APPENDIX A – DRAFT ENGINEERING ANALYSIS DATA REQUEST SHEETS

DOE seeks average incremental production cost to take basic models in the categories shown 

from the current DOE minimum efficiency level (or proposed baseline level) to the specified 

efficiency level. For those product classes where more than one basic model may exist, please 

indicate the minimum and maximum incremental costs that would be incurred across the array of 

basic models.

The data sheets are divided by product and contain tables requesting shipment and manufacturer 

cost data. The shipment-weighted energy use data of Table A-2 should be based on the DOE 

clothes washer test procedure (10 CFR 430, subpart B, appendix J1, J2).

Shipments

For commercial clothes washers, the AHAM 2005 Fact Book offers historical shipments data, 

but the information is not disaggregated by product class. As shown in the “shipment request” 

tables below, DOE hopes to collect both shipments data and shipment-weighted average 

efficiency data dating back to 1995. In addition, DOE hopes to collect market share efficiency 

data (i.e., data on the distribution of equipment shipments by efficiency) for each product class. 

Manufacturer Costs

Incremental cost data (in U.S. dollars) include the materials, labor, and overhead needed to take 

basic models from the current minimum DOE baseline efficiency standard to each higher 

efficiency level. The depreciation of the conversion capital expenditures is an important 

component of the overhead for DOE to understand. Therefore, DOE is requesting information 

about conversion capital expenditures by efficiency level.

DOE requests notification from those interested parties planning to submit data by the close of 

the framework comment period.

Please provide aggregated industry data for the following tables.
Table A-1 Commercial Clothes Washer Shipments, Domestic plus Imports, in

Thousands of Units

Year Total Top-Loading % Imported Front-Loading % Imported

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010 164,196 104,159 * 60,037 *

2011 160,973 106,592 * 54,381 *

For the type of data requested in the table above, it is AHAM’s policy to only retain 

the previous two calendar years of data collected from its members. 

*AHAM only has collected domestic shipment data from its members. 
Table A-2 Shipment-Weighted Average Efficiency Data 

Top-Loading Front-Loading

Year EF / MEF / IMEF* WF / IWF† EF / MEF / IMEF* WF / IWF†

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010 1.36 (MEF) 9.10 (WF) 2.19 (MEF) 4.68 (WF)

2011 1.32 (MEF) 9.33 (WF) 2.31 (MEF) 4.43 (WF)

* Please specify whether energy factor (EF), modified energy factor (MEF), or integrated modified energy 

factor (IMEF).

† Please specify whether water factor (WF) or integrated water factor (IWF).

For the type of data requested in the table above, it is AHAM’s policy to only retain 

the previous two calendar years of data collected from its members.
Table A-3 Market Share Efficiency Data*

Top-Loading Front-Loading

Efficiency Bins Market Share†

(Percent) Efficiency Bins Market Share†(Percent)

MEF WF 2009 2010 2011 MEF WF 2009 2010 2011

1.26 9.5 82% 80% 1.72 8.0 1% 0%

1.42 9.5 18% 20% 1.80 7.5 1% 0%

1.60‡ 8.5‡ 0% 0% 2.00‡ 5.5‡ 28% 28%

2.20 5.1 68% 34%

2.40 4.0 0% 38%

2.60 3.7 0% 0%

* Efficiency bins correspond to those used during the prior CCW rulemaking in addition to the proposed 

TSLs for this rulemaking. 

† Total market shares should equal 100%.

‡ January 8, 2013 DOE standard.

For the type of data requested in the table above, it is AHAM’s policy to only retain 

the previous two calendar years of data collected from its members. 

Notes:

• Models with MEF/WF data not meeting the criteria for both MEF and WF for any 

of the Efficiency Bins in the table above were included in the Efficiency Bin for 

which the value of the lesser efficient, MEF or WF, is satisfied. For example, a 

model with a MEF = 2.01 and WF = 5.6 would have been included in the 1.80/7.5 

Efficiency Bin.

 

• The percentages for the Front-Loading may not add up to 100% due to the absence 

of the current Federal Minimum Standard levels from the MEF/WF Efficiency Bins 

listed in the table. 
Table A-4 Aggregate Manufacturer Cost Data: Front-Loading Commercial Clothes 

Washers

Efficiency Level Baseline Level 1 Level 2 Level 3

MEF 2.00 2.20 2.40 2.60

WF 5.5 4.5 4.0 3.7

Average Incremental Costs ($ Per Unit)*

Direct Material 0

Direct Labor 0

Overhead# 0

Minimum Incremental Costs ($ Per Unit)*

Direct Material 0

Direct Labor 0

Overhead# 0

Maximum Incremental Costs ($ Per Unit)*

Direct Material 0

Direct Labor 0

Overhead# 0

Conversion Capital Expenditures ($, Millions)

Building CAPX 0

Tooling/ Equipment CAPX 0

R&D 0

Marketing 0

* Incremental costs per unit should be reported relative to the baseline unit’s cost.

# Depreciation on the conversion capital expenditure should NOT be included in incremental overhead. 

_______________________________________________.

Direct material – Costs of raw materials including scrap that can be traced to final or end products. Direct material 

costs do not include indirect material costs, which are attributed to supplies that may be used in the production 

process but are not assigned to final products (e.g., lubricating oil for production machinery).

Direct labor – The earnings of workers who assemble parts into a finished good or operate machines in the 

production process. Direct labor includes the fringe benefits of direct laborers, such as group health care, as well as 

overtime pay. Direct labor does not include indirect labor, which is defined as the earnings of employees who do not 

work directly in assembling equipment, such as supervisors, janitors, stockroom personnel, and forklift operators.

Overhead – Factory overhead excluding depreciation. Factory overhead includes indirect labor, downtime, set-up 

costs, indirect material, expendable tools, maintenance, property taxes, insurance on assets, and utility costs. Factory 

overhead does not include selling, general, and administrative costs (SG&A); R&D; interest; or profit (accounted for 

by DOE separately).

AHAM has not collected the type of data requested in the table above from its 

members. 
Manufacturer Impact Analysis Questions:

• What fraction of the Commercial Clothes Washer manufacturing industry is represented 

by AHAM? Please indicate if this is by quantity or value of shipments.

Response: AHAM does not collect total commercial clothes washer shipments, and so 

we cannot provide a response to this question.

• Are you aware of, or do you represent any small business or low volume manufacturers? 

Please identify them. 

• In the absence of new standards, do you expect any industry consolidation?

• Could new standards disproportionately advance or harm the competitive positions of 

some firms?

• Could new standards result in disproportionate economic or performance penalties for 

particular consumer/user subgroups?

• Beyond price and energy efficiency, could new standards result in products that will be 

more or less desirable to consumers due to changes in product functionality, utility, or 

other features?

• What distribution channels are used from the manufacturer to the retail outlet? What is 

the share of product going through each distribution channel?