CHAPTER 5. ENGINEERING ANALYSIS 

TABLE OF CONTENTS 

5.1	 INTRODUCTION ........................................................................................................... 5-1
 

5.2	 TECHNOLOGIES UNABLE TO BE INCLUDED IN THE FINAL RULE 

ANALYSIS...................................................................................................................... 5-2
 

5.3	 EQUIPMENT CLASSES ANALYZED.......................................................................... 5-2
 

5.4	 EFFICIENCY LEVELS................................................................................................... 5-3
 

5.4.1	 Baseline Units .................................................................................................................. 5-3 
 

5.4.2	 Incremental Efficiency Levels ......................................................................................... 5-4
 

5.5	 METHODOLOGY OVERVIEW .................................................................................... 5-5
 

5.5.1	 AHAM Data Request....................................................................................................... 5-5
 

5.5.2	 Manufacturer Interviews.................................................................................................. 5-6
 

5.5.3	 Review of Previous Technical Support Documents ........................................................ 5-6
 

5.5.4	 Equipment Testing........................................................................................................... 5-6
 

5.6	 ANALYSIS AND RESULTS.......................................................................................... 5-6
 

5.6.1	 AHAM Data..................................................................................................................... 5-6
 

5.6.2	 Review of the Most Recent TSD for Residential Clothes Washers................................. 5-9
 

5.6.2.1 1996 AHAM Cost and Energy Use Data Submittal Review.........................5-9
 

5.6.2.2 2000 TSD Reverse-Engineering Review..................................................... 5-14
 

5.6.2.3 Other Observations Regarding the 2000 Residential Clothes Washer TSD 5-20
 

5.6.3	 Cost-Efficiency Curves.................................................................................................. 5-23
 

LIST OF TABLES 

Table 5.4.1 Baseline Modified Energy Factor and Water Factor for Commercial Clothes 

Washers................................................................................................................... 5-3
 

Table 5.4.2 Efficiency Levels for Top-Loading Commercial Clothes Washers........................ 5-5
 

Table 5.4.3 Efficiency Levels for Front-Loading Commercial Clothes Washers ..................... 5-5
 

Table 5.6.1 AHAM Commercial Clothes Washer Shipments and Shipment-Weighted 

MEF and WF Data Submittal ................................................................................. 5-7
 

Table 5.6.2 AHAM Baseline MEF Commercial Clothes Washer Average Energy and 

Water Use Data Submittal ...................................................................................... 5-7
 

Table 5.6.3 AHAM Commercial Clothes Washer Incremental Cost Data Submittal................ 5-8
 

Table 5.6.4 1996 AHAM Residential Clothes Washer Cost Data Submittal .......................... 5-11
 

Table 5.6.5 1996 AHAM Residential Clothes Washer Energy and Water Use Data 

Submittal............................................................................................................... 5-13
 

Table 5.6.6 Commercial Clothes Washer Cost-Efficiency Curves........................................... 5-23
 

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EERE-2006-STD-0127 COMMENT 69.1
LIST OF FIGURES 

Figure 5.6.1 AHAM Commercial Clothes Washer Incremental Cost Data Submittal............. 5-8
 

Figure 5.6.2 2000 Low-Volume versus High-Volume Clothes Washer Cost 

Disadvantage...................................................................................................... 5-18
 

Figure 5.6.3 2000 Cost Disadvantage of Producing 100,000 versus 1.5MM Clothes 

Washers per Year with Green Field Facility...................................................... 5-19
 

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EERE-2006-STD-0127 COMMENT 69.1
CHAPTER 5. ENGINEERING ANALYSIS 

5.1 INTRODUCTION 

After conducting the screening analysis, the U.S. Department of Energy (DOE) 

performed an engineering analysis based on the remaining design options. The engineering 

analysis consists of estimating the energy and water consumption and costs of commercial 

clothes washers (CCWs) at various levels of increased efficiency. This section provides an 

overview of the engineering analysis (section 5.1), considers technologies that are unable to 

analyzed for this rulemaking (section 5.2), discusses equipment classes (section 5.3), establishes 

baseline unit specifications (section 5.4.1), discusses incremental efficiency levels (section 

5.4.2), explains the methodology used during data gathering (5.5) and discusses the analysis and 

results (section 5.6) As described in section 1.3 of chapter 1 of this technical support document 

(TSD), DOE is continuing the rulemaking for energy conservation standards for microwave oven 

standby power, and analyses related to these products will be published in a separate TSD. In 

addition, DOE issued a final rule adopting energy conservation standards for conventional 

cooking products (i.e., cooktops and ovens) and microwave oven energy factor (EF), and details 

of the analyses for these products are contained in the corresponding final rule TSD. 

The primary inputs to the engineering analysis are baseline information from the market 

and technology assessment (chapter 3 of this final rule TSD) and technology options from the 

screening analysis (chapter 4). Additional inputs include cost and energy efficiency data, which 

DOE received from the Association of Home Appliance Manufacturers (AHAM) and qualified 

and supplemented through limited laboratory testing, data gained through review of recent 

residential clothes washer (RCW) engineering analyses, and other primary and secondary 

research. The primary output of the engineering analysis is a set of cost-efficiency curves. In the 

subsequent markups analysis (chapter 7), DOE determined customer (i.e. equipment purchaser) 

prices by applying distribution markups, sales tax and contractor markups. After applying these 

markups, they serve as the input to the building energy-use and end-use load characterization 

(chapter 6) and the life-cycle cost (LCC) and payback period (PBP) analyses (chapter 8). 

DOE typically structures its engineering analysis around one of three methodologies. 

These are: 1) the design-option approach, which calculates the incremental costs of adding 

specific design options to a baseline model; 2) the efficiency-level approach, which calculates 

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

particular design options used to achieve such increases; and/or 3) the reverse engineering or 

cost-assessment approach, which involves a “bottom-up” manufacturing cost assessment based 

on a detailed bill of materials (BOM) derived from teardowns of the product or equipment being 

analyzed. Deciding which methodology to use for the engineering analysis depends on the 

equipment, the design options under study, and any historical data that DOE can draw on. 

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EERE-2006-STD-0127 COMMENT 69.1
5.2	 TECHNOLOGIES UNABLE TO BE INCLUDED IN THE FINAL RULE 

ANALYSIS 

In performing the engineering analysis, DOE did not consider for analysis certain 

technologies that met the screening criteria but were unable to be evaluated for one or both of the 

following reasons: 1) data are not available to evaluate consumer usage of equipment 

incorporating the technology and, therefore, the test procedure conditions and methods may not 

be applicable; and 2) data are not available to evaluate the energy efficiency characteristics of the 

technology. In these cases, DOE is unable to adequately assess how these technologies impact 

annual energy consumption. Furthermore, certain technologies cannot be measured according to 

the conditions and methods specified in the existing test procedure. 

Although several manufacturers have made claims regarding improved wash 

performance and greater utility of improved drum designs for front-loading clothes washers, 

DOE is unaware of any publicly available data to corroborate a decrease in cycle time or water 

consumption or an increase in modified energy factor (MEF) as a result of implementing this 

design option. Therefore, DOE will not analyze this design option for the final rule. 

Even though DOE considers consumer usage of CCWs to be well-defined, the current 

tests procedures do not measure standby power. Also, DOE is unaware of any data 

demonstrating energy savings associated with low-standby power supplies for CCWs. Thus, in 

the context of the present rulemaking, DOE eliminated the low-standby-power design option 

from the final rule analysis. 

5.3	 EQUIPMENT CLASSES ANALYZED 

DOE separated CCWs into equipment classes. In general, the criteria for separation into 

different classes are: 1) type of energy used (natural gas or electricity); and 2) capacity or other 

performance-related features such as those that provide utility to the consumer, or others deemed 

appropriate by the Secretary that would justify the establishment of a separate energy 

conservation standard. (42 U.S.C. 6295 (q) and 6316(a)) For CCWs, DOE analyzed the 

following equipment classes based on the method of access: 

 Top-loading; and 

 Front-loading. 

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EERE-2006-STD-0127 COMMENT 69.1
5.4 EFFICIENCY LEVELS 

5.4.1 Baseline Units 

DOE selected baseline units as reference points for each equipment class, against which 

DOE measured changes resulting from energy conservation standards. The baseline unit in each 

equipment class represents the basic characteristics of equipment in that class. Typically, a 

baseline unit is a unit that just meets current required energy conservation standards and provides 

basic consumer utility. DOE used the baseline units in the engineering analysis and the lifecycle-cost and payback-period analysis. To determine energy savings and changes in price, DOE 

compared each higher energy efficiency or lower energy efficiency design option with the 

baseline unit. 

The identification of baseline units required establishing the baseline efficiency level. For 

CCWs, energy conservation standard levels are defined by two factors normalized by wash 

basket volume—MEF and water factor (WF). The MEF is the quotient of the cubic foot capacity 

of the clothes container divided by the total clothes washer energy consumption per cycle. The 

MEF takes into consideration not only the energy consumption of the washer but also the amount 

of energy required to dry clothes based on the remaining moisture content (RMC) of the clothes. 

The WF is the quotient of the total weighted per-cycle water consumption divided by the cubic 

foot capacity of the clothes washer. These two variables are only directly related to each other 

via the average hot water usage by a clothes washer as measured by the test procedure. Other 

measured variables affect only one variable or the other. For example, cold water consumption 

only affects the WF, while RMC only affects the MEF. 

The Energy Policy and Conservation Act (EPCA) of 1975 (42 U.S.C. 6291–6309) 

establishes the following energy and water conservation standards for all CCWs: a minimum 

MEF of 1.26 cubic feet (ft3

) per kilowatt-hour (kWh) and a maximum WF of 9.5 gallons per ft3. 

(42 U.S.C. 6313(e); see also 70 FR 60416 (Oct. 18, 2005), adding 10 CFR 431.156) Based on 

comments and the determination at that time to consider a single equipment class for CCWs, 

DOE selected baseline levels for the advance notice of proposed rulemaking (ANOPR), 

published on November 15, 2007 (72 FR 64432; November 2007 ANOPR), that were based on 

current Federal energy conservation standards. Because, as discussed in detail in chapter 3, the 

determination of two equipment classes for CCWs was subsequently made, DOE revised the 

baseline levels presented in the November 2007 ANOPR to characterize top-loading and frontloading CCWs separately. DOE has selected the baseline MEFs and WFs for the two equipment 

classes as listed in Table 5.4.1. 

Table 5.4.1 Baseline Modified Energy Factor and Water Factor for Commercial Clothes 

Washers 

Equipment Class MEF, 

ft3

/kWh 

WF, 

gallons/ft3 

Top Loading 1.26 9.5 

Front Loading 1.72 8.0 

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EERE-2006-STD-0127 COMMENT 69.1
 

5.4.2 Incremental Efficiency Levels 

DOE analyzed several efficiency levels for both equipment classes and obtained 

incremental cost data at each of these levels. Table 5.4.2 and Table 5.4.3 provide efficiency 

levels and the reference source of each level. The highest efficiency levels were initially 

identified based on a review of available equipment literature for models commercially available. 

DOE conducted additional testing and analysis in response to comments received on the notice 

of proposed rulemaking (NOPR) published on October 17, 2008 (73 FR 62034; October 2008 

NOPR) to verify the maximum available efficiency level for top-loading CCWs. 

EPCA mandates that DOE determine both a minimum MEF and a maximum WF for 

CCWs. The two variables are related to a limited extent, but it was not clear initially to DOE 

which factor is more important in setting the energy conservation standards. DOE determined, 

based on comments from interested parties, that a high MEF and low WF are not necessarily 

correlated, and, thus, a max-tech level based on the highest MEF and lowest WF is not realistic. 

That is, a CCW with the highest possible MEF may not achieve the lowest possible WF. 

Similarly, a CCW with the lowest WF may not achieve the highest MEF. Therefore, DOE 

selected CCWs currently available on the market that exhibit a balance of high MEF and low WF 

to represent the max-tech levels. 

For top-loading CCWs, DOE analyzed two efficiency levels beyond the baseline, as 

listed in Table 5.4.2. These levels were based on the Consortium for Energy Efficiency (CEE) 

Commercial Clothes Washer Initiative, and maximum levels that are currently commercially 

available (max-tech). For the October 2008 NOPR, DOE proposed an additional, third efficiency 

level because market surveys of currently available models suggested a max-tech level of (1.76 

MEF/8.3 WF) for top-loading CCWs. However, DOE received comments on the October 2008 

NOPR that raised questions on the validity of this max-tech level. Because EPCA requires DOE 

to consider the max-tech level in the analysis of efficiency levels for CCW energy conservation 

standards (42 U.S.C. 6295(o)(2)(A) and 6316(a)), DOE decided, in light of the uncertainty 

surrounding the performance of the CCW model upon which the top-loading max-tech level was 

based, to test several units of that model at an independent laboratory. Results from a 3-unit 

sample indicated that the MEF and WF of these units are below and above, respectively, the 

max-tech levels—1.63 MEF/8.4 WF. Therefore, for the supplemental notice of proposed 

rulemaking (SNOPR) published November 9, 2009 (74 FR 57738; November 2009 SNOPR), 

DOE revised the max-tech level downward one level to 1.60 MEF/8.5 WF. DOE received 

comments in response to the November 2009 SNOPR that questioned whether wash performance 

could be maintained for top-loading CCWs at the proposed max-tech level. In the absence of an 

industry-accepted, standardized test for CCW wash performance, however, DOE relies on 

manufacturers to market and sell only those products that they feel perform adequately. 

Therefore, for the final rule, DOE maintained the top-loading efficiency levels proposed in the 

November 2009 SNOPR. 

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EERE-2006-STD-0127 COMMENT 69.1
Table 5.4.2 Efficiency Levels for Top-Loading Commercial Clothes Washers 

Level Efficiency Level Source Efficiency Level 

MEF, ft3

/kWh WF, gallons/ft3 

baseline DOE Standard (effective 2007) 1.26 9.5 

1 CEE Tier 1 (January 1, 2004) 1.42 9.5 

2 CEE Tier 2 (January 1, 2004) (Max-Tech) 1.60 8.5 

For front-loading CCWs, DOE analyzed four efficiency levels beyond the baseline for 

CCWs, as listed in Table 5.4.3. These levels were based on ENERGY STAR, the CEE 

Commercial Clothes Washer Initiative, and maximum levels that are currently commercially 

available. Two gap-fill levels were added based on interested party input between the CEE Tier 

3A and the maximum available level. For front-loading CCWs, DOE has determined a max-tech 

level of 2.35 MEF/4.4 WF, based on a currently available CCW. This model was selected after 

an extensive market survey, and DOE’s research suggests that its combination of high MEF and 

low WF represents the best-in-class balance between MEF and WF. 

Table 5.4.3 Efficiency Levels for Front-Loading Commercial Clothes Washers 

Level Efficiency Level Source Efficiency Level 

MEF, ft3

/kWh WF, gallons/ft3 

baseline ENERGY STAR (effective 2007) 1.72 8.0 

1 CEE Tier 3A (January 1, 2004) 1.80 7.5 

2 Gap Fill 1 2.00 5.5 

3 Gap Fill 2 2.20 5.1 

4 Max-Tech 2.35 4.4 

5.5 METHODOLOGY OVERVIEW 

DOE used data submitted by AHAM as the primary source of cost information for the 

engineering analysis. AHAM provided DOE with aggregated incremental manufacturing cost 

data from its member companies. DOE conducted an independent review of the AHAM data 

using several methods and data sources. To gain a better understanding of the data submitted by 

member companies and to be able to relate the costs of improving efficiency to discrete (or 

system) technologies, DOE conducted interviews with manufacturers of CCWs and revised 

estimates accordingly. In addition, DOE reviewed the previous TSD for RCWs to evaluate 

technology options, and performed limited equipment teardowns and performance testing. 

5.5.1 AHAM Data Request 

In support of this rulemaking effort, DOE requested incremental cost data from AHAM 

for CCWs. The data represent the average incremental production cost to improve a baseline unit 

to a specified efficiency level. This methodology constitutes an efficiency-level approach to the 

engineering analysis because DOE examined aggregated incremental increases in manufacturer 

selling price at specified levels of energy efficiency. In addition, DOE requested shipments, 

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EERE-2006-STD-0127 COMMENT 69.1
shipment-weighted average efficiency, and market share efficiency data. Tables of aggregated 

data provided to DOE by AHAM are contained in appendix 5A. 

5.5.2 Manufacturer Interviews 

AHAM provided to DOE shipment-weighted manufacturer costs. These costs included 

the shipment-weighted average cost as well as the lowest and highest single-manufacturer cost to 

achieve efficiency levels above the baseline level. Presenting the data in this manner enables 

interested parties to appreciate the variability in baseline units, design strategies, and cost 

structures that exist among manufacturers. To better understand and explain the causes of these 

cost variances, DOE supplemented these cost data with information obtained through follow-up 

manufacturer interviews. These confidential interviews provided a deeper understanding of the 

various combinations of technologies used to increase equipment efficiency, and their associated 

manufacturing costs. 

During the interviews, DOE also gathered information about the capital expenditures 

required to increase the efficiency of the baseline units to various efficiency levels (i.e., capital 

conversion costs by efficiency or energy-use level). The interviews provided information about 

the size and the nature of the capital investments. DOE also requested information about the 

depreciation method used to expense the conversion capital. 

5.5.3 Review of Previous Technical Support Documents 

DOE reviewed the 2000 RCW TSD, since residential and CCWs share the same design 

options, are frequently built on the same chassis, and are therefore subject to similar economic 

impacts. 

5.5.4 Equipment Testing 

DOE conducted performance testing of three units of the max-tech model identified for 

the October 2008 NOPR. These tests, consisting of measuring the MEF and WF according to the 

DOE test procedure, were carried out at an independent test laboratory. 

5.6 ANALYSIS AND RESULTS 

5.6.1 AHAM Data 

To support the DOE rulemaking, AHAM collected incremental CCW manufacturing cost 

data from its member companies in October 2006. Table 5.6.1 compiles unit shipment and 

energy efficiency data for CCWs from 2002–2005. 

5-6 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

Table 5.6.1 AHAM Commercial Clothes Washer Shipments and Shipment-Weighted 

MEF and WF Data Submittal 

Year Total Shipments MEF (ft3

/kWh) WF 

(gallons / ft3

) 

2002 175,187 1.30 11.77 

2003 190,720 1.33 11.42 

2004 178,382 1.33 11.33 

2005 177,394 1.41 10.91 

Table 5.6.2 reproduces AHAM's 2006 data submittal for the average water and power 

consumption agitator top-loading CCWs that meet the baseline 1.26 MEF energy efficiency 

level. Since January 2007, however, CCWs manufactured at this baseline 1.26 MEF must meet a 

lower WF (9.5) than the one listed in the AHAM data submittal. 

Table 5.6.2 AHAM Baseline MEF Commercial Clothes Washer Average Energy and 

Water Use Data Submittal 

Attributes of Average 1.26 MEF Washer 

Power Consumption 

per Wash Cycle (kWh) 

MEF 

(ft3

/kWh) 

WF 

(gallons / 

ft3

) 

Washer 

Capacity 

(ft3

) 

Water Use 

(gallons/cycle) 

Standby Power 

Consumption 

(W) 

Hot 

Water 

Machine 

Power 

Dryer 

Power 

1.26 11.1 3.1 34.3 * 0.87 0.18 1.38 

DOE initially requested incremental cost data for efficiency levels presented in the 

framework document for the single equipment class including both top-loading and front-loading 

CCWs. Data submitted by AHAM for the November 2007 ANOPR, shown in Table 5.6.3, 

represents aggregated input from the producers of CCWs sold in the United States. The 

shipment-weighted incremental cost at each level is the cost to upgrade the baseline efficiency 

machine (1.26 MEF/9.5 WF) to that efficiency level for the single equipment class. The CCW 

industry currently has only three manufacturers with more than 1-percent market share, and there 

are a limited number of CCWs that operate at different efficiency points, restricting the amount 

of data that AHAM could submit.a Four efficiency levels contain no cost data since AHAM 

requires a minimum of three data points per efficiency level before submitting shipmentweighted results. Therefore, AHAM submitted two manufacturing cost estimates: 1) $74.63 at 

efficiency level 1; and 2) $316.35 at efficiency level 5, as noted in Table 5.6.3. 

a

 AHAM is limited to publishing data to efficiency levels where at least three AHAM members can submit cost 

efficiency data, which AHAM then weights according to unit shipments by manufacturer. 

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EERE-2006-STD-0127 COMMENT 69.1
 

Table 5.6.3 AHAM Commercial Clothes Washer Incremental Cost Data Submittal 

Efficiency Level 1 2 3 4 5 6 

Exploratory MEF Levels – Commercial 

Clothes Washers 1.42 1.6 1.72 1.8 2 2.2 

Exploratory WF Levels – Commercial 

Clothes Washers 9.5 8.5 8.0 7.5 5.5 5.1 

Incremental Costs ($ Per Unit) – 

Shipment-Weighted $ 74.73 * * * $ 316.35 * 

* Insufficient data reported 

Figure 5.6.1 plots the efficiency levels for the single CCW equipment class established in 

the November 2007 ANOPR for which AHAM submitted incremental manufacturing cost data, 

i.e. the baseline efficiency level, efficiency level 1, and efficiency level 5. Incremental Mfg. Cost ($/unit) 

350 

300 

250 

200 

150 

100 

50 

0 

EL 5: 5.5WF 

EL 1: 9.5WF 

Baseline EL: 

9.5WF 

1.2 1.4 1.6 

MEF 

1.8 2 2.2 

EL = Efficiency Level 

Figure 5.6.1 AHAM Comm

Submittal 

ercial Clothes Washer Incremental Cost Data 

Manufacturers stated that the baseline efficiency level (1.26 MEF/9.5 WF) and the 

efficiency level 1 (1.42 MEF/9.5 WF) are attainable with agitator top-loading CCWs. 

Manufacturers also stated that efficiency level 5 (2.00 MEF/5.5 WF) would require the use of 

front-loading CCWs. Therefore, DOE believes the data in Table 5.6.3 is subject to a platform 

change from agitator top-loading to front-loading CCWs between efficiency level 1 and 

efficiency level 5. Given the persistent manufacturing cost difference between these platforms, 

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EERE-2006-STD-0127 COMMENT 69.1
an incremental cost “curve” with more intermediate data points would thus likely exhibit a steep 

step change wherever that platform change occurs. 

5.6.2 Review of the Most Recent TSD for Residential Clothes Washers 

In 2001, DOE concluded a rulemaking for RCWs. The intent of this section is to review 

some of the conclusions drawn in the 2000 TSD that supported that rulemaking, to update the 

data presented in it, and to assess in which ways the RCW TSD can be used in the context of this 

CCW rulemaking. In particular, this review focuses on the manufacturing costs published in the 

2000 TSD. First, the 1996 AHAM RCW cost data submittal provided for the 2000 TSD is 

examined, followed by the 2000 reverse-engineering analysis and an update on the low-volume 

manufacturer (LVM) case. 

5.6.2.1 1996 AHAM Cost and Energy Use Data Submittal Review 

In 1996, manufacturers submitted manufacturing cost and energy use estimates by 

efficiency level for RCWs to AHAM. This data was then aggregated by market share and 

efficiency level to prevent the disclosure of confidential information, and the results were used in 

the analysis reported in the 2000 TSD. While this process yielded viable results in the RCW 

rulemaking, the results are not directly applicable to the current CCW rulemaking due to 

differences in the following key parameters: 1) intended use and cycle life, 2) production scale, 

3) technical advancements, 4) market share, 5) platform mixing, and 6) incompatibility of the 

MEF and WF pairings in the data submittal. 

Intended Use and Cycle Life 

Clothes washer manufacturers have traditionally designed their commercial units to share 

many parts with their residential platforms. Shared components typically consist of parts that do 

not affect unit life, such as cabinet stampings, that may or may not be selectively upgraded. For 

example, entry-level RCW cabinets typically feature a powder-coated plastic finish whereas 

commercial models may feature a more durable enameled finish. Purchased components such as 

motors, timers, and switches may also be customized to reflect the different and more rigorous 

usage patterns expected in commercial applications. For example, one manufacturer stated that 

their CCWs are expected to last 12,000 wash cycles whereas residential models are expected to 

last 6,000 or fewer wash cycles. 

Production Scale 

In 1996, a twenty-fold scale difference existed between residential and CCW market unit 

shipments. Since then, RCW shipments have grown while CCW sales have stagnated or 

declined. As a result, the current scale difference is more than forty-fold. 

The scale difference helps explain why CCWs have traditionally been a product 

extension of existing RCW platforms for most manufacturers. By sharing many components with 

residential models, research and development, tooling and equipment, and other costs can be 

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EERE-2006-STD-0127 COMMENT 69.1
spread over the largest number of clothes washers. Consequently, any additional investment 

required for CCWs alone is depreciated over a much smaller production volume. 

As efficiency standards are raised, manufacturers may be required to make investments in 

the form of capital expenditures, research and development, and implementation to meet such 

standards. Investments such as new tooling and research, in particular, are “step” functions, 

requiring a minimum investment regardless of production volume. A standard that affects CCWs 

first may thus require a substantial investment that can only be depreciated over a much smaller 

production volume. 

As a result of the much lower production volumes, the per-unit conversion costs to 

accommodate higher efficiencies are greater per efficiency increment for CCWs than they are for 

residential models. Therefore, DOE believes Table 4.2 published in the 2000 TSD (duplicated 

below as Table 5.6.4) is not valid for CCWs, because the fixed costs are assumed to be 

depreciated over a much larger product volume and because the higher-volume production 

processes manufacturers envisioned minimize variable cost increases. Most manufacturers of 

RCWs in 1996 had production levels in excess of 300,000 units per year, with the leading 

manufacturer producing about 3.5 million top-loading washers per year. In contrast, the two 

leading CCW manufacturers in 2007 had total CCW production levels of about 100,000 units per 

year. 

Currently, as in 1996, there is an LVM that operates in both the residential and 

commercial markets. While its volumes in the residential market are very small on a percentage 

basis, this manufacturer is very prominent in the CCW market. Unlike its diversified 

competitors, this company exclusively manufactures laundry equipment. A review of the U.S. 

Securities and Exchange Commission (SEC) 10-K documents revealed that, as of 2005, this 

company derived 22 percent of its total revenue from the sale of front- and top-loading clothes 

washers and 87 percent of that income was from the commercial market. As a result, this 

company will be affected disproportionately by the CCW rulemaking compared to its 

competitors, for whom CCWs represent about 2 percent of total clothes washer sales. For more 

information on the LVM, see chapter 13 and appendix 13A of this TSD. 

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EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

 

 

 

 

 

Table 5.6.4 1996 AHAM Residential Clothes Washer Cost Data Submittal 

Product Characteristics 

Incremental Variable Costs 

($ per Unit) Total 

Fixed 

Costs ($ 

per unit) 

Incremental 

Mfg. Cost 

($ per unit) 

No. of 

Respondents 

Percent 

Improvement MEF WF 

Materials Labor Overhead Total 

Baseline 0.817 13.779 

5 0.860 13.732 $0.01 $0.01 $0.00 $0.02 $0.07 $0.09 5 

10 0.908 13.710 $0.25 $0.04 $0.01 $0.30 $0.61 $0.91 5 

15 0.961 13.670 $3.18 $0.10 $0.04 $3.32 $1.01 $4.33 5 

20 1.021 13.342 $10.71 -$0.02 $1.80 $8.89 $6.21 $15.10 5 

25 1.089 9.220 $36.14 $8.61 $0.09 $44.84 $19.29 $64.13 5 

30* 

35 1.257 7.601 $86.73 $10.94 $7.78 $105.45 $22.72 $128.17 5 

40 1.362 7.610 $87.15 $10.94 $7.78 $105.87 $22.72 $128.59 5 

45 1.485 8.570 $125.58 $15.52 $14.51 $155.61 $24.67 $180.28 4 

50 1.634 8.570 $132.40 $15.68 $14.51 $162.59 $24.67 $187.26 4 

* No data were submitted at this efficiency level 

Technical Advancements 

While the general function of clothes washers has not changed since the 2000 TSD, many 

different technologies have been implemented. As with dishwashers and other residential 

appliances, clothes washers are built on platforms whose baseline performance can be improved 

with design options. Some platforms are inherently more energy and water efficient than others, 

allowing a manufacturer to use fewer design options to reach a particular efficiency level, but 

there are efficiency limits inherent to every platform regardless of how many design options are 

employed. These limits affect the MEF as well as the WF. 

Clothes washers currently often use electronic controllers instead of electromechanical 

controllers, which were more prevalent at the time of the 2000 TSD. Electronic controllers 

usually carry a cost premium over electromechanical timers, driving up manufacturing cost. 

However, such controllers are appealing to customers and are required for some design options. 

Besides enabling certain design options, electronic controllers allow owners to more easily 

monitor washer utilization, functional status, and other parameters. There are potential reliability 

benefits as well. For example, one reason that variable-water-height selectors are atypical in 

commercial top-loading clothes washers is that owners prefer not to give users the ability to 

select water levels. If they did, users could attempt to wash a full load on a “low water” setting, 

potentially damaging the washer and/or the clothes being washed. Electronic controllers may be 

able to detect such overload conditions and stop the wash cycle before the clothes washer is 

harmed. Alternatively, controllers can be programmed to “reset” to default settings after each 

wash cycle. This forces the end-user select the appropriate cycle for each use, potentially 

reducing the incidence of accidental overloads. 

Some manufacturers have also phased out mechanical transmission and clutch systems, 

replacing them with variable-speed electronic drive systems. Benefits include a reduction in 

mechanical complexity, increased cabinet space to accommodate potential expansion of the 

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EERE-2006-STD-0127 COMMENT 69.1
basket/tub, and greater wash program flexibility. The substitution of electronics for mechanical 

systems can increase overall unit cost, particularly if fixed in-house assets that had been used to 

manufacture mechanical transmission and clutch systems become stranded assets. 

Many design options available in RCWs have yet to find application in CCWs. The 

reliability and longevity requirements of CCWs combined with the production scale issues are 

such that manufacturers avoid adding design options unless necessary. As the part count 

increases, so does the probability that the clothes washer will break down, and purchased parts 

sourced just for CCWs are likely to carry a cost premium. Thus, DOE expects manufacturers will 

continue to introduce new features first in the residential markets before transitioning them to the 

commercial field. 

Since the 2000 RCW TSD was written, there have been numerous technological 

advances incorporated into clothes washers, and the manufacturing costs submitted to AHAM 

were based on RCW models that are no longer in production. Thus, even if DOE could ascertain 

the manufacturing cost differential between commercial and residential clothes washers in 1996, 

that differential would no longer be valid for current models. 

Most importantly, manufacturers have been able to improve the MEF and WF of agitator 

clothes washers at a much lower cost than they projected in 1996. Instead of using front-loading 

or non-agitator top-loading clothes washers as projected to meet a 1.26 MEF, current baseline 

1.26 MEF CCWs consist of agitator models with reduced water consumption, lower wash 

temperatures, and improved control systems. Thus, manufacturers were able to reach the current 

efficiency requirements at much lower cost than projected in 1996. One manufacturer noted that 

the costs of improved control systems are substantially higher than those of the 

electromechanical controls they replaced and that the wash performance and hence end-user 

utility of top-loading clothes washers are affected by lower WF and higher MEF requirements. 

Market Share 

The market shares that AHAM used to aggregate manufacturer-submitted data were valid 

for the RCW market in 1996. However, since then there has been significant consolidation by 

domestic producers, and multiple foreign brands have started selling their clothes washers in the 

United States. More importantly, the market shares of producers in the RCW market are not 

equivalent to the market shares of manufacturers in the CCW industry. 

Four to five RCW manufacturers submitted manufacturing cost data estimates for each 

efficiency level for the 1996 AHAM data request. However, there are currently essentially only 

three U.S. CCW manufacturers: Alliance Laundry Systems LLC (Alliance), General Electric GE 

Consumer & Industrial (GE), and Whirlpool (via its acquisition of Maytag Corporation 

(Maytag)). The low number of manufacturers limits current AHAM data submittals to DOE 

since AHAM requires a minimum of three data points per efficiency level before it publishes any 

results. 

Since AHAM adjusts incremental manufacturing cost data submittals by efficiency level 

on a market-share basis, the manufacturing costs submitted by the largest manufacturers have the 

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EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

 

 

greatest weight. As noted above, the distributions of market share by manufacturer for 

commercial and residential clothes washers are quite different. Since DOE does not have access 

to the disaggregated data, there is no opportunity to compensate for market share differences 

between markets, even if the costs of manufacturing residential and CCWs were the same. 

Platform Mixing 

DOE’s efforts to update the 1996 AHAM data submittal are hindered by the submittal’s 

aggregation of top- and front-loading clothes washers. Based on the AHAM-supplied energy and 

water use data, reproduced in Table 5.6.5, DOE assumes that the cost and energy use tables 

contained only agitator top-loading data for efficiency improvement levels of up to, and 

including, 20 percent. This assumption is driven by the consistent water usage up to that point 

and the low incremental costs to reach that efficiency level. Similarly, DOE assumes that the two 

highest efficiency levels, 45 and 50 percent improvement, exclusively incorporated front-loading 

clothes washers. The 25 to 40 percent improvement categories appear to have aggregated highefficiency top-loading as well as front-loading clothes washers. 

Table 5.6.5 1996 AHAM Residential Clothes Washer Energy and Water Use Data 

Submittal 

Product Characteristics Energy Use (kWh/cycle) Water Use 

Percent 

Improvement MEF 

Total Energy 

w/Dryer (kWh 

/cycle) 

Clothes 

Container 

(ft3

) 

Hot 

Water 

Machine 

Energy 

Dryer 

Energy 

(gal/ 

cycle) (gal/ft3

) 

Baseline 0.817 3.227 2.847 1.587 0.209 1.430 39.181 13.779 

5 0.860 3.165 2.817 1.543 0.209 1.413 38.613 13.732 

10 0.908 3.017 2.822 1.408 0.209 1.400 38.613 13.710 

15 0.961 2.833 2.832 1.216 0.209 1.407 38.621 13.670 

20 1.021 2.739 2.893 1.113 0.218 1.408 38.446 13.342 

25 1.089 2.292 2.866 0.715 0.304 1.273 26.600 9.220 

30* 

35 1.257 1.866 2.749 0.462 0.133 1.270 21.030 7.601 

40 1.362 1.859 2.749 0.462 0.133 1.263 21.030 7.610 

45 1.485 1.651 2.736 0.429 0.114 1.107 23.405 8.570 

50 1.634 1.574 2.736 0.413 0.114 1.047 23.405 8.570 

* No data were submitted at this efficiency level. 

Since DOE does not have access to the disaggregated data and the clothes washer 

platforms that underlie the AHAM data submittals, there is no method by which DOE can assess 

how relevant the data submittal is to the current rulemaking. It is not clear to DOE which models 

were submitted at each efficiency level, whether these models use the same platforms as current 

CCWs, nor what efficiency improvements manufacturers have been able to achieve with these 

models since 1996. 

Incompatibility of the MEF and WF Pairings 

Table 5.6.5 shows the lowest shipment-weighted WF at 1.26 MEF. No top-loading 

clothes washers could reach 1.634 MEF in 1996, suggesting that the clothes washers at the two 

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EERE-2006-STD-0127 COMMENT 69.1
highest efficiency levels consisted of front-loading clothes washers, whereas baseline units 

consisted of agitator top-loading clothes washers. The WF is lowest at 1.26 MEF, indicating that 

the shipment-weighted WF for that efficiency level included clothes washers that had a lower 

WF than residential front-loading clothes washers did at that time. 

DOE is aware of an agitator top-loading CCW platform from a major manufacturer that 

had achieved a 7.3 WF by employing a spray rinse. However, this unit was withdrawn from the 

market a number of years ago, allegedly due to end-user complaints regarding rinse performance. 

The CEC database of current CCWs lists no top-loading clothes washers with a similar WF. The 

closest model is an agitator top-loading washer platform with an 8.3 WF. The top-loading clothes 

washer platform currently listed in the CEC RCW database that meets the 7.6 WF does not exist 

in a commercial version and consists of a non-agitator design. 

Thus, the results at 1.26 MEF in Table 5.6.5 suggest multiple platforms, likely consisting 

of agitator top-loading with spray rinse, non-agitator top-loading, and front-loading RCWs. 

Neither spray-rinse agitator nor non-agitator clothes washers are currently in production for 

commercial purposes. The incompatibility between the WF of machine properties submitted to 

AHAM for the 1996 data submittal and machines currently on the market is yet another 

indication of how the projections of manufacturers diverged from the agitator top-loading clothes 

washers they developed to meet the 1.26 MEF/9.5 WF requirements. 

Conclusion 

There are sufficient changes in market conditions due to intended use and cycle life, 

production scale, technical advancements, and market share to preclude the use of the 1996 

AHAM data submittal as a basis for the current CCW analysis. Furthermore, the 1996 AHAM 

data submittal cannot be factored into the analysis due to platform mixing and the resulting 

inability to disaggregate the data into top- and front-loading machines. 

5.6.2.2 2000 TSD Reverse-Engineering Review 

Further manufacturing cost data by efficiency level was developed for the 2000 RCW 

rulemaking by DOE. Since DOE has access to this data, DOE has decided to review and publish 

data that remains relevant to the current CCW rulemaking. 

Reviewed Models 

For the 2000 RCW TSD, DOE reverse-engineered eight RCWs in 1999 from 

manufacturers with substantial market share. DOE subsequently developed cost models to 

estimate the manufacturing costs of these washers at varying production levels. 

The market share covered by the RCW platforms reverse-engineered in 1999 was about 

80 percent. Three of the washers shared a chassis with CCWs in 1999. DOE could make 

estimates regarding the costs to update these platforms for commercial use, but the market share 

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EERE-2006-STD-0127 COMMENT 69.1
covered by these platforms is currently less than 20 percent of the commercial market, limiting 

the usefulness of the results. 

All three of the major manufacturers currently serving the CCW industry have introduced 

new models or significantly revised existing models since the 2000 RCW TSD. Some 

manufacturers have updated the drive systems and other major system components to 

differentiate their equipment or improve energy efficiency. As a result, there have been 

significant changes in the baseline cost of clothes washers that the 2000 TSD could not have 

analyzed, even if it had reviewed CCW models. 

Market Share and Scale 

The U.S. CCW market is very small compared to the RCW market. Whereas shipments 

of RCWs have been increasing, with more than 9.2 million units in 2005, CCW sales have 

stagnated or declined to about 200,000 units per year. The RCW market is dominated by the 

merged Whirlpool-Maytag entity, which has an approximate combined market share of 70 

percent. The RCW sales of this entity exceed 6 million units per year, approximately 30 times 

the entire CCW market. 

This scale difference is important in this analysis because agitator top-loading residential 

and CCWs typically share many parts to minimize tooling and equipment investments. Thus, a 

manufacturer that benefits from high manufacturing volumes on the residential side has a much 

larger potential base of units over which to depreciate investments. Commercial assembly lines 

can be repurposed towards RCW production if the commercial top-loading washer platform is no 

longer cost effective to produce. 

While the largest competitor in the U.S. clothes washer manufacturing business may not 

realize much cost benefit due to manufacturing scale in moving to 6 million units per year versus 

the 1.5 million units per year modeled during the 2001 RCW rulemaking, there are other 

advantages to scale. For example, research and development and other overhead functions can be 

leaner as a percentage of sales revenue, yet still have far more available resources than 

comparable departments at lower-volume competitors. 

High-volume competitors have a long history of improving the performance of agitator 

top-loading clothes washers via add-on design options such as spray rinse, nutating plates, and 

other means. For a lower-volume manufacturer, it is inherently more difficult to assemble and 

defend an intellectual-property portfolio. Similarly, an LVM may have to wait for innovations to 

trickle down from common suppliers since high-volume manufacturers typically get first (and 

sometimes exclusive) access to new technologies. 

Manufacturers whose production comprises a high percentage of CCWs are thus 

impacted disproportionately by any regulatory burden regarding CCWs. One low-volume U.S. 

clothes washer manufacturer was contractually barred from manufacturing RCWs from 1999 

until 2004. While its subsequent SEC 10-K reports show significant growth in the residential 

market segment, commercial sales are still substantially higher. As a result, this LVM is not only 

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EERE-2006-STD-0127 COMMENT 69.1
concentrated in the CCW market, but its lack of diversification makes it particularly sensitive to 

any impacts on its CCW business as well. 

The Low-Volume Manufacturer Case 

The LVM has been successfully competing with much larger competitors in the 

commercial laundry market for several years. Based on the LVM's public SEC 10-K filings, 

DOE has estimated that the LVM derives about a third of its total revenues from the sales of 

clothes washers and dryers, which are usually bundled. Clothes washer sales by themselves 

account for more than 20 percent of total revenue. Laundry equipment for institutional use 

largely makes up the balance. For a detailed breakdown of LVM revenues by product line, 

equipment line, and market segment, see chapter 13 and appendix 13A of this TSD, which detail 

DOE's methodology and results for the LVM analysis. 

As of 2006, agitator top-loading clothes washers sold by the LVM into the commercial 

market segment represented about 65 percent of total clothes washer unit shipments and about 60 

percent of total CCW revenues. Thus, any market disruption that eliminates the use of such 

clothes washers from the commercial market would affect the LVM disproportionably due to the 

relative importance of the business and its effect on manufacturing scale. Such a transition also 

poses a business risk since a platform change will reduce the value of accumulated spare-parts 

inventories, technician training, etc. to route operators. Thus, any switching cost to other brands 

could be substantially reduced. 

The LVM released a front-loading clothes washer for sale in 1999 and does not presently 

manufacture any non-agitator top-loading clothes washers. As of 2005, its sales of front-loading 

clothes washers represented approximately 20 percent of total washer unit shipments and 

approximately 35 percent of total washer revenues. Given the scale of the manufacturer at the 

time, the front-loading design was likely optimized for very low production volume. Should the 

entire CCW industry be forced to migrate to front-loading clothes washers, the LVM would thus 

have to make substantial investments to make its design more cost competitive. As of 2008, the 

proportion of front-loading to top-loading washers grew to 30 versus 70 percent, respectively. 

While the LVM is already at work to reduce front-loading unit costs, a market transition to frontloading washers accelerated by federal standards would most likely result in the LVM moving its 

front-loading manufacturing offshore. 

However, unlike its larger rivals, the LVM does not benefit from very large scale in its 

residential operations to help amortize the investments in research, development, plant 

expenditures, and implementation expenses. The size of the CCW market by itself is simply too 

small to justify large lump-sum investments. The agitator top-loading units that the LVM 

manufactures have benefited from years of investments and refinements, whereas the frontloading model received its first update in 2003. 

Besides benefiting from ongoing development and investments, agitator top-loading 

clothes washers at the LVM also benefit from well-depreciated equipment and tooling and a 

long-term knowledge base. In the past, the LVM had residential sales well in excess of its CCW 

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EERE-2006-STD-0127 COMMENT 69.1
 

 

sales before a non-compete contract cut off the LVM from the residential market from 1999 until 

2004. Thus, while the LVM has gained the experience of producing hundreds of thousands of 

top-loading clothes washers per year, it has yet to gain the same experience with its front-loading 

clothes washer line. 

The loss of the commercial market for agitator top-loading clothes washers is likely to 

make residential models of those clothes washers too expensive to manufacture due to the much 

smaller scale. Whether the LVM could remain in the front-loading clothes washer business 

despite the loss of the agitator top-loading clothes washer business is also uncertain. To date, the 

LVM has been able to grow its business despite adverse market conditions and much larger 

competitors. 

Implications of Scale for the Low-Volume Manufacturer 

As discussed previously, most of the clothes washers under review in the 2001 RCW 

rulemaking did not share a chassis with a commercial model. Thus, the results of the engineering 

analysis in the 2000 TSD do not apply to present day CCWs except for a very narrow set of 

observations. 

A universal factor in manufacturing is scale, which describes how many units over which 

a fixed investment can be amortized. As part of the 2000 reverse-engineering analysis for RCWs, 

DOE tried to understand the implications of low-volume manufacturing. Figure 5.6.2, originally 

published as Figure 5.10 in the 2000 RCW TSD, averages the cost differences among multiple 

baseline top-loading vertical-axis RCWs at production levels of 1.5 million and 0.3 million units 

per year. It also averages front-loading horizontal-axis results for the residential front-loading 

horizontal-axis clothes washers that DOE reverse-engineered. 

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EERE-2006-STD-0127 COMMENT 69.1
Figure 5.6.2 2000 Low-Volume versus High-Volume Clothes Washer Cost 

Disadvantage 

While the units under review in the 2000 RCW TSD are not applicable to the current 

CCW analysis, the impact of manufacturing scale is still relevant to the CCW market. As 

manufacturing volumes shrink, labor costs rise due to growing inefficiencies within the 

fabrication and assembly lines. The effect of manufacturing scale on depreciation is even more 

pronounced, as there are minimum tooling and equipment investments required to start 

operations, regardless of what the actual manufacturing volume turns out to be. Careful design 

will minimize the amount of additional tooling required to bring new equipment to market. 

Results from the 2000 TSD analysis for the effects of manufacturing scale are presented 

as follows, recognizing that similar results will likely apply to CCWs. Figure 5.6.3 examines the 

case of very low-production volumes (100,000 units per year) versus producing at high volumes 

(1,500,000 units per year). Driven mainly by increases in depreciation costs, the very lowvolume manufacturing cost increment over high-volume manufacturing increases to about $80 

for both top-loading vertical-axis and front-loading horizontal-axis clothes washers. 

5-18 

EERE-2006-STD-0127 COMMENT 69.1
$0.00 

$10.00 

$20.00 

$30.00 

$40.00 

$50.00 

$60.00 

$70.00 

$80.00 

$90.00 

USD 

Other 

Depreciation 

Labor 

Materials 

V-Axis	 H-Axis 

Figure 5.6.3 2000 Cost Disadvantage of Producing 100,000 versus 1.5MM Clothes 

Washers per Year with Green Field Facility 

The agitator top-loading clothes washer market is largely commoditized, resulting in 

fierce price competition. As of 2006, a $156 price difference for the end user ($80 manufacturing 

cost multiplied by a 1.93 total markup (see chapter 7 of this TSD)) was not likely to be 

sustainable. However, the LVM is aided in this equipment segment by the extant tooling and 

equipment, years of research and development, etc. which represent a sunk cost. 

In contrast, the front-loading clothes washer manufacturing line would have to increase 

its output by multiples to meet the unit demand that the top-loading line currently sustains. Since 

the two platforms do not share many components, the top-loading line would be likely to be 

written off, while substantial investments would be required to expand the output of the frontloading line. Such investments may not be justified by the potential market for them, and the 

larger rivals have a great advantage in terms of leveraging their RCW shipments to minimize 

depreciation on a per-unit basis. 

Thus, while the LVM may be able to compete with its bigger rivals on the agitator toploading platform due to depreciated plant and equipment, prior high-volume experience, and a 

long learning curve, it would be competing at a great disadvantage with its larger rivals should 

front-loading CCWs become the only platform that can meet future energy efficiency standards. 

Manufacturers operating at very low volumes are likely to face margin pressure for both 

top- and front-loading clothes washers. To counter pressure from high-volume manufacturers, 

low-volume producers have to compete on the basis of service, reliability, bundling, and 

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EERE-2006-STD-0127 COMMENT 69.1
equipment differentiation. Its long legacy in the agitator top-loading market also aids the LVM in 

competing successfully with larger rivals. 

Conclusion 

In conclusion, the LVM faces larger rivals in all of the clothes washer markets it 

competes in, yet the LVM has been able to grow its revenue despite being heavily concentrated 

in the stagnant CCW market. As a result, the elimination of the agitator top-loading clothes 

washer platform from the CCW market would impact this manufacturer disproportionately and 

could therefore represent a material risk to the company. 

5.6.2.3 Other Observations Regarding the 2000 Residential Clothes Washer TSD 

Historic Background 

When DOE began the 2001 RCW rulemaking, the U.S. RCW market consisted almost 

exclusively of top-loading vertical-axis platforms. Table 3.9 in the 2000 TSD noted that toploading vertical-axis clothes washers comprised a 99.9 percent market share as of 1995. 

Available front-loading horizontal-axis clothes washers were limited to imported goods and two 

domestic platforms. While the majority of overall clothes washer shipments in the United States 

still consist of top-loading clothes washers, the shipment levels and market share of front-loading 

clothes washers have grown significantly. 

Unlike in 1995, all remaining U.S. manufacturers now sell front-loading clothes washers 

that are either produced in their own factories or outsourced. The majority of residential frontloading clothes washers sold in the United States today are manufactured abroad. While a greater 

proportion of CCWs are made domestically, significant market scale differences remain. Thus, 

as markets for top-loading clothes washers decline, domestic clothes washer production will 

likely decline also. 

In the 1996 AHAM data submittal, the maximum potential improvement was capped at 

an MEF of 1.634, whereas front-loading clothes washers from multiple vendors currently reach 

MEFs in excess of 2.00. Manufacturers have also increased the basket capacity of top- and frontloading clothes washers, reaching up to 4.7 ft3

 in some residential models. The WFs are also 

significantly lower on several current front-loading clothes washers found in either residential or 

CCW markets than they were for models in the 2000 TSD. 

As a result of the RCW rulemaking, the standards for RCWs were increased in two steps, 

reaching an MEF of 1.26 as of January 1, 2007. When that standard was issued, no front-loading 

clothes washer MEFs were below 1.26. Thus, only top-loading clothes washers were affected by 

the rulemaking. In the interim, manufacturers worked to find the most cost-effective way to 

modify their top-loading platforms to meet the current minimum MEF. 

At the time of the 2000 TSD, a correlation was noted and assumed between MEF and WF 

(see Table 5.6.5). However, no WF was imposed in the final rulemaking. As a result, 

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EERE-2006-STD-0127 COMMENT 69.1
manufacturers could largely focus on reducing the energy content of the wash and rinse water 

rather than having to jointly focus on the MEF and the WF. None of the agitator top-loading 

clothes washers that currently meet the 1.26 MEF minimum efficiency standard also reach the 

WF predicted for that efficiency level by the 2000 TSD. Typically, such current top-loading 

clothes washers use two more gallons of water per ft3

 of capacity than the WF associated with 

the 1.26 MEF standard in the 2000 TSD. 

Impact of Equipment Test Procedures 

EPACT 2005 amended EPCA to require DOE to rate CCWs with the same test procedure 

established for RCWs. (42 U.S.C. 6314(a)(8)) DOE adopted test procedures for CCWs in a final 

rule published on October 18, 2005. 70 FR 60407, 60416. The testing procedure for RCWs is 

codified in 10 CFR part 430, subpart B, appendix J1. 

When calculating MEF, the DOE test procedure factors in end-user-selectable variables 

including the wash and rinse water temperatures, and fill level. Thus, adaptive water levels 

(either user-set or automatic) and temperature choices are accounted for in the calculation. Some 

design options, such as reducing the amount of rinse water, have an efficiency benefit regardless 

of the user-set program. These and other design options have allowed the three highest-volume 

CCW manufacturers to reach the 1.26 MEF standard level at relatively low cost by making 

evolutionary changes to their top-loading platforms. 

For example, the calculated MEF is a function of the cycle water temperatures. By 

requiring a cold rinse and offering more warm or cold wash programs while reducing the number 

of hot wash cycle options, the MEF of a washer can be raised without affecting the WF. The 

incremental cost of offering more wash temperatures or lowering the temperatures overall is 

relatively minor. Similarly, the added cost and complexity of offering a water level selector 

switch is relatively minor but it allows manufacturers to take advantage of the credits that the 

DOE test procedure gives to washers that have this design option. 

At the time of the AHAM data submittal for the 2000 TSD, clothes washer manufacturers 

had little experience with the updated clothes washer test procedure, which was not published in 

the Federal Register until August 27, 2000. The only top-loading clothes washers on the market 

at the time that could reach an MEF of 1.26 were proprietary in design. Furthermore, the clothes 

washer manufacturing cost estimates for the 1.26 MEF levels were an amalgam of the high-cost 

proprietary top-loading design and several front-loading washers. 

In conclusion, the cost of upgrading top-loading washers to reach an MEF of 1.26 was 

lower than manufacturers estimated according to the AHAM-supplied data. No expensive design 

options had to be employed to push the top-loading platform to that MEF level. Therefore, DOE 

believes that the current manufacturing cost of an agitator top-loading clothes washer that meets 

the 1.26 MEF/9.5 WF efficiency level is within 10 percent of the cost of a baseline washer in 

Table 5.6.5 once these costs are adjusted for inflation. 

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EERE-2006-STD-0127 COMMENT 69.1
Persistence of Baseline Top-loading versus Front-loading Clothes Washer Cost 

Differential 

Since the publication of the 2000 TSD, the clothes washer market has been transformed 

by the entrance of more foreign competitors, significant market consolidation, and the 

appearance of RCWs that have higher load capacities than the basket-capacity limits defined by 

EPACT 2005. For example, front-loading RCWs from BSH Home Appliances Corporation 

(Bosch-Siemens), GE, LG Electronics, Inc. (LG), and Whirlpool have a stated basket capacity in 

excess of the 3.5 ft3

 capacity product class definition limit set by EPACT 2005 for RCWs. 

Despite the entrance of multiple front-loading clothes washers into the commercial and 

residential markets, a significant retail price difference between agitator top- and front-loading 

clothes washer platforms persists. This suggests that manufacturers have yet to overcome the 

inherently higher costs associated with manufacturing front-loading clothes washer platforms. 

These cost differences are due in part to the suspensions, seals, drive systems, and 

stainless-steel wash baskets that front-loading clothes washers employ and which can be simpler, 

unnecessary, and/or less expensive in baseline top-loading models. The higher strength, stiffness, 

and vibration-resistance requirements for front-loading clothes washers add further cost and 

complexity. Electronic drive systems are found in all front-loading clothes washers, whereas 

simpler and less expensive induction motors are typically found on baseline top-loading clothes 

washers. 

High-volume manufacturers of top-loading clothes washers also benefit from a plant and 

equipment stock that have been largely depreciated, yet remain functional. The growth in frontloading clothes washer sales continues to demand factory expansion and the resultant 

investments. 

As noted above, the reverse-engineering analysis of the 2000 RCW TSD is largely not a 

valid basis upon which to compare costs in the commercial market. However, it is interesting to 

note how manufacturers were able to meet the current 1.26 MEF RCW standard with little to no 

additional manufacturing cost. Thus, the cost of a baseline top-loading washer has not changed 

much in the interim, other than to reflect changes in raw materials costs. Front-loading clothes 

washer costs are similarly affected, so that the manufacturing cost differential between the two 

RCW platforms has remained largely the same. 

The retail pricing survey for this current TSD underscores this persistent differential, as 

noted in Figure 3.11.1 in chapter 3 of this TSD. This figure demonstrates that the average retail 

price difference between commercial top-loading and front-loading washers varies between $531 

for washers with coin boxes and $625 for washers without coin boxes. As noted in chapter 7 of 

this TSD, the total markup from manufacturer to end user is 1.93 for CCWs. Therefore there is a 

manufacturing cost difference of $275 to $327 between top-loading and front-loading CCW 

platforms. 

This difference is about $100 higher than the average difference calculated in the 2000 

RCW TSD between a baseline top-loading and two front-loading clothes washers that were 

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EERE-2006-STD-0127 COMMENT 69.1
subjected to reverse-engineering analysis. However, the residential designs were produced at 

much a higher manufacturing scale, suggesting higher cost optimization, better purchasing 

power, and lower raw material costs. Higher-volume manufacturing allows a manufacturer to 

consider more platform and design options that could not be economically justified at a very low 

manufacturing scale. 

Thus, the $316 cost difference in the AHAM-submitted data for top-loading and frontloading CCWs is plausible. A cost difference higher than that found in the residential market is 

reasonable since CCWs are designed to be more rugged, are required to be more reliable, and are 

produced at a much lower scale. As a consequence, manufacturers cannot readily cost-optimize 

front-loading designs to the extent that they have been able to refine their extant top-loading 

units. In addition, even an optimized front-loading CCW will remain inherently more expensive 

to produce than a high-volume residential model built on the same platform due to the volume 

over which customized items like controllers have to be depreciated. 

5.6.3 Cost-Efficiency Curves 

Based on its analysis, for this final, the Department has retained all cost estimates 

presented in the October 2008 NOPR and November 2009 SNOPR, though they were revised 

with a Producer Price Index (PPI) multiplier to update them to 2008$. These are shown in Table 

5.6.6. 

Table 5.6.6 Commercial Clothes Washer Cost-Efficiency Curves 

Efficiency 

Level 

Modified Energy Factor (ft3

/kWh) / Water Factor 

(gallons/ft3

) Incremental Cost 

Top-Loading Front-Loading 

TopLoading FrontLoading 

Baseline 1.26/9.5 1.72/8.0 $0.00 $0.00 

1 1.42/9.5 1.8/7.5 $77.60 $0.00 

2 1.60/8.5 2.0/5.5 $134.99 $14.21 

3 N/A 2.2/5.1 N/A $39.34 

4 N/A 2.35/4.4 N/A $66.16 

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