1 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

The Parker Ranch installation in Hawaii

Test Procedure for Clothes Dryers and Room Air Conditioners

Supplemental Notice of Proposed 

Rulemaking Public Meeting

Margaret Sullivan

July 14, 2010

Department of Energy

Energy Efficiency & Renewable Energy

Email. AHAM2-2008-TP-0010@hq.doe.gov
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Agenda

9:00 – 9:20 am

9:20 – 9:45 am

9:45 – 10:10 am

10:10 – 10:45 am

10:45 – 11:00 am

11:00 – 11:30 am

Welcome, Attendee Introductions and Agenda Overview

Introduction and Regulatory History

Covered Products; Standby/Off Mode: Incorporating by 

Reference IEC 62301

Standby/Off Mode: Determination of Modes to be 

Incorporated, Added Specifications to the Test Method 

and Measurements

Break

Standby/Off Mode: Calculation of Energy Use, Measures 

of Energy Consumption
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Agenda (Continued)

11:30 – 12:00 pm

12:00 – 1:00 pm

1:00 – 1:30 am

1:30 – 2:00 pm

2:00 – 2:30 pm

2:30 – 3:00 pm

3:00 pm

Active Mode: Dryer Automatic Cycle Termination

Lunch

Active Mode: Vent-less Dryers, Detergent Specifications 

for Dryer Test Cloth Preconditioning

Active Mode: Changes to Reflect Consumer Usage 

Patterns and Capabilities

Active Mode: Room Air Conditioner and Dryer 

Referenced Test Procedures, Technical Correction for 

Gas Dryers, Clarification to Dryer Gas Supply Conditions

Compliance with EPCA; Requirements; Effects of Test 

Procedure Revisions on Compliance with Standards

Closing Remarks and Adjourn
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 Introductions

 Role of the Facilitator

 Ground Rules (norms)

– Listen as an ally

– Use short, succinct statements/keep to the point

– Hold any sidebar conversations outside of the room

– Focus on issues, not personalities

– Speak one at a time (raise hand to be recognized; state your name for 

the record)

– Set cell phones to silent/vibrate

 Housekeeping Items

Welcome and Introduction
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Introduction

Purpose of the Test Procedure SNOPR Public Meeting

 Present the Department’s proposed test procedures for clothes 

dryers and room air conditioners

 Seek comment from participants on the proposed test procedures

 Discuss specific issues or questions related to the proposal

 Discuss the next steps for the rulemaking
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Test Procedure Rulemaking Process

NOPR SNOPR

 NOPR published on December 9, 2008 (NOPR Public Meeting on 

December 17, 2008)

 SNOPR published on June 29, 2010 (SNOPR Public Meeting today, 

July 14, 2010)

 Comments on SNOPR from interested parties

• Transcript records oral comments from today’s public meeting

• Written comments (comment period closes August 30, 2010)

 DOE reviews and considers all comments

Final

Rule
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Introduction

Regulatory History

 Clothes Dryer Test Procedure Final Rule. 46 FR 27324, May 19, 1981.

• Established test procedure with provisions for measuring the energy factor (EF)

 Room Air Conditioner Test Procedure Final Rules. 42 FR 27898, June 

1, 1977; 44 FR 37938, June 29, 1979.

• Established and amended test procedure with provisions for measuring the 

energy efficiency ratio (EER).

• Incorporated by reference:

– ANSI Z234.1-1972, “Room Air Conditioners”

– ASHRAE Standard 16-69, “Method of Testing for Rating Room Air 

Conditioners”
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Introduction

Regulatory History – Continued

 Energy Independence and Security Act of 2007 (EISA 2007) 

Amendments to the Energy Policy and Conservation Act (42 U.S.C. 

6291 et seq.)

• Directs DOE to incorporate a measure of standby and off mode energy 

consumption into its test procedures for residential clothes dryers and room air 

conditioners.

 Clothes Dryer and Room Air Conditioner Test Procedure Notice of 

Proposed Rulemaking (Issued on December 9, 2008, referred to as the 

December 2008 TP NOPR)

• DOE proposed amendments to address the statutory requirement to incorporate 

a measure of standby and off mode energy consumption into the test 

procedures.

• DOE received comments on the harmonization of mode definitions and testing 

procedures with the international standards, in particular the consideration of 

IEC Standard 62301 Second Edition Committee Draft 2 (IEC Standard 62301 

CD2).
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Introduction

Consideration of IEC Standard 62301

 After the December 2008 TP NOPR, DOE decided to allow for the 

consideration of a revised version of IEC Standard 62301, which was 

expected to be published in July 2009.

• Based on review of drafts of the updated IEC Standard 62301, the revisions 

could include different mode definitions.

 More recently, DOE received information that IEC Standard 62301 

Second Edition is not expected to be published until late 2010.

• Would not be in time for the consideration of standby and off mode power 

consumption in the concurrent energy conservation standards rulemaking.

 DOE decided to publish the SNOPR to consider the new mode 

definitions from the most recent draft version of IEC Standard 62301 

Second Edition.

• Designated as IEC Standard 62301 Committee Draft for Vote (IEC Standard 

62301 CDV).

• DOE believes that such new mode definitions represent the best definitions 

available for the analysis in support of the SNOPR. 
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Introduction

Consideration of Active Mode Test Procedures

 Framework Document to consider amended energy conservation 

standards for residential clothes dryers and room air conditioners 

(October 2007 Framework Document).

• Published on October 9, 2007. 72 FR 57254.

• DOE identified potential revisions to the active mode test procedures for the 

covered products.

• Received comments from interested parties on potential amendments.

 DOE decided after the December 2008 TP NOPR to conduct a 

rulemaking to address active mode test procedure issues for clothes 

dryer and room air conditioners 

• DOE decided to address the balance of the active mode test procedure issues in 

the test procedure SNOPR.
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Test Procedure Overview

1. Products Covered by the Test Procedure Changes

2. Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode Test Procedures

a. Incorporating by Reference IEC Standard 62301 (First Edition, 2005-06) for Measuring Standby 

Mode and Off Mode Power in Clothes Dryers and Room Air Conditioners

b. Determination of Modes to be Incorporated

c. Adding Specifications for the Test Methods and Measurements for Clothes Dryer and Room Air 

Conditioner Standby Mode and Off Mode Testing

d. Calculation of Energy Use Associated with Standby Modes and Off Mode

e. Measures of Energy Consumption
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Covered Products

Products Covered by the Test Procedure Changes –

Clothes Dryers

 The proposed test procedure amendments for clothes dryers cover 

both gas and electric clothes dryers. 10 CFR 430.2 provides the 

following definitions:

• “Electric clothes dryer means a cabinet-like appliance designed to dry fabrics in 

a tumble-type drum with forced air circulation. The heat source is electricity and 

the drum and blower(s) are driven by an electric motor(s).”

• “Gas clothes dryer means a cabinet-like appliance designed to dry fabrics in a 

tumble-type drum with forced air circulation. The heat source is gas and the 

drum and blower(s) are driven by an electric motor(s).”

 The proposed amendments cover:

• Vented gas and electric clothes dryers.

• Vent-less clothes dryers, including combination washer/dryers.
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Covered Products

Products Covered by the Test Procedure Changes – Room 

Air Conditioners

 10 CFR 430.2 defines “room air conditioner” as “a consumer product, 

other than a ‘packaged terminal air conditioner,’ which is powered by 

a single-phase electric current and which is an encased assembly 

designed as a unit for mounting in a window or through the wall for 

the purpose of providing delivery of conditioned air to an enclosed 

space. It includes a prime source of refrigeration and may include a 

means for ventilating and heating.”

 Proposed amendments cover:

• Room air conditioners designed for single- or double-hung windows

– With or without louvered sides 

– With or without reverse cycle

• Casement-slider and casement-only window-type room air conditioners.
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Test Procedure Overview

1. Products Covered by the Test Procedure Changes

2. Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode Test Procedures

a. Incorporating by Reference IEC Standard 62301 for Measuring Standby Mode and Off Mode Power 

in Clothes Dryers and Room Air Conditioners

b. Determination of Modes to be Incorporated

c. Adding Specifications for the Test Methods and Measurements for Clothes Dryer and Room Air 

Conditioner Standby Mode and Off Mode Testing

d. Calculation of Energy Use Associated with Standby Modes and Off Mode

e. Measures of Energy Consumption
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Incorporating IEC Standard 62301

IEC Standard 62301 – Testing Methods and Procedures

 DOE proposed in the December 2008 TP NOPR to incorporate the 

same clauses from IEC Standard 62301 First Edition for measuring 

both standby and off mode power consumption. 

 Section 4 clauses – provide conditions for: 

• Supply voltage, frequency, and waveform

• Ambient room air temperature

• Power measurement meter tolerances 

 Section 5 clauses:

• Clarify the measurement of standby mode for units with a short-duration 

higher power state before a lower power state

• Provide methods for measuring standby mode and off mode power when the 

power measurement is either stable or unstable (i.e., varies over a 

representative cycle).
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Incorporating IEC Standard 62301

Updated IEC Standard 62301

 IEC is developing an updated test standard, IEC Standard 62301 

Second Edition.

• DOE anticipated, based on reviews of draft versions of IEC Standard 62301 

Second Edition, that revisions could include different mode definitions.

 DOE decided to consider the new standby, off, and active mode 

definitions from the draft version IEC Standard 62301 CDV for the 

SNOPR.

• New mode definitions expand upon EPCA mode definitions. 

• Provide additional guidance as to which functions are associated with each 

mode.

 For the SNOPR, DOE is proposing standby, off, and active mode 

definitions based on IEC Standard 62301 CDV.
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Incorporating IEC Standard 62301

IEC Standard 62301 – Testing Methods and Procedures

 DOE did not receive any comments opposed to the proposed 

testing methods and procedures referenced in IEC Standard 62301 

First Edition.

 The SNOPR does not affect DOE’s proposal in the December 2008 

TP NOPR to incorporate by reference the presented clauses from 

IEC Standard 62301 First Edition. 

DOE invites comment on the adequacy of IEC Standard 62301 to 

measure standby power for clothes dryers and room air conditioners 

in general, and on the suitability of incorporating into DOE 

regulations the following specific provisions from IEC Standard 

62301: section 4 (“General conditions for measurements”), paragraph 

4.2, “Test room,” , paragraph 4.3 “Power supply” (for room air 

conditioners only), paragraph 4.4, “Supply voltage waveform,” and 

paragraph 4.5, “Power measurement accuracy,” and section 5 

(“Measurements”), paragraph 5.1, “General” and paragraph 5.3, 

“Procedure.” (Issue #1)
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Test Procedure Overview

1. Products Covered by the Test Procedure Changes

2. Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode Test Procedures

a. Incorporating by Reference IEC Standard 62301 for Measuring Standby Mode and Off Mode Power 

in Clothes Dryers and Room Air Conditioners

b. Determination of Modes to be Incorporated

c. Adding Specifications for the Test Methods and Measurements for Clothes Dryer and Room Air 

Conditioner Standby Mode and Off Mode Testing

d. Calculation of Energy Use Associated with Standby Modes and Off Mode

e. Measures of Energy Consumption
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Modes to be Incorporated

 DOE proposed in the December 2008 TP NOPR to use the EPCA 

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

• Also proposed to clarify the range of main functions that would be classified 

as active mode functions and to define multiple standby modes for both 

clothes dryers and room air conditioners.

 DOE proposed in the December 2008 TP NOPR to define multiple 

standby modes.

• Clothes Dryers:

– Inactive Mode

– Cycle Finished Mode

– Delay Start Mode

• Room Air Conditioners

– Inactive Mode

– Delay Start Mode

– Off-cycle Mode

December 2008 TP NOPR Proposed Definition of Modes
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Modes to be Incorporated

 DOE is proposing revised active, standby, and off mode definitions 

based on the definitions provided in IEC Standard 62301 CDV.

 DOE is proposing the following definition of active mode.

• “Active mode” means a mode which includes product modes where the 

energy using product is connected to a mains power source, has been 

activated and provides one or more main functions. 

Definition of Modes
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Modes to be Incorporated

 IEC Standard 62301 CD2 provided additional clarification that 

“delay start mode is a one off user initiated short duration function 

that is associated with an active mode.”

 IEC Standard 62301 CDV removed this clarification.

• In response to comments on IEC Standard 62301 CD2 that led to IEC 

Standard 62301 CDV, IEC states that delay start mode is a one off function of 

limited duration.

• DOE infers this to mean that delay start mode would not be considered a 

standby mode and that no conclusion is made as to whether delay start mode 

would be considered part of active mode.

 DOE is continuing to propose the additional clarifications for the 

range of main functions that would be classified as active mode 

functions, as proposed in the December 2008 TP NOPR.

Definition of Modes – Active Mode
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Modes to be Incorporated

Definition of Modes – Standby Mode

 Based on the definition provided in IEC Standard 62301 CDV, DOE is 

proposing the following definition of standby mode.

• “Standby mode” means any product modes where the energy using product is 

connected to a mains power source and offers one or more of the following 

user oriented or protective functions which may persist for an indefinite time:

– To facilitate the activation of other modes (including activation or 

deactivation of active mode) by remote switch (including remote control), 

internal sensor, or timer;

– Continuous functions, including information or status displays (including 

clocks) or sensor-based functions.

• Additional clarification that a timer is a continuous clock function (which may 

or may not be associated with a display) that provides regular scheduled 

tasks (e.g., switching) and that operates on a continuous basis.
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Modes to be Incorporated

Definition of Modes – Standby Mode

 Delay start and cycle finished modes for clothes dryers and delay 

start and off-cycle modes for room air-conditioners would not be 

considered part of a standby mode.

• Not modes that persist for an indefinite time.

 These modes each represent a negligible portion (0.1 percent or 

less) of the annual energy use for each product.

• An integrated energy efficiency metric would not be measurably affected by 

either the inclusion or exclusion of the energy use in any of these modes.

• Benefit of incorporating these modes is outweighed by the burden on 

manufacturers to measure power consumption in each of these modes.

 DOE is not proposing to define delay start, cycle finished, and offcycle modes or to measure power consumption in these modes. 

• DOE is only proposing provisions for measuring energy consumption in the 

inactive and off mode.
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Modes to be Incorporated

Definition of Modes – Standby Mode

DOE invites comment on the proposed definition of “standby mode,” 

which is based on the definition in IEC Standard 62301 CDV. (Issue 

#2)

DOE invites comment on the establishment of inactive mode as the 

only standby mode for clothes dryers and room air conditioners and 

the determination that delay start mode, cycle finished mode, and offcycle mode would not be considered standby modes. DOE further 

invites comment on the proposed mode definitions and on the 

question of whether there are any modes consistent with the “active 

mode,” “standby mode,” or “off mode” definitions under the 

proposed definitions that have not been identified and that can 

represent significant energy use. (Issue #3 and #4)
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Modes to be Incorporated

Network Mode

 DOE received comments in response to the December 2008 TP 

NOPR to consider network mode.

 IEC Standard 62301 CDV defines network mode as follows.

• Network mode is a mode category which “includes any product modes where 

the energy using product is connected to a mains power source and at least 

one network function is activated (such as reactivation via network command 

or network integrity communication) but where the primary function is not 

active.”

 DOE is unaware of any clothes dryers or room air conditioners 

currently available on the market that incorporate a networking 

function. 

• Unaware of any data regarding network mode in these products to determine 

appropriate testing procedures for incorporation into the DOE test procedures 

for the these products. 

 For these reasons, the proposed amendments do not include 

network mode.
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Modes to be Incorporated

Network Mode – Request for Comment

DOE welcomes comment on whether clothes dryers and room air 

conditioners are currently available that incorporate a networking 

function and whether definitions and testing procedures for a 

network mode should be incorporated into the DOE test procedure. 

DOE also requests comment on appropriate methodologies for 

measuring energy consumption in a network mode, and data on the 

results and repeatability of such testing methodology. (Issue #5)
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Modes to be Incorporated

Definition of Modes – Off Mode

 DOE is proposing the following definition of off mode based upon 

the definition in IEC Standard 62301 CDV.

• “Off mode” means a mode which includes any product modes where the 

energy using product is connected to a mains power source and is not 

providing any standby mode or active mode function and where the mode 

may persist for an indefinite time. An indicator that only shows the user that 

the product is in the off position is included within the classification of off 

mode.
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Test Procedure Overview

1. Products Covered by the Test Procedure Changes

2. Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode Test Procedures

a. Incorporating by Reference IEC Standard 62301 for Measuring Standby Mode and Off Mode Power 

in Clothes Dryers and Room Air Conditioners

b. Determination of Modes to be Incorporated

c. Adding Specifications for the Test Methods and Measurements for Clothes Dryer and Room Air 

Conditioner Standby Mode and Off Mode Testing

d. Calculation of Energy Use Associated with Standby Modes and Off Mode

e. Measures of Energy Consumption
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Test Methods and Measurements

Specifications for Test Methods and Measurements –

Clothes Dryer Test Period

 Dryers may reduce power consumption by automatically dimming 

or powering down their displays after a period of user inactivity.

• Proposed in the December 2008 TP NOPR that the test be conducted after 

the power level has dropped to its low level.

 Section 5.3 of IEC Standard 62301 First Edition: 

• Stable power - requires waiting at least 5 minutes for the product to stabilize 

and then measuring the power at the end of an additional time period of not 

less than 5 minutes. 

• Unstable power - requires a measurement period of no less than 5 minutes, or 

one or more complete operating cycles of several minutes or hours.
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Test Methods and Measurements

Specifications for Test Methods and Measurements –

Clothes Dryer Test Period

 DOE received comments that the test procedures should specify a 

30-minute stabilization period and a measurement period at least 10 

minutes.

 Dryers may remain in the higher-power state for the duration of a 5-

minute stabilization period and 5-minute measurement period, then 

drop to the lower-power state more representative of inactive mode.

 IEC Standard 62301 CDV specifies a stabilization period of at least 

30 minutes prior to a measurement period of not less than 10 

minutes.

• Sufficient time for displays that automatically dim or power down to reach the 

lower-power state prior to measurement.

• Would allow for representative measurements among products that may have 

varying time periods before the power drops to a low level. 
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Test Methods and Measurements

Specifications for Test Methods and Measurements –

Clothes Dryer Test Period

 A test period of “not less than” or “at least” a specified amount of 

time may result in different test technicians testing the same 

product for different periods of time.

 To ensure that testing procedures for standby and off mode are 

clear and consistent, DOE is proposing to require that the 

stabilization period be 30 to 40 minutes, and the test period be 10 

minutes. 
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 Interested parties commented that the appliance should be 

configured at the factory or “default” settings prior to the initiation 

of the test measurements.

 DOE believes provisions for setting up the appliance should be 

specified in the test procedure.

• Setting up the appliance in accordance with manufacturer’s instructions or in 

the factory or “default” settings would allow manufacturers to ship appliances 

set in a low power mode that consumers may switch out of during typical 

standby or off mode use.

 DOE proposes that the appliance be set up in the settings that 

produce the highest power consumption level, consistent with the 

particular standby of off mode definition under test. 

• Provides a clear and consistent testing method.

Test Methods and Measurements

Specifications for Test Methods and Measurements –

Clothes Dryer Setup
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Test Methods and Measurements

Specifications for Test Methods and Measurements –

Room Air Conditioner Test Room Temperature

 DOE proposed in the December 2008 TP NOPR to require that test 

room temperature be maintained at 74 ± 2 °F, and that the 

temperature control setting be 79 °F.

 DOE received comments that the proposed room temperature would 

represent a testing burden.

 The test chamber ambient conditions proposed in the December 

2008 TP NOPR would be relevant only for off-cycle mode.

• If the test procedure is limited to measurement of a single standby mode and 

an off mode, the proposed close tolerance on ambient temperature would not 

be required.
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Test Methods and Measurements

 Because DOE is not proposing in the SNOPR to measure off-cycle 

mode, DOE is revising its proposal in the December 2008 TP NOPR 

to provide flexibility for the test room temperature for standby and 

off mode testing:

• Testing may be conducted in test facilities used for testing cooling 

performance. 

• If testing is not conducted in such a facility, the test facility shall comply with 

the test conditions in section 4.2 of IEC Standard 62301.

 Indoor temperature conditions required by the cooling performance 

test fall within the temperature range allowed by IEC Standard 

62301.

Specifications for Test Methods and Measurements –

Room Air Conditioner Test Room Temperature

DOE requests comment on the proposed room ambient temperature 

range for standby mode and off mode power measurements for room 

air conditioners and clothes dryers. (Issue #6)
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Test Methods and Measurements

 DOE received comments that the standby and off mode test 

procedures should specify a 30-minute stabilization period and a 

measurement period at least 10 minutes.

• DOE does not have any information/data suggesting that these stabilization 

and measurement periods would produce more representative or consistent 

measurements than the December 2008 TP NOPR proposed time periods. 

 To ensure testing procedures for standby and off mode are clear 

and consistent, DOE proposes to require that the stabilization 

period be 5 to 10 minutes, and the test period be 5 minutes.

Specifications for Test Methods and Measurements –

Room Air Conditioner Test Period
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Test Procedure Overview

1. Products Covered by the Test Procedure Changes

2. Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode Test Procedures

a. Incorporating by Reference IEC Standard 62301 for Measuring Standby Mode and Off Mode Power 

in Clothes Dryers and Room Air Conditioners

b. Determination of Modes to be Incorporated

c. Adding Specifications for the Test Methods and Measurements for Clothes Dryer and Room Air 

Conditioner Standby Mode and Off Mode Testing

d. Calculation of Energy Use Associated with Standby Modes and Off Mode

e. Measures of Energy Consumption
37 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Calculation of Energy Use

 Active mode energy use for clothes dryers is expressed in terms of 

total energy use per drying cycle.

 DOE determined that it is technically feasible to incorporate 

measures of standby and off mode energy use into the overall 

energy-use metric. 

 DOE examined standby and off mode energy consumption in terms 

of annual energy use apportioned on a per-cycle basis. 

Calculation of Energy Use – Clothes Dryers
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Calculation of Energy Use

 DOE proposed estimates of annual hours and approximate annual 

energy use for different modes in the December 2008 TP NOPR.

December 2008 TP NOPR Estimate of Annual Energy Use 

of Clothes Dryer Modes if All Modes are Possible

Mode Hours Typical (W) Annual Energy Use (kWh)

Active 140 6,907 967

Delay Start 34 3 0.1

Cycle Finished 429 3 1

Off and Inactive 8,157 0.5 to 3 4 to 24

 Based upon comments, DOE believes, under the proposed 

definitions of standby and off mode, this allocation of annual hours 

to inactive and off modes is appropriate.

 This SNOPR does not affect DOE’s proposal in the December 2008 

TP NOPR for this allocation of hours.
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Calculation of Energy Use

 DOE is not proposing amendments to measure delay start and cycle 

finished modes for clothes dryers.

• These modes each represent a negligible portion (0.1 percent or less) of the 

annual energy use. 

• More appropriate under a simplified approach to allocate the hours associated 

with delay start and cycle finished modes to off/inactive modes.

 DOE proposes to maintain the estimate of 8,620 non-active hours 

that would be allocated to inactive and off modes.

 SNOPR does not affect the December 2008 TP NOPR proposal for 

the allocation of hours between inactive and off mode.

• Allocate the hours entirely to either off mode or standby mode, as appropriate, 

if only one of these modes is possible.

• Allocate the hours equally if both modes are possible.

Calculation of Energy Use Associated with Standby 

Modes and Off Mode – Clothes Dryers
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Calculation of Energy Use

Calculation of Energy Use Associated with Standby 

Modes and Off Mode – Clothes Dryers

 DOE proposes to calculate clothes dryer energy use per cycle 

associated with standby and off modes by: 

1. Calculating the product of wattage and allocated hours for all possible standby 

and off modes

2. Summing the results

3. Dividing the sum by 1,000 to convert from Wh to kWh

4. Dividing by 283* cycles per year

*Revised number of dryer cycles per year part of the proposed amendments to active mode test procedure.

DOE seeks comment on the approach for determining total energy 

use for standby mode and off mode for clothes dryers, including its 

accuracy and test burden. DOE also invites comment and requests 

data on the estimates for annual hours associated with each mode, 

including the 140 hours specified by the current test procedure for 

active mode (drying). (Issue #7)
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Calculation of Energy Use

 For the December 2008 TP NOPR, DOE estimated the annual hours 

for standby and off modes and the relative magnitudes of annual 

energy use in standby and off modes in an example for a 

representative 8,000 Btu/hour, 9 EER unit.

Mode Hours Typical (W) Annual Energy Use (kWh)

Active Cooling 750 889 667

Delay Start 90 2 0.2

Off-Cycle 440 2 0.9

Off/Inactive 4,850 0.5 to 4 2.5 to 10

December 2008 TP NOPR Estimate of Annual Hours for 

Off/Inactive Modes – Room Air Conditioners
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Calculation of Energy Use

 DOE is not proposing amendments to the room air conditioner test 

procedure to measure delay start and off-cycle power consumption. 

• These modes each represent a negligible portion (0.1 percent or less) of the 

annual energy use. 

• More appropriate under a simplified approach to allocate the hours associated 

with delay start and off-cycle modes to off/inactive modes.

 DOE proposes the estimate of 5,115 hours as the non-active hours 

that would be allocated to inactive and off modes for room air 

conditioners.

 SNOPR does not affect the December 2008 TP NOPR proposal for 

the allocation of hours between inactive mode and off mode.

• Allocate the hours entirely to either off mode or standby mode, as appropriate, 

if only one of these modes is possible.

• Allocate the hours equally if both modes are possible.

Calculation of Energy Use Associated with Standby 

Modes and Off Mode – Room Air Conditioners
43 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Calculation of Energy Use

Calculation of Energy Use Associated with Standby 

Modes and Off Mode – Room Air Conditioners

 DOE continues to propose to calculate room air conditioner annual 

energy use associated with standby and off modes by: 

1. Calculating the products of wattage and allocated hours for all possible 

standby and off modes

2. Summing the results

3. Dividing the sum by 1,000 to convert from Wh to kWh

DOE seeks comment on the approach for determining total energy 

use for standby mode and off mode for room air conditioners, 

including its accuracy and test burden. DOE also invites comment 

and requests data on the estimates for annual hours associated with 

each mode, including the estimate of “unplugged” time. (Issue #8)
44 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure Overview

1. Products Covered by the Test Procedure Changes

2. Clothes Dryer and Room Air Conditioner Standby Mode and Off Mode Test Procedures

a. Incorporating by Reference IEC Standard 62301 for Measuring Standby Mode and Off Mode Power 

in Clothes Dryers and Room Air Conditioners

b. Determination of Modes to be Incorporated

c. Adding Specifications for the Test Methods and Measurements for Clothes Dryer and Room Air 

Conditioner Standby Mode and Off Mode Testing

d. Calculation of Energy Use Associated with Standby Modes and Off Mode

e. Measures of Energy Consumption
45 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Measures of Energy Consumption

Measures of Energy Consumption

 DOE proposed the following combined metrics addressing active, 

standby, and off modes for clothes dryers and room air conditioners 

in the December 2008 TP NOPR.

 Clothes Dryers: 

• “Per-cycle integrated total energy consumption expressed in kWh”

• “Integrated energy factor” (IEF)

 Room Air Conditioners:

• “Integrated annual energy consumption”

• “Integrated energy efficiency ratio” (IEER)

 This proposal from the December 2008 TP NOPR for the integrated 

metrics is not affected by the SNOPR. 
46 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure Overview

3. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures

a. Automatic Cycle Termination for Clothes Dryers

b. Test Procedure for Vent-less Clothes Dryers

c. Detergent Specifications for Clothes Dryer Test Cloth Preconditioning

d. Changes to Reflect Current Usage Patterns and Capabilities

e. Room Air Conditioner Referenced Test Procedures

f. Clothes Dryer Referenced Test Procedure

g. Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy 

Consumption

h. Clarification of the Gas Supply Test Conditions for Gas Clothes Dryers

4. Compliance with Other EPCA Requirements

5. Effects of Test Procedure Revisions on Compliance with Standards
47 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Automatic Cycle Termination for 

Clothes Dryers

Automatic Cycle Termination for Clothes Dryers

 The current DOE clothes dryer test procedure may not adequately 

measure the benefits of automatic cycle termination.

 Current DOE test procedure provides a single credit for enhanced 

performance of clothes dryers equipped with automatic termination.

• Defined by a Field Use (FU) scaling factor applied to the per-cycle drying 

energy consumption. 

• Time termination control dryer FU factor equals 1.18, while automatic 

termination control dryer FU factor equals 1.04 (12 percent credit).

• Does not distinguish between the type of sensing control system and the 

sophistication and accuracy of the control system.
48 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Automatic Cycle Termination for 

Clothes Dryers

Industry and International Clothes Dryers Test Standards

 DOE reviewed industry and international clothes dryer test 

standards for testing procedures for evaluating automatic 

termination control clothes dryers. 

• AHAM HLD-1-2009, “Household Tumble Type Clothes Dryers”

• European Standard EN 61121, “Tumble dryers for household use – Methods 

for measuring the performance” (Edition 3 2005)

• Australia/New Zealand Standard 2442

– AS/NZS Standard 2442.1: 1996, “Performance of household electrical appliances –

Rotary clothes dryers, Part 1: Energy consumption and performance”

– AS/NZS Standard 2442.2: 2000, “Performance of household electrical appliances –

Rotary clothes dryers, Part 2: Energy labelling requirements”

 AHAM HLD-1-2009 and EN Standard 61121 do not provide 

representative comparisons of energy consumption between timer 

dryers and automatic cycle termination dryers.
49 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Automatic Cycle Termination for 

Clothes Dryers

Automatic Cycle Termination for Clothes Dryers - AS/NZS 

Standard 2442

 AS/NZS Standard 2442 Testing Procedures:

• Accounts for the amount of over-drying associated with automatic termination 

control dryers beyond a specified RMC.

– Effectively takes into consideration the accuracy of different automatic termination 

sensor technologies.

• Provides an accurate and representative method for comparing the energy 

consumption between timer dryers and automatic termination control dryers.

 DOE proposes to incorporate the test procedures for timer dryers 

and automatic termination control dryers based on provisions in 

AS/NZS Standard 2442 with modifications as appropriate for the 

DOE test procedure.
50 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Automatic Cycle Termination for 

Clothes Dryers

Automatic Cycle Termination – Dryer Type Definitions

 DOE proposes the following definitions based on the definitions 

provided in AS/NZS Standard 2442.1.

• “Timer dryer” is a dryer which can be preset to carry out at least one 

sequence of operations to be terminated by a timer, but may also be manually 

controlled.

• “Automatic termination control dryer” is a dryer which can be preset to carry 

out at least one sequence of operations to be terminated by means of a 

system assessing, directly or indirectly, the moisture content of the load. An 

automatic termination control dryer with supplementary timer shall be tested 

as an automatic termination control dryer.

 Definitions are very similar to the definitions in EN Standard 61121.
51 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Automatic Cycle Termination for 

Clothes Dryers

Automatic Cycle Termination – Test Load Preparation

 DOE proposes to add the following test load preparation 

requirements based on the methods in AS/NZS 2442.1: 

• Require that the moisture content of the test load be between 42 and 47* 

percent of the bone-dry weight of the test load, serving as an initial 

preparation step prior to the final mass adjustments.

• Make a final mass adjustments, such that the moisture content is 47 percent ±

0.33 percent by adding water uniformly to the load in a very fine spray.

– The ± 0.33 percent allowable RMC range was determined based upon the allowable 

range specified in AS/NZS Standard 2442.1 (190 percent ± 0.02 kg of the bone dry 

weight). 

*As discussed later, proposing to change the initial RMC from 70 percent to 47 percent

 Improves the repeatability and helps to reduce the variation from 

test to test.

 Allows for a more representative comparison between timer dryers 

and automatic cycle termination dryers.
52 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Automatic Cycle Termination for 

Clothes Dryers

Water Temperature for Dryer Test Load Preparation

 Section 2.7 of the current DOE test procedure (test load preparation) 

requires that the test load be agitated in 100° ± 5 °F water. 

 DOE recognizes that some clothes washers may use a default cold 

rinse cycle at the end of the wash cycle.

• Current DOE clothes washer test procedure specifies a cold rinse 

temperature of 60° ± 5 °F.

• DOE does not have data indicating whether a different water temperature for 

dryer test load preparation would be more representative of current consumer 

usage habits.

 DOE is not proposing any changes to the water temperature for 

clothes dryer load preparation at this time.

• If consumer usage data is made available indicating that a 60° ± 5 °F water 

temperature is more representative of consumer usage, DOE may adopt an 

alternate approach specifying this water temperature for test load preparation. 
53 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Automatic Cycle Termination for 

Clothes Dryers

Water Temperature for Dryer Test Load Preparation –

Request for Comment

DOE invites comment on whether the existing water temperature of 

100° ± 5 °F for test load preparation in the existing test procedure is 

representative of consumer usage habits, and, if not, what would be a 

representative value. DOE also requests data quantifying how 

changes to the water temperature for clothes dryer test load 

preparation would affect the measured efficiency as compared to the 

existing DOE test procedure, in particular for those units that are 

minimally compliant with current energy conservation standards. 

(Issue #10)
54 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Automatic Cycle Termination for 

Clothes Dryers

Automatic Cycle Termination – Test Cycle

 DOE also proposes to include the following testing procedures in 

section 3.3, “Test cycle,” of the DOE test procedure specific to each 

type of dryer, based on the test methods provided in AS/NZS 2442.1. 

 Timer dryers:

• The clothes dryer shall be operated at the maximum temperature setting and, 

if equipped with a timer, at the maximum time setting. 

• The load shall be dried to 5–6 percent RMC without the dryer advancing into 

cool down, resetting the timer if necessary. 

• The procedure would then be repeated until the RMC of the test load is 4–5 

percent.
55 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Automatic Cycle Termination for 

Clothes Dryers

Automatic Cycle Termination – Test Cycle

 Automatic Termination Control Dryers:

• A “normal” program shall be selected for the test cycle to be most 

representative of consumer usage. 

• Where the drying temperature can be chosen independently of the program, it 

shall be set to the maximum. 

• When the heater switches off for the final time at the end of the drying cycle 

(immediately before the cool-down period begins), the dryer shall be stopped. 

• If the final RMC is greater than 5 percent, the tests shall be invalid and a new 

run shall be conducted using the highest dryness level setting. Any test cycle 

in which the final RMC is 5 percent or less shall be considered valid.

• The cycle setting selected for the test shall be recorded.
56 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Automatic Cycle Termination for 

Clothes Dryers

Automatic Cycle Termination Test Cycle – Cool-Down

 At least two ways to terminate the drying cycle during the test:

• Termination before cool-down.

– AS/NZS Standard 2442.1

– AHAM HLD-1-2009

• Termination at the end of the selected test cycle.

– EN Standard 61121

 DOE proposes for the SNOPR that the test cycle for automatic 

termination control dryers does not include the cool-down phase.

• Based on AS/NZS Standard 2442 because it provides a more representative 

comparison of energy consumption between timer dryers and automatic 

termination control dryers.

• Harmonizes DOE test methods with industry and international test standards.
57 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Automatic Cycle Termination for 

Clothes Dryers

Automatic Cycle Termination Test Cycle – Cool-Down

 DOE is considering the alternative method of EN Standard 61121 

because it may provide incentives for energy-saving improvements.

• Residual heat during the cool-down period may be used to continue drying 

clothes while slowly spinning the drum to achieve a desired RMC.

• Such potential for energy efficiency improvement would not be captured by 

the test methods DOE is proposing for the SNOPR.

 DOE may adopt an alternate approach to include the measurement 

of the cool-down period as part of the proposed automatic cycle 

termination test methodology. 

DOE welcomes comment on whether the cool-down period should be 

included as part of the active mode test cycle for automatic 

termination control dryers. In addition, DOE also welcomes data 

quantifying how including the cool-down period in the test cycle 

would affect the measured efficiency of clothes dryers as compared 

to the existing DOE test procedure, in particular for those units that 

are minimally compliant with current energy conservation standards. 

(Issue #12)
58 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Automatic Cycle Termination for 

Clothes Dryers

Automatic Cycle Termination – Calculations of Results

 DOE proposes the following amendments to the calculations of 

derived results from test measurements in the DOE test procedure.

 For timer dryers, DOE proposes to use the results from the 

proposed tests cycles to interpolate the per-cycle energy 

consumption required to dry the test load to exactly 5-percent RMC.

• DOE is unaware of any data that would indicate the 1.18 FU factor credit for 

timer dryers is inaccurate and not currently representative of consumer usage 

habits. 

• DOE does not intend to revise the 1.18 FU factor for timer dryers at this time.
59 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Automatic Cycle Termination for 

Clothes Dryers

Automatic Cycle Termination – Calculations of Results

 For automatic termination control dryers, DOE proposes to revise 

the FU factor credits to more appropriately account for over-drying 

energy consumption.

• Automatic termination control clothes dryer FU factor would equal 1.0. Any 

over-drying energy consumption would be included in the per-cycle energy 

consumption, resulting in a reduction in measured EF. 

• An automatic termination control dryer that is able to dry the test load to 

exactly 5-percent RMC (eliminating over-drying) would result in a higher 

measured efficiency than if it over-dried the test load to an RMC less than 5 

percent. 

 DOE estimated, based on limited testing, that baseline dryers would 

possibly over-dry the test load to below 5-percent RMC such that 

the energy consumption and measured EF would be equivalent to 

that measured by the existing DOE test procedure.

• No changes to the current energy conservation standards would be 

warranted.
60 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Automatic Cycle Termination for 

Clothes Dryers

Automatic Cycle Termination – Request for Comment

DOE invites comment on the adequacy of AS/NZS Standard 2442, 

along with proposed definitions and clarifications, to measure energy 

consumption for timer and automatic termination control clothes 

dryers to account for over-drying energy consumption. 

DOE invites comments on whether the proposed FU factor credits for 

timer and automatic termination control dryers, along with the 

revised calculations for per-cycle energy consumption, are 

appropriate. 

DOE welcomes comment on whether a final RMC of 5 percent is 

appropriate, and, if not, what a representative final RMC would be. 

DOE also welcomes data from dryers tested according to the 

proposed test procedure, in particular for units which minimally 

comply with current energy conservation standards, as well as data 

showing whether one sensor technology is more accurate, and 

reduces over-drying, than another. (Issue #9)
61 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Automatic Cycle Termination for 

Clothes Dryers

Cycles and Settings for Timer Dryer and Automatic 

Termination Control Dryer Testing – Request for Comment

DOE invites comment on whether using the maximum temperature 

setting for timer dryers is representative of current consumer usage 

habits. 

DOE also invites comment on whether the proposed cycles and 

settings for the automatic termination control dryer tests are 

representative of current consumer usage habits. 

DOE requests comment on whether multiple cycles and settings 

should be tested and how the results from those multiple tests 

should be evaluated, and if so, how testing multiple cycles and 

settings would affect the measured efficiency as compared to the 

existing DOE clothes dryer test procedure.. (Issue #11)
62 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure Overview

3. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures

a. Automatic Cycle Termination for Clothes Dryers

b. Test Procedure for Vent-less Clothes Dryers

c. Detergent Specifications for Clothes Dryer Test Cloth Preconditioning

d. Changes to Reflect Current Usage Patterns and Capabilities

e. Room Air Conditioner Referenced Test Procedures

f. Clothes Dryer Referenced Test Procedure

g. Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy 

Consumption

h. Clarification of the Gas Supply Test Conditions for Gas Clothes Dryers

4. Compliance with Other EPCA Requirements

5. Effects of Test Procedure Revisions on Compliance with Standards
63 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure for Vent-less Clothes 

Dryers

Vent-less Clothes Dryers

 Manufacturers of vent-less clothes dryers commented that the 

current DOE test procedure is unable to test this type of dryer.

• Current DOE test procedure requires an exhaust restrictor to simulate 

backpressure effects of a vent tube in an installed condition.

 Vent-less clothes dryers do not vent exhaust air to the outside as a 

conventional dryer does.
64 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure for Vent-less Clothes 

Dryers

Alternate Test Procedure for Vent-less Clothes Dryers 

Presented in LG Petition for Waiver

 DOE presented an alternate test procedure for vent-less dryers in 

the Petition for Waiver and Denial of the Application for Interim 

Waiver of LG Electronics from the DOE Clothes Dryer Test 

Procedure. 71 FR 49437 (August 23, 2006).

• Added separate definitions for a “conventional clothes dryer” and a 

“condensing clothes dryer.”

• Qualified the requirement for an exhaust simulator for only conventional 

clothes dryers.

 DOE conducted limited tests of vent-less clothes dryers according 

to the alternate test procedure.

• Results show less than 2 percent variation in measured EF from test to test.

• Based on this limited testing, the alternate testing procedures appear to 

produce repeatable results.
65 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure for Vent-less Clothes 

Dryers

Vent-less Clothes Dryer Test Standards

 DOE investigated test standards used internationally. 

• EN Standard 61121

• AS/NZS Standard 2442

 Whirlpool submitted comments providing amendments to the DOE 

test procedure to include methods for testing condensing dryers.

• Largely based on EN Standard 61121. 

 EN Standard 61121 includes relevant test procedures for 

condensing (vent-less) clothes dryers.
66 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure for Vent-less Clothes 

Dryers

Test Procedure for Vent-less Clothes Dryers – Dryer Type 

Definitions

 Based on the definitions in the LG Petition for Waiver, EN Standard 

61121, AS/NZS Standard 2442, and Whirlpool’s proposed 

amendments, DOE proposes the following definitions:

• “Conventional clothes dryer” is “a clothes dryer that exhausts the evaporated 

moisture from the cabinet.”

• “Vent-less clothes dryer” is “a clothes dryer that uses a closed-loop system 

with an internal condenser to remove the evaporated moisture from the 

heated air. The moist air is not discharged from the cabinet.”
67 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure for Vent-less Clothes 

Dryers

Test Procedure for Vent-less Clothes Dryers – Installation 

Conditions

 Based on the LG Petition for Waiver, the test standards, and 

Whirlpool’s proposed amendments, DOE proposes to amend the 

installation conditions in its test procedure to qualify the 

requirement for an exhaust simulator to only apply to conventional 

clothes dryers.

• Additional proposed clarifications: 

– Vent-less dryers shall be tested without the exhaust simulator installed. 

– If a dryer is designed to operate with an optional exhaust duct, the dryer shall be 

tested without the duct installed. 

 Provides additional clarity and covers all possible clothes dryer 

configurations 

 Provides harmonization with international test standards. 
68 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure for Vent-less Clothes 

Dryers

 DOE proposes the following requirements regarding a condensation 

box based on provisions in EN Standard 61121 to provide additional 

clarity to cover all possible configurations:

• Section 2.1, “Installation” – “If a manufacturer gives the option to use a ventless dryer with or without a condensation box, the dryer shall be tested with 

the condensation box installed.”

• Section 3.3, “Test cycle” – “If the dryer automatically stops during a cycle and 

the reason is that the condensation box is full of water, the test is stopped, 

and the test run is invalid” to ensure consistency of the measured efficiency.

 Based on Whirlpool’s proposal, DOE proposes to add the 

requirement that “the condenser unit of the dryer must remain in 

place and not be taken out of the dryer for any reason between 

tests.”

• Provides additional clarification and ensures that all manufacturers are testing 

products under the same conditions. 

Test Procedure for Vent-less Clothes Dryers – Installation 

Conditions
69 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure for Vent-less Clothes 

Dryers

Test Procedure for Vent-less Clothes Dryers – Preconditioning 

 Section 2.8 of the current DOE test procedure, “Clothes dryer 

preconditioning,” states:

• Before any test cycle is initiated, the dryer must be operated without a test 

load in non-heat mode for 15 minutes or until the discharge air temperature 

varies less than 1 °F during a period of 10 minutes, whichever is longer.

 Vent-less clothes dryers do not have discharge air.

 Based on EN Standard 61121, DOE proposes the following for ventless dryer preconditioning:

• The steady-state temperature must be equal to ambient room temperature 

before the start of all test runs with an additional note that this can be done by 

leaving the machine at ambient room conditions for at least 12 hours but not 

more than 36 hours between tests.

 DOE proposes to add a qualification to the existing pre-conditioning 

procedure that it applies only to vented clothes dryers.
70 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure for Vent-less Clothes 

Dryers

Test Procedure for Vent-less Clothes Dryers – Test Cycle 

 DOE proposes, based on EN Standard 61121 and Whirlpool’s 

proposal, to specify in section 3.3, “Test cycle,” of the DOE test 

procedure the following for vent-less dryers:

• The first cycle after a period of non-operation longer than 36 hours shall not 

be used for evaluation, and that, between test cycles, the door of the tumble 

dryer shall be closed except for loading (and unloading).

 These provisions will maintain a clear and repeatable testing 

procedure and produce accurate and representative results.

 EN Standard 61121 requires that at least five valid test cycles be 

performed and the results averaged.

• DOE clothes dryer test procedure does not specify multiple test cycles to 

obtain the representative EF.

• DOE is not aware of data suggesting that test-to-test variation is sufficient to 

warrant a requirement for more than one test cycle.

• DOE is not proposing amendments to the number of valid test cycles.
71 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure for Vent-less Clothes 

Dryers

Test Procedure for Vent-less Clothes Dryers – Request for 

Comment

DOE invites comment on the adequacy of proposed definitions and 

installation conditions for vent-less clothes dryers, which are based 

upon the alternate test procedure presented in the LG Petition for 

Waiver. DOE further invites comment on the proposed additional 

clarifications to the installation conditions, condensation boxes, 

dryer preconditioning, and testing conditions based on EN Standard 

61121 and Whirlpool’s proposed amendments. (Issue #13)

DOE also invites comment and data suggesting that test-to-test 

variation is sufficient to warrant a requirement for more than one 

clothes dryer test cycle. (Issue #14)
72 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure for Vent-less Clothes 

Dryers

Test Procedure for Vent-less Clothes Dryers – Water 

Consumption 

 DOE investigated water consumption of vent-less clothes dryers.

• Only vent-less combo washer/dryers use water to condense moisture in the 

air exiting the drum for products on the U.S. market.

 DOE measured the water consumed by a vent-less combo 

washer/dryer.

• Combination washer/dryer consumed on average 3.25 gallons of cold water.

• Combo washer/dryers represent a very small niche of the U.S. dryer market. 

• DOE believes that the benefit of measuring water use for vent-less dryers is 

outweighed by the burden on manufacturers.

 DOE is not proposing to include a requirement to measure the water 

consumption for vent-less condensing clothes dryers.

DOE requests comment and data on the water consumption of ventless clothes dryers and whether measurement of water consumption 

should be included in the DOE test procedure. (Issue #13)
73 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure Overview

3. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures

a. Automatic Cycle Termination for Clothes Dryers

b. Test Procedure for Vent-less Clothes Dryers

c. Detergent Specifications for Clothes Dryer Test Cloth Preconditioning

d. Changes to Reflect Current Usage Patterns and Capabilities

e. Room Air Conditioner Referenced Test Procedures

f. Clothes Dryer Referenced Test Procedure

g. Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy 

Consumption

h. Clarification of the Gas Supply Test Conditions for Gas Clothes Dryers

4. Compliance with Other EPCA Requirements

5. Effects of Test Procedure Revisions on Compliance with Standards
74 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Clothes Dryer Test Cloth 

Preconditioning 

Detergent Specifications for Clothes Dryer Test Cloth 

Preconditioning

 The DOE test procedure specifies that the test cloth be 

preconditioned using AHAM Standard Test Detergent IIA.

• This detergent is obsolete and no longer supplied by AHAM or other suppliers. 

• The current AHAM standard detergent is AHAM standard test detergent 

Formula 3.

 DOE proposes to amend the test procedure to specify the use of 

AHAM detergent Formula 3 for preconditioning.

 AHAM’s clothes dryer test standard, AHAM HLD-1-2009, specifies a 

standard test detergent Formula 3 dosage of 27 g + 4.0 g/lb of base 

test load for test cloth pre-treatment. 

• DOE is proposing to amend the test load size for standard-size clothes dryers 

to 8.45 lb ±.085 lb. 

– Detergent dosage for AHAM standard test detergent Formula 3 of 60.8 g.
75 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Clothes Dryer Test Cloth 

Preconditioning 

Detergent Dosage

 DOE believes the detergent concentration should be set by the 

pounds of test cloth in this standard-size test load. 

• This load is more closely matched to the maximum water fill level than is the 

compact-size test load.

 DOE is proposing to require 60.8 g of AHAM standard test detergent 

Formula 3 for test cloth preconditioning.

DOE invites comment on the proposed revisions to the detergent 

formulation and dosage specifications, requiring 60.8g of AHAM 

standard test detergent Formula 3 for clothes dryer test cloth 

preconditioning. DOE also welcomes data showing the effects of 

changing the detergent specifications for test cloth preconditioning 

on the measured EF for clothes dryers. (Issue #15)
76 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure Overview

3. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures

a. Automatic Cycle Termination for Clothes Dryers

b. Test Procedure for Vent-less Clothes Dryers

c. Detergent Specifications for Clothes Dryer Test Cloth Preconditioning

d. Changes to Reflect Current Usage Patterns and Capabilities

e. Room Air Conditioner Referenced Test Procedures

f. Clothes Dryer Referenced Test Procedure

g. Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy 

Consumption

h. Clarification of the Gas Supply Test Conditions for Gas Clothes Dryers

4. Compliance with Other EPCA Requirements

5. Effects of Test Procedure Revisions on Compliance with Standards
77 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Clothes Dryer Number of Annual Cycles

 The average number of dryer use cycles assumed in the revised 

DOE clothes washer test procedure is inconsistent with the use 

cycles in the clothes dryer test procedure.

• Clothes washer test procedure specifies 392 annual washer use cycles and 

assumes that 84 percent of all washer loads are dried in dryers (329 dryer 

cycles per year).

• Current clothes dryer test procedure assumes 416 dryer cycles per year. 

 2004 California Statewide Residential Appliance Saturation Study 

(RASS) surveyed clothes dryer usage patterns. 

• For the 6,790 households that said they owned a clothes dryer, average 

usage was 4.69 loads per week, or approximately 244 loads per year. 

• Study provides only a limited dataset. 
78 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Clothes Dryer Number of Annual Cycles – 2005 RECS

 DOE reviewed data from the Energy Information Administration 

(EIA)’s 2005 Residential Energy Consumption Survey (RECS). 

• National sample survey of housing units. 

• For each sample home, RECS provides data on the number of laundry loads 

(washer cycles) washed per week and the frequency of clothes dryer use. 

• Using the RECS data, DOE estimated the average usage to be 283 cycles 

per year. 

 Based on 2005 RECS data, DOE proposes to amend the number of 

annual use cycles in its test procedure to 283 cycles per year.

DOE seeks comment on the proposed amendment to change the 

number of clothes dryer annual use cycles to 283 cycles for all 

product classes of clothes dryers based upon data from the 2005 

RECS. (Issue #16)
79 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Clothes Dryer Initial Remaining Moisture Content

 RMC is the ratio of the weight of water contained by the test load at 

the completion of the clothes washer energy test cycle to the bonedry weight of the test load, expressed as a percent. 

• The current DOE clothes dryer test procedure specifies an initial RMC of 70 ±

3.5 percent.

 Since the clothes dryer test procedure was established in 1981, 

average clothes washer RMC has decreased due to the introduction 

of higher efficiency models with higher final spin speeds.

• For the residential clothes washer standard which became effective January 

1, 2007 (1.26 MEF), DOE estimated a weighted-average RMC of 56 percent.
80 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Clothes Dryer Initial Remaining Moisture Content

 DOE estimated the RMC of clothes washers using a distribution of 

values for models listed in the December 2008 CEC product 

database. 

• RMC values ranged from 30 percent to 61 percent, with an average of 46 

percent. 

 AHAM provided data showing the shipments of residential clothes 

washers for which RMC was reported, along with shipmentweighted RMC
81 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

AHAM Data Submittal – Shipment-Weighted Average RMC 

for Residential Clothes Washers 

* Data contains only shipments for which the RMC was reported.

46

47

48

49

50

51

52

53

54

55

2000 2001 2002 2003 2004 2005 2006 2007 2008

Shipment-Weighted RMC (%)

Year
82 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Clothes Dryer Initial Remaining Moisture Content

 Based on review of the CEC product database and AHAM data, DOE 

believes that an initial RMC of 47 percent is representative of 

current residential clothes dryer initial test load characteristics. 

 DOE proposes to amend the clothes dryer test procedure to require 

that the initial RMC be changed from 70 percent to 47 percent.

 DOE estimated, based on internal testing, a 41-percent increase in 

EF from switching from 70-percent to 47-percent initial RMC. 

• DOE will consider addressing this change in the concurrent standards 

rulemaking for residential clothes dryers. 
83 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Clothes Dryer Initial Remaining Moisture Content –

Request for Comment

DOE seeks comment on the proposed amendments to the DOE clothes 

dryer test procedure to change the initial RMC to 47 percent to reflect 

current consumer usage habits, based on the trends of the shipmentweighted average RMC of clothes washers shown in data submitted by 

AHAM. DOE further welcomes comment and data indicating an 

appropriate initial RMC and how that initial RMC would affect the 

measured EF of clothes dryers, in particular units that are minimally 

compliant with current energy conservation standards. (Issue #17)
84 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Clothes Dryer Test Load Weight

 Section 2.7, “Test loads,” of the current DOE clothes dryer test 

procedure requires:

• 7.00 lb ± .07 lb test load for standard-size dryers. 

• 3.00 lb ± .03 lb test load for compact-size dryers.

 In response to comments on the October 2007 Framework 

Document, DOE investigated whether the average test load weight 

for standard-capacity dryers is consistent with the current 

generation of washer capacities. 
85 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Clothes Dryer Test Load Weight

 Procter and Gamble conducted an internal study (2003) on 

household laundry habits on a representative set of the U.S. 

population.

• The clothes washer load weight data:

– Sample size of 3367 loads of laundry from a total of 510 respondents, 

– Average load size for top- and front-loading clothes washers was 7.2 lb and 8.4 lb, 

respectively. 

• DOE estimated, using AHAM data, the shipment-weighted average load size 

for all clothes washers to be approximately 7.5 lbs.

• Clothes washer capacities were likely to have increased since the survey was 

conducted in 2003.
86 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

AHAM Trends in Energy Efficiency 2008 Data on Tub 

Volume for Residential Clothes Washers

2

2.2

2.4

2.6

2.8

3

3.2

3.4

1980 1985 1990 1995 2000 2005 2010

Shipment-Weighted Average Tub 

Volume (cu. ft.)

Year

 The shipment-weighted average tub volume increased from 2.52 ft3

in 1981 to 3.22 ft3 in 2008 (22.4% increase).
87 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

DOE Clothes Washer Test Load Size Requirements (Table 

5.1 of 10 CFR 430 Subpart B, Appendix J1)

 Average load size in the washer test procedure increases by 21 

percent based on the increase in capacity shown in the AHAM Data.

• DOE believes this proportionally impacts clothes dryer load sizes. 

 Applying this ratio to the clothes dryer test load size would result in 

an increase from 7.00 lb to 8.45 lb for standard-size dryers.

Container 

Volume (ft3)

Minimum 

Load (lb)

Maximum 

Load (lb)

Average Load 

(lb)

≥2.50 to <2.60 3.00 10.50 6.75

≥3.20 to <3.30 3.00 13.30 8.15
88 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Clothes Dryer Test Load Weight

 Based on this data, DOE proposes to amend the clothes dryer test 

load size to 8.45 lb ± .085 lb for standard-size dryers. 

 DOE believes most compact-size dryers are used in conjunction 

with compact-size washers.

• DOE does not have any information to suggest that the tub volume of such 

clothes washers has changed significantly. 

• DOE is not proposing to change the 3-lb test load size currently specified in 

the test procedure for compact clothes dryers.
89 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Clothes Dryer Test Load Weight – Effects on Measured EF

 Based on testing results in a National Institute of Standards and 

Technology (NIST) report, DOE estimated the percentage change in 

EF for an 8.45-lb test load by linearly interpolating the results for 7-

lb and 9-lb tests. 

 Using this method, the EF would increase by about 3.8 percent 

when increasing the test load size from 7 lb to 8.45 lb. 

DOE seeks comment on the proposed amendments to the DOE 

clothes dryer test procedure to change the clothes dryer test load 

size to 8.45 lb ± .085 lb for standard-size dryers. DOE also welcomes 

data on clothes washer and clothes dryer test load sizes 

representative of current consumer usage habits for both compactsize and standard-size units. DOE further requests data on how any 

changes in test load size would affect the measured EF of clothes 

dryers, in particular units that are minimally compliant with current 

energy conservation standards. (Issue #18)
90 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Room Air Conditioner Annual Operating Hours

 DOE test procedure currently assumes room air conditioners have 

an average annual use of 750 hours.

• DOE’s technical support document from September 1997 (most recent room 

air conditioner standards rulemaking) showed closer to 500 hours for the 

average annual operational hours.

 DOE’s investigation of usage pattern data revealed a lack of 

metered and survey data for the operating hours of individual room 

air conditioners. 

 DOE found two sources of survey data:

• The CEC California Statewide RASS survey contained only aggregated 

residential data, which limited any analysis pertaining to the annual operating 

hours. Its regional scope also limited the relevance of the data. 

• EIA’s 2005 RECS provides extensive data on individual residences and a 

more expansive and representative sample of households. 
91 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Room Air Conditioner Annual Operating Hours – EIA’s 

2005 RECS

 Using 2005 RECS data, DOE developed a household sample for the 

annual hours of use of a room air conditioner, which was used to 

calculate a weighted national average of usage hours.

• The data in the 2005 RECS indicates that the estimated average annual 

usage is 810 hours. 

 DOE does not consider the increase of 60 hours to be significant.

• Does not exceed the uncertainty level associated with the RECS-based 

approach for estimation of this value. 

 DOE is not proposing a change at this time in the annual operating 

hours used in the test procedure.

DOE seeks comment on the determination that the 750 annual 

operating hours specified by the current DOE test procedure for 

room air conditioners is still representative based upon data from the 

2005 RECS. (Issue #19)
92 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Room Air Conditioner Part-Load Performance

 DOE room air conditioner test procedure measures full-load 

performance. 

• Not able to assess energy savings associated with technologies which 

improve part-load performance. 

 DOE does not plan to consider amendments to measure part-load 

performance.

• Widespread use of part-load technology in room air conditioners would 

probably not occur because of the development of a part-load metric.

• The significant effort of development of an accurate part-load metric is not 

likely to be warranted by the expected minimal energy savings.
93 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Room Air Conditioner Ambient Test Conditions

 DOE considered whether the ambient test conditions in its room air 

conditioner test procedure are representative of typical 

installations.

• DOE received comments that the ambient temperature should be increased 

from 95°F to 115°F. 

• DOE did not receive further information to support the specification of the 

higher temperature.

 DOE is not considering amendments to the ambient test conditions 

at this time.

DOE invites comment and data indicating representative ambient test 

conditions for the DOE room air conditioner test procedure. DOE 

further requests data showing how any changes to the ambient 

conditions would affect the measured EER of room air conditioners, 

in particular units that are minimally compliant with current energy 

conservation standards. (Issue #20)
94 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure Overview

3. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures

a. Automatic Cycle Termination for Clothes Dryers

b. Test Procedure for Vent-less Clothes Dryers

c. Detergent Specifications for Clothes Dryer Test Cloth Preconditioning

d. Changes to Reflect Current Usage Patterns and Capabilities

e. Room Air Conditioner Referenced Test Procedures

f. Clothes Dryer Referenced Test Procedure

g. Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy 

Consumption

h. Clarification of the Gas Supply Test Conditions for Gas Clothes Dryers

4. Compliance with Other EPCA Requirements

5. Effects of Test Procedure Revisions on Compliance with Standards
95 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Referenced Test Procedures

Room Air Conditioner Referenced Test Procedures

 The room air conditioner test procedure cites two test standards:

• American National Standard (ANS) (since renamed American National 

Standards Institute (ANSI)) Z234.1-1972, “Room Air Conditioners;” and 

• American Society of Heating, Refrigerating, and Air-Conditioning Engineers 

(ASHRAE) Standard 16-69, “Method of Testing for Rating Room Air 

Conditioners.”

 Both the ANSI and ASHRAE standards have been updated since 

DOE last revised its room air conditioner test procedure. 

 Current standards:

• ANSI/AHAM RAC-1-R2008, “Room Air Conditioners”; and

• ANSI/ASHRAE Standard 16-1983 (RA 2009) “Method of Testing for Rating 

Room Air Conditioners and Packaged Terminal Air Conditioners.”
96 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Referenced Test Procedures

Room Air Conditioner Referenced Test Procedures

 DOE suggested in the October 2007 Framework Document to 

consider updating its test procedure to incorporate by reference the 

most recent test standards. 

• Interested parties commented in support of referencing the most recent ANSI 

and ASHRAE test standards.

• Sections that would be referenced in ANSI/AHAM RAC-1-R2008 do not 

introduce any new changes in the measurement of cooling capacity or power 

input. 

• Sections that would be referenced in ANSI/ASHRAE Standard 16-1983 (RA 

2009) would introduce changes to the determination of capacity, four new 

temperature measurements, and changes to the test tolerances. 
97 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Referenced Test Procedures

Room Air Conditioner Referenced Test Procedures

 DOE proposes to amend the DOE test procedure to reference the 

relevant sections ANSI/AHAM RAC-1-R2008 and ANSI/ASHRAE 

Standard 16-1983 (RA 2009).

• Provides more accurate and repeatable measurements of capacity.

• Provides greater flexibility to manufacturers in selecting equipment and 

facilities .

• Does not add any significant testing burden.

DOE invites comment on the proposed amendments to update the 

references in the DOE room air conditioner test procedure to 

reference the latest ANSI and ASHRAE test standards, ANSI/AHAM 

RAC-1-R2008 and ANSI/ASHRAE Standard 16-1983 (RA 2009). (Issue 

#21)
98 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure Overview

3. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures

a. Automatic Cycle Termination for Clothes Dryers

b. Test Procedure for Vent-less Clothes Dryers

c. Detergent Specifications for Clothes Dryer Test Cloth Preconditioning

d. Changes to Reflect Current Usage Patterns and Capabilities

e. Room Air Conditioner Referenced Test Procedures

f. Clothes Dryer Referenced Test Procedure

g. Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy 

Consumption

h. Clarification of the Gas Supply Test Conditions for Gas Clothes Dryers

4. Compliance with Other EPCA Requirements

5. Effects of Test Procedure Revisions on Compliance with Standards
99 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Clothes Dryer Referenced Test 

Procedure

AHAM Standard HLD-1

 DOE clothes dryer test procedure currently references AHAM 

Standard HLD-1-1974, “AHAM Performance Evaluation Procedure 

for Household Tumble Type Clothes Dryers.” 

• Section 3.3.5 of AHAM Standard HLD-1-1974 provides specifications for the 

exhaust simulator.

 AHAM HLD-1 has been updated since DOE established its clothes 

dryer test procedure. The current standard is AHAM Standard HLD1-2009.

• Section 3.3.5.1 of AHAM Standard HLD-1-2009 provides the same 

requirements for the exhaust simulator as required by AHAM Standard HLD1-1974.

 DOE proposes to amend the DOE test procedure to reference 

section 3.3.5.1 of AHAM Standard HLD-1-2009. 
100 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Clothes Dryer Referenced Test 

Procedure

Optional Clothes Dryer Exhaust Simulator

 AHAM Standard HLD-1-2009 also allows for the optional use of a 

modified exhaust simulator. 

• Test standard notes that only limited testing has been done to compare results 

using the two exhaust simulators, and that users are invited to submit results 

and comments for both options. 

 DOE will continue to require the standard exhaust simulator 

currently referenced by the DOE clothes dryer test procedure. 

 DOE clothes dryer test procedure also references an obsolete 

AHAM clothes dryer test standard, AHAM Standard HLD-2EC.

• No provisions of this test standard are currently used in DOE’s test procedure.

• DOE proposes to remove this reference.
101 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Clothes Dryer Referenced Test 

Procedure

Clothes Dryer Referenced Test Procedure – Request for 

Comment

DOE invites comment on the proposed amendments to update the 

reference in the DOE clothes dryer test procedure to reference the 

latest AHAM clothes dryer test standard, AHAM Standard HLD-1-

2009, and to eliminate the reference to obsolete AHAM Standard HLD2EC. DOE also invites comment on whether the optional modified 

exhaust simulator in AHAM Standard HLD-1-2009 is appropriate for 

incorporation into the DOE clothes dryer test procedure. DOE seeks 

data comparing the effects of the two exhaust simulators in AHAM 

Standard HLD-1-2009 on the measured EF, in particular for units that 

minimally comply with current energy conservation standards. (Issue 

#22)
102 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure Overview

3. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures

a. Automatic Cycle Termination for Clothes Dryers

b. Test Procedure for Vent-less Clothes Dryers

c. Detergent Specifications for Clothes Dryer Test Cloth Preconditioning

d. Changes to Reflect Current Usage Patterns and Capabilities

e. Room Air Conditioner Referenced Test Procedures

f. Clothes Dryer Referenced Test Procedure

g. Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy 

Consumption

h. Clarification of the Gas Supply Test Conditions for Gas Clothes Dryers

4. Compliance with Other EPCA Requirements

5. Effects of Test Procedure Revisions on Compliance with Standards
103 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Technical Correction

Technical Correction for the Per-cycle Gas Dryer Continuously 

Burning Pilot Light Gas Energy Consumption

 Current DOE clothes dryer test procedure contains a technical error 

in the calculation of the per-cycle gas dryer continuously burning 

pilot light gas energy consumption, Eup, in Btu’s per cycle.

 DOE proposes to revise this equation as follows:

• Should correctly subtract the active mode hours per year from the total hours 

per year to give the number of non-active mode hours per year the pilot is 

consuming gas, before dividing by dryer cycles per year.

• The equation should read ((8760 - 140)/283), instead of (8760 – 140/283). 

DOE seeks comment on its proposed correction to the calculation of 

the per-cycle gas dryer continuously burning pilot light gas energy 

consumption. (Issue #23)
104 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure Overview

3. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures

a. Automatic Cycle Termination for Clothes Dryers

b. Test Procedure for Vent-less Clothes Dryers

c. Detergent Specifications for Clothes Dryer Test Cloth Preconditioning

d. Changes to Reflect Current Usage Patterns and Capabilities

e. Room Air Conditioner Referenced Test Procedures

f. Clothes Dryer Referenced Test Procedure

g. Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy 

Consumption

h. Clarification of the Gas Supply Test Conditions for Gas Clothes Dryers

4. Compliance with Other EPCA Requirements

5. Effects of Test Procedure Revisions on Compliance with Standards
105 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Gas Clothes Dryer Gas Supply Test 

Conditions

Clarification of the Gas Supply Test Conditions for Gas Dryers

 Section 2.3.2.1 and 2.3.2.2 of the DOE test procedure:

• Specifies maintaining the gas supply to the clothes dryer at a normal inlet test 

pressure immediately ahead of all controls at 7 to 10 inches of water column 

for natural gas or 11 to 13 inches of water column for propane gas.

• References to “normal inlet test pressure” may be confusing as to what is 

meant by the term “normal.” 

• Such language is not necessary because the gas supply pressure 

immediately ahead of all controls is explicitly stated.

 DOE proposes to revise this language to specify maintaining “the 

gas supply to the clothes dryer immediately ahead of all controls at 

a pressure of” 7 to 10 inches of water column for natural gas and 11 

to 13 inches of water column for propane gas.
106 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Gas Clothes Dryer Gas Supply Test 

Conditions

Clarification of the Gas Supply Test Conditions for Gas Dryers

 DOE proposes minor revisions to the specifications for a gas 

pressure regulator in sections 2.3.2.1 and 2.3.2.2 of the test 

procedure.

• Clarify that the outlet pressure for a dryer equipped with a pressure regulator 

for which the manufacturer specifies an outlet pressure, should be 

approximately that recommended by the manufacturer.

DOE seeks comment on its proposed clarifying language for 

specifying the natural gas and propane supply pressure conditions 

for testing gas clothes dryers. (Issue #24)
107 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure Overview

3. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures

a. Automatic Cycle Termination for Clothes Dryers

b. Test Procedure for Vent-less Clothes Dryers

c. Detergent Specifications for Clothes Dryer Test Cloth Preconditioning

d. Changes to Reflect Current Usage Patterns and Capabilities

e. Room Air Conditioner Referenced Test Procedures

f. Clothes Dryer Referenced Test Procedure

g. Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy 

Consumption

h. Clarification of the Gas Supply Test Conditions for Gas Clothes Dryers

4. Compliance with Other EPCA Requirements

5. Effects of Test Procedure Revisions on Compliance with Standards
108 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Compliance with Other EPCA 

Requirements

Test Burden

 Section 323(b)(3) of EPCA requires that any prescribed or amended 

test procedures shall be reasonably designed to produce test 

results which measure energy efficiency, energy use or estimated 

annual operating cost during a representative average use cycle or 

period of use and shall not be unduly burdensome to conduct. 

 DOE tentatively concluded in the December 2008 TP NOPR that the 

proposed amendments for measuring standby and off mode power 

consumption would satisfy this requirement. 
109 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Compliance with Other EPCA 

Requirements

Test Burden – Standby/Off Mode

 DOE is not proposing amendments to measure delay start and cycle 

finished modes in the clothes dryer test procedure or delay start 

and off-cycle modes in the room air conditioner test procedure.

 DOE received comments that the December 2008 TP NOPR 

proposed ambient temperature conditions for measuring room air 

conditioner standby power would increase testing burden.

• DOE is proposing to provide manufacturers flexibility in the ambient conditions 

for standby and off mode testing.

 DOE tentatively concludes that the proposed amendments to the 

clothes dryer and room air conditioner test procedures for 

measuring standby and off modes are not unduly burdensome.
110 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Compliance with Other EPCA 

Requirements

Test Burden – Clothes Dryer Active Mode

 The proposed amendments to test automatic termination control 

dryers and vent-less dryers are based on international testing 

standards used in Australia and the EU, respectively.

• A number of manufacturers that sell dryers in the United States also sell 

clothes dryers in Australia and in the EU. 

• Likely already test clothes dryers according to these test standards.

• Would not require testing methods and equipment substantially different from 

those in the current DOE test procedure. 

• Would not require manufacturers to make major investment in test facilities 

and new equipment. 

 Proposed amendments to reflect current usage patterns and 

capabilities do not substantially change the testing procedures and 

methods such that they would become burdensome to conduct. 
111 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Compliance with Other EPCA 

Requirements

Test Burden – Room Air Conditioner Active Mode

 Proposed amendments to update the references to external 

standards in the DOE room air conditioner test procedure are based 

on revised standards representing current industry practices and 

methods.

• Would not require manufacturers to make any significant new investment in 

test facilities and equipment, nor require significant changes in the testing 

methodology.
112 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Test Procedure Overview

3. Clothes Dryer and Room Air Conditioner Active Mode Test Procedures

a. Automatic Cycle Termination for Clothes Dryers

b. Test Procedure for Vent-less Clothes Dryers

c. Detergent Specifications for Clothes Dryer Test Cloth Preconditioning

d. Changes to Reflect Current Usage Patterns and Capabilities

e. Room Air Conditioner Referenced Test Procedures

f. Clothes Dryer Referenced Test Procedure

g. Technical Correction for the Per-cycle Gas Dryer Continuously Burning Pilot Light Gas Energy 

Consumption

h. Clarification of the Gas Supply Test Conditions for Gas Clothes Dryers

4. Compliance with Other EPCA Requirements

5. Effects of Test Procedure Revisions on Compliance with Standards
113 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Effects of Test Procedure Revisions 

on Compliance with Standards

Effects of Test Procedure Revisions on Compliance with 

Standards

 DOE must determine to what extent, if any, the proposed test 

procedures would alter the measured energy efficiency of covered 

products as determined under the existing test procedures. If DOE 

determines that an amended test procedure would alter the 

measured efficiency of a covered product, DOE must amend the 

applicable energy conservation standard during the rulemaking 

carried out with respect to such test procedure. (42 U.S.C. 6293(e)) 

 EPCA provides that amendments to the test procedures to include 

standby mode and off mode energy consumption will not determine 

compliance with previously established standards. (U.S.C. 

6295(gg)(2)(C)) 
114 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Effects of Test Procedure Revisions 

on Compliance with Standards

Effects of Test Procedure Revisions on Compliance with 

Standards – Clothes Dryer Active Mode

 DOE believes that only the revisions to the initial RMC and to the 

standard-size dryer test load sizes would affect the measured EF as 

compared to the existing test procedure. 

 Based upon DOE testing and analysis of minimally compliant 

clothes dryers and review of available research: 

• The proposed amendments to the initial RMC would increase the measured 

EF of minimally compliant clothes dryers by 41 percent.

• The proposed amendments to the test load size for standard-size clothes 

dryers would increase the measured EF by 3.8 percent. 
115 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Effects of Test Procedure Revisions 

on Compliance with Standards

Energy Factor of Minimally Compliant Clothes Dryers with 

the Current and Proposed Amended Test Procedure

 Based on the proposed amendments, the measured EF would 

increase by about 41 percent for compact-size clothes dryers and 

about 46 percent for standard-size clothes dryers. 

 DOE will consider such changes in the concurrent energy 

conservation standards rulemaking for clothes dryers and room air 

conditioners.

Product Class

Energy Factor (lb/kWh)

Current Test 

Procedure

Proposed Amended 

Test Procedure

1. Electric, Standard (4.4 ft3 or greater capacity) 3.01 4.39

2. Electric, Compact (120 v) (less than 4.4 ft3 capacity) 3.13 4.41

3. Electric, Compact (240 v) (less than 4.4 ft3 capacity) 2.90 4.09

4. Gas 2.67 3.90
116 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Effects of Test Procedure Revisions 

on Compliance with Standards

Clothes Dryer Test Procedure Proposed Amendments –

Addition of Appendix D1

 Proposed clothes dryer test procedure amendments for active mode 

would substantially change the existing EF metric.

 DOE has tentatively decided to create a new appendix D1 in 10 CFR 

430 subpart B for the proposed amendments.

• Such an appendix would contain a clothes dryer test procedure that 

manufacturers would be required to use on the mandatory compliance date of 

amended clothes dryer energy conservation standards. 

• Manufacturers would continue to use appendix D for clothes dryers until the 

energy conservation standards are amended; at that time, testing would be 

conducted pursuant to appendix D1.
117 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Effects of Test Procedure Revisions 

on Compliance with Standards

Effects of Test Procedure Revisions on Compliance with 

Standards – Room Air Conditioners

 DOE has tentatively concluded that the proposed amendments to 

the DOE room air conditioner test procedure would not affect the 

measured EER of room air conditioners.

DOE invites comment on how the proposed amendments to the DOE 

test procedures for clothes dryers and room air conditioners will 

affect the measured efficiency of products. In particular, DOE seeks 

data showing how certain proposed amendments affect the EF or 

EER of minimally compliant clothes dryers or room air conditioners, 

respectively. (Issue #25)
118 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

In all correspondence, include all of the following:

– Residential Clothes Dryers and Room Air Conditioners Rulemaking

– Docket Number EERE-2008-BT-TP-0010

– Regulatory Identification Number (RIN) 1904-AC02

Email: AHAM2-2008-TP-0010@hq.doe.gov

Comment period closes August 30, 2010

Postal Mail: 

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

Mailstop EE-2J

1000 Independence Avenue, S.W.

Washington, DC 20585-0121

Courier: 

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

950 L’Enfant Plaza, S.W., 6th Floor

Washington, DC 20024 

Telephone: (202) 586-2945

DOE Seeks Comments on its 

Proposal
119 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Additional Information
120 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Automatic Cycle Termination for 

Clothes Dryers

Automatic Cycle Termination – Effects on Measured EF

 EPCA requires that DOE must determine how the EF of clothes 

dryers which are minimally compliant would be affected by the 

amendments to the test procedure, and based on this, amend the 

energy conservation standards as appropriate. (42 U.S.C. 6293(e))

 For the standards rulemaking, DOE conducted a limited number of 

tests at an independent laboratory to analyze the various automatic 

termination technologies found in DOE’s sample of dryers.

• Over-drying to lower final RMCs requires higher energy consumption, with a 

slightly exponential trend likely because it becomes more difficult to remove 

final small amounts of moisture remaining in the test load.

• DOE did not observe any apparent relationships between the type of 

automatic termination sensor technology used and the amount of over-drying.

• Testing results may not be representative of the proposed testing methods. 

– DOE had not yet developed the proposed test procedure for automatic cycle 

termination at the time that this testing was conducted. 

– Test conditions different than those proposed were used (i.e., various cycle 

termination settings were applied to achieve low RMCs). 
121 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Automatic Cycle Termination for 

Clothes Dryers

DOE Automatic Cycle Termination Test Results

0

0.5

1

1.5

2

2.5

3

3.5

0 20 40 60 80

Energy Consumption (kWh)

Estimated RMC (%)

 Vented electric standard dryer single test run showing the 

cumulative energy consumption as the test load is dried 
122 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Automatic Cycle Termination for 

Clothes Dryers

DOE Automatic Cycle Termination Test Results

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.0 1.0 2.0 3.0 4.0 5.0 6.0

Over-drying Energy Consumption 

(kWh)

Estimate Final RMC (%)

Temperature Sensing

Moisture Sensing
123 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Automatic Cycle Termination for 

Clothes Dryers

Automatic Cycle Termination – Effects on Measured EF

 Effect of changing the FU credit from 1.04 to 1.0 for automatic 

termination control dryers.

• An automatic termination control dryer capable of drying the test load to very 

close to 5-percent RMC (no over-drying) would receive a 4 percent credit in 

EF compared to the current DOE test procedure.

 Effects of requiring the test load to be dried to a target final RMC of 

5 percent (or lower) for automatic cycle termination dryers.

• Measured energy consumption would decrease and EF increase if the target 

RMC of 5 percent is achieved (no over-drying), compared to the current DOE 

test procedure which uses a correction factor to determine the energy 

consumption required to dry the test load to a final RMC of 4 percent.

• Based on the differences in the calculations of per-cycle energy consumption 

using a starting RMC of 47 percent, if the target final RMC of 5 percent is 

achieved, DOE believes that the EF would increase by about 2.4 percent 

using the proposed test procedure as compared to the current DOE test 

procedure. 
124 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Automatic Cycle Termination for 

Clothes Dryers

Automatic Cycle Termination – Effects on Measured EF

 All clothes dryers currently available on the U.S. market that are 

covered under the current energy conservation standards are 

equipped with some form of automatic cycle termination sensing.

 DOE believes that a clothes dryer which is minimally compliant with 

current energy conservation standards would likely use a less 

accurate automatic termination control system.

• Such a dryer would possibly over-dry the test load below 5-percent RMC, 

such that the energy consumption and measured EF would be equivalent to 

that measured by the existing DOE clothes dryer test procedure.

• No changes to the current energy conservation standards as a result of the 

proposed amendments for automatic cycle termination would be warranted. 
125 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Clothes Dryer Initial Remaining Moisture Content –

Effects on Measured EF

 DOE investigated how the proposed amendments to change the 

initial RMC would alter the measured efficiency.

• AHAM provided data on the change in measured EF that was observed when 

the initial RMC was reduced from nominally 70 percent to nominally 56 

percent.

– Measured EF increased by an average of 22 percent in AHAM’s test sample of 11 

baseline clothes dryers. Average EF increased from 3.09 to 3.77 lb/kWh.
126 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

AHAM Data Submission on the Effects of Changes to the 

Initial RMC on Measured EF 

-0.4

-0.2

0

0.2

0.4

0.6

0.8

1

2.95 3 3.05 3.1 3.15 3.2 3.25 3.3

Change in EF at 56% RMC (lb/kWh)

EF at 70% RMC (lb/kWh)

Corrected Scaling Factor

Existing Scaling Factor
127 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Clothes Dryer Initial Remaining Moisture Content –

Effects on Measured EF

 DOE conducted similar tests subsequent to the October 2007 

Framework Document for representative baseline dryers.

• One vented electric standard, one vented electric compact (240V), vented 

gas, and vent-less electric compact (240V). 

• Tested each unit according to the current DOE dryer test procedure, but 

changing initial RMC to 56 ± 1 percent and 39 ± 1 percent to evaluate the 

effects of lowering the initial RMC.

• Data shows a non-linear trend in EF as a function of initial RMC.

• Using a polynomial trend to fit the datasets, DOE estimated a 47 percent 

increase EF resulting from changing the initial RMC to 47 percent.

 After this analysis was complete, DOE conducted further testing on 

one maximum-available gas clothes dryer (tested for the standards 

rulemaking) to evaluate the effects on EF of changing the initial 

RMC.

• Tested at reduced initial RMCs of 56 percent ± 3.5 percent and 47 percent ±

3.5 percent. 
128 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Clothes Dryer Initial Remaining Moisture Content –

Effects on Measured EF (56% and 39% RMC Tests)

2

2.5

3

3.5

4

4.5

5

5.5

6

0 10 20 30 40 50 60 70 80

EF (lb/kWh)

Initial RMC (%)

Vented Electric Standard

Vented Electric Compact (240V)

Vented Gas

Vent-less Electric Compact (240V)
129 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Clothes Dryer Initial Remaining Moisture Content –

Effects on Measured EF (56% and 47% RMC Tests)

2.5

2.7

2.9

3.1

3.3

3.5

3.7

3.9

4.1

4.3

30 40 50 60 70 80

EF (lb/kWh)

Initial RMC (%)

 Test results for a maximum-available gas dryer showed an average 

increase in EF of 40.6% when using an initial RMC of 47%.
130 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Clothes Dryer Initial Remaining Moisture Content –

Effects on Measured EF

 DOE believes that a 41-percent increase in EF resulting from 

switching from 70-percent to 47-percent initial RMC for a minimally 

compliant clothes dryer is representative.

• The current energy conservation standards in terms of EF for vented clothes 

dryer product classes would need to be increased by 41 percent, based upon 

this proposed amendment. 

• DOE would consider addressing this change in the concurrent standards 

rulemaking for residential clothes dryers, for which a final rule is scheduled for 

publication by June 30, 2011. 
131 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Clothes Dryer Test Load Weight – Effects on Measured EF

 EF for clothes dryers is the bone-dry test load weight divided by the 

clothes dryer energy consumption per cycle.

 The proposed amendments to the test load size would increase 

both the bone-dry test load weight and the energy consumption per 

cycle. 

 As lower nominal RMCs are reached at the end of the test cycle, the 

rate and efficiency of water removal from the load would be higher 

for the larger test load simply because there would be more water in 

the load, hence making it easier to remove. 
132 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

NIST Vented Electric Standard Clothes Dryer Variable Test 

Load Data

 The National Institute of Standards and Technology (NIST) 

conducted testing to investigate the effects of changing the clothes 

dryer load size on the measured efficiency for a vented electric 

standard clothes dryer with a capacity of 6.3 ft3.

• Clothes dryers were tested according to the DOE clothes dryer test 

procedure, except the test load size was varied from 2 lb to 15 lb. 

Test Number 1 2 3 4 5 6 7 8

Nominal Bone-Dry 

Weight, lb 2 3 5 7 9 11 13 15

Initial RMC, % 70.30 70.67 70.52 69.99 70.67 72.81 69.35 70.34

Final RMC, % 2.84 2.48 3.73 2.88 1.28 5.27 4.29 4.67

Per-Cycle Energy 

Consumption, kWh 0.970 1.167 1.637 2.160 2.638 3.303 4.005 4.582

EF, lb/kWh 2.06 2.56 3.04 3.24 3.41 3.33 3.25 3.27

Percentage Change in EF 

Compared to 7-lb Test, % -36.6 -20.9 -6.0 0.0 5.2 2.7 0.3 1.1
133 | Test Procedures for Clothes Dryers and Room Air Conditioners eere.energy.gov

Changes to Reflect Current Usage 

Patterns and Capabilities

Clothes Dryer Test Load Weight – Effects on Measured EF

 DOE estimated the percentage change in EF for an 8.45-lb test load 

by linearly interpolating the NIST testing results for the 7-lb and 9-lb 

tests. 

 Using this method, the EF would increase by about 3.8 percent 

when increasing the test load size from 7 lb to 8.45 lb. 

• DOE believes that this percentage change in EF can be applied to all vented 

standard-size clothes dryer product classes because it believes the moisture 

removal mechanisms are comparable among them.