3-i

CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT

TABLE OF CONTENTS

3.1 INTRODUCTION ........................................................................................................... 3-1

3.2 PRODUCT DEFINITIONS............................................................................................. 3-1

3.3 PRODUCT CLASSES..................................................................................................... 3-1

3.4 PRODUCT TEST PROCEDURES ................................................................................. 3-2

3.5 MANUFACTURER TRADE GROUPS ......................................................................... 3-3

3.5.1 Association of Home Appliance Manufacturers.............................................................. 3-3

3.5.2 Coin Laundry Association ............................................................................................... 3-3

3.5.3 Multi-housing Laundry Association ................................................................................ 3-3

3.6 MANUFACTURER INFORMATION ........................................................................... 3-4

3.6.1 Manufacturers and Market Shares................................................................................... 3-4

3.6.2 Mergers and Acquisitions................................................................................................ 3-4

3.6.3 Small Business Impacts ................................................................................................... 3-4

3.6.4 Distribution Channels ...................................................................................................... 3-5

3.7 REGULATORY PROGRAMS ....................................................................................... 3-6

3.7.1 Energy Policy Act of 2005............................................................................................... 3-7

3.7.2 Energy Independence and Security Act of 2007.............................................................. 3-7

3.7.3 State Energy Conservation Standards.............................................................................. 3-8

3.7.4 Canadian Energy Conservation Standards....................................................................... 3-8

3.7.5 International Standby Power Regulatory Programs......................................................... 3-9

3.8 VOLUNTARY PROGRAMS........................................................................................ 3-10

3.8.1 ENERGY STAR............................................................................................................ 3-10

3.8.2 Consortium for Energy Efficiency................................................................................. 3-11

3.8.3 Federal Energy Management Program .......................................................................... 3-11

3.8.4 Manufacturer Tax Credits for Energy-Efficient Appliances ......................................... 3-11

3.8.5 Rebates for Highly Energy-Efficient Products.............................................................. 3-12

3.9 HISTORICAL SHIPMENTS......................................................................................... 3-13

3.9.1 New Multi-Family Unit Starts....................................................................................... 3-13

3.9.2 Unit Shipments............................................................................................................... 3-14

3.9.3 AHAM Data................................................................................................................... 3-15

3.9.4 Imports and Exports....................................................................................................... 3-17

3.10 HISTORICAL EFFICIENCIES..................................................................................... 3-17

3.11 PRODUCT RETAIL PRICES....................................................................................... 3-18

3.12 INDUSTRY COST STRUCTURE................................................................................ 3-20

3.13 TECHNOLOGY ASSESSMENT.................................................................................. 3-20

3.13.1 Product Operations and Components............................................................................. 3-20

3.13.2 Technology Options....................................................................................................... 3-22

3.13.2.1 Adaptive water fill .......................................................................................3-23

3.13.2.2 Advanced agitation concepts for top-loading machines..............................3-23

3.13.2.3 Capacity increase .........................................................................................3-24

3.13.2.4 Direct-drive motor .......................................................................................3-24
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3.13.2.5 Higher spin speeds to reduce remaining moisture content ..........................3-25

3.13.2.6 Increased motor efficiency...........................................................................3-26

3.13.2.7 Ozonated laundering ....................................................................................3-26

3.13.2.8 Polymer bead cleaning.................................................................................3-26

3.13.2.9 Spray rinse ...................................................................................................3-27

3.13.2.10 Temperature-differentiated pricing controls................................................3-27

3.13.2.11 Thermostatically controlled mixing valves..................................................3-27

3.13.2.12 Water circulation loop..................................................................................3-28

3.13.3 Energy Efficiency .......................................................................................................... 3-28

LIST OF TABLES

Table 3.6.1 Major and Other Commercial Clothes Washer Manufacturers................................ 3-4

Table 3.7.1 Energy Conservation Standards for Commercial Clothes Washers Established 

by EPACT 2005................................................................................................... 3-7

Table 3.7.2 Energy Conservation Standards for Commercial Clothes Washers Established 

by January 2010 Final Rule ................................................................................. 3-7

Table 3.7.3 Current Canadian Energy Conservation Standards for Household-Style 

Commercial Clothes Washers.............................................................................. 3-9

Table 3.7.4 Current Canadian Standard Levels for High-Efficiency Household-Style 

Commercial Clothes Washers.............................................................................. 3-9

Table 3.7.5 EU Ecodesign Requirements for Standby and Off Mode....................................... 3-10

Table 3.8.1 ENERGY STAR Criteria for Commercial Clothes Washers ................................. 3-11

Table 3.8.2 Manufacturer Tax Credits for Energy-Efficient Clothes Washers, 2011-2013 ...... 3-12

Table 3.9.1 New Multi-Family Housing Unit Starts in the United States from 2000-2013...... 3-14

Table 3.9.2 Industry Shipments of Commercial Clothes Washers 2002–2011 ......................... 3-15

Table 3.9.3 AHAM Commercial Clothes Washer Shipment-Weighted Average Efficiency 

Data Submittal ................................................................................................... 3-15

Table 3.9.4 AHAM Top-Loading Commercial Clothes Washer Market Share Efficiency 

Data, 2010-2013................................................................................................. 3-16

Table 3.9.5 AHAM Front-Loading Commercial Clothes Washer Market Share Efficiency 

Data, 2010-2013................................................................................................. 3-16

Table 3.9.6 Import and Export Data for Commercial Clothes Washers, 2003-2013................. 3-17

Table 3.10.1 Energy Efficiency Trends for Commercial Clothes Washers, 2002-2011 ........... 3-18

Table 3.11.1 Commercial Clothes Washer Retail Prices........................................................... 3-19

Table 3.13.1 Design Options Removed from Consideration..................................................... 3-22

Table 3.13.2 Technology Options for Residential Clothes Washers......................................... 3-23

LIST OF FIGURES

Figure 3.6.1 Distribution Channel for Commercial Clothes Washers......................................... 3-6

Figure 3.9.1 Multi-Family Housing Unit Starts, 2000–2013..................................................... 3-14

Figure 3.9.2 Annual CCW Shipments 2002-2011..................................................................... 3-15
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Figure 3.9.3 Import and Export Trends for Commercial Clothes Washers, 2003-2013............ 3-17

Figure 3.10.1 Energy Efficiency Trends for Commercial Clothes Washers, 2002-2011.......... 3-18

Figure 3.13.1 Distribution of Commercial Clothes Washers by MEF ...................................... 3-29

Figure 3.13.2 Distribution of Commercial Clothes Washers by WF......................................... 3-29
3-1

CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT

3.1 INTRODUCTION

This chapter provides a profile of the commercial clothes washer (CCW) industry in the 

United States. The U.S. Department of Energy (DOE) developed the market and technology 

assessment presented in this chapter primarily from publicly available information. This 

assessment is helpful in identifying the major manufacturers and their product characteristics, 

which form the basis for the engineering and the life-cycle cost (LCC) analyses. Present and past 

industry structure and industry financial information help DOE in the process of conducting the 

manufacturer impact analysis.

3.2 PRODUCT DEFINITIONS

The Energy Policy and Conservation Act of 1975, as amended, defines commercial 

clothes washers as follows:

The term “commercial clothes washer” means a soft-mount, front-loading or soft-mount, 

top-loading clothes washer that:

A) has a clothes compartment that:

i) for horizontal-axis clothes washers, is not more than 3.5 cubic feet; and 

ii) for vertical-axis clothes washers, is not more than 4.0 cubic feet; and 

B) is defined for use in: 

i) applications in which the occupants of more than 1 household will be using the 

clothes washer, such as multi-family housing common areas and coin laundries; 

or

ii) other commercial applications. 

(42 U.S.C. 6311(21))

3.3 PRODUCT CLASSES

DOE separated commercial clothes washers into product classes and has formulated 

separate energy conservation standards for each class. The criteria for separation into different 

product classes are: (1) type of energy used; (2) capacity; or (3) 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 the existing energy conservation standards, DOE defines two product classes for 

commercial clothes washers based on location of access:
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 Top-loading

 Front-loading

DOE maintains this product class distinction for the amended energy conservation 

standards adopted in the final rule.

3.4 PRODUCT TEST PROCEDURES

The Energy Policy and Conservation Act (EPCA), Pub. L. 94-163, 42 U.S.C. 6291 et seq, 

as amended, mandates that the test procedures for commercial clothes washers shall be the same 

as the test procedures established by DOE for residential clothes washers (RCW). (42 U.S.C. 

6314(a)(8)). The DOE test procedures for commercial clothes washers currently being 

manufactured is codified at title 10 of the Code of Federal Regulations (CFR) part 430, subpart 

B, appendix J1 (hereafter, “appendix J1”). On March 7, 2012, DOE published a final rule 

amending its test procedures for residential clothes washers (“March 2012 final rule”). (77 FR 

13888) The March 2012 final rule included minor amendments to appendix J1 and also 

established a new test procedure at appendix J2 (hereafter, “appendix J2”).

Beginning March 7, 2015, manufacturers of commercial clothes washers may use either 

appendix J1 or appendix J2 to demonstrate compliance with the current standards established by 

the January 2010 final rule. Manufacturers using appendix J2 would be required to use the 

conversion equations established in a separate test procedure rulemaking to translate the 

measured efficiency metrics into equivalent appendix J1 values.a The use of appendix J2 will be 

required to demonstrate compliance with the amended energy conservation standards established 

by this final rule, and the conversion equations will no longer be used at that time.

As described further in chapter 5 of this TSD, DOE also considered the Association of 

Home Appliance Manufacturers (AHAM) test method HLW-1-2010, “Performance Evaluation 

Procedures for Household Clothes Washers” (referred to here as “AHAM HLW-1-2010”), in 

order to evaluate potential impacts on cleaning and rinsing performance as a result of more 

stringent standard levels. AHAM HLW-1-2010 is typically used to measure the performance of 

residential clothes washers; however, given the similarity of CCWs covered in this rulemaking to 

RCWs, and through consultation with CCW manufacturers, DOE determined that AHAM HLW1-2010 would be appropriate to use for comparison testing of CCWs. Specifically, DOE 

performed the soil/stain removal, rinsing effectiveness, and sand removal tests provided in 

HLW-1-2010.

 

aAdditional details regarding DOE’s test procedure rulemaking for commercial clothes washers are available at 

DOE’s rulemaking webpage: 

http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx?ruleid=86. All rulemaking documents 

are also available at www.regulations.gov, under Docket # EERE-2013-BT-TP-0002.
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3.5 MANUFACTURER TRADE GROUPS

DOE recognizes the importance of trade groups in disseminating information and 

promoting the interests of the industry that they support. To gain insight into the commercial

clothes washer industry, DOE researched various associations available to manufacturers, 

suppliers, and users of such equipment.

DOE identified several trade groups that support, or have an interest in, the residential 

cooking product and/or CCW industries, including the Association of Home Appliance 

Manufacturers (AHAM), the Coin Laundry Association (CLA), and the Multi-housing Laundry 

Association (MLA).

3.5.1 Association of Home Appliance Manufacturers

AHAM,1formed in 1967, aims to enhance the value of the home appliance industry 

through leadership, public education and advocacy. AHAM provides services to its members 

including government relations; certification programs; an active communications program; and 

technical services and research. In addition, AHAM conducts other market and consumer 

research studies and publishes periodic industry reports. AHAM also develops and maintains 

technical standards for various appliances to provide uniform, repeatable procedures for 

measuring specific product characteristics and performance features.

3.5.2 Coin Laundry Association

The CLA2is a trade association representing the 30,000 coin laundry owners in the 

United States and around the world. Since 1960, the CLA has provided education and service to 

the entrepreneurs of the coin laundry industry, promoted their business interests, and promoted 

the industry to the general public.

3.5.3 Multi-housing Laundry Association

The MLA,3founded in 1959, is a trade association of operator and supplier companies 

providing professional laundry services for the multi-housing industry. The MLA works for a 

favorable legislative and regulatory climate for the industry, facilitates the exchange of technical 

and business information among members, and demonstrates the value of the industry to target 

markets.
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3.6 MANUFACTURER INFORMATION

3.6.1 Manufacturers and Market Shares

DOE estimates that there are five domestic and two foreign manufacturers of the types of 

commercial clothes washers covered by this rulemaking. DOE estimates that two major 

manufacturers hold over 90 percent of the market share of commercial clothes washers covered 

by DOE standards: Alliance Laundry Systems LLCband Whirlpool Corporationc. Other 

manufacturers include AB Electrolux,d Continental Girbau, Inc., General Electric, and LG. Table 

3.6.1 lists these manufacturers.

Table 3.6.1 Major and Other Commercial Clothes Washer Manufacturers

Major Manufacturers Other Manufacturers

Alliance Laundry Systems AB Electrolux

Whirlpool Continental Girbau

General Electric

LG

3.6.2 Mergers and Acquisitions

DOE described the merger between Whirlpool and Maytag, which was completed on 

March 31, 2006, in chapter 3 of the TSD accompanying the January 2010 final rule.

4

On September 8, 2014, GE announced that it had signed an agreement to sell its 

appliance business to Electrolux for $3.3 billion. As part of the transaction, GE entered into a 

long-term agreement with Electrolux to continue use of the GE Appliances brand. As of the date 

of the announcement, the transaction remains subject to regulatory approvals, and is targeted to 

close in 2015.5

3.6.3 Small Business Impacts

DOE considers the possibility of small businesses being impacted by the promulgation of 

energy conservation standards. Based on the size standards published by the Small Business 

Association (SBA) (65 FR 30840, May 15, 2000, as amended at 67 FR 52602, Aug. 13, 2002; 74 

FR 46313, Sept. 9, 2009), to be categorized as a small business manufacturer of commercial 

clothes washers under North American Industry Classification System (NAICS) 333318, “Other 

commercial and service industry machinery manufacturing,” a commercial laundry equipment 

 

b Alliance Laundry Systems markets the following brands: Speed Queen, UniMac, Huebsch, and IPSO.

c Whirlpool also markets the Maytag brand. Whirlpool merged with Maytag on March 31, 2006. 

d AB Electrolux also markets the Wascomat brand.
3-5

manufacturer and its affiliates may employ a maximum of 1000 employees. The 1000-employee

threshold includes all employees in a business’s parent company and any other subsidiaries. 

Using this classification in conjunction with a search of industry databases and the SBA member 

directory, DOE did not identify any manufacturers of commercial clothes washers that qualify as 

small businesses. 

DOE identified one low-volume manufacturer (LVM) of commercial clothes washers. 

Unlike small business manufacturers, there is no employment limit associated with LVMs. 

Instead, LVMs are characterized by their low overall production volumes relative to their 

competitors, often associated with specialization within a singular industry. In 2012, the LVM 

derived 98 percent of its revenues from the sale of laundry equipment and service parts, while, 

for its main competitor, this percentage was 30 percent. Within the clothes washer segment, 

DOE estimates that the LVM derived 88 percent of its clothes washer equipment revenues from 

the sale of commercial clothes washers covered by this rulemaking. Because the commercial 

clothes washer industry itself is characterized by low total shipments, with less than 200,000 

units sold annually in the U.S., the concentration of this manufacturer’s business in this industry 

qualifies them as an LVM. Where the LVM operates at a much smaller scale and does not 

manufacture products across a broad range of industries, this rulemaking could have 

disproportionate impacts on the LVM compared to its large, diversified competitors. 

Accordingly, DOE performed an in-depth analysis of the issues relating to the commercial 

clothes washer LVM. The manufacturer subgroup analysis is discussed in greater detail in the 

final rule and in chapter 12 of this TSD.

3.6.4 Distribution Channels

Understanding the distribution channels of products covered by this rulemaking is an 

important facet of the market assessment. DOE gathered information regarding the distribution 

channels for commercial clothes washers from publicly available sources and through 

discussions with manufacturers. Figure 3.6.1 illustrates the major CCW distribution channels, 

which were originally described in a 1998 Consortium for Energy Efficiency (CEE) report 

describing their Commercial, Family-Sized Clothes Washer Initiative.

6 Through discussions with 

CCW manufacturers, DOE has determined that these distribution channels remain relevant for 

the current CCW market.
3-6

Figure 3.6.1 Distribution Channel for Commercial Clothes Washers

The 1998 CEE report states that the CCW market can be divided into three areas, 

including: (1) laundromats; (2) private multi-family housing; and (3) large institutions (e.g., 

military barracks, universities, and housing authorities.) Most large institutions and a majority of 

private multifamily housing (between 50 and 90 percent) do not purchase clothes washers 

directly. Rather, these organizations lease their laundry space to a third party known as a route 

operator. Route operators supply laundry equipment and maintain facilities in exchange for a 

percentage of the laundry revenue. Laundromats and some private building managers, 

conversely, will purchase clothes washers directly from distributors. The main difference 

between route operators and distributors is the length of service provided to their clients. Route 

operators provide on-going support, while distributor support ends at the point of sale.

3.7 REGULATORY PROGRAMS

The following section details current regulatory programs mandating energy conservation 

standards for CCWs. 
3-7

3.7.1 Energy Policy Act of 2005

The Energy Policy Act of 2005 (EPACT 2005), P.L. 109-58, amended EPCA to expand 

DOE’s energy conservation program to include commercial clothes. This legislation established 

the first energy conservation standards for CCWs, shown in Table 3.7.1, without consideration of 

separate product classes. These standards became effective January 1, 2007.

Table 3.7.1 Energy Conservation Standards for Commercial Clothes Washers Established 

by EPACT 2005

Metric Standard Effective 

January 1, 2007

Modified Energy Factor (MEF), ft3/kwh/cycle 1.26 (minimum)

Water Factor (WF), gal/cycle/ft3 9.5 (maximum)

EPACT 2005 further directed DOE to conduct two rulemaking cycles to determine 

whether to amend these standards: the first final rule was required by January 1, 2010, which was 

fulfilled by the January 2010 final rule. Table 3.7.2 shows the amended standard levels from the 

January 2010 final rule, which became effective January 8, 2013.

Table 3.7.2 Energy Conservation Standards for Commercial Clothes Washers Established 

by January 2010 Final Rule

Standards Effective January 8, 2013

Equipment Class Modified Energy Factor

(cu.ft./kWh/cycle)

Water Factor

(gal/cycle/cu.ft)

Top-Loading ≥ 1.60 ≤ 8.5

Front-Loading ≥ 2.00 ≤ 5.5

The second final rule is required by January 1, 2015, which is fulfilled by the current 

rulemaking. (42 U.S.C. 6313(e))

3.7.2 Energy Independence and Security Act of 2007

The Energy Independence and Security Act of 2007 (EISA 2007), Pub. L. No. 110-142, 

amended EPCA to require any final rule for new or amended energy conservation standards for 

consumer products promulgated after July 1, 2010 to address standby mode and off mode energy 

use. (42 U.S.C. 6295(gg)(3)) This requirement applies to residential clothes washers but does not 

apply to commercial clothes washers, which are covered under DOE’s energy conservation 

program for certain industrial equipment (42 U.S.C. 6311-6317). Specifically, when DOE 

adopts a standard for a covered consumer product after July 1, 2010, it must, if justified by the 

criteria for adoption of standards under EPCA (42 U.S.C. 6295(o)), incorporate standby mode 

and off mode energy use into the standard, or, if that is not feasible, adopt a separate standard for 

such energy use for that product. (42 U.S.C. 6295(gg)(3)(A)-(B)) In the March 2012 final rule, 

DOE incorporated standby and off mode energy use with active mode energy use into an 
3-8

integrated metric, integrated modified energy factor (IMEF), contained in the new appendix J2 

test procedure. Appendix J2 also retains provisions for calculating modified energy factor 

(MEFJ2). The amended energy standards for CCWs are based on MEFJ2, which does not 

incorporate standby and off mode power.

3.7.3 State Energy Conservation Standards

Prior to the passage of EPACT 2005, several States proposed and adopted State-level 

efficiency regulations for commercial clothes washers that are identical, or very similar, to 

EPACT 2005 regulations. Complete details of these State-level regulations are available in 

chapter 3 of the TSD accompanying the January 2010 final rule.7 The EPACT 2005 energy and 

water use standards for CCWs preempt any State efficiency standards since they became 

effective January 1, 2007. DOE is not aware of any State-level energy conservation programs for 

commercial clothes washers since the standards from EPACT 2005 became effective.

3.7.4 Canadian Energy Conservation Standards

The Canadian government regulates the efficiency of household-style commercial clothes 

washers. The standard levels are contained in Table 11 of the Canadian Standard Association 

(CSA) C360-13 test method (“CSA C360-13”), Energy performance, water consumption and 

capacity of household clothes washers.

8 CSA C360-13 defines household-style commercial 

clothes washers as follows:

Household style commercial clothes washer means a soft-mounted front-loading or softmounted top-loading clothes washer that is designed for use in—(i) Applications in 

which the occupants of more than one household will be using the clothes washer, such 

as multi-family housing common areas and coin laundries; or (ii) other commercial 

applications.

Table 3.7.3 shows the currently applicable regulations for household-style commercial 

clothes washers from Table 11 of CSA C360-13. These standards are harmonized with the U.S. 

standards that became effective January 8, 2013.
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Table 3.7.3 Current Canadian Energy Conservation Standards for Household-Style 

Commercial Clothes Washers

Standards Effective January 8, 2013

Equipment Class

Modified Energy Factor,

L/kWh/cycle

(cu.ft./kWh/cycle)

Water Factor,

L/cycle/L

(gal/cycle/cu.ft)

Vertical-axis ≥ 45.31

(≥ 1.6)

≤ 1.13

(≤ 8.5)

Horizontal-axis ≥ 56.63

(≥ 2.0)

≤ 0.73

(≤ 5.5)

Canada also defines voluntary standard levels for high-efficiency household-style 

commercial clothes washers in Table 13 of CSA C360-13. These standards, shown in Table 

3.7.4, are consistent with the U.S. ENERGY STAR version 6.0 standards as described later in 

this chapter. These high-efficiency standard levels are not defined by product class.

Table 3.7.4 Current Canadian Standard Levels for High-Efficiency Household-Style 

Commercial Clothes Washers

Standards Effective February 1, 2013

Equipment Class

Modified Energy Factor,

L/kWh/cycle

(cu.ft./kWh/cycle)

Water Factor,

L/cycle/L

(gal/cycle/cu.ft)

Household-style commercial 

clothes washers

≥ 62.3

(≥ 2.2)

≤ 0.6

(≤ 4.5)

CSA C360-13 does not yet contain updated standards for household-style commercial 

clothes washers based on appendix J2. DOE believes that such standards may be harmonized 

with the final standards promulgated as a result of this rulemaking, and would be incorporated 

into CSA C360-13 shortly thereafter.

3.7.5 International Standby Power Regulatory Programs

The International Energy Agency (IEA) has raised awareness of standby power through 

publications, international conferences, and policy advice to governments. In 1999, the IEA 

developed the “1-Watt Plan,” which proposed reducing standby power internationally in 

electronic devices and which advocates that all countries harmonize energy policies and adopt 

the same definition and test procedure. The IEA has advocated a 1 watt (W) requirement for all 

consumer electrical products (unless specifically excluded) in standby mode. The IEA also stated 

that IEC 62301 provides an internationally sanctioned definition and test procedure for standby 

power which is now widely specified and used.9
3-10

The European Union passed the Ecodesign Directive in 2005 which calls for an 

implementing measure to reduce standby power for a specified list of energy using products, 

which include household clothes washers. DOE does not believe that these regulations would 

apply to commercial clothes washers. On December 18, 2008, the Commission of the European 

Communities published Commission Regulation (EC) No 1275/2008 containing Ecodesign 

requirements for standby and off mode electric power consumption of electrical and electronic 

household and office equipment. Table 3.7.5 presents the requirements for energy consumption 

in standby and off mode power.

10

Table 3.7.5 EU Ecodesign Requirements for Standby and Off Mode

Mode Maximum Power (Watts)

Tier 1 (effective January 07, 2010)

Off (no function) 1.0 W

Standby (only reactivation function) 1.0 W

Standby (information or status display plus reactivation function) 2.0 W

Tier 2 (effective January 07, 2013)

Off (no function) 0.5 W

Standby (only reactivation function) 0.5 W

Standby (information or status display plus reactivation function) 1.0 W

3.8 VOLUNTARY PROGRAMS

DOE reviewed several voluntary programs promoting commercial clothes washers in the 

United States. Many programs, including ENERGY STAR, CEE, and the Federal Energy 

Management Program (FEMP), establish voluntary energy conservation standards for these 

products.

3.8.1 ENERGY STAR

ENERGY STAR, a voluntary labeling program backed by the U.S. Environmental 

Protection Agency (EPA) and DOE, identifies energy efficient products through a qualification 

process. To qualify, a product must exceed Federal minimum standards by a specified amount, or 

if no Federal standard exists, exhibit selected energy saving features. The ENERGY STAR 

program works to recognize the top quartile of products on the market, meaning that 

approximately 25 percent of products on the market meet or exceed the ENERGY STAR levels. 

ENERGY STAR specifications exist for several products, including commercial clothes washers.

ENERGY STAR criteria exist for commercial clothes washers with capacities greater 

than 1.6 cubic feet.11 New criteria for CCWs became effective on February 1, 2013, shown 

below in Table 3.8.1. The ENERGY STAR program does not distinguish between product 

classes for CCWs.
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Table 3.8.1 ENERGY STAR Criteria for Commercial Clothes Washers

Standards Effective February 1, 2013

Equipment Type Modified Energy Factor

(cu.ft./kWh/cycle)

Water Factor

(gal/cycle/cu.ft)

Commercial Clothes Washers ≥ 2.2 ≤ 4.5

3.8.2 Consortium for Energy Efficiency

The CEE12 develops initiatives for its North American members to promote the 

manufacture and purchase of energy efficient products and services. The goal of the organization 

is to induce lasting structural and behavioral changes in the marketplace, resulting in the 

increased adoption of energy efficient technologies. CEE has historically maintained a 

Commercial Clothes Washer Initiative that encourages the purchase and use of energy and water 

efficient commercial clothes washers. Given recent changes to federal minimum efficiency 

standards and ENERGY STAR criteria for commercial clothes washers, the CEE Commercial 

Clothes Washer Specification is not currently active. As a result, publication of the associated 

qualifying product list is also temporarily suspended. According to information on the CEE 

website, the specification will be reinstated once the revised levels are finalized through the CEE 

specification revision process. CEE anticipates that this will be completed by the end of 2014.

3.8.3 Federal Energy Management Program

DOE’s FEMP13 works to reduce the cost and environmental impact of the Federal 

government by advancing energy efficiency and water conservation, promoting the use of 

distributed and renewable energy, and improving utility management decisions at Federal sites.

FEMP helps Federal buyers identify and purchase energy efficient equipment, including 

commercial clothes washers.

The National Energy Conservation Act (P.L. 95-619), Executive Order 13423, and 

Federal Acquisition Regulations Subpart 23.2 and 53.223 require that Federal agencies purchase 

ENERGY STAR-qualified products. Currently, the FEMP recommendations for commercial 

clothes washers are equivalent to the ENERGY STAR standard levels described above.

3.8.4 Manufacturer Tax Credits for Energy-Efficient Appliances

EPACT 2005 amended the Internal Revenue Code of 1986 (26 U.S.C. 1 et seq.) to 

establish a tax credit to manufacturers for the production in the United States of energy efficient 

CCWs. (26 U.S.C. 45M(b)(1)(B)) A credit of $100 was established for CCWs manufactured in 

the calendar year 2006 or 2007 which met the ENERGY STAR qualifying criteria in effect in 

2007. The total credit for CCWs was equal to an applicable credit amount multiplied by the 

eligible production, subject to a $75 million limit, reduced by the amount of credit taken in 

previous years. The eligible production for CCWs equaled the number of appliances produced in 
3-12

a year divided by the average number of appliances produced during the preceding 3-calendaryear period.

The Energy Improvement and Extension Act of 2008 (Pub. L. 110-343; Oct. 3, 2008) 

further amended the Internal Revenue Code of 1986 to modify and extend the manufacturer tax 

credits for CCWs to apply to equipment produced in calendar years 2008, 2009, or 2010. (26 

U.S.C. 45M(b)(2)) Eligible production was calculated over a 2-calendar-year period and the total 

credit limit calculation was reduced by the amount of credit taken in prior years beginning after 

December 31, 2007. Further, the aggregate credit amount did not apply to CCWs meeting or 

exceeding 2.2 MEF/4.5 WF. (26 U.S.C. 45M(c)(2) and (e))

The Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 

(Pub. L. 111-312) and the American Taxpayer Relief Act of 2012 (Pub. L. 112-240) further 

extended the manufacturing tax credits for all clothes washers, including CCWs, through 2013. 

(26 U.S.C. 45M(b)(2 )(B Table 3.8.2 shows the applicable tax credit amounts based on MEF and 

WF. Although CCWs are eligible to receive these tax credits, DOE’s market survey conducted 

for this rulemaking indicates that no top-loading or front-loading CCWs on the market achieve 

the MEF and WF levels required to receive the tax credits. 

Table 3.8.2 Manufacturer Tax Credits for Energy-Efficient Clothes Washers, 2011-2013

Equipment Type Modified Energy Factor

(cu.ft./kWh/cycle)

Water Factor

(gal/cycle/cu.ft)

Credit

Amount

Top-Loading Clothes Washers1 ≥ 2.2 ≤ 4.5 $175

Top-Loading Clothes Washers ≥ 2.4 ≤ 4.2 $225

Front-Loading Clothes Washer ≥ 2.8 ≤ 3.5 $225

1. Effective only in 2011

3.8.5 Rebates for Highly Energy-Efficient Products

States, electric utilities, municipalities, and other organizations promote the purchase of 

highly energy-efficient commercial clothes washers through consumer rebates. Typically, these 

programs offer rebates for products meeting existing ENERGY STAR efficiency levels. DOE

jointly manages the Database of State Incentives for Renewables & Efficiency (DSIRE), which 

lists the financial incentives available in each state for purchasing energy-efficient products, 

including CCWs.14
3-13

3.9 HISTORICAL SHIPMENTS

Awareness of annual product shipment trends is an important aspect of the market 

assessment and in the development of the standards rulemaking. DOE reviewed data collected by 

the U.S. Census Bureau and AHAM to evaluate commercial clothes washer product shipment 

trends and the value of these shipments, which were used during the shipments analysis (chapter 

9 of this TSD).

3.9.1 New Multi-Family Unit Starts

Trends in multi-family unit starts can affect shipments of commercial clothes washers.

Table 3.9.1 and 

Figure 3.9.1 show the number of new multi-family housing units (with 5 units or more) 

started in the United States from 2000-2013.

15 Over the 5-year period from 2000–2005, multifamily unit starts remained stable at around 300,000 units annually. Between 2005 and 2009, 

multi-family unit starts decreased significantly to around 100,000 units annually. Since 2009, 

multi-family unit starts have increased steadily, reaching almost 300,000 in 2013.
3-14

Table 3.9.1 New Multi-Family Housing Unit Starts in the United States from 2000-2013

Year

Multi-Unit

Housing Starts

(000’s)

Figure 3.9.1 Multi-Family Housing Unit Starts, 2000–2013

2000 299

2001 293

2002 308

2003 315

2004 303

2005 311

2006 293

2007 277

2008 266

2009 98

2010 104

2011 167

2012 234

2013 294

3.9.2 Unit Shipments

AHAM provided shipment estimates during the last rulemaking for the period 2002-

2005, and during the current rulemaking for the period 2010-2013, as presented in Table 3.9.2

and Figure 3.9.2 below.

16 After steadily declining from 191,000 total shipments in 2003 to 

161,000 in 2011, total shipments increased to 206,000 in 2013. This increase was largely driven 

by an increase in top-loading sales.
3-15

Table 3.9.2 Industry Shipments of Commercial Clothes Washers 2002–2011

Shipments (000’s)

Figure 3.9.2 Annual CCW Shipments 2002-2011

Year Total

TopLoadFrontLoad

2002 175 n/a n/a

2003 191 n/a n/a

2004 178 n/a n/a

2005 177 n/a n/a

2006 n/a n/a n/a

2007 n/a n/a n/a

2008 n/a n/a n/a

2009 n/a n/a n/a

2010 164 104 60

2011 161 107 54

2012 173 120 53

2013 206 151 55

3.9.3 AHAM Data

AHAM also provide shipment-weighted average efficiency levels disaggregated by 

product class for 2010 through 2013, as shown in Table 3.9.3. During this period, weighted MEF 

has steadily increased for both top-loading and front-loading CCWs. AHAM stated in its data 

submission that the increase in weighted WF for top-loading CCWs in 2012 and 2013 is due to 

sell-through of older models. Weighted WF for front-loading CCWs has steadily decreased 

during the period 2010-2013.

Table 3.9.3 AHAM Commercial Clothes Washer Shipment-Weighted Average Efficiency 

Data Submittal

Top-Loading Front-Loading

Year Weighted MEF Weighted WF Weighted MEF Weighted WF

2010 1.36 9.10 2.19 4.68

2011 1.32 9.33 2.31 4.43

2012 1.28 9.77 2.34 4.36

2013 1.46 9.63 2.38 4.05
3-16

AHAM also provided market share efficiency data for top-loading and front-loading 

commercial clothes washers for 2010 through 2013, as shown in Table 3.9.4 and Table 3.9.5. 

The submitted values represent the market shares for clothes washers up to the listed efficiency 

levels.

Table 3.9.4 AHAM Top-Loading Commercial Clothes Washer Market Share Efficiency 

Data, 2010-2013

Top-Loading

Efficiency Bins Market Share (%)

MEF WF 2010 2011 2012 2013

1.26 9.5 82% 80% 77% 43%

1.42 9.5 18% 20% 22% 0%

1.60 8.5 0% 0% 1% 57%

Notes:

1. 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 = 1.60 and WF = 9.0 would have been included in the 

1.42/9.5 Efficiency Bin.

2. The 2013 data for the 1.60/8.5 Efficiency Bin includes products with higher efficiency levels up to and 

including the maximum efficiency level available on the market.

Table 3.9.5 AHAM Front-Loading Commercial Clothes Washer Market Share Efficiency 

Data, 2010-2013

Front-Loading

Efficiency Bins Market Share (%)

MEF WF 2010 2011 2012 2013

< 1.72 > 8.0 2% 0% 0% 0%

1.72 8.0 1% 0% 0% 0%

1.80 7.5 1% 0% 0% 0%

2.00 5.5 28% 28% 30% 0%

2.20 5.1 68% 34% 20% 31%

2.40 4.0 0% 38% 50% 69%

2.60 3.7 0% 0% 0% 0%

Notes:

1. 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.
3-17

3.9.4 Imports and Exports

DOE obtained import and export data from the U.S. International Trade Commission’s 

DataWeb database.17 Table 3.9.6 and Figure 3.9.3 show the number of coin-operated commercial 

clothes washer imports and exports for the period 2003-2013. The quantity of exports is

substantially greater than imports. Exports have generally decreased from a peak of around 

120,000 units in 2005 to around 56,000 units in 2013. Imports have generally increased from 

around 3,800 units in 2003 to around 6,500 units in 2013.

Table 3.9.6 Import and Export Data for Commercial Clothes Washers, 2003-2013

Unit Shipments

Figure 3.9.3 Import and Export Trends for Commercial 

Clothes Washers, 2003-2013

Year Imports Exports

2003 3,780 112,110

2004 3,793 109,307

2005 3,499 120,856

2006 2,113 94,841

2007 4,581 88,382

2008 3,543 77,195

2009 2,858 54,513

2010 6,264 46,006

2011 5,701 52,391

2012 12,037 56,409

2013 6,543 56,227

3.10 HISTORICAL EFFICIENCIES

Table 3.10.1 and Figure 3.10.1 show the shipment-weighted trend in MEF from 2002-

2013. This data was provided by AHAM during the last rulemaking for the period 2002-2005, 

and during the current rulemaking for the period 2010-2013. The increase in weighted efficiency 

in 2013 is due to the amended energy conservation standards that became effective January 8, 

2013.

0

20

40

60

80

100

120

140

Shipments (thousands)

Year

Exports

Imports
3-18

Table 3.10.1 Energy Efficiency Trends for Commercial Clothes Washers, 2002-2011

Shipment-Weighted 

MEF

Figure 3.10.1 Energy Efficiency Trends for 

Commercial Clothes Washers, 2002-2011

Year Total

TopLoadFrontLoad

2002 1.30 n/a n/a

2003 1.33 n/a n/a

2004 1.33 n/a n/a

2005 1.41 n/a n/a

2006 n/a n/a n/a

2007 n/a n/a n/a

2008 n/a n/a n/a

2009 n/a n/a n/a

2010 1.66 n/a n/a

2011 1.65 1.36 2.19

2012 1.60 1.28 2.34

2013 1.71 1.46 2.38

3.11 PRODUCT RETAIL PRICES

DOE conducted a search of retail prices for CCWs by contacting several CCW distributors 

by phone and by gathering pricing data for CCW models available for sale on the Internet. Table 

3.11.1 summarizes the data collected by DOE. Where DOE obtained multiple prices for the same 

model, the average price is shown in the table.
3-19

Table 3.11.1 Commercial Clothes Washer Retail Prices

Manufacturer Model Product Class

Control Panel 

Type

Payment System 

Type Vendor Price

GE WNRD2050G Top-Loading No Vend Display None AppliancesDirect.com $682 

Alliance Laundry Systems SWNSX2PP112TW01 Top-Loading No Vend Display Coin Box Appliances Direct $909 

Alliance Laundry Systems SWNBC2PP112TW01 Top-Loading Vend Price Display Coin Box Appliances Direct $1,052 

Alliance Laundry Systems SWNLC2PP112TW01 Top-Loading Vend Price Display Coin Box Appliances Direct $1,086 

Whirlpool CAE2743BQ Top-Loading No Vend Display Coin Slide Home Depot $764 

Whirlpool MHN30PDBWW Front-Loading Vend Price Display Coin Box Appliances Connection $1,579 

Whirlpool CHW8990AW Front-Loading Vend Price Display Coin Box Whirlsource.com $1,225 

Alliance Laundry Systems SFNLCFSP* Front-Loading Vend Price Display Coin Box Yankee Equipment $1,900 

Alliance Laundry Systems SFNNCFSP* Front-Loading Vend Price Display Coin Box Yankee Equipment $1,900 

LG GCW1069* Front-Loading No Vend Display None Daniels Equipment $1,695 

GE WNRD2050G Top-Loading No Vend Display None AppliancesDirect.com $682 

Alliance Laundry Systems SWNSX2PP112TW01 Top-Loading No Vend Display Coin Box Appliances Direct $909 
3-20

Based on its market survey, DOE determined that retail price is largely a function of the 

type of loading (i.e., top-loading or front-loading) as well as whether the unit offers a control 

panel that displays vend price. Vend price display units would be primarily sold to Laundromats 

and multi-family housing laundries; whereas units with no vend price display would be used 

mostly in other commercial applications where fare is not charged.

As discussed further in chapter 8 of the TSD, DOE used manufacturing costs developed 

for specific standard levels in combination with manufacturer and distributor markups, sales 

taxes, and installation costs to establish the total installed cost differences between baseline and 

more efficient commercial clothes washers. DOE used the above range in current retail price 

differences between top-loading and front-loading clothes washers as an indication of the 

reasonableness of the total installed cost estimates that it developed for residential clothes 

washers.

3.12 INDUSTRY COST STRUCTURE

Chapter 12 of this TSD provides a detailed financial analysis of the industry cost 

structure for commercial clothes washers. This analysis identifies key financial inputs including 

cost of capital, working capital, depreciation, and capital expenditures.

3.13 TECHNOLOGY ASSESSMENT

The purpose of the technology assessment is to understand how the product uses energy 

and potential changes that could reduce energy consumption. DOE typically uses information

about “technology options”—existing technologies and prototype designs and concepts—to 

identify technologies product manufacturers could use to attain higher energy efficiency levels.

3.13.1 Product Operations and Components

In preparation for the screening and engineering analyses, DOE prepared a brief 

description of the characteristics and operation of commercial clothes washers. These 

descriptions provide a basis for understanding the technologies used to improve product 

efficiency.

Commercial clothes washers are appliances designed to clean clothes by using a solution 

of soap and/or detergent and water with mechanical agitation. Clothes washers use electricity to 

operate one or more pumps and to power an electric motor that agitates and spins the clothes. 

Clothes are washed, rinsed, and spun within a tub that is inside a cabinet. Because clothes 

washers require heated water for hot and warm water cycles, a separate water heater is typically 

needed to supply hot water. Most of the energy used by clothes washers is for water heating. 

Water is fed into the clothes washer through electrically operated water valves, one connected to 

a hot water supply line and a second connected to a cold water supply line.
3-21

Traditional top-loading clothes washers have an opening on the top of the cabinet, 

covered by a door, which gives access to the inner basket where the load to be washed is placed. 

The inner basket is typically perforated and is surrounded by a larger outer tub which holds the 

water when the machine is running. The inner basket typically contains an agitator along a 

vertical axis, which undergoes a reversing circular motion. The motion of the agitator, which is 

powered by an electric motor, circulates the clothes vertically from the bottom to the top of the 

basket. The spinning action of the inner basket and the drain pump are also powered by the 

motor. Traditional top-loading clothes washers use more water than other types of washers, and 

therefore, consume more energy during heated wash cycles. They also typically extract less 

water from laundry during the spin cycle, which results in longer drying time and greater overall

energy consumption.

Non-agitator top-loading clothes washers may have a “wash plate” rather than an agitator 

to move the clothes within the basket. These top-loading clothes washers function by partially 

filling the tub with water for wash and rinse cycles and using very high spin speeds to extract 

rinse water from the clothes during the spin cycle. These top-loading clothes washers are more 

efficient in terms of water and energy than traditional top-loaders, but their high spin speeds that 

reduce drying time (and thus dryer energy consumption) may wrinkle clothing more than 

traditional top-loader spin speeds. These machines work best with low-foaming, high efficiency 

detergent.

Front-loading clothes washers utilize a cylindrical tub or drum rotating on a horizontal or 

nearly-horizontal axis to wash clothes. Clothes are usually loaded along the axis of the 

cylindrical drum, which has led to this type of clothes washer to be called a front-loader. The 

clothes are cleaned by tumbling them in the water (i.e., clothes are lifted to the top of the drum 

by the rotation of the cylinder and then dropped into the water below.) The cylindrical drum is 

only partially filled with water for wash and rinse cycles. High spin speeds are used to extract the 

water from the clothes during the spin cycles. These clothes washers are typically more efficient 

in terms of water and energy than traditional top-loaders, but as with non-agitator top-loading 

clothes washers, their high spin speeds may wrinkle clothing.

Manufacturers typically base CCWs on existing RCW platforms. This simplifies 

fabrication and assembly (e.g. commercial and residential clothes washers can be assembled on 

the same assembly line), and helps reduce the fixed costs associated with tooling, overhead etc. 

for the (typically) much lower CCW manufacturing volumes. However, some CCW components 

are selectively upgraded to make them more rugged, reliable, and vandal-resistant. Furthermore, 

the user interface is usually simplified (presenting the commercial user with fewer wash choices 

than a residential user) and the control system is designed to interface with various payment 

systems (ranging from coin slides to magnetic card readers). Lastly, the wash cycles may be 

redesigned to allow satisfactory operation in an approximately 30-minute wash cycle.
3-22

3.13.2 Technology Options

In order to gain a deeper understanding of the technological improvements used to 

increase the efficiency of commercial clothes washers, DOE identified several possible 

technologies and examined the most common improvements used in today’s market.

For the technology assessment for this rulemaking, DOE considered a subset of the 

design options considered during the previous CCW standards rulemaking. Based on information 

published in recent trade publications, technical reports, manufacturer literature, and through 

product teardowns, DOE has observed that the results of the technology screening analysis 

performed during the previous rulemaking remain largely relevant for this rulemaking. After 

further analysis of the both the CCW and RCW markets and discussions with manufacturers of 

both CCWs and RCWs, DOE concluded that some of the technologies previously included in the 

analysis are not considered “technology options” for improving efficiency because they have 

negligible or no impact on the energy efficiency of a commercial clothes washer. Table 3.13.1

lists the specific technologies DOE eliminated from consideration and provides a brief 

justification for each.

Table 3.13.1 Design Options Removed from Consideration

Design Option Removed 

from Consideration Justification for Removal

Adaptive control systems 

(not including adaptive water 

fill controls)

DOE is not aware of any adaptive control systems for commercial clothes 

washers other than adaptive water fill controls, which are considered a separate 

design option. In addition, DOE has not found any indications of adaptive 

control systems being used to achieve energy savings in clothes washers. 

Horizontal-axis design This would be considered a design option only if DOE were to eliminate the 

product class distinction based on axis of loading. However, DOE has retained

two separate product classes, top-loading and front-loading.

Improved horizontal-axis 

washer drum design

DOE does not have any data to suggest that changes to a horizontal-axis drum 

design could provide improvements in efficiency (e.g. drum shape or hole 

patterns).

Low standby power controls DOE is proposing amended energy standards based on the MEFJ2 metric, which 

would exclude measurement of standby and off mode power.

Reduced thermal mass DOE has not found any data indicating potential energy savings due to reduced 

thermal mass of the wash basket or outer wash tub. DOE believes any such 

energy savings would be negligible.

Silver ion injection DOE has determined that silver ion injection technology is no longer available 

on the market for residential clothes washers and has not been considered as a 

technology option for commercial clothes washers.

Tighter tub tolerance DOE’s engineering analyses for prior rulemakings have indicated that 

manufacturers have already achieved the maximum feasible reduction in spacing 

between the wash basket and outer was tub, leaving little, if any, room for 

improvement.

Based on comments received from interested parties in response to the framework 

document, DOE added temperature-differentiated pricing controls as a technology option for 

consideration. Table 3.13.2 shows the complete list of technology options considered by DOE in 
3-23

the technology assessment. Detailed descriptions of each technology option are provided after 

the table.

Table 3.13.2 Technology Options for Residential Clothes Washers

1. Adaptive water fill

2. Advanced agitation concepts for top-loading machines 

3. Capacity increase

4. Direct-drive motor 

5. Higher spin speeds to reduce remaining moisture content 

6. Motor efficiency improvements

7. Ozonated laundering

8. Polymer bead cleaning

9. Spray rinse or similar water-reducing rinse technology 

10. Temperature-differentiated pricing controls

11. Thermostatically controlled mixing valves 

12. Water recirculation loop

3.13.2.1 Adaptive water fill

Adaptive water fill controls incorporate advanced control technologies to sense the size 

of the clothing load and adjust the water level accordingly. This technology option can overcome 

the tendency of consumers to manually select a water level greater than required for a given load. 

The most common implementation is a water level pressure sensor, which measures the pressure 

of the pooled water at the bottom of the tub. During the water fill portion of the cycle, dry 

clothing absorbs most of the incoming water. As the clothes become saturated, water begins 

pooling in the bottom of the wash tub. Once the pooled water reaches a predetermined height, the 

pressure will trigger the sensor to shut off the water flow.

This technology is used primarily to save water; however, energy is also saved by 

reducing the amount of hot water used in the wash cycle. DOE testing indicates that for toploading clothes washers, adaptive water fill controls can provide to up 50% energy and water 

savings compared to clothes washers with manual water fill controls. Nearly all front-load 

clothes washers already implement adaptive water fill controls, but higher efficiency can be 

achieved by implementing more sensitive water level pressure sensors. DOE estimates that such 

sensors can provide around 10% additional energy and water savings for those machines that 

already have adaptive water fill control.

3.13.2.2 Advanced agitation concepts for top-loading machines

Advanced agitation designs replace the standard agitator found in traditional top-loading 

clothes washers. The most common implementation of this technology is a rotating “impeller” 

wash plate at the bottom of the drum. A traditional agitator requires clothing to be fully 

suspended in water; as the agitator rotates, the agitator vanes catch the clothing and move the 

garments through the watear. A rotating wash plate, however, requires a much lower water level 
3-24

inside the wash tub to clean the clothing properly. The wet clothing load sits on top of the wash 

plate, and as the wash plate rotates, raised fins catch the clothing along the bottom of the wash 

tub to rotate the garments. If the wash tub contains too much water and the clothing becomes 

suspended in water, the wash plate is unable to rotate the clothing effectively. DOE believes that 

the lack of a standard agitator may encourage machine overloading in a coin laundry 

environment, and that this technology is more susceptible to producing poorer wash performance 

when overloaded compared to a traditional agitator design.

As with adaptive water fill controls, impeller wash plates are used primarily to save 

water; however, energy is also saved by reducing the amount of hot water used in the wash 

cycle. In addition, the absence of the agitator increases the available capacity for the same size 

wash tub. Advanced agitation systems add considerable complexity to the control strategies for 

top-loading clothes washers.

DOE has identified only one top-loading commercial clothes washer, manufactured by 

Whirlpool, that uses an advanced agitation concept. This clothes washer uses a rotating wash 

plate in combination with a vane-less agitator column, which is intended primarily to prevent 

over-loading of the machine by the end user.

DOE testing indicates that the use of impeller wash plates can directly contribute around 

10% energy and water savings in top-loading clothes washers.

3.13.2.3 Capacity increase

Implementing a larger tub capacity can contribute to improved efficiency because a larger 

amount of clothing can be washed using an incremental increase in the quantity of water that is 

less than the incremental increase in capacity, therefore reducing the amount of water and energy 

per pound of clothing. DOE estimates that increased capacity can contribute around 10-15% 

energy and water savings.

End-users typically value larger capacity clothes washers, so increases in tub capacity 

provide increased end-user utility. However, a larger clothes container capacity may be 

considered a detriment to coin-operated laundry owners and route operators because a larger 

capacity tub may result in fewer wash cycles performed by the end-user customer. In competitive 

markets, coin-operated laundries may not be able to sustain higher vend fares to compensate for 

the lower number of “turns” per day. In addition, based on discussions with manufacturers, 

larger tub capacities may encourage the over-loading of machines by end-user customers.

Because of these perceived negative impacts on utility, unlike the residential clothes washer 

market, manufacturers may not be willing to aggressively increase tub volumes in order to 

achieve higher efficiency levels.

3.13.2.4 Direct-drive motor

A baseline clothes washer typically uses a relatively simple and inexpensive single-speed 

or dual-speed capacitor-start induction motor, in combination with a mechanical transmission, 
3-25

and sometimes a pulley belt. A direct-drive motor can replace this conventional 

motor/transmission system. Rather than using a belt and/or transmission, a direct-drive motor is 

mounted directly to the wash tub along the axis of rotation, thus directly driving the rotation of 

the wash tub and eliminating transmission and/or gearbox losses. A direct drive motor for a 

clothes washer is typically a variable-speed, electronically-controlled permanent magnet motor.

DOE has observed increasingly widespread use of direct-drive motors in the residential 

clothes washer market, particularly for front-loading clothes washers and high-efficiency toploading clothes washers. DOE has identified only one front-loading commercial clothes washer, 

manufactured by LG, that uses a direct drive motor.

DOE testing indicates that direct-drive permanent magnet motors can reduce a clothes 

washer’s motor energy consumption by up to 50 percent; however, because motor energy 

represents such a small portion of overall clothes washer energy, total energy is reduced by 

roughly five percent.

3.13.2.5 Higher spin speeds to reduce remaining moisture content 

The clothes washer test procedure requires measuring the remaining moisture content of 

the clothing load, which is calculated as:

WI

WC WI RMC (  )



where Wc is the weight of the test cloth immediately after completion of the washer spin cycle, 

and Wi is the “bone dry” weight of the test cloth. The RMC measurement is used to determine 

the estimated drying energy that would be needed to dry the clothes in an electric clothes dryer 

after the wash cycle is complete. The drying energy is included in the MEF equation to 

encourage manufacturers to reduce the remaining moisture content of the clothing coming out of 

the clothes washer, since that will subsequently result in clothes dryer energy savings.

The most common ways to reduce the RMC include increasing the spin speed of the 

wash basket for the final spin cycle, or using a longer spin cycle. Since increasing the duration of 

the spin cycle would result in a longer total cycle time, which would negatively impact consumer 

utility, manufacturers focus mainly on increasing the spin speed of the final spin cycle.

Implementing faster spin speeds requires more advanced motor technologies, including 

electronic feedback sensing; stronger tub materials such as stainless steel; more robust bearings; 

and consumer safety protections such as locking lids.

Since mechanical water removal is more energy efficient than using heat to evaporate it, 

overall energy consumption for the combined wash and dry process is reduced. DOE testing 

indicates that faster spin speeds can reduce the calculated drying energy by 30% or more. 

Because drying energy constitutes a majority of the total energy captured in the MEF metric, this 

translates to 15-20% total energy savings.
3-26

3.13.2.6 Increased motor efficiency

Around 10 percent of the total energy factored into the MEF metric is used by the electric 

motor. The typical clothes washer has a 1⁄2 –2⁄3 horsepower single-speed or dual-speed capacitorstart induction motor. Drive system efficiency can be increased by using a buck-boost power 

factor correction circuit (PFC). This reduces inverter complexity and cost by controlling inverter 

output voltage through changing DC bus voltage without affecting performance. Using a PFC 

circuit can improve efficiency by more than 1.5 times from that of a single-phase induction 

motor.18 Three-phase induction motors have also been shown to consume 50 percent less power 

than universal commutator motors through better control of motor slip.19

3.13.2.7 Ozonated laundering

Ozonated laundering systems are available for large-scale commercial or institutional 

multi-load clothes washers. An ozone laundry system consists of a separate wall-mounted unit 

that pumps ambient air through an ozone generator, which is then directly injected into the wash 

water. The ozone may be injected into the cold water line or directly into the clothes washer

through a port located in the clothes washer sump. Once in the water, the ozone reacts with 

insoluble soils, making them soluble, after which the mechanical action of the washing separates 

the soils from the fabric. Ozone also acts as a natural disinfectant, providing sanitization in 

colder water temperatures.

Ozone laundry technology saves energy because the water is not heated for lightly to 

moderately soiled laundry. For heavily soiled laundry, temperatures of 100–110 °F are used, 

which are lower than the temperatures required in a conventional washer. The reduced water 

temperature results in energy savings of up to 89 percent. Also, since fewer chemicals are used, 

the rinse time is minimized, thereby reducing the total cycle time and water consumption.20

3.13.2.8 Polymer bead cleaning

Polymer bead cleaning uses the absorbent properties of nylon polymer beads to clean 

clothes. The nylon beads are added to the wash drum with a small amount of water and detergent 

to loosen the dirt or stains on the clothing. The clothes are tumbled with the polymer beads for 

around 45 minutes. The polarity of the nylon polymer attracts stains from the clothing. Under 

humid conditions, the polymer becomes absorbent. Dirt is attracted to the surface and then 

absorbed into the center of the bead. At the end of the cycle, the polymer beads are separated 

from the clothing through an inner drum/outer drum rotation process.

This technology was developed by Xeros Ltd. in the United Kingdom, and the company

has recently introduced this technology to the U.S. market. Research conducted by Xeros in the 

United Kingdom has shown that this technology could reduce water consumption by up to 90

percent compared to a traditional clothes washer. Including lower temperature cleaning and 

reduced detergent consumption, total laundry energy consumption could be reduced by up to 40

percent.21
3-27

3.13.2.9 Spray rinse

Traditional vertical-axis clothes washers immerse the clothing completely in water during 

the wash and rinse phases of the cleaning cycle. Spray-rinse systems eliminate the immersion 

requirement by spraying rinse water into the drum while the wash basket is rotating. The 

centrifugal force of the rotating basket pins the clothes against the outer walls and subsequently 

forces the rinse liquid through the clothes. In the process, the rinsing liquid picks up remaining 

suds and transports them into the sump, from which they are drained. Since immersion or partial 

immersion is no longer necessary, less rinse water is required.

On clothes washers that provide only a cold rinse option, spray rinse technology provides 

water savings but no energy savings. On clothes washers that provide a warm rinse option, spray 

rinse will provide energy savings by reducing the quantity of hot water consumed during the 

rinse portion of the cycle. DOE testing indicates that spray rinse technology can provide around 

25% water savings.

3.13.2.10 Temperature-differentiated pricing controls

Temperature-differentiated pricing controls offer the potential to incentivize energy 

savings by providing favorable vend pricing for lower-temperature settings. End-users may thus 

opt for lower-temperature settings than they might otherwise have selected under 

undifferentiated pricing. DOE’s market analysis confirmed the availability of this feature on 

multiple commercial clothes washer models from multiple manufacturers. DOE is not aware of 

any information regarding the extent to which this feature changes the temperature selection 

frequencies of end users.

3.13.2.11 Thermostatically controlled mixing valves

Thermostatically controlled water valves (TCWVs) are clothes washer inlet valves that 

have the ability to sense and adjust the hot and cold supply water. This technology option 

achieves energy savings by more accurately controlling inlet water temperature for hot and warm 

fills. In a typical non-thermostatically-controlled water inlet system, two solenoid valves are used 

on a timed basis; one valve opens for hot water fills while the other opens for cold water fills. 

Both solenoid valves are opened if a warm water setting is selected.

Energy can be saved with a TCWV by either reducing the hot water temperature and/or 

reducing the warm water temperature. For example, the TCWV could be used to lower the hot 

wash temperature from 135 °F to 130 °F by mixing hot water (at 135 °F test inlet conditions) 

with cold water. Warm water temperature could be similarly reduced. The energy savings can 

vary widely depending on the test standard’s specified inlet hot water temperature, the selected 

temperature of the warm water, and the amount of hot water consumed.

The TCWV technology option has the potential to overstate the real-world energy 

savings, depending on the proximity of the water heater to the installed clothes washer. When 

tested under laboratory conditions, the clothes washer is typically close to the hot water source, 
3-28

whereas this is generally not the case in a home laundry setting. A large distance between the hot 

water source and the clothes washer can create a significant temperature drop due to line losses. 

Because of these line losses, a clothes washer with a TCWV may use more hot water than 

predicted on the basis of laboratory testing. Similarly, in a real-world application, savings will 

also vary with the temperature of incoming cold water. The unheated water temperature will vary 

with both geographic location and time of year. More energy would likely be saved in cases of 

warmer “cold” supply water, as a TCWV would then reduce the amount of time a hot water 

valve is open. The amount of savings is also dependent on the set point of the TCWV, the water 

heater set point, the temperature selection of the wash (hot or warm cycle), and the location of 

the sensing thermostat controlling the inlet water valves.

3.13.2.12 Water circulation loop

Water recirculation pumps are used in some high-efficiency clothes washers to 

recirculate water out of the bottom sump and spray it back into the wash drum during certain 

parts of the cycle. This reduces the amount of unusable standing water in the sump and reduces 

the amount of new water that must be periodically introduced into the clothes washer.

DOE testing indicates that water recirculation pumps can provide water and energy 

savings of around 5-10%.

3.13.3 Energy Efficiency

In preparation for the screening and engineering analyses, DOE gathered data on the 

energy efficiency of commercial clothes washers available in the marketplace in November 

2013. While this section is not intended to provide a complete characterization of the energy 

efficiency of all commercial clothes washers currently available and in use, it does provide an 

overview of the vast majority of units available currently on the market.

DOE used its Compliance Certification Database to identify CCW models on the 

market.22 As of November 2013, DOE’s database contains 253 CCW models. DOE excluded any 

models in the database that do not achieve the new standard levels effective January 8, 2013. A 

large number of these models belong to the same basic model. DOE defines a “basic model” as

all units of a given type of covered product (or class thereof) manufactured by one manufacturer, 

having the same primary energy source, and which have essentially identical electrical, physical, 

and functional (or hydraulic) characteristics that affect energy consumption, energy efficiency, 

water consumption, or water efficiency. (10 CFR 430.2) After filtering out non-unique basic 

models and models that do not achieve the January 8, 2013 standards, DOE identified 8 toploading basic models and 11 front-loading basic models available on the market.

Figure 3.13.1 displays the distribution of commercial clothes washers as a function of 

MEF, as measured using appendix J1. As shown in the figure, no overlap exists between the 

MEF ratings of top-loading and front-loading CCWs. Top-loading MEF values range from 1.60 

to 1.85, and front-loading MEF values range from 2.20 to 2.60.
3-29

 

Figure 3.13.1 Distribution of Commercial Clothes Washers by MEF

Figure 3.13.2 displays the distribution of commercial clothes washers as a function of 

WF, as measured using appendix J1. As shown in the figure, no overlap exists between the WF 

ratings of top-loading and front-loading CCWs. Top-loading WF values range from 6.2 to 8.5, 

and front-loading WF values range from 3.7 to 4.5.

Figure 3.13.2 Distribution of Commercial Clothes Washers by WF

0

1

2

3

4

5

6

1.5 1.6 1.7 1.8 1.9 2.0 2.1 2.2 2.3 2.4 2.5 2.6 2.7

Frequency

MEF (based on Appendix J1)

Top-Loading

Front-Loading

0

1

2

3

4

5

3.03.43.84.24.65.05.45.86.26.67.07.47.88.28.6

Frequency

WF (based on Appendix J1)

Top-Loading

Front-Loading
3-30

REFERENCES

1 Association of Home Appliance Manufacturers website: www.aham.org.

2 Coin Laundry Association website: For more information, visit www.coinlaundry.org

3 Multi-Housing Laundry Association website: http://www.mla-online.com/

4 Technical Support Document accompanying the January 8, 2010 final rule is available at

http://www.regulations.gov/#!documentDetail;D=EERE-2006-STD-0127-0118.

5 GE Appliances. “GE Agrees to Sell Appliances Business to Electrolux for $3.3B.” 

September 8, 2014. Available online at: http://pressroom.geappliances.com/news/ge-agreesto-sell-appliances-business-to-electrolux-for-3-3b

6 CEE, Commercial Family-Sized Washers: An Initiative Description, 1998. No longer 

accessible online.

7 Technical Support Document accompanying the January 8, 2010 final rule is available at

http://www.regulations.gov/#!documentDetail;D=EERE-2006-STD-0127-0118.

8 CSA C360-13 available at http://shop.csa.ca/en/canada/energy-efficiency/c360-

13/invt/27019792013. The CSA C360-03 test method has been superseded by C360-13 and 

is no longer available online.

9

Internation Energy Agency website: http://www.iea.org/.

10 Commission of the European Communities. 2008. “Commission Regulation (EC) No. 

1275/2008 of 17 December 2008 implementing Directive 2005/32/EC of the European 

Parliament and of the Council with regard to ecodesign requirements for standby and off

mode electric power consumption of electrical and electronic household and office 

equipment.” December 18, 2008. Available online at http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:339:0045:0052:EN:PDF (Accessed 

December 2009)

11 ENERGY STAR criteria for commercial clothes washers: 

http://www.energystar.gov/index.cfm?c=clotheswash.pr_crit_clothes_washers

12 Consortium for Energy Efficiency website: http://www.cee1.org.

13 Federal Energy Management Program website: http://www.eere.energy.gov/femp.

14 Database of State Incentives for Renewables & Efficiency website: www.dsireusa.org

 
3-31

 

15 U.S. Census Bureau. “New Residential Construction.” Accessed online at 

http://www.census.gov/construction/nrc/.

16 AHAM shipment data submissions.

2006 data submission available at: http://www.regulations.gov/#!documentDetail;D=EERE2006-STD-0127-0031

2012 data submission available at: http://www.regulations.gov/#!documentDetail;D=EERE2012-BT-STD-0020-0013

2014 data submission available at: http://www.regulations.gov/#!documentDetail;D=EERE2012-BT-STD-0020-0032

17 U.S. International Trade Commission. “USITC Interactive Tariff and Trade DataWeb.” 

Accessed online at http://dataweb.usitc.gov, Feb. 2014.

18 Hoghani, J.S. and Heidari, M. “High Efficient Low Cost Induction Motor Drive for 

Residential Applications.” 2006 International Symposium of Power Electronics, Electrical 

Drives, Automation and Motion. IEEE. pp. 1399-1402. May 26, 2006.

19 Bourgeois, J.-M. “Energy Saving Motor Controls for Washing Machines.” Electronik. Vol. 

50, No. 12, pp. 58-61. July 12, 2001. 

20 “Cold Facts: Textile/Linen Wear Study of Traditional versus EcoTex Ozone Laundry Wash 

Practices.” Clearwater Tech, LLC. Available at http://www.cwtozone.com.

21 Xeros Bead Cleaning website: http://www.xeroscleaning.com/

22 DOE Compliance Certification Database: http://www.regulations.doe.gov/certificationdata/CCMS-79222370561.html