment combinations listed do not represent products that are covered under 

the regulatory definitions for refrigeration products. Three examples are set forth in the table 

above; namely, a product that has one or more wine storage compartments and two products that 

have only wine storage and freezer compartments. 

DOE emphasizes that the “wine storage” compartment description as discussed herein applies 

only to compartments that are not “designed to be capable of achieving storage temperatures 

below 39 °F (3.9 °C)”. 10 CFR Part 430.2. Hence, a compartment configured for wine storage or 

identified as a wine storage compartment in marketing literature that achieves temperatures 

below 39 °F (3.9 °C) is a fresh food compartment for the purposes of identifying the applicable 

product definition and determining scope of coverage with DOE’s regulations. In addition, a 

compartment that is designed to be a fresh food compartment, but does not reach 39 °F (3.9 °C) 

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or lower in an energy test in a 90  ̊F ambient temperature with controls set to the coldest position 

is still a fresh food compartment. 

Q: How should covered refrigeration products that include wine storage compartments be 

tested? 

A: The current energy efficiency test procedures address testing for the different types of 

products. Refrigerators and refrigerator-freezers are tested as set forth in 10 CFR 430, subpart B, 

appendix A1, and freezers are tested as set forth in Appendix B1. Compartment temperature 

settings for the tests are as indicated in section 3.2 of the applicable appendix. If the wine storage 

compartment is a separate auxiliary compartment in such a product (i.e. access to it is through a 

separate exterior door rather than through the door of another compartment), it would be tested 

with the standardized temperature of a fresh food compartment (45  ̊F (7.2  ̊C)). If testing of such 

a product that meets the electric refrigerator or electric refrigerator-freezer definition is 

impossible or leads to test results that are inconsistent with a representative average use cycle 

because of the wine storage compartment’s inability to approach the standardized fresh food 

compartment temperature of 45  ̊F (7.2  ̊C), manufacturers have the option of requesting test 

procedure waivers. (See 10 CFR 430.27.) We note that DOE recently issued general guidance 

on waivers in the context of residential clothes washers. See 

http://www.gc.energy.gov/documents/LargeCapacityRCW_guidance_122210.pdf. 

Q: Which product classes apply to hybrid refrigeration products that include wine storage 

compartments? 

A: Energy conservation standards applicable to hybrid products including wine storage 

compartments with fresh food and/or freezer compartments are determined based on the 

applicable product classes as presented in 430.32(a). In most cases, identification of the 

applicable product class will be clear based on the characteristics of a given basic model. For 

instance, a product including only fresh food and wine storage compartments is an allrefrigerator. If it is compact and has automatic defrost, it is product class 13; if it is compact and 

has manual defrost, it is product class 11. (See 10 CFR 430.32(a).) If the manufacturer does not 

believe there is a clear distinction as to which product class is applicable to a given basic model, 

manufacturers are encouraged to request additional clarification from DOE. DOE notes that all 

basic models, including those with various compartment types, which meet the definition of 

electric refrigerator, electric refrigerator-freezer, or freezer must be certified to the Department. 

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