CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT 

TABLE OF CONTENTS 

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

3.2 PRODUCT AND EQUIPMENT DEFINITIONS ........................................................... 3-1 

3.3 PRODUCT AND EQUIPMENT CLASSES................................................................... 3-2 

3.4 PRODUCT AND EQUIPMENT TEST PROCEDURES................................................ 3-7 

3.5 MANUFACTURER TRADE GROUPS ......................................................................... 3-9 

3.5.1 Association of Home Appliance Manufacturers............................................................ 3-10 

3.5.2 Coin Laundry Association ............................................................................................. 3-10
 

3.5.3 Multi-housing Laundry Association .............................................................................. 3-10 

3.6 MANUFACTURER INFORMATION ......................................................................... 3-10 

3.6.1 Manufacturers and Market Shares ................................................................................. 3-10 

3.6.2 Mergers and Acquisitions .............................................................................................. 3-15 

3.6.3 Small Business Impacts ................................................................................................. 3-17 

3.6.4 Distribution Channels .................................................................................................... 3-17 

3.7 REGULATORY PROGRAMS ..................................................................................... 3-18 

3.7.1 Federal Energy Conservation Standards Prior to EPACT 2005 .................................... 3-19 

3.7.2 Energy Policy Act of 2005............................................................................................. 3-19 

3.7.3 Energy Independence and Security Act of 2007............................................................ 3-19 

3.7.4 Standards Adopted as Part of This Rulemaking ............................................................ 3-21 

3.7.5 State Energy Conservation Standards............................................................................ 3-21 

3.7.6 Canadian Energy Conservation Standards..................................................................... 3-23 

3.7.7 Foreign Standby Power Regulatory Programs............................................................... 3-23 

3.8 VOLUNTARY PROGRAMS........................................................................................ 3-26 

3.8.1 Consortium for Energy Efficiency................................................................................. 3-26 

3.8.2 ENERGY STAR ............................................................................................................ 3-26 

3.8.3 Federal Energy Management Program .......................................................................... 3-27 

3.8.4 Manufacturer Tax Credits for Energy-Efficient Appliances ......................................... 3-27 

3.9 HISTORICAL SHIPMENTS......................................................................................... 3-28 

3.9.1 New Home Starts ........................................................................................................... 3-28 

3.9.2 Unit Shipments............................................................................................................... 3-29 

3.9.3 Value of Shipments........................................................................................................ 3-30 

3.9.4 Imports and Exports....................................................................................................... 3-32 

3.10 MARKET SATURATION ............................................................................................ 3-33 

3.11 PRODUCT RETAIL PRICES ....................................................................................... 3-33 

3.11.1 Gas Ranges with Standard Ovens: Standing Pilot Ignition versus Pilotless Ignition.... 3-34 

3.11.2 Commercial Clothes Washers........................................................................................ 3-36 

3.12 INDUSTRY COST STRUCTURE................................................................................ 3-39 

3.13 INVENTORY LEVELS AND CAPACITY UTILIZATION RATES.......................... 3-40 

3.14 TECHNOLOGY ASSESSMENT.................................................................................. 3-42 

3.14.1 Product and Equipment Operation and Components..................................................... 3-42 

3.14.1.1 Cooking Products......................................................................................... 3-42 

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EERE-2006-STD-0127 COMMENT 69.1
3.14.1.2 Commercial Clothes Washers...................................................................... 3-46 

3.14.2 Technology Options....................................................................................................... 3-47 

3.14.2.1 Cooking Products......................................................................................... 3-47 

3.14.2.2 Commercial Clothes Washers...................................................................... 3-72 

3.14.3 Energy Efficiency .......................................................................................................... 3-83 

3.14.3.1 Cooking Products......................................................................................... 3-83 

3.14.3.2 Commercial Clothes Washers...................................................................... 3-91 

LIST OF TABLES 

Table 3.6.1 Major and Other Range, Oven and Cooktop Manufacturers................................. 3-13 

Table 3.6.2 Major and Other Microwave Oven Manufacturers................................................ 3-13 

Table 3.6.3 Major and Other Commercial Clothes Washer Manufacturers ............................. 3-14 

Table 3.6.4 Core Appliance Manufacturers.............................................................................. 3-15 

Table 3.7.1 EPACT 2005 Standards for Commercial Clothes Washers................................... 3-19 

Table 3.7.2 State Commercial Clothes Washer Regulations Similar to EPACT 2005............. 3-21 

Table 3.7.3 California State Efficiency Standards for Commercial Clothes Washers ............. 3-22 

Table 3.7.4 California Water Conservation Standards for Residential Clothes Washers......... 3-22 

Table 3.7.5 Canadian Energy Conservation Standards for Electric Cooking Products............ 3-23 

Table 3.7.6 Canadian Energy Conservation Standards for Residential Clothes Washers........ 3-23 

Table 3.8.1 CEE Criteria for Commercial Clothes Washers .................................................... 3-26 

Table 3.8.2 ENERGY STAR Criteria for Commercial Clothes Washers ................................ 3-27 

Table 3.8.3 FEMP Recommendations for Microwave Ovens .................................................. 3-27 

Table 3.8.4 FEMP Recommendations for Commercial Clothes Washers................................ 3-27 

Table 3.8.5 Manufacturer Tax Credits for Energy-Efficient CCWs in EIEA 2008 .................. 3-28 

Table 3.9.1 Industry Shipments of Cooking Products (Domestic and Import in 

Thousands of Units)........................................................................................... 3-30 

Table 3.9.2 2005 ENERGY STAR Shipments by Product (Domestic and Import)................. 3-30 

Table 3.9.3 Household Appliance Manufacturing Statistics by Year....................................... 3-31 

Table 3.9.4 Disposition of Previous Appliance (Percentage)................................................... 3-31 

Table 3.9.5 Household Cooking Appliance Manufacturing Statistics by Year........................ 3-32 

Table 3.9.6 2007–2008 Imports of Appliances Covered by this Rulemaking.......................... 3-32 

Table 3.9.7 2007–2008 Exports of Appliances Covered by this Rulemaking ......................... 3-33 

Table 3.10.1 Appliance Saturation (Number in Millions) and Percentage of U.S. 

Households with Product ................................................................................... 3-33 

Table 3.11.1 Residential Appliance Retail Prices..................................................................... 3-34 

Table 3.11.2 Gas Standard Range Retail Prices for Standing Pilot and Pilotless Ignition 

Systems .............................................................................................................. 3-35 

Table 3.11.3 Commercial Clothes Washer Retail Prices.......................................................... 3-37 

Table 3.12.1 Household Appliance Industry Employment and Earnings................................. 3-39 

Table 3.12.2 Household Appliance Industry Census Data ....................................................... 3-40 

Table 3.12.3 Industry Cost Structure Using SEC Data............................................................. 3-40 

Table 3.13.1 Household Appliance Industry Census Data ....................................................... 3-41 

Table 3.13.2 Full Production Capacity Utilization Rates ......................................................... 3-42 

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EERE-2006-STD-0127 COMMENT 69.1
 

 

Table 3.14.1 Technology Options for Gas Cooktops ............................................................... 3-48 

Table 3.14.2 Technology Options for Open (Coil) Element Electric Cooktops....................... 3-54 

Table 3.14.3 Technology Options for Smooth Element Electric Cooktops ............................. 3-56 

Table 3.14.4 Technology Options for Gas and Electric Ovens ................................................ 3-58 

Table 3.14.5 Technology Options for Microwave Ovens – Energy Factor.............................. 3-66 

Table 3.14.6 Technology Options for Microwave Oven – Standby Power.............................. 3-70 

Table 3.14.7 Technology Options for Commercial Clothes Washers ...................................... 3-73 

LIST OF FIGURES 

Figure 3.6.1 2007 Market Shares for the Domestic Electric Range Market............................. 3-11 

Figure 3.6.2 2007 Market Shares for the Domestic Gas Range Market................................... 3-12 

Figure 3.6.3 2006 Market Shares for the Domestic Microwave Oven Market......................... 3-14 

Figure 3.6.4 2007 Core Appliance Market Shares.................................................................... 3-15 

Figure 3.6.5 Commercial Clothes Washer Distribution Channels............................................ 3-18 

Figure 3.9.1 New Privately Owned Single-Family and Multi-Family Housing Unit Starts 

in the United States from 1998–2008 ............................................................... 3-29 

Figure 3.11.1 Commercial Clothes Washer Retail Prices as a Function of Loading-Type 

and Presence of Coin Box.................................................................................. 3-38 

Figure 3.14.1 Standard Electric Ranges in the NRCan Database ............................................. 3-84 

Figure 3.14.2 Self-Cleaning Electric Ranges in the NRCan Database ..................................... 3-85 

Figure 3.14.3 Electric Cooktops in the NRCan Database......................................................... 3-85 

Figure 3.14.4 Self-Cleaning Electric Ovens in the NRCan Database....................................... 3-86 

Figure 3.14.5 Non-Self-Cleaning Electric Ovens in the NRCan Database .............................. 3-87 

Figure 3.14.6 AHAM Microwave Oven Efficiency versus Rated Output Power .................... 3-88 

Figure 3.14.7 AHAM Microwave Oven Efficiency versus Oven Volume............................... 3-89 

Figure 3.14.8 AHAM and CBEEDAC Microwave Oven Standby Power versus Rated 

Output Power,

..................................................................................................... 3-90 

Figure 3.14.9 Microwave Oven Standby Power Consumption from the FEMP Database....... 3-91 

Figure 3.14.10 Commercial Clothes Washer MEFs in the CEC, ENERGY STAR, and 

CEE Databases ................................................................................................. 3-92 

Figure 3.14.11 Commercial Clothes Washer WFs in the CEC, ENERGY STAR, and 

CEE Databases ................................................................................................. 3-93 

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EERE-2006-STD-0127 COMMENT 69.1
CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT 

3.1 INTRODUCTION 

This chapter provides a profile of the residential cooking product and commercial clothes 

washer (CCW) industries 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 AND EQUIPMENT DEFINITIONS 

DOE defines “cooking products” under the Energy Policy and Conservation Act 

(EPCA) of 1975 (42 U.S.C. 6291–6309) as “consumer products that are used as the major 

household cooking appliances. They are designed to cook or heat different types of food by one 

or more of the following sources of heat: gas, electricity, or microwave energy. Each product 

may consist of a horizontal cooking top containing one or more surface units and/or one or more 

heating compartments. They must be one of the following classes: conventional ranges, 

conventional cooking tops, conventional ovens, microwave ovens, microwave/conventional 

ranges and other cooking products.” (10 CFR 430.2) 

The Energy Policy Act of 2005 (EPACT 2005) (Pub. L. 109-58) established the 

definition of a commercial clothes washer 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. 

(EPACT 2005, section 136(a)(4)) 

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EERE-2006-STD-0127 COMMENT 69.1
 

 

 

3.3 PRODUCT AND EQUIPMENT CLASSES 

DOE separated each product and equipmenta (residential cooking products and CCWs) 

into classes. When evaluating and establishing energy conservation standards, DOE divides 

covered products and equipment into different classes using the following criteria: (1) type of 

energy used, 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 cooking products, the product classes defined by DOE are based on energy source 

(i.e., gas or electric) and the cooking method (i.e., cooktops, ovens, and microwave ovens). 

There are five cooking product classes: (1) gas cooktops; (2) electric cooktops; (3) gas ovens; (4) 

electric ovens; and (5) microwave ovens. DOE’s product classes are based on the list of classes 

defined by DOE in its 1996 Technical Support Document for Residential Cooking Products 

(1996 TSD), which was released as part of the previous standards rulemaking.b Gas and electric 

rangesc are not listed below as product classes. Because ranges consist of both a cooktop and 

oven, any potential cooktop and oven standards would apply to the individual components of the 

range. As a result, product classes for ranges are not necessary. 

For gas cooktops, DOE’s defined product class is: 

• Conventional burners. 

Commercial-style gas burners, which are characterized by firing rates greater than 14,000 

British thermal units per hour (Btu/h) were not considered for analysis due to a lack of available 

data for determining efficiency characteristics. In addition, the test procedure for gas cooktops is 

based on measuring temperature rise in an aluminum block with a diameter dictated by the firing 

rate of the burner. The maximum diameter of the test block is sufficient to measure higher output 

residential-scale burners. For commercial-type burners that must have larger diameter burner 

rings to accomplish complete combustion, however, this maximum test block diameter may be 

too small to achieve proper heat transfer and may not be representative of the dimensions of 

suitable cookware. 

For electric cooktops, DOE’s 1996 TSD determined that the ease of cleaning smooth 

elements provides enhanced consumer utility over coil elements. Because smooth elements 

typically use more energy than coil elements, DOE defined the following product classes for 

electric cooktops: 

• Low or high wattage open (coil) elements; and 

• Smooth elements. 

a

 The term “product” is used generally to refer to consumer appliances, while “equipment” is used generally to refer 

to commercial units. 

b

 Available online at www.eere.energy.gov/buildings/appliance_standards/residential/cooking_products.html 

c

 DOE defines a “conventional range” under EPCA as “a class of kitchen ranges and ovens which is a household 

cooking appliance consisting of a conventional cooking top and one or more conventional ovens.” (10 CFR 430.2) 

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EERE-2006-STD-0127 COMMENT 69.1
DOE determined for the notice of proposed rulemaking (NOPR) for these products that 

was published on October 17, 2008 (October 2008 NOPR) that gas and electric grills and 

griddles would not be analyzed because DOE is not aware of any data upon which it can base a 

determination of either adequacy of the test procedure to measure energy efficiency or energy 

efficiency characteristics of products in these niche classes. 

For electric ovens, the 1996 TSD determined that the type of oven-cleaning system is a 

utility feature that affects performance. DOE found that standard ovens and ovens using a 

catalytic continuous-cleaning process use roughly the same amount of energy. On the other hand, 

self-cleaning ovens use a pyrolytic process that provides enhanced consumer utility with lower 

overall energy consumption as compared to either standard or catalytically lined ovens. Thus, 

DOE defined the following product classes for electric ovens: 

• Standard oven with or without a catalytic line; and 

• Self-clean oven. 

For gas ovens, for the same reasons as for electric ovens, DOE defined the following 

product classes: 

• Standard oven with or without a catalytic line; and 

• Self-clean oven. 

DOE proposed in the advance notice of proposed rulemaking (ANOPR), published on 

November 15, 2007 (November 2007 ANOPR), that standing pilot ignition systems do not 

provide unique utility that would warrant a separate product class for gas cooking products 

incorporating them. 72 FR 64432, 64463 (Nov. 15, 2007). In considering standing pilot ignition 

systems as either a separate product class or a design option, DOE notes that the purpose of such 

systems is to ignite the gas when burner operation is called for during a cooking process, and 

either standing pilot or electronic ignition provides this function. In addition, DOE has concluded 

from previous analysis that the average consumer does not experience frequent enough or long 

enough power outages to consider the ability to operate in the event of an electric power outage a 

significant utility. 

DOE notes that the Energy Independence and Security Act of 2007 (EISA 2007; Pub. L. 

110-140) amended EPCA provide an exception from the residential boiler energy conservation 

standards for “[a] boiler that is manufactured to operate without any need for electricity or any 

electric connection, electric gauges, electric pumps, electric wires, or electric devices. . . .” (42 

U.S.C. 6295(f)(3)(C)) Such units are typically equipped with a standing pilot. The October 2008 

NOPR referred indirectly to this exception by stating that DOE addressed it in its residential 

furnace and boiler rulemaking. 73 FR 62034, 62048 (Oct. 17, 2008). DOE is clarifying this 

statement as follows. DOE’s full rulemaking analysis (conducted prior to passage of EISA 2007) 

did not result in such an exception in its most recent energy conservation standards rulemaking 

for residential furnaces and boilers. 72 FR 65136 (Nov. 19, 2007). However, DOE subsequently 

published a final rule in the form of a technical amendment whose sole purpose was to codify the 

EISA 2007 amendments to EPCA pertaining to residential furnace and boiler standards set by 

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EERE-2006-STD-0127 COMMENT 69.1
statute, including the exception above. 73 FR 43611, 43613 (July 28, 2008). Because the July 28, 

2008 rule implemented statutory provisions over which the Department had no rulemaking 

discretion, DOE did not conduct any supporting analysis or provide any input on this boiler 

exclusion. Congress incorporated this exclusion in the energy conservation standards for boilers, 

but Congress chose not to include a similar provision for gas cooking products with standing 

pilots. Accordingly, DOE used the applicable EPCA provisions for determining whether 

performance-related features warrant separate energy conservation standards (42 U.S.C. 

6295(q)(1)), and DOE determined in the October 2008 NOPR that it would be unable to create a 

similar exception for gas cooking products because there is no unique utility associated with gas 

cooking products equipped with standing pilot ignition, compared to those with electronic 

ignition. 73 FR 62034, 62048 (Oct. 17, 2008). DOE based this understanding on its tentative 

conclusion that there is not expected to be any appreciable difference in cooking performance 

between gas cooking products with or without a standing pilot and that battery-powered 

electronic ignition systems could provide ignition in the absence of line power (i.e., electricity 

from the utility grid). Id. 

Through market research conducted for the October 2008 NOPR, DOE determined that 

battery-powered electronic ignition systems have been implemented in other products, such as 

instantaneous gas water heaters, barbeques, furnaces, and other appliances, and the use of such 

ignition systems appeared acceptable under the applicable safety standards contained in the 

American National Standards Institute (ANSI) Z21.1-2005 and Addenda 1-2007, Household 

Cooking Gas Appliances (ANSI Z21.1). Therefore, subgroups with religious and cultural 

practices which prohibit the use of line electricity (i.e., electricity from the utility grid), or that do 

not have line electricity available, could still use gas cooking products without standing pilots, 

assuming gas cooking products would be made available with battery-powered ignition. 

Furthermore, there is not expected to be any appreciable difference in cooking performance 

between gas cooking products with or without a standing pilot. Thus, DOE concluded in the 

October 2008 NOPR (73 FR 62034, 62048 (Oct. 17, 2008)) that standing pilot ignition systems 

do not provide a distinct utility and that a separate class for standing pilot ignition systems is not 

warranted under section 325(q)(1) of EPCA. (42 U.S.C. 6295(q)(1)) 

DOE continues to believe that the consumer utility that would need to be maintained for 

these subgroups is the same as for all consumers (i.e., the ability to ignite the cooking product 

under the nominal conditions of installation, which for these consumer subgroups includes the 

absence of electrical service.) DOE also considered whether additional utility is conferred by the 

ability to provide ignition during an atypical event such as a loss of line power for those 

consumers who have electrical service, but DOE did not receive additional information regarding 

duration and frequency of power outages that would lead it to conclude that the ability to operate 

during such an event represents significant utility. Therefore, DOE maintained in a final rule 

published April 8, 2009 (74 FR 16040; the “April 2009 Final Rule”) that there is no unique 

utility provided by standing pilot ignition systems, and that a separate product class for gas 

cooking products incorporating standing pilots is not warranted under 42 U.S.C. 6295(q). In 

making this determination, however, DOE recognized that achieving safe ignition in gas cooking 

products for consumer subgroups without electricity in the home in the absence of standing pilot 

ignition requires an alternative ignition technology that does not rely on line power. As discussed 

in detail in section 3.14.2.1, DOE identified battery-powered ignition systems as a potential 

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EERE-2006-STD-0127 COMMENT 69.1
alternative to standing pilots, and believes that such systems will likely be commercially 

available to these consumer subgroups at the time the energy conservation standards adopted by 

the April 2009 Final Rule are effective. 

Commercial-style gas ovens, with larger cavity volumes (i.e., those that correspond to 

cabinet widths of 36 inches) and higher firing rate burners (i.e., greater than 22,500 Btu/h), were 

not analyzed as a separate product class. DOE recognizes that the test procedure may not 

adequately measure performance of commercial-style ovens because the single test block may 

not adequately measure the temperature distribution that is inherent with these products. Further, 

DOE is unaware of efficiency data or data evaluating the adequacy of the test procedure, so 

therefore did not conduct an analysis on this product class in this rulemaking. 

For microwave ovens, DOE defined no further class breakdown. This product class can 

encompass microwave ovens with and without browning elements, but does not include 

microwave ovens that incorporate convection systems (combination ovens). DOE did not 

conduct an analysis for this rulemaking of combination microwave ovens due to a lack of data 

evaluating the applicability of the test procedure to microwave ovens incoporating convection 

systems. 

For commercial clothes washers, DOE defined the following equipment classes based 

on the method of access: 

• Top-loading washers 

• Front-loading washers 

Typically, top-loading clothes washers (also known as top-loaders) have a wash basket 

that rotates around a vertical axis, while front-loader clothes washers (also known as frontloaders) have a wash basket that rotates around a horizontal axis. DOE is aware of one U.S. 

manufacturer with negligible market share that produces horizontal-axis residential clothes 

washers (RCWs) which are accessible from the top, using a hatch in the wash basket. For the 

purposes of this analysis, however, the terms “vertical-axis” and “top-loading” are used 

interchangeably, as will the terms “horizontal-axis” and “front-loading.” Additionally, clothes 

washers that have a wash basket whose axis of rotation is tilted from horizontal are considered to 

be horizontal-axis machines for the purposes of this analysis. 

In the November 2007 ANOPR, DOE stated that it planned to consider a single class for 

CCWs in accordance with the prescriptive standards for such equipment set in EPACT 2005. 72 

FR 64432, 64465 (Nov. 15, 2007). Through EPACT 2005, Congress imposed a minimum energy 

efficiency threshold for all CCWs to meet. EPACT 2005 placed all CCWs into a single 

equipment class with a single energy efficiency and water efficiency standard for all covered 

equipment. Id. Accordingly, these standards encompass both top-loading and front-loading 

CCWs. 

DOE has the authority to establish additional classes within the CCW equipment 

category, if warranted. 72 FR 64432 (Nov. 15, 2007). In considering whether separate classes are 

warranted, DOE must consider the utility and performance characteristics to determine whether 

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EERE-2006-STD-0127 COMMENT 69.1
 

 

 

the relevant requirements have been met. (42 U.S.C. 6295(q); 6313(a)) Among the criteria DOE 

considered when examining potential separate product classes for clothes washers was the wash 

basket axis of rotation, which DOE also used for RCWs. (See 10 CFR 430.32(g)) 

Although DOE considered issuing a single CCW equipment class in the November 2007 

ANOPR that would encompass both top-loading and front-loading CCWs, further consideration 

of the relevant statutory provisions and the public comments on the November 2007 ANOPR led 

DOE to conclude that EPCA does not permit adoption of a standard that would eliminate toploading CCWs. Accordingly, for the reasons explained below, DOE decided for the October 

2008 NOPR to establish two classes of CCWs based upon axis of access (i.e., top-loading or 

front-loading). 

When directing the Secretary to consider amendments to the energy efficiency standards 

for CCWs, Congress did not mandate use of a single class or alter other relevant provisions of 

the statute related to setting classes. First, under 42 U.S.C. 6311(21), the definition of 

“commercial clothes washer” specifically includes both horizontal-axis clothes washers (frontloading machines) and vertical-axis clothes washers (top-loading machines). Further, the 

prescriptive standards for CCWs (1.26 Modified Energy Factor (MEF)/9.5 Water Factor (WF)), 

as set forth in 42 U.S.C. 6313(e), are achievable by both top-loading and front-loading machines. 

Neither provision indicates an intention to eliminate either type of CCW currently available. 

Next, 42 U.S.C. 6295(o)(4)d

 provides, “The Secretary may not prescribe an amended or 

new standard ... that is likely to result in the unavailability in the United States in any covered 

product type (or class) of performance characteristics (including reliability), features, sizes, 

capacities, and volumes that are substantially the same as those generally available in the United 

States at the time of the Secretary’s finding.” This statutory provision demonstrates 

congressional intent to forego potential energy savings under certain enumerated circumstances. 

DOE determined that this provision applies to the present CCW rulemaking. 

In previous rulemakings, DOE concluded that the method of “loading” clothes in washers 

(axis of access) is a “feature” within the meaning of 42 U.S.C. 6295(o)(4) and, consequently, 

established separate equipment classes for top-loading and front-loading RCWs. 56 FR 22263 

(May 14, 1991). DOE reiterated this position in denying the California Energy Commission’s 

(CEC) petition for waiver from Federal preemption of its RCW regulation.e 71 FR 78157 (Dec. 

28, 2006). DOE denied the CEC petition for three separate and independent reasons, one of 

which was that “interested parties demonstrated by a preponderance of evidence that the State of 

California regulation would likely result in the unavailability of a class of residential clothes 

washers in California. ... [T]he rule would violate EPCA in another way, i.e., it would mandate 

the 6.0 WF standard in 2010, which would likely result in the unavailability of top-loader 

residential clothes washers.” Id. at 78157–58. Given the similarities in technologies and design 

and operating characteristics between RCWs and CCWs, in DOE’s judgment, it determined for 

d

 This provision is also applicable to CCWs, pursuant to 42 U.S.C. 6316(a). 

e DOE’s denial of the CEC petition was reversed by the Ninth Circuit and the petition was remanded for further 

review. (California Energy Comm’n v. DOE, No. 07-71576 (October 28, 2009)). 

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EERE-2006-STD-0127 COMMENT 69.1
 

the October 2008 NOPR that the axis of access must be accorded similar treatment in the context 

of the current CCW rulemaking. 73 FR 62034, 62050 (Oct. 17, 2008). 

DOE concluded for the October 2008 NOPR that if it were to propose an amended 

standard for CCWs under the statutory criteria set forth in EPCA based upon a single equipment 

class, the result would be a standard that would effectively eliminate top-loading CCWs from the 

market, because it would set an MEF for all CCWs at a level significantly higher than the maxtech for top-loading machines. Because such a standard would violate the statute (42 U.S.C. 

6295(o)(4); 6313(a)), DOE decided to propose separate equipment classes and accompanying 

standards for top-loading and front-loading CCWs in the October 2008 NOPR. Id. at 62049–50. 

DOE maintained these classes for the supplemental notice of proposed rulemaking (SNOPR), 

published November 9, 2009 (November 2009 SNOPR). 74 FR 57738, 57746–47. 

For the final rule, DOE concludes, consistent with its preliminary conclusion in the 

October 2007 NOPR and November 2008 SNOPR, that top-loading involves consumer utilities 

that, in the context of CCWs, are a feature for purposes of 42 U.S.C. 6295(o)(4). Therefore, DOE 

is maintaining separate equipment classes for top-loading and front-loading CCWs. 

3.4 PRODUCT AND EQUIPMENT TEST PROCEDURES 

Test procedures exist for all products and equipment covered by this rulemaking to 

determine energy efficiency and annual energy use as the basis for representation and 

determination of compliance with energy conservation standards. DOE established test 

procedures for residential cooking products and clothes washers through the rulemaking process. 

EPACT 2005 established a test procedure for CCWs. 

DOE revised its test procedure for cooking products to more accurately measure their 

efficiency and energy use. For DOE’s cooking products test procedure, DOE published the 

revisions as a final rule in 1997; these included: (1) a reduction in the annual useful cooking 

energy; (2) a reduction in the number of self-cleaning oven cycles per year; and (3) incorporation 

of portions of the International Electrotechnical Commission (IEC) Standard 705-1998 and 

Amendment 2-1993, Methods for measuring the performance of microwave ovens for household 

and similar purposes (IEC Standard 705) for the cooking performance testing of microwave 

ovens. (62 FR 51976, (October 3, 1997); 10 CFR part 430, subpart B, appendix I) Note that as of 

1997, IEC has established a new numbering convention for standards. This test procedure has 

accordingly been assigned the publication number IEC Standard 60705, and the current test 

procedure is IEC Standard 60705 Edition 3.2-2006 (IEC Standard 60705).f 

Section 310 of EISA 2007 amends Section 325 of the EPCA to require that that the test 

procedures for ranges and ovens and microwave ovens be amended to include measurement of 

standby mode and off mode power, taking into consideration the most current version of IEC 

Standard 62301, Household electrical appliances—Measurement of standby power (IEC 

Standard 62301) and IEC Standard 62087, Methods of measurement for the power consumption 

f

 For more information visit www.iec.ch. 

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EERE-2006-STD-0127 COMMENT 69.1
 

 

of audio, video and related equipment.

g

 EPCA, as amended by EISA 2007, also states that the 

final rule for this test procedure shall be published no later than March 31, 2011. (42 U.S.C. 

6295(gg)) DOE notes that the current version of IEC Standard 62301 is designated IEC Standard 

62301 Ed. 1.0-2005-06. DOE is also aware that IEC has proposed an updated standard, IEC 

Standard 62301 Ed. 2.0, that, in part, amends the definitions of modes to include off mode(s), 

network connected standby mode(s), and disconnected mode as well as standby mode(s). 

However, this revision to IEC Standard 62301 is not expected to be finalized until after the final 

rule is published for this overall rulemaking. 

DOE believes separate test procedure rulemakings for standby mode and off mode power 

for microwave ovens and conventional cooking products are warranted. DOE does not have any 

data on standby power consumption in conventional cooking products that indicate the potential 

for significant energy savings. Accordingly, DOE is considering test procedure amendments for 

conventional cooking products in a later rulemaking that meets the March 31, 2011, deadline set 

by the EISA 2007 amendments to EPCA. (42 U.S.C. 6295(gg)(2)(B)) 

For microwave ovens, a test procedure change to incorporate standby mode and off mode 

power was initiated in parallel with the current rulemaking. On December 17, 2008, DOE 

published a microwave oven test procedure NOPR in which it proposed: (1) to incorporate by 

reference into its microwave oven test procedure specific clauses from IEC Standard 62301 as to 

methods for measuring average standby mode and average off mode power consumption; (2) to 

incorporate into that test procedure pertinent definitions that are set forth in EISA 2007 

amendments to EPCA; and (3) to adopt language to clarify the application of certain of the 

clauses that DOE proposes to incorporate by reference from IEC Standard 62301. 73 FR 62134 

(Oct. 17, 2008). In the MWO test procedure NOPR, DOE also proposed a technical correction to 

an equation in the existing microwave oven test procedure, which concerns energy use in the 

active mode. Id. at 62137, 62141–42. DOE received comments on the October 2008 NOPR 

which objected to certain definitions that were included in the proposed microwave oven test 

procedure amendments. The commenters supported the incorporation of definitions provided in a 

revision of IEC Standard 62301 expected to be completed later that year. 

DOE believes that it is beneficial to harmonize, where possible, its standards and test 

procedures with those of other countries and international agencies, particularly in the area of 

standby power. DOE recognizes that IEC Standard 62301 is an internationally accepted test 

standard for the measurement of standby power in residential appliances, and that it would be 

beneficial to many manufacturers to be required to meet only a single standby power standard 

because they produce microwave ovens for markets in multiple countries. In considering a 

standby power standard for microwave ovens, along with associated amendments to the 

microwave oven test procedure, DOE proposed to incorporate language for definitions of “active 

mode”, “standby mode”, and “off mode” as provided by the EISA 2007 amendments to EPCA. 

(42 U.S.C. 6295(gg)(1)(A)) However, in directing DOE to amend its test procedures to address 

standby and off mode power consumption, the EISA 2007 amendments to EPCA allow DOE to 

amend the EPCA definitions of these modes, while requiring that DOE take “into consideration 

the most current versions” of IEC Standard 62301 and IEC Standard 62087. (42 U.S.C. 

g

 IEC Standard 62087 does not cover any products for this rulemaking, and therefore was not considered. 

3-8
 

EERE-2006-STD-0127 COMMENT 69.1
6295(gg)(1)(B) and (2)(A)) In light of these statutory provisions and recognizing the benefits of 

harmonization, DOE decided to continue this rulemaking, as to microwave oven standby power 

standards, until the language in the second edition of IEC Standard 62301 is finalized, which was 

expected to occur by July 2009. However, the publication date of IEC Standard 62301 has since 

been delayed until late 2010. Therefore, DOE decided it would consider further modifications to 

DOE’s microwave oven test procedure, particularly the “standby mode” and “off mode” 

definitions in consideration of the language provided in the most recent draft version of the 

second edition of IEC Standard 62301, and, on the basis of such amended test procedures, DOE 

will analyze potential energy conservation standards for microwave oven standby mode and off 

mode energy consumption. DOE anticipates issuing SNOPRs for microwave oven energy 

conservation standards and the microwave oven test procedure in order to obtain public input on 

DOE’s updated proposals regarding microwave oven standby mode and off mode energy 

consumption. As part of such SNOPRs, DOE will carefully consider and address any microwave 

oven-related comments on the October 2008 NOPR that remain relevant. At that time, this TSD 

will be updated to reflect additional information on microwave oven that DOE has received and 

research it has conducted. 

EPACT 2005 amended EPCA to require that commercial clothes washers be rated 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. DOE 

recognizes that the use of the RCW test procedure could provide an opportunity for CCW 

manufacturers to incorporate design options for which the RCW test procedure gives credit, but 

which are unlikely to save energy in CCWs or provide additional utility to consumers under 

actual operating conditions. For example, adaptive fill and load selector switches are unlikely to 

be used by CCW consumers, who generally pay a fixed fee per load and who are thus 

incentivized to run full-sized loads and/or select the maximum fill setting. While DOE believes 

commercial laundry practices likely differ from residential practices, DOE does not consider 

these differences to warrant the amendment of the CCW test procedure, since the characteristic 

energy and water use for CCWs are taken into account in the NOPR (and SNOPR) analyses. 

DOE recognizes that in certain situations, the controls and/or operation of a CCW can be such 

that certain design features (e.g., fill level) can be set so that the CCW will not necessarily 

achieve the same energy and water savings that might be expected for RCWs. However, DOE 

does not have sufficient usage data to alter its preliminary conclusion that the existing RCW test 

procedure is adequate to measure the energy consumption of CCWs. 

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 residential 

cooking product and CCW industries, DOE researched various associations available to 

manufacturers, suppliers, and users of such equipment. DOE also used the member lists of these 

groups in the construction of an exhaustive database containing domestic manufacturers. 

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 

3-9
 

EERE-2006-STD-0127 COMMENT 69.1
 

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

Association (MLA). 

3.5.1 Association of Home Appliance Manufacturers 

AHAM,h formed 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 for room air conditioners, dehumidifiers 

and room air cleaners; an active communications program; and technical services and research. 

In addition, AHAM conducts other market and consumer research studies and publishes a 

biennial Fact Book. 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 CLA,i based in Downers Grove, Illinois, is 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,j founded 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. 

3.6 MANUFACTURER INFORMATION 

The following section details information regarding domestic manufacturers of 

residential cooking products and CCWs, including estimated market shares (section 3.6.1), 

industry mergers and acquisitions (section 3.6.2), potential small business impacts (section 

3.6.3), and product distribution channels (section 3.6.4). 

3.6.1 Manufacturers and Market Shares 

Using publicly available data (e.g. Appliance Magazine and market assessments done by 

third parties), DOE estimates the market shares for domestic manufacturers of each of the 

h

 For more information visit www.aham.org. 

i

 For more information visit www.coinlaundry.org. 

j

 For more information visit www.mla-online.com. 

3-10
 

EERE-2006-STD-0127 COMMENT 69.1
products contained in this standards rulemaking. Manufacturers may offer multiple brand names. 

Some of the brand names come from independent appliance manufacturers which have been 

acquired over time, and domestic manufacturers may put their brand on a product manufactured 

overseas. Companies included in this analysis may also be off-shore manufacturers that maintain 

a significant domestic presence via a U.S. entity. 

For cooking products (including ovens, cooktops, and ranges) DOE estimates that there 

are approximately 16 domestic manufacturers. As discussed in section 3.6.2, Maytag 

Corporation (Maytag) and Whirlpool Corporation (Whirlpool) merged in 2006 but have 

continued to maintain both product lines to this date. GE Consumer & Industrial (GE) and 

Whirlpool represent nearly three quarters of the electric range products market. GE represents 

over a third of the gas range products market, while the combined Whirlpool and Maytag 

comprise over a quarter. AB Electrolux (Frigidaire), Peerless-Premier Appliance Co. (PeerlessPremier), and other small manufacturers make up the difference in both markets. Figure 3.6.1 

and Figure 3.6.2 illustrate the 2007 market shares for the domestic residential electric and gas 

range markets, respectively. 

Peerless Premier, 

5% 

Maytag, 7% 

Electrolux 

(Frigidaire), 9% 

GE, 48% 

Whirlpool, 22% 

Others, 9% 

Figure 3.6.1 2007 Market Shares for the Domestic Electric Range Market1 

3-11
 

EERE-2006-STD-0127 COMMENT 69.1
Others, 5%
 

Peerless Premier,
 

7%
 

Whirlpool, 11% GE, 38% 

Maytag, 14% 

Electrolux 

(Frigidaire), 25% 

Figure 3.6.2 2007 Market Shares for the Domestic Gas Range Market2 

In addition to the manufacturers presented above, manufacturers of ovens, cooktops, and 

ranges also include BSH Home Appliances Corporation (Bosch-Siemens) (which acquired 

Thermador Corporation), Dacor, Inc. (Dacor), De’Longhi America, Inc. (De’Longhi), Fagor 

America Inc. (Fagor), Fisher & Paykel Appliances Limited (Fisher & Paykel) (which acquired 

Dynamic Cooking Systems Inc.), Haier America Trading, LLC (Haier), Miele, Inc. (Miele), 

Kenyon International, Inc. (Kenyon), Sub-Zero Freezer Company, Inc. (Sub-Zero) (which 

acquired the residential division of the Wolf Appliance Company (Wolf)), Felix Storch, Inc. 

(Summit), and Viking Range Corporation (Viking). Table 3.6.1 lists these manufacturers. 

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EERE-2006-STD-0127 COMMENT 69.1
 

 

 

Table 3.6.1 Major and Other Range, Oven and Cooktop Manufacturers 

Major Manufacturers Other Manufacturers 

GE Peerless-Premier 

Whirlpool Bosch-Siemens 

Maytag Dacor 

Frigidaire De’Longhi 

Fagor 

Fisher & Paykel 

Haier 

Miele 

Kenyon 

Sub-Zero 

Summit 

Viking

 The microwave oven market differs from the rest of the domestic cooking product 

market in that many of the manufacturers are foreign-owned companies with manufacturing 

facilities outside of the United States, and many of the domestic appliance manufacturers rebrand 

foreign-manufactured products. Table 3.6.2 illustrates the 2006k

 market shares for the U.S. 

microwave oven market. Microwave oven manufacturers with facilities inside the United States 

include Maytag, the Sharp Electronics Corporation (Sharp), Sub-Zero, Summit, and Viking. 

Figure 3.6.3 lists microwave manufacturers active in the domestic market. 

Table 3.6.2 Major and Other Microwave Oven Manufacturers 

Major Manufacturers Other Manufacturers 

LG Electronics, Inc. (LG) Daewoo Electronics Company, Ltd. (Daewoo) 

Sharp Panasonic Corporation of America (Panasonic) 

Samsung Electronics America, Inc. (Samsung) Whirlpool 

Guangdong Galanz Enterprise Co., Ltd. (Galanz) 

GD Midea Microwave Oven Mfg. Co., Ltd. (Midea) 

Sanyo 

Sub-Zero 

Summit 

Viking 

k

 The September 2008 issue of Appliance Magazine did not provide 2007 market share data for microwave ovens. 

3-13 

EERE-2006-STD-0127 COMMENT 69.1
 

 

Others, 12% 

Whirlpool, 4%
 

LG Electronics, 35%
 

Panasonic, 8% 

Daewoo, 8% 

Samsung, 12% 

Figure 3.6.3 2006 Market Shares for the Domestic Microwave Oven Market3

 For commercial clothes washers, DOE estimates that there are six domestic and three 

foreign manufacturers. The majority of market share is held by four major manufacturers, 

including Alliance Laundry Systems LLC (Alliance), Maytag, Whirlpool, and GE.4 Other 

manufacturers include AB Electrolux (Electrolux)l

, Continental Girbau, Inc. (Continental), LG, 

Staber Industries, Inc. (Staber), and Bermil Industries Corporation (Wascomat). Table 3.6.3 lists 

these manufacturers. 

Table 3.6.3 Major and Other Commercial Clothes Washer Manufacturers 

Sharp, 21% 

Major Manufacturers Other Manufacturers 

Alliance Electrolux 

Maytag Continental 

Whirlpool LG 

GE Staber 

 Wascomat 

l

 Commercial clothes washers are marketed under the Electrolux Professional brand, as opposed to residential 

clothes washers which are primarily marketed under the Frigidaire brand. 

3-14 

EERE-2006-STD-0127 COMMENT 69.1
3.6.2 Mergers and Acquisitions 

Due to mergers and acquisitions, the home appliance industry continues to consolidate. 

While this phenomenon varies from product to product within the industry, the large market 

shares of a few companies provide evidence in support of this characterization. 

According to the September 2008 issue of Appliance Magazine, four manufacturers 

comprise 85 percent of the core appliance market share. “Core appliances” include dishwashers, 

clothes dryers, freezers, ranges, refrigerators, and clothes washers. Table 3.6.4 lists these core 

appliance manufacturers, and Figure 3.6.4 illustrates the breakdown of 2007 market shares in the 

core appliance category. 

Table 3.6.4 Core Appliance Manufacturers 

Core Appliance Manufacturers 

Whirlpool 

GE 

Frigidaire 

Maytag 

Other, 12% 

Haier, 3% 

Whirlpool, 32% 

Maytag, 12% 

Electrolux 

(Frigidaire), 16% 

GE, 25%
 

Figure 3.6.4 2007 Core Appliance Market Shares5 

On August 22, 2005, Whirlpool, headquartered in Benton Harbor, Michigan, and Maytag, 

based in Newton, Iowa, announced plans to merge in a deal worth $2.7 billion.6 Maytag 

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EERE-2006-STD-0127 COMMENT 69.1
 

shareholders approved the merger on December 22, 2005. Shortly after announcing the merger, 

Whirlpool submitted a pre-merger notification to the U.S. Department of Justice (DOJ). The DOJ 

Antitrust Division initiated an investigation, scheduled to end February 27, 2006, into the effects 

of the merger, including potential lessening of competition or the creation of a monopoly. 

Following this initial review, the DOJ asked for additional materials from each company and 

extended the review to March 30, 2006. 

Opponents of the merger asserted that the combined companies would control as much as 

70 percent of the residential laundry market and as much as 50 percent of the residential 

dishwasher market.7

 Whirlpool claimed that their large potential residential laundry market 

share was skewed because the company produces washing machines for Sears, which sells them 

under their Kenmore in-house brand. Whirlpool went on to say that they must periodically bid 

with other manufacturers to keep the Kenmore contract and that Sears controls the pricing of the 

Kenmore units.8 

In early January 2006, U.S. Senator Tom Harkin and U.S. Representative Leonard 

Boswell, both of Iowa, called upon the DOJ to block the merger, claiming it would give 

Whirlpool an unfair advantage in the home appliance industry. The Congressmen wrote, that if 

the DOJ does not block the deal, the agency should at least “require that Whirlpool divest the 

washer and dryer portions of Maytag to a viable purchaser who will have the financial capability 

and desire to continue to operate that business.”9 

On March 29, 2006, DOJ closed its investigation and approved the merger. DOJ claims 

“that the proposed transaction is not likely to reduce competition substantially. The combination 

of strong rival suppliers with the ability to expand sales significantly and large cost savings and 

other efficiencies that Whirlpool appears likely to achieve indicates that this transaction is not 

likely to harm consumer welfare.”10 

The DOJ Antitrust Division focused its investigation on residential laundry, although it 

considered impacts across all products offered by the two companies. DOJ determined that the 

merger would not give Whirlpool excessive market power in the sale of its products and that any 

attempt to raise prices would likely be unsuccessful. In support of this claim, DOJ noted that (1) 

other U.S. brands, including Kenmore, GE, and Frigidaire, are well established; (2) foreign 

manufacturers, including LG and Samsung, are gaining market share; (3) existing U.S. 

manufacturers are below production capacity; (4) the large home appliance retailers have 

alternatives available to resist price increase attempts; and (5) Whirlpool and Maytag 

substantiated large cost savings and other efficiencies that would benefit consumers.11 

Whirlpool and Maytag completed the merger on March 31, 2006. This large merger 

follows several other mergers and acquisitions in the home appliance industry. For example, 

Maytag acquired Jenn-Air Corporation (Jenn-Air) in 1982, Magic Chef, Inc. (Magic Chef) in 

1986, and Amana Appliances (Amana) in 2001. Whirlpool acquired the KitchenAid division of 

Hobart Corporation (KitchenAid) in 1986. White Consolidated Industries (WCI) acquired the 

Frigidaire division of General Motors Corporation in 1979, and AB Electrolux acquired WCI 

(and therefore Frigidaire) in 1986. 

3-16
 

EERE-2006-STD-0127 COMMENT 69.1
3.6.3 Small Business Impacts 

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

energy conservation standards for residential cooking products and CCWs. At this time, DOE is 

aware of two small cooking products manufacturers, defined by the Small Business Association 

(SBA) as having 750 employees or fewer, who produce products that fall under this rulemaking 

and who, therefore, would be impacted by a minimum efficiency standard. DOE evaluated the 

potential impacts on these small businesses as part of the manufacturer impact analysis (MIA), 

which it conducted as a part of the October 2008 NOPR and April 2009 Final Rule analyses. For 

CCWs, manufacturers with 500 or fewer employees are classified by the SBA as small 

businesses. DOE is unaware of any such CCW manufacturers. For further information on the 

cooking products small businesses, see chapter 13 of the April 2009 Final Rule 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 residential cooking products and CCWs from publicly available sources. This 

section contains distribution channel information for residential appliances and CCWs. 

The distribution chain for residential appliances, including cooking products, differs from 

commercial products, as the majority of consumers purchase their appliances directly from 

retailers. These retailers include: (1) home improvement, appliance, and department stores; (2) 

Internet retailers; (3) membership warehouse clubs; and (4) kitchen remodelers. The AHAM 

Fact Book 2005 reports that home improvement stores claim nearly one out of every four dollars 

spent on appliances.12 

Home appliance retailers generally obtain products directly from manufacturers. The 

AHAM Fact Book 2003 shows that over 93 percent of residential appliances are distributed from 

the manufacturer directly to a retailer.13 

For commercial clothes washers, DOE used a 1998 Consortium for Energy Efficiency 

(CEE) report describing their Commercial, Family-Sized Clothes Washer Initiative (see section 

3.8.1 of this TSD).14 This report includes an assessment of the CCW market. Figure 3.6.5 

illustrates the CCW distribution channels identified in this report, which DOE believes are 

representative of the current market as well. 

CEE reports 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.15 

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EERE-2006-STD-0127 COMMENT 69.1
Manufacturer

Route Operator

Distributor (some 

overlap with route 

operators)

Private & 

Institutional 

Building Manager

( 85%)

Laundromat

(~15%)

According to CEE’s report, there are between 2 and 3 million CCWs installed in the 

United States. In general, these washers are replaced at a rate of 10 percent per year, resulting in 

a replacement of approximately 200,000 to 300,000 washers annually. In its 2007 CCW data 

submittal, AHAM reported somewhat lower shipment volumes of 175,000 to 190,000 units per 

year from 2002–2005. CEE also reports that, of this annual replacement total, approximately 15 

percent go to laundromats while 85 percent go to the multi-family sector.16 DOE updated this 

estimate for the final rule (see chapter 11 of this TSD). 

~

Manufacturer 

Route Operator 

Distributor (some 

overlap with route 

operators) 

Private & 

Institutional 

Building Manager 

(~85%) 

Laundromat 

(~15%) 

Source: CEE, Commercial, Family-Sized Washers: An Initiative 

Description ofption of the Consortium for Energy Efficiency, 1998. 

Figure 3.6.5 Commercial Clothes Washer Distribution Channels 

3.7 REGULATORY PROGRAMS 

The following section details current regulatory programs mandating energy conservation 

standards for residential cooking products and CCWs. Section 3.7.1 discusses Federal energy 

conservation standards prior to EPACT 2005, section 3.7.2 reviews new standards issued by 

EPACT 2005, section 3.7.3 reviews upcoming standards under EISA 2007, section 3.7.4 presents 

standards adopted for cooking products as part of this current rulemaking, and section 3.7.5 

provides an overview of existing State standards. In addition, section 3.7.6 reviews standards in 

Canada that may impact the companies servicing the North American market and section 3.7.7 

reviews foreign standby power regulatory programs. 

3-18
 

EERE-2006-STD-0127 COMMENT 69.1
 

 

3.7.1 Federal Energy Conservation Standards Prior to EPACT 2005 

The National Appliance Energy Conservation Act of 1987 (NAECA) (42 U.S.C. 6291­

6309) amended EPCA to establish prescriptive standards for gas cooking products, requiring 

gas ranges and ovens with an electrical supply cord not to be equipped with constant burning 

pilots and directed DOE to conduct two cycles of rulemakings to determine if more stringent 

standards are justified. (42 U.S.C. 6295 (h)(1)-(2)) DOE initially analyzed standards for cooking 

products as part of an eight-product standards rulemaking. It issued a NOPR on March 4, 1994, 

proposing performance standards for gas and electric residential cooking products, including 

microwave ovens. 59 FR 10464. In accordance with its Procedures for Consideration of New or 

Revised Energy Conservation Standards for Consumer Products (the “Process Rule”) (61 FR 

36974 (July 15, 1996); 10 CFR part 430, subpart C, appendix A), DOE refined its standards 

analysis of cooking products. With regard to gas cooking products, DOE focused on the 

economic justification for eliminating standing pilots. Partially due to the difficulty of 

conclusively demonstrating that elimination of standing pilots was economically justified, DOE 

issued a final rule on September 8, 1998, that covered only electric cooking products, including 

microwave ovens. 63 FR 48038. The final rule found that standards were not economically 

justified for electric cooking products. DOE never completed that standards rulemaking for gas 

cooking products. 

3.7.2 Energy Policy Act of 2005 

On August 8, 2005, the President signed into law EPACT 2005. This legislation 

established energy conservation standards for several residential and commercial products, 

including commercial clothes washers. Without consideration for product classes, section 

136(e) of EPACT 2005 amends section 342 of EPCA, 42 U.S.C. 6313, to add subsection (e) for 

CCWs, which establishes energy and water conservation standards. These Federally mandated 

standards for CCWs became the national standards when they took effect on January 1, 2007. 

Table 3.7.1 provides EPACT 2005 standards for CCWs. 

Table 3.7.1 EPACT 2005 Standards for Commercial Clothes Washers 

Clothes Washer Classification Standards Effective January 1, 2007 

MEF* (ft3

/kWh/cycle) WF* (gallons/ ft3/cycle) 

Top- and front-loading 1.26 9.5 

*The Modified Energy Factor (MEF), is a measure of how many kilowatt-hours (kWh) are required to wash each 

cubic foot (ft3

) of washer capacity. It measures the total energy consumption of the washer and also accounts for the 

amount of energy required to dry clothes based on the remaining moisture content of the clothes. Water Factor (WF) 

is measured in gallons of water required per cycle per cubic foot of washer capacity. 

New subsection 342(e), 42 U.S.C. 6313(e) also requires that DOE issue a final rule by 

January 1, 2010, to determine whether these standards for CCWs should be amended. 

3.7.3 Energy Independence and Security Act of 2007 

On December 19, 2007, the President signed into law EISA 2007, which contains 

numerous amendments to EPCA. Section 325 of EPCA is amended by section 310 of EISA 2007 

to require DOE to regulate standby mode and off mode energy consumption as part of an energy 

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EERE-2006-STD-0127 COMMENT 69.1
 

conservation standard for all covered products, including residential ranges and ovens and 

microwave ovens, for which a final rule is adopted after July 10, 2010. (42 U.S.C. 

6295(gg)(1)(A)) Off mode is defined by EISA 2007 as “the condition in which an energy-using 

product—(I) is connected to a main power source; and (II) is not providing any standby or active 

mode function.” (42 U.S.C. 6295(gg)(1)(A)(ii)) Active mode refers to the main (cooking) 

function, while standby is defined by EISA 2007 as “the condition in which an energy-using 

product (I) is connected to a main power source; and (II) offers 1 or more of the following useroriented or protective functions: (aa) To facilitate the activation or deactivation of other 

functions (including active mode) by remote switch (including remote control), internal sensor, 

or timer. (bb) Continuous functions, including information or status displays (including clocks) 

or sensor-based functions.” (Id.; 42 U.S.C. 6295(gg)(1)(A)(iii)) 

 Because the final rule for this rulemaking was issued by DOE on March 31, 2009, an 

energy conservation standard for cooking products set forth by this rulemaking is not required to 

incorporate standby mode and off mode energy consumption. Although DOE is also not required 

to incorporate standby mode and off mode energy consumption for any cooking products at this 

time, in the November 2007 ANOPR, DOE stated that it was considering including standby 

power in the energy conservation standards and intended to initiate amendment of its test 

procedure to measure microwave oven standby power because: 1) energy conservation in 

standby mode represents a significant proportion of microwave oven annual energy 

consumption; and 2) the range of standby power among microwave ovens currently on the 

market suggests that the likely impact of a standard would be significant. Such a test procedure 

change is a prerequisite to incorporate a standby power requirement as part of the energy 

conservation standard for microwave ovens.m Data obtained by DOE during testing of a 

representative sample of microwave ovens and from AHAM show standby power ranging from 

1.1 to 5.8 W. At the Federal Energy Management Program (FEMP)-defined limit of 2 W, the 

resulting 17.2 kWh of annual standby energy use represents 13 percent of the estimated annual 

cooking energy consumption for a baseline microwave oven. DOE is unaware of any microwave 

ovens currently on the market in the United States that consume energy in off-mode, 

differentiable from standby mode. Therefore, in the October 2008 NOPR, DOE proposed 

standards for microwave oven standby power only, but remained open to consideration of offmode standards. 

DOE also tentatively concluded in its microwave oven test procedure rulemaking that a 

standard for microwave oven standby mode and off mode energy consumption would be 

technologically feasible and economically justified. Therefore, concurrent with the October 2008 

NOPR, DOE published in the Federal Register a test procedure NOPR for microwave ovens to 

provide for the measurement of standby mode and off mode power consumption by these 

products. 73 FR 61134 (Oct. 17, 2008). DOE received comments on the test procedure NOPR 

which objected to certain definitions that were included in the proposed microwave oven test 

procedure amendments. The commenters supported the incorporation of definitions provided in a 

revision of an industry standard for measuring standby power consumption expected to be 

m As discussed in the November 2007 ANOPR, addressing standby mode and off mode energy consumption is not 

required for this rulemaking under EPCA, but DOE sought to publish a final rule for the test procedure amendments 

prior to March 31, 2009, in order to allow the microwave oven energy conservation standards to account for standby 

mode and off mode power. 

3-20
 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

completed in mid-2009. DOE concluded that it should defer consideration of microwave oven 

energy conservation standards until such time that the revised industry standard becomes 

available for consideration in the microwave oven test procedure amendments. DOE intends to 

complete the rulemaking process for microwave ovens as expected once additional key data and 

information becomes available, keeping in mind the relevant statutory deadlines. The EISA 2007 

amendments to EPCA require DOE to amend the ranges and ovens and microwave oven test 

procedure to incorporate standby and off mode energy consumption no later than March 31, 

2011. (42 U.S.C. 6295(gg)(2)(B)(vi)) 

As stated previously, DOE does not have any data on standby power consumption in 

conventional cooking products (i.e., electric and gas cooktops and ovens) that indicate the 

potential for significant energy savings. For this reason, DOE did not consider regulating standby 

and off-mode power for conventional cooking products as part of the current rulemaking. 

3.7.4 Standards Adopted as Part of This Rulemaking 

In the April 2009 Final Rule, DOE issued a final rule for energy conservation standards 

pertaining to cooking efficiency for residential electric and gas kitchen ranges and ovens and 

microwave ovens, adopting prescriptive standards for gas cooking products, requiring gas ranges 

and ovens not to be equipped with constant burning pilots No energy conservation standards for 

the cooking efficiency for residential electric kitchen ranges and ovens and microwave ovens 

were found to be justified, and, therefore, the April 2009 Final Rule maintained the “no 

standard” standard for these products. The effective date for these new standards would be April 

8, 2012. 

3.7.5 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. The EPACT 2005 energy and water use standards for CCWs preempt 

any State efficiency standards since they became effective January 1, 2007. Table 3.7.2 presents 

information regarding States adopting CCW standards comparable to EPACT 2005. 

Table 3.7.2 State Commercial Clothes Washer Regulations Similar to EPACT 2005 

State Effective Date Difference from EPACT 2005 

Arizona MEF and WF: 1/1/08 Standards effective one year later than EPACT 2005 

California MEF: 1/1/05 

WF: 1/1/07 MEF standard effective two years earlier than EPACT 2005 

Connecticut MEF and WF: 7/1/06 Standards effective six months earlier than EPACT 2005 

Maryland MEF and WF: 3/1/07 Standards effective two months later than EPACT 2005 

New Jersey MEF: 1/1/07 

WF: 1/1/10 

Water factor standard effective three years later than EPACT 

2005 

Oregon MEF and WF: 1/1/08 Standards effective one year later than EPACT 2005 

Rhode Island MEF and WF: 1/1/07 Identical to EPACT 2005 

Washington MEF - For Sale: 1/1/07 

MEF - Installation: 1/1/08 Does not address water factor 

3-21
 

EERE-2006-STD-0127 COMMENT 69.1
 

As presented in the table above, the State of California mandates energy and water 

conservation standards for commercial front-loading and commercial top-loading automatic 

clothes washers. Table 3.7.3 provides the State’s CCW energy conservation standards, which are 

dependent on clothes container capacity, and the water conservation standards, which became 

effective two years after the MEF standards. 

Table 3.7.3 California State Efficiency Standards for Commercial Clothes Washers 

Clothes Washer 

Classification 

Clothes Container 

Compartment Capacity 

(ft3

) 

Minimum MEF 

Effective 

January 1, 2005 

Maximum WF 

Effective January 1, 

2007 

Front-loading < 3.5 ft3

 1.26 9.5 

Top-loading < 1.6 ft3 

≥ 1.6 ft3 and < 4.0 ft3 

0.65 

1.26 

9.5 

9.5 

In addition to the efficiency standards discussed above, the State of California requires 

that commercial top-loading semi-automatic clothes washers and commercial suds-saving 

clothes washers manufactured on or after January 1, 2005, have an unheated rinse water option. 

 Additionally, California issued minimum water conservation standards for RCWs. While 

this does not directly affect products covered by the rulemakings, DOE is aware that this 

standard may have impacts on manufacturers of CCWs and other household appliances. 

Although Federal standards exist for the energy consumption of RCWs, no such standard exists 

for the water efficiency. On September 16, 2005, the California Energy Commission (CEC) 

issued a petition for an exemption from Federal preemption to seek to apply its own State 

regulation for RCW WF. DOE accepted written comments regarding this California petition until 

April 7, 2006. Table 3.7.4 provides the State’s proposed RCW water conservation standards and 

their respective effective dates. 

Table 3.7.4 California Water Conservation Standards for Residential Clothes Washers 

Clothes Washer Maximum WF 

Classification Effective January 1, 2007 Effective January 1, 2010 

Top-loading 8.5 6.0 

Front-loading 8.5 6.0 

On December 28, 2006, DOE issued a decision denying the California petition. 71 FR 

78157. The denial of the petition was based on three factors. First, DOE determined that it does 

not have the statutory authority to prescribe a rule for California that would become effective by 

January 1, 2007, the first of two compliance dates contained in Title 20, section 1605.2(p)(1) of 

the California Code of Regulations. Second, DOE ruled that the CEC had not established by a 

preponderance of the evidence that the State of California has unusual and compelling water 

interests, a condition required by EPCA for DOE to grant California a waiver from Federal 

preemption. (42 USC 6297(d)(1)(B)) Finally, a preponderance of evidence showed that the 

California regulation would likely result in the unavailability of a class of RCWs, specifically 

top-loader machines, in California. The State submitted to DOE a request for reconsideration.17 

On October 28, 2009, the Ninth Circuit Court issued a decision reversing DOE’s denial of the 

CEC petition for exemption from existing energy efficiency standards for RCWs and remanding 

the petition for further review.18 

3-22
 

EERE-2006-STD-0127 COMMENT 69.1
 

3.7.6 Canadian Energy Conservation Standards 

Canada’s Energy Efficiency Regulations (hereafter Regulations) mandate minimum 

energy conservation standards for certain residential cooking products, including electric and 

gas ranges, cooktops, and ovens. The Regulations do not cover microwave ovens. Like U.S. 

DOE standards, Canadian Regulations require that gas cooking products, including ranges, 

ovens, and cooktops, with an electrical supply cord not be equipped with constant burning pilots. 

Table 3.7.5 presents the Regulations for electric cooking products. 

Table 3.7.5 Canadian Energy Conservation Standards for Electric Cooking Products 

Cooking Product Classification Maximum Allowable Energy 

Consumption (kWh/year)* 

Free-standing or built-in ranges with one or more surface elements and 

one or more ovens 

2.0V + 458 

Built-in or wall-mounted ranges without surface elements and with one or 

more ovens 

2.0V + 200 

Counter-mounted ranges without ovens and with one or more surface 

elements on a conventional (i.e., not modular) cooktop 258 

* Where V = volume of oven in liters 

The Canadian government also regulates the efficiency of residential clothes washers. 

While this standard does not directly apply to products covered by this rulemaking, DOE 

understands that this standard may still impact some North American manufacturers in the home 

appliance industry. This Regulation applies to standard or compact electrically operated 

household clothes washers that are top- or front-loaded, and that have an internal control system 

that regulates the water temperature without the need for user intervention subsequent to 

initiation of machine operation. Table 3.7.6 lists the current standards that went into effect 

January 1, 2007, along with the previous standards that went into effect January 1, 2004. 

Table 3.7.6 Canadian Energy Conservation Standards for Residential Clothes Washers 

Clothes Washer Classification Minimum MEF (L/kWh/cycle) 

January 1, 2004 January 1, 2007 

Vertical-axis compact (< 45 liter capacity) 18.40 18.40 

Vertical-axis standard (≥ 45 liter capacity) 29.45 35.68 

Horizontal-axis* 29.45 35.68 

Suds-saving* NA NA 

* These product classes shall be equipped with an unheated rinse water option. 

3.7.7 Foreign 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 

3-23
 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

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

standby power, which is now widely specified and used.n 

A number of countries have implemented regulatory approaches to standby power in 

microwave ovens. Australia has announced plans to implement a mandatory 1 W requirement 

for all consumer electrical products by 2012, including microwave ovens.19 The Korea Energy 

Management Corporation developed their “e-standby” program, which currently has a voluntary 

labeling program for microwave ovens with less than 1 W of standby power. The program is 

currently transitioning to a mandatory 1 W standard by the year 2010.20 In accordance with 

Japan’s Top Runner Program,o

 Japanese appliance manufacturers made a voluntary declaration 

to reduce standby power consumption of microwave ovens without a timer as close to 0 W as 

possible and that of microwave ovens with a timer to 1 W or lower.21 

The European Union (EU) recently enacted the Commission Regulation (EC) No. 

1275/2008 of December 17, 2008, implementing design requirements for standby and off mode 

power for electrical and electronic household and office equipment, including microwave 

ovensd. Annex II of the regulation specifies the following maximum power requirements: 

1. One year after this Regulation has come into force: 

(a) Power consumption in ‘off mode’: 

Power consumption of equipment in any off-mode condition shall not exceed [1.00] 

W. 

(b) Power consumption in ‘standby mode(s)’: 

The power consumption of equipment in any condition providing only a reactivation 

function, or providing only a reactivation function and a mere indication of enabled 

reactivation function, shall not exceed [1.00] W. 

The power consumption of equipment in any condition providing only information or 

status display, or providing only a combination of reactivation function and 

information or status display, shall not exceed [2.00] W. 

(c) Availability of off mode and/or standby mode 

Equipment shall, except where this is inappropriate for the intended use, provide off 

mode and/or standby mode and/or another condition which does not exceed the 

n

 For more information, visit www.iea.org. 

o

 Japan’s Energy Conservation Act uses a “top runner” method to set energy efficiency targets for residential, 

commercial, and transportation sector equipment. Target values for future products are set based on the level of the 

most energy efficient products on the market at the time of the value setting process. For more information, visit 

www.eccj.or.jp/index_e.html 

3-24
 

EERE-2006-STD-0127 COMMENT 69.1
applicable power consumption requirements for off mode and/or standby mode when 

the equipment is connected to the mains power source. 

2. Four years after this Regulation has come into force: 

(a) Power consumption in ‘off mode’: 

Power consumption of equipment in any off-mode condition shall not exceed [0.50] 

W. 

(b) Power consumption in ‘standby mode(s)’: 

The power consumption of equipment in any condition providing only a reactivation 

function, or providing only a reactivation function and a mere indication of enabled 

reactivation function, shall not exceed [0.50] W. 

The power consumption of equipment in any condition providing only information or 

status display, or providing only a combination of reactivation function and 

information or status display, shall not exceed [1.00] W. 

(c) Availability of off mode and/or standby mode 

Equipment shall, except where this is inappropriate for the intended use, provide off 

mode and/or standby mode and/or another condition which does not exceed the 

applicable power consumption requirements for off mode and/or standby mode when 

the equipment is connected to the mains power source. 

(d) Power management 

When equipment is not providing the main function, or when other energy-using 

product(s) are not dependent on its functions, equipment shall, unless inappropriate 

for the intended use, offer a power management function, or a similar function, that 

switches equipment after the shortest possible period of time appropriate for the 

intended use of the equipment, automatically into: 

— standby mode, or 

—	 off mode, or 

—	 another condition which does not exceed the applicable power consumption 

requirements for off mode and/or standby mode when the equipment is connected 

to the mains power source. The power management function shall be activated 

before delivery. 

3-25
 

EERE-2006-STD-0127 COMMENT 69.1
 

3.8 VOLUNTARY PROGRAMS 

DOE reviewed several voluntary programs promoting energy efficient residential 

cooking products and CCWs in the United States. Many programs, including the CEE, ENERGY 

STAR, and FEMP, establish voluntary energy conservation standards for these products. 

3.8.1 Consortium for Energy Efficiency 

 The CEEp 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. 

In 1998, CEE launched the Commercial, Family-Sized Washer Initiative as an offshoot of 

its Residential Clothes Washer Initiative. The initiative encourages the purchase and use of 

energy and water efficient commercial clothes washers for laundromats, multi-family buildings 

and institutions. Table 3.8.1 presents the current voluntary efficiency specifications for the 

program. In order to qualify, a CCW must exceed the minimum MEF and remain below a 

specified WF. 

Table 3.8.1 CEE Criteria for Commercial Clothes Washers 

Level MEF WF 

Tier 1 1.80 7.5 

Tier 2 2.00 6.0 

Tier 3 2.20 4.5 

3.8.2 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.q 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 CCWs. 

ENERGY STAR criteria exist for top- and front-loading commercial clothes washers 

with capacities greater than 1.6 cubic feet. New ENERGY STAR criteria for CCWs, which 

include energy and water consumption ratings, became effective January 1, 2007. The current 

criteria and previous criteria are contained in Table 3.8.2. 

p

 For more information, visit www.cee1.org. 

q

 For more information, visit www.energystar.gov. 

3-26
 

EERE-2006-STD-0127 COMMENT 69.1
 

 

Table 3.8.2 ENERGY STAR Criteria for Commercial Clothes Washers 

Clothes Washer Classification Previous Criteria Level Current Criteria Levels 

Top- and front-loading clothes 

washers MEF ≥ 1.42 MEF ≥ 1.72 WF ≤ 8.0 

3.8.3 Federal Energy Management Program 

 DOE’s FEMPr 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 

microwave ovens and CCWs. 

Executive Order 13221 Energy Efficient Standby Power Devices, signed July 31, 2001, 

requires that Federal agencies purchase commercially available products with low standby 

power. 66 FR 40571. FEMP, therefore, issues standby power recommendations for microwave 

ovens. Table 3.8.3 presents the microwave oven recommendations. 

Table 3.8.3 FEMP Recommendations for Microwave Ovens 

Microwave Oven Classification Standby Power (W)* 

Standard Microwave Oven ≤ 2 

* Based on test procedures specified in IEC Standard 62301

 For commercial clothes washers, FEMP issues energy efficiency recommendations 

based on washer volume. Table 3.8.4 presents the CCW recommendations. 

Table 3.8.4 FEMP Recommendations for Commercial Clothes Washers 

Clothes Washer Tub Volume Annual Energy Use (kWh/yr)* MEF 

1.9 - 2.5 ft3 410 or less 2.5 or higher 

2.6 – 3.3 ft3 520 or less 2.5 or higher 

* Based on 392 wash cycles per year (10 CFR part 430, subpart B, appendix J1) 

FEMP estimates that, with electric water heating, replacing a 2.48 ft3

 CCW exhibiting an 

MEF of 1.80 with a clothes washer exhibiting an MEF of 2.50 will save $1,400 over the lifetime 

of the unit (assuming Federal average energy prices). The same replacement with gas water 

heating will save $800 over the lifetime of the clothes washer. 

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 

r

 For more information, visit www.eere.energy.gov/femp. 

3-27
 

EERE-2006-STD-0127 COMMENT 69.1
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 

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

The Energy Improvement and Extension Act of 2008 (EIEA 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)) Table 3.8.5 lists the applicable credit amounts based on 

MEF and WF. In addition, eligible production is 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 does not apply to CCWs meeting 

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

Table 3.8.5 Manufacturer Tax Credits for Energy-Efficient CCWs in EIEA 2008 

MEF WF Applicable Credit Amount Limitations 

2.0 6.0 $150 Up to $75 million* 

2.2 4.5 $250 Not subject to total credit limit 

* Reduced by the amount of credit taken in previous years after December 31, 2007. 

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, EPA, and AHAM to evaluate residential appliance product shipment 

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

10 of this TSD.) 

3.9.1 New Home Starts 

Trends in new home starts may directly affect shipments of certain home appliances. 

While there is certainly both a replacement and remodeling market for some appliances 

including cooking products, these products are also fixtures in virtually all new homes. Multifamily unit starts can also affect shipments of CCWs. 

Figure 3.6.1 presents the number of new single-family and multi-family housing units 

started in the United States from 1998–2007. Over the 5-year period from 2000–2005, singlefamily home starts increased 39.4 percent, to 1,716,000 units annually. However, between 2005 

and 2008, single-family home starts decreased 63.8 percent, to 622,000 units annually. Multifamily unit starts have remained relatively flat over the past 10 years, hovering around 350,000 

units annually, although they decreased to 283,500 in 2008.22 

3-28
 

EERE-2006-STD-0127 COMMENT 69.1
0 

200 

400 

600 

800 

1,000 

1,200 

1,400 

1,600 

1,800 

2,000 

Housing Units Started (thousands of units) 

1998 2000 2002 2004 2006 2008
 

Single-Family Units Multi-Family Units 

Figure 3.9.1 New Privately Owned Single-Family and Multi-Family Housing Unit Starts in 

the United States from 1998–2008 23 

3.9.2 Unit Shipments 

AHAM’s Fact Book provides annual unit shipments for residential appliances. Table 

3.9.1 presents annual shipments of cooking products. In the 10-year period from 1995–2005, 

shipments of electric and gas free-standing ranges and surface cooking units, electric built-in 

ranges, and microwave ovens increased, while shipments of built-in gas ranges decreased. 

3-29
 

EERE-2006-STD-0127 COMMENT 69.1
 

Table 3.9.1 Industry Shipments of Cooking Products (Domestic and Import in Thousands 

of Units) 24 

Year 

Cooking Products 

Electric Ranges Gas Ranges 

Microwave 

Ovens 

FreeStanding Built-In 

Surface 

Cooking 

Units Total 

FreeStanding BuiltIn 

Surface 

Cooking 

Units Total 

2005 4,685 973 542 6,201 3,139 64 560 3,762 13,862 

2004 4,612 963 570 6,145 3,124 67 528 3,719 15,526 

2003 4,238 841 543 5,622 2,897 67 455 3,419 14,274 

2002 4,030 780 528 5,338 2,781 71 416 3,268 13,311 

2001 3,842 726 498 5,066 2,580 72 384 3,036 13,446 

2000 3,826 706 494 5,026 2,729 70 377 3,176 12,644 

1999 3,785 705 493 4,983 2,698 72 367 3,137 11,422 

1998 3,481 652 506 4,639 2,543 71 336 2,950 10,365 

1997 3,177 617 446 4,240 2,391 73 280 2,744 8,883 

1996 3,123 614 418 4,155 2,366 72 272 2,710 8,771 

1995 2,931 598 389 3,917 2,391 84 240 2,715 8,162 

ENERGY STAR shipment data for residential clothes washers may also prove useful 

during this standards rulemaking. Table 3.9.2 presents the 2005 breakdown of ENERGY STAR 

versus non-ENERGY STAR shipments for RCWs. 

Table 3.9.2 2005 ENERGY STAR Shipments by Product (Domestic and Import) 

Product 

Shipments % ENERGY 

STAR of 

Total

ENERGY STAR- 25

Qualified Other Total26 

Residential Clothes 

Washers 3,424,000 5,970,000 9,394,000 36.5 

3.9.3 Value of Shipments 

Table 3.9.3 provides the value of shipments for the household appliance industry from 

1994–2006 based upon data from the U.S. Census Bureau’s Annual Survey of Manufacturers 

(ASM).s The ASM expresses all dollar values in nominal dollars; i.e., 2006 data are expressed in 

2006 dollars, and 2005 data are expressed in 2005 dollars. Using the Gross Domestic Product 

Implicit Price Deflator, DOE converted each year’s value of shipments to 2006 dollars. In 

constant 2006 dollars, the value of shipments has declined by nearly 22 percent over the 13-year 

period. 

s

 Available online at www.census.gov/mcd/asm-as1.html. 

3-30
 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

Table 3.9.3 Household Appliance Manufacturing Statistics by Year27 

Year Value of Shipments in Nominal 

Dollars ($1000) 

Value of Shipments in 2006 Dollars 

($1000) 

2006 22,965,146 22,965,146 

2005 24,620,117 25,341,881 

2004 23,989,141 25,439,547 

2003 23,026,196 25,111,893 

2002 22,269,541 24,803,498 

2001 22,298,897 25,269,862 

2000 23,414,965 27,171,194 

1999 22,372,219 26,526,720 

1998 22,471,878 27,030,451 

1997 21,394,445 26,019,810 

1996 22,156,900 27,395,591 

1995 22,391,300 28,210,228 

1994 22,793,900 29,305,108 

The increase in shipment volumes combined with an overall decrease in constant-dollar 

shipment values indicates that the U.S. appliance industry is very competitive. 

According to data presented in the AHAM Fact Book 2003, many old appliances are still 

being used after consumers purchase new units of same product. Table 3.9.4 presents the various 

methods by which consumers dispose of their older appliances. 

Table 3.9.4 Disposition of Previous Appliance (Percentage)28 

Product Kept It 

Left with 

Previous 

Home 

Sold / Gave 

Away 

Recycling 

Facility 

Left at 

Curb for 

Disposal 

Retailer 

Took Away 

Ranges 6 37 21 13 8 15 

Built-In Ranges 4 46 11 15 12 13 

Microwave Ovens 17 11 32 12 23 4 

The value of shipments of residential cooking products, a subset of the household 

appliance industry as defined in the ASM, has fluctuated over the last 13 years when viewed in 

2006 real dollars. Overall, the real value of shipments in 2006 was less than one percent lower 

than the value in 1994. Table 3.9.5 provides the industry value of shipments for household 

cooking appliance manufacturing. 

3-31
 

EERE-2006-STD-0127 COMMENT 69.1
 

 

Table 3.9.5 Household Cooking Appliance Manufacturing Statistics by Year29 

Year Value of Shipments in Nominal 

Dollars ($1000) 

Value of Shipments in 2006 

Dollars ($1000) 

2006 4,864,268 4,864,268 

2005 5,114,677 5,264,619 

2004 4,798,227 5,088,332 

2003 4,691,713 5,116,685 

2002 4,327,308 4,819,694 

2001 3,773,442 4,276,192 

2000 4,178,958 4,849,346 

1999 3,915,499 4,642,604 

1998 3,849,167 4,629,997 

1997 3,520,635 4,281,778 

1996 3,564,700 4,407,524 

1995 3,788,200 4,772,657 

1994 3,813,900 4,903,362 

3.9.4 Imports and Exports 

There is a large market for the import and export of home appliances. Each month 

AHAM publishes import and export data for certain home appliances. These data are released by 

the U.S. Census Bureau and aggregated by a third party. On the whole, major appliance unit 

imports decreased 1.0 percent in 2007 as compared to 2006. Major appliance unit exports 

increased 5.2 percent over the same period. 

Table 3.9.6 shows selected import data from AHAM’s 2008 Preliminary Year End 

Import/Export Trade Report.

30 For microwave ovens less than or equal to 31.0 inches in width, 

coin-operated washing machines, and non-portable cooking products, both the number and value 

of units imported decreased. For electric stoves, ranges, and ovens, the number of units imported 

decreased over the 1-year period, while the value of those units increased. For microwave ovens 

greater than 31.0 inches in width, both the number and value of units imported increased. 

Overall, the value of major appliance imports decreased 11.6 percent from 2007–2008. 

Table 3.9.6 2007–2008 Imports of Appliances Covered by this Rulemaking31 

Appliance Description Jan. – Dec. 

2007 

Jan. – Dec. 

2008 

% Change 

Jan. – Dec. 

2007 

Jan. – Dec. 

2008 

Units $ Mil (Nominal) % Change 

Non-portable cooking 

products 1,305,620 1,022,076 -21.7 371.400 277.865 -25.2 

Coin-operated washing 

machines 4,581 3,543 -22.7 7.242 5.707 -21.2 

Microwave ovens ≤ 22.5 

inches 5,762,615 4,568,579 -20.7 179.536 165.057 -8.1 

Microwave ovens > 

22.5-31.0 inches 4,098,404 2,392,880 -41.6 196.218 118.232 -39.7 

Microwave ovens > 31.0 

inches 7,194,222 8,378,109 16.5 634.807 679.657 7.1 

Electric stoves, ranges, 

and ovens 2,551,125 2,392,253 -6.2 488.655 532.871 9.0 

3-32
 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

 

Table 3.9.7 shows selected export data from AHAM’s 2008 Preliminary Year End 

Import/Export Trade Report.

32 For the 1-year period from 2007–2008, both the number and 

value of unit exports of non-portable cooking products and electric stoves, ranges, and ovens 

increased. For the same time period, the number of coin-operated washing machines and 

microwave oven exports decreased, but the value of microwave oven exports increased. The 

value of coin-operated washing machines exports decreased. Overall, the total value of exports 

decreased 9.0 percent. 

Table 3.9.7 2007–2008 Exports of Appliances Covered by this Rulemaking 33 

Appliance Description Jan. – Dec. 

2007 

Jan. – Dec. 

2008 

Jan. – Dec. 

2007 

Jan. – Dec. 

2008 

Units % Change $ Mil (Nominal) % Change 

Non-portable cooking 

products 122,264 126,065 3.1 68.352 69.786 2.1 

Coin-operated washing 

machines 89,440 77,195 -13.7 41.729 37.296 -10.6 

Microwave ovens 300,993 294,373 -2.2 36.689 40.038 9.1 

Electric stoves, ranges, 

and ovens 482,608 524,339 8.6 273.390 303.664 11.1 

3.10 MARKET SATURATION 

AHAM’s Fact Book 2005 presents the market saturation for cooking products. While the 

percentage of U.S. households with electric ranges and/or cooktops and microwave ovens has 

decreased slightly since 2001, the market saturation of gas cooking products has increased. Table 

3.10.1 presents the appliance saturation and percentage of U.S. households with each product as 

reported in the AHAM Fact Book 2005. The number of U.S. households with each product is 

based on U.S. Census Bureau projections of occupied units in the relevant year. 

Table 3.10.1 Appliance Saturation (Number in Millions) and Percentage of U.S. 

Households with Product 34 

Product 

1970 1982 1990 2001 2005 

# % # % # % # % # % 

Electric Ranges / 

Cooktops* 25.8 40.6 48.4 58 58.4 62.6 69.2 66.3 71 65.3 

Gas Ranges / 

Cooktops* 36.6 57.7 35.7 42.7 36.1 38.7 39.4 37.8 42.2 39 

Microwave 

Ovens Neg. Neg. 21.4 25.6 77.2 82.7 94.6 90.7** 97.2 89.3 

* Cooktops not included in 1970 or 1982 data 

** Includes over-the-range and countertop microwave ovens 

3.11 PRODUCT RETAIL PRICES 

Table 3.11.1 presents the average retail prices (in nominal dollars) of several residential 

appliances and the Consumer Price Index (CPI) of each year (1982–84 = 100). Although prices 

3-33
 

EERE-2006-STD-0127 COMMENT 69.1
for electric and gas ranges have increased since 1980, the increase has been at a much slower rate 

than the annual rate of inflation. Prices of microwave ovens and automatic clothes washers have 

decreased in the same time period. 

Table 3.11.1 Residential Appliance Retail Prices 35 

Product 

Average Retail Prices (Nominal $) Percent Change 

1980 1994 2002 2005 1980–2005 

Electric Ranges 412 503 508 444 7.8% 

Gas Ranges 380 499 497 462 21.6% 

Microwave Ovens 450 239 145 99 -78.0% 

Automatic Clothes Washers 386 394 426 359 -7.0% 

Consumer Price Index* 82.4 148.2 179.9 195.3 137.0% 

* U.S. Department of Labor, Bureau of Labor Statistics, Consumer Price Index: U.S. city average. 1982–84 = 100. 

3.11.1 Gas Ranges with Standard Ovens: Standing Pilot Ignition versus Pilotless Ignition 

As described in section 3.14.2, pilotless ignition devices such as electronic ignition 

devices for gas cooktops and electronic or electric ignition devices for gas standard ovens can be 

used in place of standing pilot ignition systems to improve the efficiency of non-self-cleaning 

gas ranges, i.e., gas standard ranges which consist of a cooktop and a standard oven. As 

discussed in chapter 8, section 8.2.6, an overwhelming majority of the gas standard range market 

is already equipped with pilotless ignition devices. Due to the large percentage of the market that 

has already moved to pilotless ignition, the current consumer retail price difference between a 

gas range with and without standing pilot ignition may provide an accurate measure of the actual 

price increase to the consumer of purchasing a gas standard range with pilotless ignition. As a 

result, DOE conducted a limited search of consumer retail prices for gas standard ranges with 

and without standing pilot ignition. Table 3.11.2 summarizes the data collected by DOE. DOE 

collected data for five major gas range brands which offered comparable models with and 

without standing pilot ignition: General Electric, Hotpoint, Frigidaire, Peerless-Premier, and 

Brown. For these brands, DOE found gas range model pairings where the only difference 

between the models was in the type of ignition system; i.e., one model had standing pilot ignition 

and the other model electronic ignition. As shown in Table 3.11.2, with the exception of Brown, 

DOE was able to determine the retail price difference between the two model types. 

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EERE-2006-STD-0127 COMMENT 69.1
 

 

Table 3.11.2 Gas Standard Range Retail Prices for Standing Pilot and Pilotless Ignition 

Systems 

Manufacturer Brand Model 

Cabinet 

Width 

(in.) Ignition 

MSRP 

or 

Retail* 

Price for 

Electronic 

Most similar 

pilot model 

General Electric General Electric36 JGBS04PPHWW 30 Pilot $379 - -

JGBS07PEHWW 30 Electronic $379 $0 JGBS04PPHWW 

General Electric Hotpoint37 RGB508PPHWH 30 Pilot $379 - -

RGB508PEHWH 30 Electronic $419 $40 RGB508PPHWH 

General Electric Hotpoint RGB508PPHCT 30 Pilot $379 - -

RGB508PEHCT 30 Electronic $419 $40 RGB508PPHCT 

General Electric Hotpoint RGB524PPHCT 30 Pilot $409 - -

RGB524PEHCT 30 Electronic $459 $50 RGB524PPHCT 

General Electric Hotpoint RGB524PPHWH 30 Pilot $409 - -

RGB524PEHWH 30 Electronic $459 $50 RGB524PPHWH 

General Electric Hotpoint38 RGA724PKWH 24 Pilot $449 - -

RGA724EKWH 24 Electronic $479 $30 RGA724PKWH 

General Electric Hotpoint39 RGA720PKWH 20 Pilot $429 - -

RGA720EKWH 20 Electronic $449 $20 RGA720PKWH 

Electrolux Frigidaire40 FGF316D 30 Pilot $399 - -

FGF316D 30 Electric $399 $0 Same model # 

Peerless-Premiere Peerless-Premiere41 GAK 1000 20 Pilot $480 - -

SAK 1000 20 Electronic $517 $37 GAK 1000 

Peerless-Premiere Peerless-Premiere42 GCK 1000 24 Pilot $546 - -

SCK 1000 24 Electronic $584 $38 GCK 1000 

Peerless-Premiere Peerless-Premiere43 GFK 1000 30 Pilot $520 - -

SFK 1000 30 Electronic $558 $38 GFK 1000 

Peerless-Premiere Peerless-Premiere44 GLK 1000 36 Pilot $633 - -

SLK 1000 36 Electronic $673 $40 GLK 1000 

Brown Brown45 WNM110 20 Pilot - - -

WNM110-7F 20 Electronic - - WNM110 

Brown Brown46 WNM610-X 24 Pilot - - -

WNM610-7 24 Electronic - - WNM610-X 

Brown Brown47 TNM210-HR 30 Pilot - - -

WNM210-7 30 Electronic - - WNM210-HR 

Brown Brown48 WNM430 36 Pilot - - -

WNM430-7 36 Electronic - - WNM430 

* MSRP = Manufacturer Suggested Retail Price; Retail Price = Price from Retailer. Retail prices for General Electric, Hotpoint, 

and Electrolux brands are MSRP. Retail prices for Peerless are retailer prices from Best Buy. 

Table 3.11.2 demonstrates that the price difference between standing pilot and electronic 

ignition systems ranges from $0 to $50 depending on the brand and size of the unit. The range in 

price provides a rough estimate of the impact on current retail pricing from replacing a standing 

pilot ignition system with an electronic ignition system. 

As shown in chapter 7 of the TSD, DOE used manufacturing costs developed for specific 

efficiency levels in combination with manufacturer and retailer markups, sales taxes, and 

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

efficient gas cooking products. DOE used the above range in current retail price differences 

between gas standard ranges with and without standing pilot ignition as an indication of the 

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EERE-2006-STD-0127 COMMENT 69.1
reasonableness of the total installed cost estimates that it developed for electric and electronic 

ignition systems. 

3.11.2 Commercial Clothes Washers 

In Table 3.11.1, automatic clothes washers pertain to RCWs, not CCWs. As a result, 

DOE conducted a limited search of consumer retail prices for CCWs by telephoning five 

commercial laundry distributors and gathering data from four Internet retailers. Table 3.11.1 

summarizes the data collected by DOE. Most of the distributors and Internet retailers provided a 

range of prices for each washer model. Only the average price for each model is provided in the 

table below. 

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EERE-2006-STD-0127 COMMENT 69.1
Table 3.11.3 Commercial Clothes Washer Retail Prices 

Source Source Type Manufacturer Brand Model Number Coin Box Loading AbsoluteHome.com49 Internet Whirlpool Whirlpool CAM2752RQ Yes Top-Load 

AbtElectronics.com50 Internet General Electric Roper RAK2751WWH Yes Top-Load 

AbtElectronics.com Internet Whirlpool Whirlpool CAM2752WH Yes Top-Load 

AbtElectronics.com Internet Whirlpool Maytag MAT12CSWH Yes Top-Load 

AJMadison.com51 Internet Whirlpool Whirlpool CAM2752RQ Yes Top-Load 

Commercial & Coin Laundry Equip.52 Distributor Whirlpool Whirlpool N/A Yes Top-Load 

Commercial & Coin Laundry Equip. Distributor Alliance Speed Queen N/A Yes Top-Load Commercial Laundry Equipment53 Distributor Alliance Speed Queen SWTBA1WN Yes Top-Load 

Gold Coin Laundry Equipment54 Distributor General Electric General Electric WCCB1030F Yes Top-Load 

Gold Coin Laundry Equipment Distributor General Electric General Electric WCCB2050 Yes Top-Load 

Mac-Gray Services55 Distributor Whirlpool Maytag MAT12PDSWW Yes Top-Load 

Texas Laundry Service56 Distributor Alliance Speed Queen JWT110, SWTB20 Yes Top-Load 

AbtElectronics.com Internet Frigidaire Frigidaire FCCW3000WH Yes Front-Load 

Commercial Laundry Equipment Distributor Alliance Speed Queen SWFB61WN Yes Front-Load 

Gold Coin Laundry Equipment Distributor General Electric General Electric WCCH404VWW Yes Front-Load Laundry Systems57 Internet Electrolux Wascomat WE16 Yes Front-Load 

Mac-Gray Services Distributor Whirlpool Maytag MAH21PDAWW Yes Front-Load 

Texas Laundry Service Distributor Alliance Speed Queen SWRF961, SWFB63 Yes Front-Load 

AbsoluteHome.com Internet General Electric General Electric WNRD2050DWC No Top-Load 

AbtElectronics.com Internet Whirlpool Maytag MAT13MNWH No Top-Load 

AJMadison.com Internet General Electric General Electric WNRD2050D No Top-Load 

Commercial & Coin Laundry Equip. Distributor N/A N/A N/A No Top-Load Commercial Laundry Equipment Distributor Alliance Speed Queen LWF02N No Top-Load 

Gold Coin Laundry Equipment Distributor General Electric General Electric WNRD2050D No Top-Load 

Mac-Gray Services Distributor Whirlpool Maytag MAT12PN No Top-Load 

Texas Laundry Service Distributor Alliance Speed Queen LWS01, LWS49 No Top-Load 

Commercial & Coin Laundry Equip. Distributor Alliance Speed Queen N/A No Front-Load 

Commercial Laundry Equipment Distributor Alliance Speed Queen LTF90AWM No Front-Load 

Laundry Systems Internet Frigidaire Wascomat WE16 No Front-Load 

Laundry Systems Internet Alliance Huebsch FTZ91AWN11 No Front-Load Laundry Systems Internet Alliance Huebsch HWFT61 No Front-Load 

Mac-Gray Services Distributor Whirlpool Maytag MAH21PNAWW No Front-Load 

Texas Laundry Service Distributor Alliance Speed Queen LTS90, FTS90 No Front-Load 

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EERE-2006-STD-0127 COMMENT 69.1
DOE was unable to establish either the energy or water efficiency of all the washers for 

which it collected retail prices. Therefore, a retail price and efficiency relationship could not be 

established. But based on the price data collected, it was evident that price was a function of the 

type of loading (i.e., top-loading or front-loading.) Thus, DOE was able to determine a gross 

estimate of the retail price difference between a relatively inefficient top-loading washer and a 

high-efficiency front-loading washer. DOE also determined that price was a function of whether 

the washer was equipped with a coin box. As a result, DOE grouped the retail price data into four 

categories based on loading type and the presence of a coin box. To demonstrate the impact of 

the loading type and coin box on retail price, Figure 3.11.1 depicts the price data listed in Table 

3.11.3 Noted in Figure 3.11.1 is the average retail price of each of the four groups into which 

DOE segregated the data. 

$1,750 

$1,500 

$1,250 

$1,000 

$750 

$500 

Top-Loading Front-Loading 

Figure 3.11.1 Commercial Clothes Washer Retail Prices as a Function of Loading-Type 

and Presence of Coin Box 

Figure 3.11.1 demonstrates that the average price difference between top-loading and 

front-loading washers varies between $531 for washers with coin boxes and $625 for washers 

without coin boxes. The above difference provides a rough estimate of the impact on current 

retail pricing from moving to a conventional top-loading washer (i.e., a washer with a verticalaxis agitator that submerges the clothes into a tub filled with water) to a conventional frontloading washer (i.e., a washer with a horizontal axis that tumbles the clothes through a pool of 

water.) 

As shown in chapter 7 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 Consumer Price 

Coin Box 

No Coin Box 

Avg Price = $824 

Average Price = $697 

Average Price = $1355 Avg Price = $1332 

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EERE-2006-STD-0127 COMMENT 69.1
 

efficient CCWs. DOE used the above range in current retail price differences between toploading and front-loading washers as an indication of the reasonableness of the total installed 

cost estimates that it developed for CCWs. 

3.12 INDUSTRY COST STRUCTURE 

DOE developed the household appliance industry cost structure from publicly available 

information from the ASM, (Table 3.12.1 and Table 3.12.2) and the U.S. Securities and 

Exchange Commission (SEC) 10-K reports filed by publicly owned manufacturers (summarized 

in Table 3.12.3). Table 3.12.1 presents the home appliance industry employment levels and 

earnings from 1994-2006. The statistics illustrate a steady decline in the number of production 

and non-production workers in the industry. 

Because the ASM expresses all dollar values in constant 2006 dollars, the following table 

shows that as industry employment levels decline, the industry payroll is also decreasing. The 

percent decrease in total industry employees tracks closely with the percent decrease in payroll 

for all employees. 

Table 3.12.1 Household Appliance Industry Employment and Earnings 58 

Year Production Workers 

(‘000) All Employees (‘000) Payroll for All Employees (2006 $ Mil) 

2006 60.0 69.7 2,644.0 

2005 64.3 76.9 2,778.3 

2004 69.4 83.7 3,068.8 

2003 71.0 85.3 3,146.5 

2002 73.5 88.8 3,334.1 

2001 76.6 92.6 3,497.5 

2000 82.7 99.5 3,815.2 

1999 82.3 97.9 3,691.2 

1998 82.4 99.5 3,716.3 

1997 79.8 97.2 3,547.4 

1996 87.1 108.1 3,798.1 

1995 88.9 110.8 3,860.6 

1994 90.4 110.4 3,846.0 

Table 3.12.2 presents the costs of materials and industry payroll as a percentage of value 

of shipments from 1994–2006. The cost of materials as a percentage of value of shipments has 

fluctuated slightly over the 13-year period. DOE notes that fluctuations in raw material costs are 

common from year to year. The cost of payroll for production workers as a percentage of value 

of shipments has declined since 2000. Similarly, the cost of total payroll as a percentage of value 

of shipments has declined since 2000. 

3-39 

EERE-2006-STD-0127 COMMENT 69.1
 

Table 3.12.2 Household Appliance Industry Census Data 59 

Year 

Cost of Materials as a 

Percentage of Value of 

Shipments (%) 

Cost of Payroll for 

Production Workers as a 

Percentage of Value of 

Shipments (%) 

Cost of Total Payroll 

(Production + Admin.) as a 

Percentage of Value of 

Shipments (%) 

2006 60.9 8.9 11.5 

2005 56.9 8.3 11.0 

2004 57.2 9.0 12.1 

2003 55.9 9.2 12.5 

2002 54.9 9.7 13.4 

2001 56.8 10.1 13.8 

2000 55.8 10.2 14.0 

1999 54.7 10.2 13.9 

1998 56.0 10.0 13.7 

1997 52.8 9.9 13.6 

1996 56.8 9.9 13.9 

1995 57.7 9.4 13.7 

1994 55.5 9.2 13.1 

Table 3.12.3 presents the industry cost structure derived from SEC 10-K reports of 

publicly owned home appliance manufacturers. DOE averaged the financial data from 2002– 

2007 of several companies to obtain an industry average. Each financial statement entry is 

presented as a percentage of total revenues. 

Table 3.12.3 Industry Cost Structure Using SEC Data 

Financial Statement Entry Percent of Revenues 

Cost of sales 81.3% 

Net income 1.7% 

Selling, general and administrative 12.8% 

Capital expenditure 3.3% 

Research and development 2.3% 

Depreciation and amortization 3.3% 

Net plant, property and equipment 18.7% 

Working capital 1.6% 

A detailed financial analysis of each of the products covered by this rulemaking is 

presented in the MIA. (See chapter 13 of this TSD.) This analysis identifies key financial inputs 

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

3.13 INVENTORY LEVELS AND CAPACITY UTILIZATION RATES 

Table 3.13.1 shows the year-end inventory for the household appliance industry, 

according to the ASM. Both in dollars and as a percentage of value of shipments, the end-of-year 

inventory for the industry has steadily declined since 1995. These data illustrate a general trend 

of domestic manufacturers retaining less of their inventories over time since 1994. 

3-40 

EERE-2006-STD-0127 COMMENT 69.1
 

Table 3.13.1 Household Appliance Industry Census Data 60 

Year End-of-Year Inventory 

(2006 $ Mil) 

End-of-Year Inventory as a 

Percentage of Value 

of Shipments (%) 

2006 1,688.5 7.4 

2005 1,681.3 6.6 

2004 1,853.4 7.3 

2003 1,857.9 7.4 

2002 1,997.2 8.1 

2001 2,223.1 8.8 

2000 2,511.9 9.2 

1999 2,503.3 9.4 

1998 2,698.4 10.0 

1997 2,592.9 10.0 

1996 2,842.7 10.4 

1995 3,139.5 11.1 

1994 3,252.8 11.1 

DOE obtained full production capacity utilization rates from the U.S. Census Bureau, 

Survey of Plant Capacity from 1994–2006. Table 3.13.2 presents utilization rates for various 

sectors of the household appliance industry. Full production capacity is defined as the maximum 

level of production an establishment could attain under normal operating conditions. In the 

Survey of Plant Capacity report, the full production utilization rate is a ratio of the actual level of 

operations to the full production level. The full production capacity utilization rate for household 

appliances in aggregate, along with the rates for cooking appliances and household laundry 

appliances, show a decrease in utilization from 1994–2006, although trends in subsets of that 

time period have fluctuated. 

3-41 

EERE-2006-STD-0127 COMMENT 69.1
Table 3.13.2 Full Production Capacity Utilization Rates61 

Year Rates (%) 

Household Appliances Cooking Appliances Household Laundry 

2006 77 65 80 

2005 74 57 79 

2004 76 61 77 

2003 78 57 85 

2002 72 56 87 

2001 70 50 90 

2000 70 55 88 

1999 75 59 87 

1998 73 66 75 

1997 73 61 80 

1996 76 66 81 

1995 79 66 83 

1994 82 72 89 

3.14 TECHNOLOGY ASSESSMENT 

This section provides a technology assessment for residential cooking products and 

CCWs. Contained in this technology assessment are details about product and equipment 

characteristics and operation (section 3.14.1), an examination of possible technological 

improvements for each product or equipment (section 3.14.2), and a characterization of the 

product and equipment efficiency levels currently commercially available (section 3.14.3). 

3.14.1 Product and Equipment Operation and Components 

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

description of the characteristics and operation of each product and equipment covered by this 

rulemaking. These descriptions provide a basis for understanding the technologies used to 

improve product and equipment efficiency. 

3.14.1.1 Cooking Products 

Residential cooking products are appliances that enable the homeowner to heat and cook 

foods by means of transfer of input energy to the food load. Input energy may be electricity, gas, 

or a combination of the two. Cooktops consist of a horizontal surface comprising one or more 

heating elements. A cooking vessel is placed on the top surface of the cooktop over the element 

to facilitate heat transfer to the food load. In conventional and microwave ovens, the cooking 

vessel is placed inside a cavity within which the energy transfer takes place. Ranges incorporate 

both an oven and a cooktop in a single unit. 

In a gas cooktop, pressurized natural gas or propane is supplied to each burner by means 

of an orifice and venturi on the underside of the cooktop surface. A sheet metal box encloses the 

array of burner supply lines as well as the controls for gas delivery and ignition, if provided. 

3-42 

EERE-2006-STD-0127 COMMENT 69.1
Primary air drawn from within the enclosure mixes with the gas at the venturis and is delivered 

to the ports typically arrayed radially on the burners above the cooktop surface. Gas flow and 

thus burner turndown is controlled by individual, typically rotary, valves connected to the burner 

supply lines. Upon ignition of the gas-air mixture, secondary air is entrained near the burner 

ports to produce a substantially radial distribution of flames. For sealed burners in which the 

cooktop surface interfaces directly with the base of each burner, all secondary air is introduced 

above the cooktop surface. Open burners can derive some secondary air from the box as well. 

Grates positioned above the burners allow a cooking vessel to be placed at the proper spacing to 

ensure adequate secondary air for complete combustion, minimization of carbon monoxide 

emissions, and adequate convective heat transfer for cooking efficiency. 

The simplest ignition scheme for a gas cooktop utilizes a standing pilot, through which a 

small amount of gas is continuously supplied and burned as the ignition source for the burners. 

Gas cooktops equipped with electrical cords cannot have a constant burning pilot (42 U.S.C. 

6295 (h)(1)) and instead utilize some form of electrically powered ignition, typically an 

intermittently activated spark igniter. An electronic control module may automatically energize 

the spark electrode whenever flame extinction is detected; otherwise the spark igniter must be 

manually reactivated by means of switches on the burner valve controls in the event of flame 

loss. Controls for the burners typically consist of manual burner adjustment as dictated by the 

rotary valve position. In order to achieve very low firing rates associated with such cooking 

processes as simmering, melting chocolate, or heating delicate sauces, some cooktops 

incorporate electronic controls that cycle burners on and off. 

An electric cooktop consists of a horizontal surface with one or more electrically 

powered heating elements located either above or below the cooktop surface. When the elements 

are located above the cooktop surface, the cooking vessel is placed directly on an element to heat 

the vessel and contents through conductive heat transfer. The elements are resistively heated by 

means of the current supplied to them. An open coil-type cooktop utilizes a spiral-wound 

sheathed heating element. Removable drip bowls beneath each element serve as catch basins for 

spills. Solid disk elements contain a similar resistive element embedded in a flat, circular cast 

iron housing to provide a more even heating surface and greater cleanability than for a coil 

element. Due to this difference in cleanability, solid disk elements are classified as a separate 

product class from open coil elements. 

Heating elements may also be located under a glass-ceramic cooktop surface. Such 

elements may be of a radiant, halogen, or inductive type, which are described in more detail 

under the technology options in section 3.14.2.1. Each of these technologies is categorized in the 

smooth cooktop product class along with solid disk elements. Electronic control systems are 

provided to energize the desired heating elements. These controls may incorporate algorithms for 

modulation of the element according to cooktop and cooking process parameters. 

Gas ovens are appliances designed to bake, roast, or broil foods within an insulated 

cavity by means of the combustion of natural gas or propane. The major components of the oven 

include the cavity, the gas burners, an ignition system, and a control system. If the oven 

3-43 

EERE-2006-STD-0127 COMMENT 69.1
incorporates a convection cooking mode, one or more fans are situated within the cavity to 

provide a means for forced-air distribution. 

The oven cavity is a formed sheet metal enclosure with provision for holding cooking 

racks at varying positions. The interior surface of the cavity may be bare metal (stainless steel), 

or it may have a porcelain coating for durability and cleanability. Additives in the porcelain 

coating can provide catalytic conversion of food spilled on the surface under normal cooking 

temperatures, thus enabling a continuous cleaning process. Alternatively, the oven may have 

features that allow it to be operated under a special self-clean mode, which heats the cavity to 

higher temperatures than those used for cooking. In the process, food spills are pyrolized, leaving 

an ash residue that is easily wiped off when the cavity cools down. 

Accessories such as lights and sensors for control of cooking processes are located within 

the cavity, while an insulated glass window in the oven door allows observation of the cooking 

processes without requiring the door to be opened (which would incur substantial heat loss). The 

outside of the cavity is wrapped with insulation to minimize heat loss to ambient surroundings. 

The space between the cavity and the outer sheet metal enclosure which is filled by the insulation 

typically is made as small as practically possible in order to maximize the cavity volume. 

Gas burners are situated at the bottom of the cavity for the bake function and the top for 

broiling. They are typically shielded by baffles or covers to protect the burners from spills and to 

help distribute heat evenly. Broil elements may also be of a radiant type in which the combustion 

of the fuel-air mixture heats a perforated ceramic matrix or a metal mesh. As the ceramic or 

metal heats, it emits infrared radiation that can produce heating and surface browning of the 

cooking load. Combustion products from each burner and gases released during the cooking 

process are vented from the top of the cavity. 

Ignition may be achieved through the use of a pilot or a hot surface igniter. In the case of 

a pilot, it may be a continuously burning standing pilot type, or an intermittently actuated spark 

igniter may be used to light the pilot when the oven controls are turned on. In either case, the 

pilot serves to heat a thermally-actuated switch that keeps the main gas valve open. With hot 

surface ignition, a ceramic heating element is placed in a location where the incoming gas-air 

mixture will impinge on it. As the element is heated electrically, its resistance goes down and 

current draw goes up. A bi-metallic gas valve in electrical series with the igniter deforms as its 

corresponding current increases, allowing gas flow as long as the hot surface igniter is energized 

by the burner controller. 

Like gas ovens, electric ovens are designed to bake, roast, or broil food. The cavity is 

similar to those of gas ovens as well, in that the surface finishes may be bare or porcelainized, 

with or without the catalytic properties. In addition, electric ovens may incorporate a self-clean 

mode for pyrolysis of food matter on in the interior surfaces. Accessories and insulation tend to be 

similar between gas and electric ovens, and electric ovens also incorporate venting, although the 

demands of such venting are lower than those for gas ovens since there are no combustion 

products. 

3-44 

EERE-2006-STD-0127 COMMENT 69.1
The heat source for the cooking process is typically provided by radiant elements. Bake 

elements are located at the bottom of the cavity, and may be either exposed or covered to provide 

spill protection and improve cleanability. Broil elements are situated at the top of the cavity. Far 

less common than radiant elements, halogen elements are also used to promote faster cooking. 

An additional cooking feature on many electric ovens and certain gas ovens is convection 

mode, in which hot air within the cavity is circulated by means of one or more fans to speed the 

cooking process, promote surface crisping, and increase cooking uniformity. Supplemental 

heating of this recirculated air may be accomplished by means of a radiant heating element 

located near the fan. 

Additional electrically-powered components in electric ovens may include cavity lights, 

electronic controls incorporating various types of displays, and cooking sensors. 

A microwave oven is an appliance which heats foods and beverages through the 

conversion of electric energy to electromagnetic (microwave) energy. The food load is placed 

inside the oven where it is subjected to the microwave energy. In the portion of the 

electromagnetic spectrum where microwave ovens operate, typically 2.45 gigahertz, water, fats, 

and sugars have high absorptivity and thus food heats readily. Glass, ceramic, and paper have 

low absorptivity at these wavelengths, while metals reflect the microwaves. Therefore 

microwave ovens efficiently heat foods while the cavity and utensils remain cool. 

The microwave energy is generated by an electrically powered magnetron. Line voltage 

is converted to the high voltage required by the magnetron through the use of a high-voltage 

transformer. The microwaves are directed from the magnetron into the cavity via a metal duct, or 

waveguide. To produce a more uniform distribution of energy in the cavity, one or more sets of 

rotating metal blades may be inserted in the waveguide to alter the microwave patterns 

temporally. Additionally, a turntable or translating tray may be provided in the cavity to move 

the load and thus promote even input energy distribution to the food. Some microwave ovens are 

equipped with electrically powered resistive or halogen heating elements for surface browning, 

and in the case of combination microwave ovens, an additional fan for forced air distribution to 

enhance cooking performance. 

To achieve reduced power levels for cooking processes such as defrosting, the magnetron 

is typically cycled at an appropriate duty cycle which results in a time-averaged power at the 

desired level. Electronic controls may include a clock/timer function as well as a humidity or 

infrared sensor for detecting when the desired level of cooking is achieved. Standby power 

consumption associated with these electronics, as well as the power supply, may be several 

watts. In addition, a light is typically provided that is turned on when the door is opened or when 

the microwave oven is in operation. 

Installation configurations include countertop and over-the-range. Over-the-range 

microwave ovens may include a ventilation fan that turns on automatically when the temperature 

from the cooktop below it rises; however, such an option is not required for certification under 

3-45 

EERE-2006-STD-0127 COMMENT 69.1
the Underwriters Laboratories (UL) Standard UL 923 - Edition 5, Standard for Microwave 

Cooking Appliances. 

3.14.1.2 Commercial Clothes Washers 

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. 

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 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 for non-agitator top-loading 

clothes washers, their high spin speeds may wrinkle clothing. 

3-46 

EERE-2006-STD-0127 COMMENT 69.1
 

Although most clothes washers using a horizontal-axis rotating drum are front-loading, 

they can be designed to be top-loading as well. In a top-loading horizontal-axis design, the 

cabinet has a door at the top that opens above the washer drum. Another door that slides or 

pivots open then provides access to the inner drum. 

Manufacturers typically base CCWs on existing RCW platforms. This simplifies 

fabrication and assembly (i.e. 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 the commercial-standard 25-minute wash cycle, for 

example. However, some recent high-efficiency CCW entrants feature wash cycles longer than 

25 minutes, indicating that manufacturers may not be able to meet such short wash cycles in 

conjunction with low water and energy consumption. 

3.14.2 Technology Options 

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

increase the efficiency of residential cooking products and CCWs, DOE identified several 

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

3.14.2.1 Cooking Products 

DOE most recently analyzed energy conservation standards for cooking products in 

1996 and 1997. In the 1997 analysis, DOE analyzed only gas cooking products to determine the 

technical and economic feasibility of eliminating standing pilots. DOE’s prior analysis in 1996, 

contained within the 1996 TSD for cooking products, identified technologies that have the 

potential for improving gas and electric cooking efficiency. DOE has considered all of these in 

this rulemaking. In addition, DOE identified low-standby-loss electronic controls as a technology 

option for several cooking products, based on review of standby power data for microwave 

ovens and the assumed applicability to conventional cooking products as well. 

For gas cooktops, DOE considered the technologies listed below. 

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Table 3.14.1 Technology Options for Gas Cooktops 

1. Catalytic burners 

2. Electronic ignition 

3. Insulation 

4. Radiant gas burners 

5. Reduced excess air at burner 

6. Reflective surfaces 

7. Sealed burners 

8. Thermostatically controlled burners 

Catalytic burners 

Catalytic burners consist of a porous ceramic or refractory material such as glass or 

ceramic wool, impregnated with a catalyst. The gas-air mixture or gas alone is fed to the catalytic 

matrix, whereupon additional ambient air diffuses into it. The catalyst, typically palladium or 

platinum, lowers the activation energy required for combustion such that the gas-air mixture 

subsequently oxidizes at temperatures below those normally required for combustion. This 

produces a uniform, low-intensity infrared radiation with no visible flame. The burners include 

an electric heating element to preheat the catalyst prior to initiating operation. Catalytic burners 

in residential appliances are investigated primarily as a means of reducing NOx emissions, since 

NOx formation is highly temperature dependent. DOE is not aware of any commercialized 

catalytic burners for gas cooktops or efficiency data for applications of catalytic burners in 

cooking appliances. 

Electronic ignition 

Gas cooktops equipped without electrical power cords use a standing pilot ignition 

system. The energy factor of the cooktop can be increased by replacing the standing pilot system 

with an electronic ignition system. Actual burner efficiency is not affected by eliminating the 

standing pilot. The resulting increase in EF is due only to the decrease in the cooktop’s annual 

gas energy consumption attributed to the pilot gas consumption. 

The most common type of electronic ignition used by gas cooktops is an intermittent 

ignition system, where spark igniters replace the standing pilots. These igniters are controlled by 

switches on each burner valve. The switches are typically rotary-actuated so that when the burner 

valve is turned to the light position, a “starter” signal is sent to the control module. Alternatively, 

the signal can be generated by electronic controls on the user interface of the cooktop. Once the 

signal is received, the control module activates the spark igniters. The control module can either 

be a supervised or an unsupervised type. Supervised modules require re-activation of the burner 

switches for cases where burner flames are accidentally extinguished. Unsupervised modules use 

a sensor located at the burner (often the igniter itself) to sense when the flame has been 

accidentally extinguished. The burner switches do not need to be re-activated, as the sensor sends 

a signal back to the control module to reactivate the igniters. Though they cost more, 

unsupervised ignition systems are preferred over systems that use supervised control modules 

since they prevent the need to check accidentally extinguished flames. Most of the currently 

manufactured gas cooktops that are equipped with intermittent ignition systems use unsupervised 

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EERE-2006-STD-0127 COMMENT 69.1
control modules. Because of this, unsupervised control systems are the type of electronic ignition 

devices being analyzed for gas cooktops. 

It is important to note that intermittent ignition systems consume negligible amounts of 

electricity. Since the control module is powered directly from line voltage, there are no 24-volt 

transformer losses associated with it. The spark igniter is activated for an extremely short time 

period so that its cumulative on-time during the course of a year, and thus its electricity 

consumption, is negligible. 

A recently introduced igniter technology utilizes a ceramic hot surface igniter in place of 

the spark igniter. With this type of ignition, the igniter may either be constantly energized 

whenever the burner valves are open, such as on a simmer setting where the burner is cycled on 

and off to achieve very low average input rates, or turned on in response to either initial burner 

gas flow or detection of flame extinction. Therefore it may be considered an unsupervised 

system. Improved cooktop utility includes elimination of the noise associated with spark ignition. 

Energy consumption during usage is higher than for spark ignition. 

DOE also identified battery-powered ignition systems as an alternative to standing pilot 

systems which does not require line power. DOE notes that American National Standards 

Institute (ANSI) Standard Z21.1, American National Standard for Household Cooking Gas 

Appliances (ANSI Z21.1), provides a number of requirements for the ignition systems in gas 

cooking products. ANSI Z21.1 requires that automatic gas ignition systems comply with the 

applicable construction provisions of the ANSI Z21.20, Standard for Automatic Gas Ignition 

Systems and Components. (Section 1.16.1 of ANSI Z21.1) ANSI Z21.1 also provides a number 

of other design and performance requirements which would need to be met by the batterypowered ignition system. 

DOE notes that it could not identify any indoor ranges incorporating such ignition 

systems that are on the market in the United States. DOE was able to identify a single gas range 

for sale in the United Kingdom that incorporates a battery-powered ignition system (i.e., that the 

oven main burner is lit by an intermittent gas pilot that is in turn lit by a battery-powered spark 

igniter.) that appeared to meet the functional safety requirements of ANSI Z21.1. This ignition 

system does not require the user to push a separate “light” button at the same time as the control 

knob is turned to allow pilot gas flow. Such a separate operation would be prohibited under 

ANSI Z21.1. However, further DOE research determined that the ignition system does not 

include a safety device to shut off the main gas valve in the event that no flame is detected, 

which is required by the ANSI standard. Therefore, DOE concludes that there are no batterypowered ignition systems incorporated into commercially available ranges that would meet 

applicable safety requirements. 

DOE also investigated the possibility that battery-powered ignition systems used in other 

indoor residential appliances in the United States could meet the requirements of ANSI Z21.1, 

even though they are not currently being incorporated in gas cooking products. DOE identified 

several such appliances, including a remote-controlled gas fireplace and instantaneous gas water 

heaters. For these products, the battery-powered ignition systems are required to meet the same 

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EERE-2006-STD-0127 COMMENT 69.1
or equivalent component-level ANSI safety standards as are required for automatic ignition 

systems in gas cooking products (ANSI Z21.20 and ANSI Z21.78). 

DOE considered the following issues regarding the application of a battery-powered 

ignition system in residential gas cooking products: (1) the lack of battery-powered ignition 

systems being available to cooking appliance manufacturers; and (2) concerns that batterypowered ignition systems would not meet the applicable safety standard ANSI Z21.1. DOE 

conducted market research and contacted gas-fired appliance manufacturers in order to discuss 

safety issues associated with battery-powered ignition systems and their application in gas 

cooking appliances per ANSI Z21.1 in particular. 

One instantaneous water heater manufacturer that DOE interviewed stated that batterypowered ignition systems for gas appliances are quite common in China due to the lack of line 

power in many rural areas. The manufacturer knew of at least one Chinese supplier which is 

currently shipping battery-powered, oven/cooktop ignition controls to the EU. DOE believes that 

the most likely reason for the lack of battery-powered ignition systems being available to 

cooking appliance manufacturers regards the economics. Because standing pilot ignition systems 

are cheaper to implement than electric ones, there is little to no market driver for batterypowered ignition systems in cooking appliances. In past interviews with ignition system 

manufacturers, DOE was told that ignition system manufacturers would be willing to develop 

and supply a battery-powered ignition source for cooking appliances if a suitable market 

presented itself. If there are a substantial number of consumers who do not want to use line 

power as manufacturers of standing pilot ranges have stated and standing pilot systems are 

eliminated, this market opportunity would finally present itself to ignition system manufacturers. 

As a result, DOE is unaware of any technological or safety requirement barriers that 

would preclude a battery-powered ignition system that could meet the requirements of ANSI 

Z21.20. However, the components would have to be tested and certified within the cooking 

product to meet the safety requirements of ANSI Z21.1. Thus, DOE contacted several cooking 

appliance manufacturers to determine whether battery-powered ignition systems could be 

integrated into residential indoor cooking appliances such that they would meet the requirements 

of ANSI Z21.1. One gas cooking appliance manufacturer stated that, from a technology 

standpoint, there are no barriers prohibiting the application of a battery-powered ignition system, 

similar to those used in appliances such as unattended instantaneous gas water heaters and 

remote-controlled gas fireplaces, into residential cooking products. Thus, DOE believes that 

battery-powered ignition systems are a technologically feasible alternative to line-powered 

electronic ignition systems in residential gas cooking products. 

DOE further notes that, although battery-powered ignition systems, which may meet 

ANSI Z21.20 (Standard for Automatic Gas Ignition Systems and Components), are not 

specifically covered by ANSI Z21.1 for use in residential gas cooking products, neither are they 

specifically disallowed. One gas cooking appliance manufacturer noted that ANSI Z21.1 is not 

able to regulate specific designs for components such as ignition systems. This gas cooking 

appliance manufacturer believes that ANSI Z21.1 would need to be modified to address 

appropriate safety concerns. However, the manufacturer was unable to identify any specific 

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provisions in the current ANSI Z21.1 and ANSI Z21.20 that would prohibit the use of batterypowered ignition systems for residential cooking products. 

DOE notes that, section 1.1.4 of ANSI Z21.1 states that “[t]his standard covers (a) 

appliances which use only gas for cooking and which are designed for connection to nominal 

120-volt electrical supplies, or (b) appliances which also use electrical energy for cooking and 

which are designed for connection to either nominal 120-volt or 240-volt electrical supplies.” 

DOE further notes that ANSI Z21.1 is currently used to certify the safety of cooking appliances 

with standing pilot ignition systems, i.e. appliances which have no line power, and that the 

standard contains multiple provisions to test standing pilot ignition systems. One gas cooking 

appliance manufacturer that DOE interviewed suggested that DOE could work with ANSI to 

develop industry-consensus recommendations for amending the scope to cover alternative 

ignition systems, including provisions for design, performance, and safety requirements for 

battery-powered ignition systems. However, the manufacturer expected that this process could 

take several years. However, the manufacturer noted that if standing-pilot ranges could get 

certified per ANSI Z21.1 despite the exclusion in section 1.1.4, that similar certifications for 

ranges with battery-powered ignition should be possible also. 

Based on the above discussion, DOE believes that it is technologically feasible to 

incorporate battery-powered ignition systems in residential cooking products as an alternative to 

line-powered electronic ignition systems by the effective date of an amended standard. 

Insulation 

 Added insulation is only used in a gas cooktop when it is installed as a countertop unit 

(not above an oven). Here, the surrounding structures encompassing the cooktop might 

experience surface temperature problems that can be alleviated by adding insulation. Insulation 

underneath the cooktop reduces the surface temperature of all exposed non-cooktop surfaces to 

levels which meet UL requirements. 

Of the information reviewed on efficiency improvements to gas cooktops, adding 

insulation was never analyzed as a method to improve cooktop performance. Manufacturers’ 

data from the previous rulemaking provided no estimate of energy efficiency improvements from 

insulating gas cooktops. 

Radiant gas burners 

Radiant gas burners transfer heat through infrared radiation from the burner surface. The 

burner consists of a porous matrix through which a premixed gas-air mixture is fed. Upon 

ignition, the flames sit on the surface of the matrix, heating the surface and causing it to emit 

radiation at infrared wavelengths. The burner is located under a glass-ceramic cooktop surface. 

One form of radiant gas burners is termed the powered Infrared Jet-Impingement (IR-Jet) 

burner. In an IR-Jet gas burner, both radiant and convective energy are transmitted to the 

cooking vessel. A forced-draft combustion fan is used to deliver the fully-premixed gas-air 

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EERE-2006-STD-0127 COMMENT 69.1
mixture to available cooktop burners. At each burner, combustion occurs at the surface of a 

perforated ceramic tile. As the tile heats, it emits radiant energy, principally in the far infrared 

regime. Combustion products are jetted through perforations in the glass-ceramic cooktop, 

delivering convective energy to the cooking vessel as well. 

As reported in the 1996 TSD, the Gas Research Institute (GRI) sponsored the 

development of the IR-Jet gas burner. With GRI’s sponsorship, the American Gas Association 

Laboratories (AGAL) worked with a range manufacturer to produce a working IR-Jet burner. 

However, the IR-Jet burner is not currently being marketed. Data collected from a boiling water 

test indicated that the AGAL-developed IR-Jet radiant burner is more efficient than a comparable 

conventional open burner. The boiling water test indicated a 16-percent increase in efficiency 

Another type of radiant gas burner utilizes a silicon carbide-fiber burner which emits 

radiation in the near-infrared spectrum. A prototype developed jointly by Tokyo Gas and Rinnai 

Corporation utilized such material in a glass-ceramic cooktop that did not incorporate jet 

impingement. Instead, combustion products were vented from underneath a solid, non-perforated 

cooktop. Such a radiant burner relied entirely on radiant heat transfer and conduction from the 

glass-ceramic after it heated up. In tests conducted according to the Japanese Industrial Standard 

(JIS) S 2103:1996, Gas burning cooking appliances for domestic use, which is a water heating 

procedure, the efficiency was reported as 43.5 percent compared with an estimated 30 percent for 

traditional gas burners.62 

Reduced excess air at burner 

The excess-air ratio is defined as the amount of air used in the combustion process of the 

gas burner divided by the amount of air necessary for stoichiometric combustion. Excess air is 

provided to ensure high-quality flame characteristics and to create a safety margin to ensure 

complete combustion is reached under all conditions. Reducing the excess-air ratio at the burner 

through redesign and shrouding can improve its efficiency. This information was provided by the 

1980 engineering analysis performed by DOE63 in support of developing energy efficiency 

standards for a variety of consumer products, including cooktops and ovens. This document does 

not specify how the burner should be redesigned and shrouded. 

Reflective surfaces 

Reflective surfaces for gas cooktops utilize highly polished or chromed drip pans 

underneath the burner. By reflecting some of the radiant heat of the burner back up to the 

cooking vessel, the efficiency of the burner is increased. The consumer must maintain the 

reflective finish by cleaning the drip pans regularly. 

Efficiency gains resulting from using reflective pans are extremely small because gas 

flames and burners have minimal infrared emissions. The primary mechanism for heat transfer to 

the cooking vessel is convection. The efficiency increase was obtained from using 

manufacturers’ data provided by AHAM and reported in the 1996 TSD. The data indicate that an 

efficiency increase of only 0.1 percent is realized due to the incorporation of reflective surfaces. 

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Sealed burners 

 Unlike conventional (open) burners, the cooktop surface surrounding sealed burners 

interfaces directly with the base of the burner. This results in a reduced amount of secondary air 

to the burner for combustion. According to the 1996 TSD, AHAM stated that sealed burners 

often have a lower gas input rating than conventional burners due to the reduction in secondary 

air. The sealed burner must obtain all of its secondary air from above the cooktop. In order to 

obtain sufficient air for proper combustion, it becomes necessary to either raise the grate height 

or de-rate the burner. Contrary to these statements, a report from the 1983 International Gas 

Research Conference64 states that the reduction in secondary air results in more primary aeration 

to the sealed burner. The increased primary aeration allows for a reduced pan-to-burner 

separation and increased burner efficiency. According to the boiling water tests conducted in the 

report, the efficiency of conventional burners ranged from 42–48 percent, while the sealed 

burner was rated at an efficiency of 53 percent. 

Manufacturers’ data provided by AHAM were used to estimate the increase in efficiency 

due to sealed burners in the 1996 TSD. An efficiency increase of approximately 2.0 percent was 

estimated. 

Thermostatically controlled burners 

Thermostatically controlled gas burners control the gas flow to the burner through the use 

of a sensing element that extends through an opening in the center of the burner. This sensing 

element makes contact with the bottom of the cooking vessel, detecting the temperature and 

controlling the input rate to the burner accordingly. If the cooking vessel has an uneven bottom 

in the area where the sensor is supposed to make contact, however, any type of useful 

temperature control is lost. 

Thermostatically controlled burners were widely sold in the late 1950s and 1960s. But 

due to customer complaints on the operating characteristics of the burner, manufacturers dropped 

this feature. As reported in the 1996 TSD, manufacturers stated that the sensor’s electric element 

retains heat due to its mass. This results in the sensor being “fooled” and causing delays in 

reaction time. These delays allow wide swings in the thermostatically controlled temperature. 

Manufacturers stated that even if improvements in sensor manufacturing resulted in no heat 

retention, the many existing variables associated with the cooking vessel (e.g., vessel material, 

food mass, type of food) make the thermostatically controlled burners’ utility and energy 

efficiency suspect. 

For open (coil) element electric cooktops, DOE considered the technologies listed 

below. 

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Table 3.14.2 Technology Options for Open (Coil) Element Electric Cooktops 

1. Electronic controls 

2. Improved contact conductance 

3. Insulation 

4. Low-standby-loss electronic controls 

5. Reflective surfaces 

Electronic controls 

Electronic controls using sophisticated control algorithms can use the dynamic thermal 

properties of the element to turn off the energy input to the element just in time to “coast” to the 

desired final temperature without overshooting it. 

Research has been conducted to determine the effect that electronic controls have on 

cooktop efficiency. Danish researchers, testing breadboard versions of microprocessor-controlled 

electric hotplates, found a 20- to 46-percent energy savings in cooking a variety of foods with 

European recipes.65 

Improved contact conductance 

The thermal contact resistance that arises from an imperfect contact between the cooking 

vessel and the open (coil) element can be reduced by improving the flatness of the element. An 

improved contact conductance allows for more heat to be transferred to the cooking vessel and, 

thus, an improvement in the efficiency of the element. 

As stated in the 1996 TSD, manufacturers asserted that they have worked on improving 

the flatness of the element and that the types that are available currently are doing an excellent 

job. They also stated that the results obtained from DOE test measurements do not reflect the 

actual performance of the open element. The aluminum test block used in the test procedure is 

much flatter than actual cooking vessels. Because of the block’s very flat surface, test 

efficiencies will be higher than those obtained from field measurements using “real” cooking 

vessels. Therefore, according to the manufacturers, increases in efficiency that can be obtained 

by improving the contact conductance under DOE test conditions will not be realized under field 

conditions. 

Sources used in assessing the efficiency gains that could be expected from improving the 

contact conductance in the 1996 analysis included: (1) manufacturers’ data provided by AHAM; 

(2) a costing analysis of technology options for residential appliances prepared by ADM 

Associates for Lawrence Berkeley National Laboratory (LBNL);66 and (3) an energy efficient 

electrical product knowledge base prepared by ORTECH International for the Canadian 

Electrical Association.67 An additional comment68 received from Arthur D. Little, Inc. (ADL) 

following the NOPR for the previous rulemaking reported that the major mechanism for heat 

transfer was physical contact between the vessel and coil, not contact pressure. Averaging the 

data from these sources results in a relative efficiency increase for this technology option of just 

over 3 percent. 

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EERE-2006-STD-0127 COMMENT 69.1
 

Insulation 

Added insulation is only used in an open (coil) element electric cooktop when it is 

installed as a countertop unit (not above an oven.) Here, the surrounding structures 

encompassing the cooktop might experience surface temperature problems that can be alleviated 

by adding insulation. Insulation underneath the cooktop reduces the surface temperature of all 

exposed non-cooktop surfaces to levels which meet UL requirements. 

Of the published information reviewed on efficiency improvements to open (coil) 

element electric cooktops, adding insulation was never mentioned as a method to improve 

cooktop performance. Manufacturers’ data provided no estimate of efficiency improvements 

from insulating cooktops. 

Low-standby-loss electronic controls 

Electronic controls may consume power even when the electric cooktop is not performing 

its intended function. Depending on the implementation of the controller, standby power is 

required to enable the electronic controls to detect user input without the user first having to turn 

on a mechanical power switch or to enable displays, illuminate switches, etc. Reducing the 

standby power consumption of electronic controls would reduce the annual energy consumption 

of the electric cooktop, but would not impact the energy consumption of the electric cooktop 

during operation. 

Reflective surfaces 

As described in the similar technology option for gas cooktops, this technology option 

utilizes highly polished or chromed drip pans underneath the heating element. By reflecting some 

of the radiant heat of the element back up to the cooking vessel, the efficiency of the element is 

increased. The consumer must maintain the reflective finish by cleaning the drip pans regularly. 

Efficiency gains resulting from using reflective pans are extremely small. The efficiency 

increase assumed in the 1996 TSD was obtained from data from the following sources: (1) 

manufacturers’ data provided by AHAM; (2) the energy efficient electrical product knowledge 

base prepared by ORTECH International for the Canadian Electrical Association;69 and (3) the 

1980 DOE engineering analysis for residential appliances.70 Averaging the data from these 

sources results in an efficiency increase of 1 percent. 

For smooth element electric cooktops, DOE considered the technologies listed below. 

Radiant elements, which were included in the 1996 TSD, were not considered as a design option 

for this rulemaking because manufacturer data provided to DOE for the 1996 TSD indicated that 

this technology does not offer an efficiency improvement over the baseline according to the DOE 

test procedure. 

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Table 3.14.3 Technology Options for Smooth Element Electric Cooktops 

1. Electronic controls 

2. Halogen elements 

3. Induction elements 

4. Low-standby-loss electronic controls 

Electronic controls 

 Sophisticated electronic controls can be applied to solid disk elements, radiant elements, 

and halogen elements to allow the element to “coast” to its final temperature. Electronic controls 

are not applicable to induction elements as the nature of its operation has no need for “coasting” 

controls. DOE is unaware of any efficiency data characterizing energy savings for electronic 

controls on smooth element cooktops. However, research previously cited suggests potential 

energy savings of this technology for open (coil) element cooktops and it is possible that similar 

energy savings could be achieved for smooth element cooktops. 

Halogen elements 

Halogen elements transfer energy to the cooking vessel by direct infrared radiation from 

high-powered tungsten-halogen lamps. The halogen element lies underneath a glass-ceramic 

panel and consists of one or more lamps installed horizontally within a corrosion-protected metal 

dish. The bottom of the metal dish is insulated with microtherm insulation. 

Radiant heating coils are commonly fitted around the halogen element to provide heat 

around the element’s edge. This results in a highly responsive element that provides an even 

temperature distribution. Halogen elements can be configured to operate across a wide range of 

capacities. Parallel or series lamp arrangements can yield power outputs from 1200–2500 W. 

Halogen lamp technology reported in the 1996 TSD consisted of a circular lamp that can provide 

a more optimum temperature distribution than traditional straight lamps. This circular lamp has 

the trademark name of Haloring. 

The 1996 TSD reported that with the continued development of halogen elements, 

efficiencies had increased. The circular halogen-lamp elements that had recently been developed 

at the time of the previous analysis could exceed the efficiency of solid disk elements as 

measured according to the DOE test procedure. Data provided for the 1996 rulemaking by a 

cooktop manufacturer were used to establish the efficiency gain of a circular halogen lamp 

element over that of a solid disk element. An efficiency increase of approximately 1.5 percent 

was measured. It is important to reiterate that this efficiency increase was only for the circular 

halogen lamp element. Other halogen lamp elements might not yield the same efficiency 

increase. The same cooktop manufacturer mentioned above also provided efficiency data based 

on boiling water tests. These tests indicated that circular halogen lamp elements can yield even 

higher efficiency increases over that of solid disk elements. European manufacturers had also 

conducted boiling water tests indicating that halogen lamp elements (the configuration of 

halogen lamp tested was not specified) are more efficient than solid disk elements.71 

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EERE-2006-STD-0127 COMMENT 69.1
 

Induction elements 

Induction elements use a solid-state power supply to convert 60 hertz alternating line 

current into a high-frequency (approximately 25 kilohertz) alternating current. This highfrequency current is supplied to an inductor. The inductor is a flat spiral winding located just 

underneath a glass-ceramic panel. The high-frequency current, which is supplied to the inductor, 

causes it to generate a magnetic field which passes through the glass-ceramic panel unaffected 

and produces eddy currents in the bottom of the cooking vessel. The vessel must be made of 

ferromagnetic material, and the eddy currents that are generated within it cause it to heat up. 

Thus, the vessel essentially becomes the heating element. 

A sensor is placed between the inductor and the glass-ceramic panel, providing a 

continuous temperature measurement of the vessel bottom. Sensors also enable the inductor to 

only heat objects of at least 4 inches in diameter. This prevents any small metal objects, such as 

forks or spoons, from accidentally being heated. In addition, since the glass-ceramic panel is 

unaffected by the magnetic field, it remains relatively cool, reducing the potential for accidental 

burns. 

The primary advantages of induction elements are their fast response and control of the 

heat source, their ease of cleaning, and their ability to heat vessels that are not flat. Because these 

features have usually been associated with gas burners, induction elements are being marketed in 

competition to them. 

As just noted, the cooking vessel used with an induction element must be made from a 

ferromagnetic material. Since aluminum is not a ferromagnetic material, the current DOE test 

procedure, which specifies an aluminum test block, cannot be used to rate this equipment. In 

1978, the National Bureau of Standards (NBS), now called National Institute of Standards and 

Technology (NIST), developed a proposed method of measuring the energy consumption of 

induction cooktops.72 The method is a modification of the current DOE test procedure. Energy 

use is determined by attaching a ferromagnetic material to the bottom of the aluminum test 

block. This modification was never formally adopted by DOE, but a source was found that 

provided data on how a typical induction element performed under the proposed method 

developed by NBS.73 An absolute efficiency of 84 percent was presented. 

Low-standby-loss electronic controls 

Electronic controls may consume power even when the electric cooktop is not performing 

its intended function. Depending on the implementation of the controller, standby power is 

required to enable the electronic controls to detect user input without the user first having to turn 

on a mechanical power switch or to enable displays, illuminate switches, etc. Reducing the 

standby power consumption of electronic controls would reduce the annual energy consumption 

of the electric cooktop, but would not impact the energy consumption of the electric cooktop 

during operation. 

For gas and electric ovens, DOE considered the technologies listed below. 

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Table 3.14.4 Technology Options for Gas and Electric Ovens 

1. Bi-radiant oven (electric only) 

2. Forced convection 

3. Halogen lamp oven (electric only) 

4. Improved and added insulation 

5. Improved door seals 

6. Low-standby-loss electronic controls 

7. No oven-door window 

8. Oven separator 

9. Pilotless ignition (gas only) 

10. Radiant burner (gas only) 

11. Reduced conduction losses 

12. Reduced thermal dmass 

13. Reduced vent rate 

14. Reflective surfaces 

15. Steam cooking 

Bi-radiant oven (electric only) 

A bi-radiant electric oven system was developed by Purdue University for Oak Ridge 

National Laboratory in the late 1970s.74 The objective of the project was to develop an electric 

oven that offered significant energy savings without compromising food quality. The bi-radiant 

oven has three important features which provide improved performance: (1) the cavity walls are 

highly reflective rather than absorptive, thereby allowing these surfaces to operate at cooler 

temperatures; (2) the heating elements, similar in construction to those in conventional ovens but 

operating at much lower temperatures, provide a prescribed, balanced radiant flux to the top and 

bottom surfaces of the food product; and (3) the baking and roasting utensils have a highly 

absorptive finish. 

The bi-radiant oven was tested under a variety of cooking conditions (including the DOE 

test procedure) and also modeled (using computer thermal analysis programs) to determine its 

performance. It demonstrated a greater than 50-percent increase in efficiency over that of a 

conventional oven. In addition, the separate upper and lower heating elements required by the 

oven provided more flexibility in baking and roasting. 

Several important practical concerns have to be addressed by manufacturers in order to 

realize the demonstrated energy savings: (1) the oven lining material must be durable enough to 

maintain the low-emissivity (less than 0.1) cavity surface; (2) microprocessor controls must be 

used; and (3) as mentioned earlier, the baking and roasting utensils must have a highly absorptive 

exterior. However, given the assumption that all of these criteria are met, the 1996 analysis 

assumed a 50-percent efficiency increase. 

Forced convection 

A forced convection oven uses a fan to distribute warm air evenly throughout the oven 

cavity. The use of forced circulation can reduce fuel consumption by cooking food more quickly, 

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EERE-2006-STD-0127 COMMENT 69.1
at lower temperatures, and in larger quantities than a natural convection oven of the same size 

and rating. The fan is placed within the rear cabinet wall and a protective screen is placed around 

it. The screen prevents any items being placed in the oven from “knocking” into the fan and 

causing damage. The screen may also assist in distributing the heated air evenly throughout the 

cavity. Product literature from manufacturers indicates that cooking times can be reduced by 

using forced convection cooking.75 As a result, forced convection is widely used in electric 

ovens. 

For gas ovens, GRI sponsored the development of two new types of ovens that 

incorporate forced convection cooking. Both oven types, one an advanced countertop oven and 

the other an advanced full-size oven with pyrolytic self-cleaning, also have steam-cooking 

options. Research and development of the ovens was being conducted at ADL at the time of the 

1996 TSD. Of the two oven types, development of the countertop oven was farther along. Test 

results indicated that countertop oven cooking times are as fast as those found in microwave 

ovens.76 More recently, multiple manufacturers have introduced gas ovens with convection fans. 

Estimates from manufacturers, researchers, and published reports (e.g., the energy 

efficient electrical product knowledge base prepared by ORTECH International for the Canadian 

Electrical Association77) were included in the 1996 TSD analysis to establish the efficiency 

increase due to forced convection. Averaging these estimates results in a relative efficiency 

increase of 23 percent for gas self-cleaning ovens using forced convection cooking. For gas 

standard ovens a value of 4.8 percent was used based on more recent GRI data.78 Additional 

data submitted during the NOPR comment period of the 1996 analysis by ADL79 showed an 

increase in efficiency for electric convection ovens of only 2.4 percent. . 

It is also important to consider the added electrical energy consumption of the convection 

fan when determining the EF for ovens incorporating convection cooking. The wattage of a 

typical convection fan motor is approximately 30 W. Since the duration of the DOE test 

procedure is approximately 30 minutes, the energy consumption of the convection fan is 

approximately 15 watt-hours (Wh). 

Additionally, ovens can use convection elements in addition to resistance and other types 

of elements to speed up the cooking process. By utilizing different cooking elements where they 

are most effective, such combination ovens can reduce the time and energy consumption 

required to cook food. For example, a convection heater and resistance element can provide rapid 

internal heating while a halogen element provides surface heating and browning. GE has 

introduced a line of combination ovens utilizing conventional resistance heating elements, 

convection heaters, and halogen elements, along with a microwave system.80 GE claims that this 

technology can reduce food preparation times by 50 percent to over 75 percent, depending on the 

item being cooked.81 However, it is unclear how much of the benefit is attributable to the forced 

convection system alone. 

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Halogen lamp oven (electric only) 

Halogen elements, similar to those used in electric cooktops, can also be used in electric 

ovens. This oven type was first introduced in Europe, but according to U.S. manufacturers, its 

acceptance has been slow in the United States. Manufacturers stated in 1996 that the cooking 

performance of the halogen lamp oven is relatively poor compared to that of a conventional 

oven, though it might be advantageous for certain broiling applications. 

Alternatively, a conventional oven can use halogen elements in addition to resistance 

and/or convection elements to speed up the cooking process. By utilizing different cooking 

elements when they are most effective, combination ovens such as the GE product described 

previously for the forced convection technology option can reduce the time and energy 

consumption required to cook food. However, no data were found or submitted to demonstrate 

how efficiently halogen elements alone perform relative to conventional ovens. 

Improved and added insulation 

The efficiency of an oven can be increased by either improving the insulation or adding 

more insulation to the cabinet walls and oven door. Most models can accommodate 4 inches of 

insulation in the cabinet walls and door without requiring extensive design changes to the oven. 

Most standard models have 2 inches of low-density (1.09 pounds (lb)/ft3

) fiberglass insulation in 

the cabinet walls and door, while most self-cleaning ovens use 2 inches of high-density (1.90 

lb/ft3) insulation. Insulation is added primarily to pass UL surface temperature tests, which 

explains why self-cleaning ovens, which require high temperatures for pyrolysis, tend to have a 

more effective insulation package. 

Data found in published papers and reports indicate that fiberglass insulation density 

levels do not exceed those found in self-cleaning ovens (1.90 lb/ft3). Thus, while both the 

thickness and density of the insulation can be increased in most standard ovens, only the 

thickness can be increased in most self-cleaning ovens. 

Since the DOE test procedure does not require maintaining heat in the oven over an 

extended period of time, manufacturers stated in the 1996 rulemaking that increasing the 

thickness or density of the oven’s insulation will demonstrate no energy savings. But data 

provided by several sources indicate that small energy savings can be realized under the 

conditions of the DOE test procedure. 

The following sources were used in the 1996 TSD to establish the efficiency increase 

from using a denser insulation (1.09 to 1.90 lb/ft3

): (1) manufacturers’ data provided by AHAM; 

(2) the costing analysis of design options for residential appliances prepared by ADM Associates 

for LBNL;82 (3) the energy efficient electrical product knowledge base prepared by ORTECH 

International for the Canadian Electrical Association;83 and (4) the 1980 DOE engineering 

analysis for residential appliances.84 Averaging the data from these sources results in an 

efficiency increase of 4.9 percent for standard gas ovens and 5.2 percent for standard electric 

ovens. 

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Two sources of data were available which showed an increase in efficiency due to adding 

more insulation (2 to 4 inches): (1) manufacturers’ data provided by AHAM for the 1996 TSD 

and (2) the 1980 DOE engineering analysis for residential appliances.85 Averaging these data 

points results in an efficiency increase of approximately 1.4 percentage points. However, GRI 

reported no change in energy consumption by adding insulation.86 

Improved door seals 

Door seals for standard ovens generally consist of a strip of silicone rubber, while selfcleaning ovens usually incorporate fiberglass seals. These seals are attached to the oven front 

frame and act as a seal for the door, which serves to reduce the loss of hot oven air through the 

door. Because some venting is required for proper cooking performance, a complete seal on the 

oven is undesirable. But the oven door seals can be improved further without sealing the oven 

completely. 

Data from the energy efficient electrical product knowledge base prepared by ORTECH 

International for the Canadian Electrical Association87 were used to estimate the efficiency 

increase from improving the door seals. The data indicated that an approximately 7-percent 

increase in efficiency was possible for standard electric ovens and both standard and selfcleaning gas ovens. However, more recent data by GRI88 show efficiency increases much less 

than the 7-percent value previously reported. A value of 1 percent, therefore, was used for the 

standard and self-cleaning gas oven analysis. The GRI report also pointed out the need for 

sufficient air flow though the oven cavity for proper heating and moisture conditions while 

cooking. 

Low-standby-loss electronic controls 

Electronic controls may consume power even when the oven is not performing its 

intended function. Depending on the implementation of the controller, standby power is required 

to enable the electronic controls to detect user input without the user first having to turn on a 

mechanical power switch or to enable displays, illuminate switches, etc. Since clock power is 

incorporated into the EF metric for both gas and electric ovens, reducing the standby power 

consumption of electronic controls would reduce the EF. Low-standby-loss electronic controls 

can be implemented in a wide variety of ways. 

No oven-door window 

Most ovens and ranges come equipped with windows in the door. Using the window, the 

contents of the oven can be viewed without opening the oven door. But oven-door windows 

allow more energy to be lost through the door and, thus, reduce the efficiency of the oven. It 

could be argued, however, that having no window in the door necessitates frequent door 

openings to check the contents of the oven. The lost energy caused by these door openings could 

offset any energy savings that would result from eliminating the door window. 

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GRI issued a topical report89 which discussed this technology option. The report was 

submitted as a written comment to the 1996 NOPR. GRI’s experimental tests showed a small 

savings in annual energy usage for both standard and self-clean ovens. However, they reported 

there could actually be a net energy loss due to consumer practices, which would be a function of 

the number of times a consumer would open the door to inspect the food while cooking. With 

four door openings per test according to the DOE test procedure, a standard oven would realize a 

net energy savings of 34 kBtu/yr. For a self-clean oven, however, GRI calculated a net energy 

loss of 3 kBtu/yr. 

Oven separator 

For loads that do not require the entire oven volume, an oven separator can be used to 

reduce the cavity volume that is used for cooking. With less oven volume to heat, the energy 

used to cook an item would be reduced. The oven separator considered here is the type that can 

be easily and quickly installed by the user. The side walls of the oven cavity would be fitted with 

“slots” that guide and hold the separator into position. Different pairs of “slots” would be spaced 

throughout the oven cavity so that the user could select different positions to place the separator. 

Manufacturers’ data provided by AHAM indicated that an absolute percentage point 

increase of approximately 0.82 is expected from using an oven separator in standard and selfcleaning electric ovens. For standard and self-cleaning gas ovens, percentage point increases of 

0.1 and 0.53 are expected, respectively. No other data were provided to demonstrate whether the 

efficiency increase should be any higher or lower. 

As of June, 2008, oven separators have been researched but never been put into 

production. 

Pilotless ignition (gas only) 

Gas ovens equipped without an electrical power cord use a standing pilot ignition system. 

The EF of the oven can be increased by replacing the standing pilot system with an electric or 

electronic ignition system. Actual oven cooking efficiency is only slightly affected by 

eliminating the standing pilot. The resulting increase in the EF is primarily due to the decrease in 

the oven’s gas energy consumption during standby. 

For gas ovens equipped with a power cord, there are two types of pilotless ignition 

systems: (1) a spark ignition system and (2) a “glo” ignition system. The spark ignition system 

uses a spark igniter to light a pilot. The pilot in turn ignites the oven burner. The igniter is 

controlled by a control module, which is activated when the thermostat knob is set to a specific 

temperature. The igniter will spark until the pilot is ignited, and the pilot will burn until the 

thermostat is turned off. If the pilot should accidentally be extinguished, a sensing circuit within 

the igniter will reactivate the control module and cause the igniter to spark. The spark ignition 

system consumes a negligible amount of electricity. Since the control module is powered directly 

from line voltage, there are no 24-volt transformer losses associated with it. The spark igniter is 

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activated for an extremely short time so that its cumulative on-time during the course of a year, 

and thus its annual electricity consumption, is negligible. 

The “glo” ignition system uses a ceramic “glo”-type igniter. When the thermostat is set to 

a specific temperature, line voltage is applied to the igniter. Once energized, the igniter draws 

typically slightly over three amps and heats to a high temperature. In series with the igniter is a 

safety valve that is electrically activated. Once the igniter current drops to a pre-determined 

amperage, the safety valve opens, allowing gas to flow to the oven burner. The hot “glo” igniter 

then ignites the oven burner. Because the safety valve remains open only when the “glo” igniter 

is drawing the correct current, the igniter must continually draw power (typically around 400 W) 

to keep the burner ignited.90 Thus the electrical energy consumption of a “glo” ignition system is 

significant. There are other types of igniters which draw less wattage which are called “mini” hot 

surface igniters (HSI). Typical mini-HSIs draw about 50 W and one is reported to operate at 24 

W. However, these low-wattage igniters draw less current than standard “glo” igniters, and 

therefore are below the threshold current needed to open the safety valve. A change in design of 

the control systems would be required to incorporate these mini-HSIs into cooking oven 

products. 

DOE also identified battery-powered ignition systems as an alternative to standing pilot 

systems which does not require line power. Such battery-powered ignition systems have been 

incorporated successfully in a range of unattended, indoor appliances available on the U.S. 

market, such as gas-fired instantaneous water heaters and remote-controlled gas fireplaces. For 

the same reasons as noted for gas cooktops, DOE believes that it is technologically feasible to 

incorporate battery-powered ignition systems in gas ovens as an alternative to line-powered 

electronic ignition systems by the effective date of an amended standard 

Radiant burner (gas only) 

Viking manufactures a gas oven with a radiant burner for broiling functions. The infrared 

element is a metal screen heated by a burner until it emits infrared radiation, rapidly heating food 

and searing the outside, while the conventional heat from the flame provides additional food 

heating. 

Reduced conduction losses 

Conduction losses from the oven can be reduced by upgrading the oven door. This 

upgrade includes an additional thermal break and a modified inner panel. In the 1996 

rulemaking, manufacturers stated that with existing instrumentation, the DOE test procedure 

cannot measure the small energy gains that can be obtained by attempting to reduce conduction 

losses. 

 However, manufacturers’ data provided by AHAM for the 1996 TSD indicated that a 

very small efficiency increase is possible. The data indicate that only an absolute percentage 

point increase of 0.05 is expected from reducing conduction losses. No other data were obtained 

to demonstrate whether the efficiency increase should be any higher or lower. 

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Reduced thermal mass 

Energy is absorbed by the oven components as the oven warms to its operating 

temperature. By reducing the amount of material used in constructing the oven, the amount of 

energy that is absorbed is reduced and hence the efficiency increases. One method of achieving 

this thermal mass reduction is to reduce the gauge of sheet metal used in constructing the oven. 

Manufacturers asserted that this type of thermal mass reduction was not possible without 

compromising structural integrity (during both use and transportation) and increasing heat losses 

for electric and gas ovens manufactured at the time of the 1996 TSD. Manufacturers stated that 

the oven walls must provide strong enough support to hold racks when baking heavy items (i.e., 

turkeys or large roasts) and that oven cavity metal thickness could not be reduced any further 

without risking cracking and greater heat losses. 

Several sources of data for the 1996 TSD indicated that a 10–20 percent reduction in 

thermal mass is possible. The sources, which state that an efficiency increase from reducing the 

thermal mass is possible, included the following: (1) manufacturers’ data provided by AHAM; 

(2) the costing analysis of design options for residential appliances prepared by ADM Associates 

for LBNL;91 and (3) the energy efficient electrical product knowledge base prepared by 

ORTECH International for the Canadian Electrical Association.92 GRI tests showed only a 0.58­

percent efficiency improvement for a self-cleaning oven with an equivalent of 5.52 pounds of 

wall material removed.93 

Reduced vent rate 

Oven vents function primarily to remove the moisture present during the baking process. 

Self-cleaning ovens have reduced vent diameters to limit the air flow in accordance with 

combustion safety regulations during the high-temperature cleaning cycle. For safety reasons for 

the combustion process, the vent rate found in self-cleaning ovens cannot be reduced any further. 

But the vent rate of standard ovens can be reduced to the vent rate of self-cleaning ovens. This 

can be accomplished by either reducing the vent-tube size or adding a baffle. A reduction in vent 

rate causes a corresponding increase in efficiency. 

Manufacturers stated in the 1996 TSD that reduced vent rates should only be considered 

for standard electric ovens. The vent diameters of standard and self-cleaning gas ovens are not 

significantly different, since both oven types need to maintain a satisfactory combustion 

environment. With regard to standard electric ovens, manufacturers asserted that vent sizes are 

unique to the design of the oven. The vent size is critical in maintaining the oven’s proper 

cooking and safety performance. According to the manufacturers, mandating a specific vent rate 

would require most oven models to be redesigned in order to maintain their proper performance. 

But manufacturers’ data provided by AHAM for the 1996 TSD indicated that the vent 

size of both standard electric and standard gas ovens could be reduced. Since all self-cleaning 

ovens are already designed with this technology, no new improvements are required by the 

industry to incorporate this technology option. Averaging the manufacturers’ data with data 

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obtained from the costing analysis of design options for residential appliances prepared by ADM 

Associates for LBNL94 results in an increase of approximately 0.62 absolute percentage points 

for standard electric ovens and 0.5 absolute percentage points for standard gas ovens. 

Reflective surfaces 

Oven efficiency can be improved by incorporating reflective surfaces onto the walls of 

the oven cavity. Reflective surfaces improve the oven’s performance by reflecting and retaining 

infrared radiation within the oven cavity, thus increasing the percentage of heat available to be 

transferred to the food load. 

GRI performed tests on this technology option which resulted in a decrease in energy 

efficiency.95 The reflective surface interfered with the convective currents and the thermostat, 

thus fooling the thermostat into cycling. GRI reported that increased reflectance from the 

chrome-plated inner surface of the oven caused repeated thermostat cycling that “might have 

contributed to the higher energy consumption,” which resulted in a 12.61-percent decrease in 

energy efficiency. ADL also commented that the reflected radiation is different from the normal 

radiation emitted by the oven cavities currently in use.96 

Based on these studies, it is uncertain whether, or how much, energy savings are 

realizable with this technology option. A smarter controller for the oven seems to be a reasonable 

fix for the thermostat cycling problem. However, there is a general lack of sophistication in the 

technology to maintain clean, reflective surfaces over the lifetime of the product. Manufacturers 

stated in the previous rulemaking that reflective surfaces degrade throughout the life of the oven, 

particularly for self-cleaning ovens. 

Steam cooking 

With steam cooking, energy is transferred to the food load by means of the condensation 

of steam on the food surface. This may take place at essentially atmospheric pressure, or the 

cavity may be pressurized in order to allow higher steam temperatures and thus higher energy 

transfer to the food. In order to maintain the proper environment regardless of pressure, a 

“steam-tight” oven cavity must be maintained. In addition, the use of steam involves 

considerably higher demands on the oven’s design and materials. Not only are different cavity 

materials required (e.g., temperature-resistant silicone seals and chrome-nickel steel), but all 

incorporated elements and accessories have to be redesigned and intensively tested. Though 

incorporating steam cooking into oven designs is a difficult task, various manufacturers claim 

that there are advantages to using steam over conventional methods of cooking. Those 

advantages include saved energy and being able to retain more of the food’s nutritional value. 

Energy is saved because food items that normally would need to be cooked separately (e.g., a 

meat roast in an oven and vegetables on a cooktop) can be cooked together using the steam 

cooking process. 

There are several electric ovens with steam functions currently on the market. BSH Home 

Appliances has recently introduced the Gaggenau Combination Steam and Convection Oven. 

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The oven utilizes a steam injection valve to control steam delivery to the cavity. The temperature 

and humidity level in the oven are user-selectable to tailor the cooking process as needed. Speed 

cooking is not advertised as the primary feature of this oven. Rather, food quality and nutrition is 

the focus. The steam capability is described as allowing vegetables to be cooked while retaining 

texture and nutritional content, meat to be roasted without drying out, and leftovers to be 

reheated without the loss of flavor and texture often associated with microwave reheating.97 

Since this is a built-in oven, water delivery and condensate drainage are provided via plumbing 

lines much like a dishwasher. Along with Miele and Viking, Gaggenau also markets a steam 

convection oven which does not require any external plumbing. Instead, it utilizes a refillable 

container for water supply and collection. 

While speed cooking is not the primary focus of steam ovens, there is evidence that there 

is time savings, particularly with larger food loads. Sharp’s countertop Superheated Steam Oven, 

introduced in August 200498 and which incorporates steam generators with conventional resistive 

heating elements, is described as reducing cook times for items such as chicken by 50 percent.99 

DOE is unaware of any efficiency data for steam ovens. 

For microwave ovens, in the 1996 TSD, DOE considered all of the following 

technologies to improve EF, with the exception of cooking sensors, dual magnetrons, and lowstandby-loss electronic controls. DOE identified cooking sensors from product literature, while 

dual magnetrons were identified in the February 2006 edition of Appliance Design as a means to 

decrease cooking times. Low-standby-loss electronic controls were identified by a review of 

AHAM data for standby power. 

Table 3.14.5 Technology Options for Microwave Ovens – Energy Factor 

1. Added insulation 

2. Cooking sensors 

3. Dual magnetrons 

4. Eliminate or improve ceramic stirrer cover 

5. Improved fan efficiency 

6. Improved magnetron efficiency 

7. Improved power supply efficiency 

8. Low-standby-loss electronic controls 

9. Modified wave guide 

10. Reflective surfaces 

Added insulation 

Adding insulation to the outside of the reflective cavity wall of the oven would diminish 

heat flow through the walls. However, because the walls absorb a negligible fraction of the 

microwave energy, there is very little difference in temperature between the inside and the 

outside of the microwave oven. Also, during the short duration of the DOE test procedure, the 

microwave oven cavity walls do not heat up. Thus, the energy savings of this technology option 

would be so small as to be not measurable. 100 

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Cooking sensors 

Moisture or humidity sensors can be incorporated into the microwave oven to detect the 

cooking state of the food load during operation, inferred by the water vapor being released into 

the cavity. When the sensor detects that a desired cooking state has been reached, the controller 

shuts off the microwave oven, thereby preventing excess energy consumption in addition to 

optimizing food quality. However, DOE is unable to obtain any data to verify any energy 

efficiency impacts. 

Dual magnetrons 

Dual-magnetron microwave ovens use two magnetrons to distribute microwave energy 

within the cavity in order to more evenly heat food. Conventional microwave ovens use a single 

magnetron to generate microwaves, and may use a stirrer to distribute these microwaves within 

the microwave cabinet. In addition, most microwave ovens use a turntable to rotate the item 

being heated in order to increase food heating uniformity. In order to vary the power of the 

microwave, the duty cycle of the magnetron is varied. 

When food is heated unevenly in a microwave, consumers must microwave items longer 

than necessary to ensure the entire item reaches the desired temperature. When a microwave 

oven uses dual magnetrons to more evenly distribute microwaves, this additional heating to 

ensure high temperature throughout the food may be reduced, reducing microwave energy 

consumption. 

In addition to increasing warming uniformity, dual magnetrons may reduce the need to 

cycle the single magnetron in most residential microwave ovens in order to modulate power. 

Cycling the single magnetron may increase wear on the magnetron, reducing its efficiency over 

its lifetime. Using two small magnetrons which together match the power of a single larger 

magnetron allows only one of these magnetrons to be engaged when then microwave oven is 

operated at reduced power levels. However, if both magnetrons share a single high voltage 

transformer, the decreased transformer efficiency at partial loading may offset any magnetron 

efficiency gains from replacing a single cycled magnetron with dual magnetrons. DOE is 

unaware of any energy efficiency data on dual magnetrons. 

Eliminate or improve ceramic stirrer cover 

Microwave ovens with fan-type mode stirrers use a cover over the fan to prevent 

inadvertent damage to the fan when inserting or removing food and to prevent degradation of the 

wave guide due to food splatter. Such models (with browning elements) sometimes use a 

ceramic mode stirrer cover because plastic types may not withstand the heat generated by the 

heating element during the browning operation.101 These stirrers absorb some microwave energy 

but are needed to prevent food splatter inside the wave guide. Eliminating the ceramic cover 

would adversely affect consumer utility by requiring cleaning of the stirrer or by reducing the 

life of the stirrer. 

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Improved fan efficiency 

Microwave ovens use either one or two fans. One fan is used to remove heat generated by 

the magnetron from the cavity. The second fan would be used where mode stirring is 

accomplished by using slow-moving metal blades. This allows for better distribution of the 

microwave energy. Since power demand is very low (2–3 W), there is no opportunity for energy 

savings in models equipped with a second fan. The blower fan that is used to cool the magnetron 

and other electrical components uses about 25 W. Increasing the efficiency of this fan can reduce 

microwave oven energy consumption. Additional data submitted during the NOPR comment 

period of the previous rulemaking were incorporated into the 1996 analysis. According to these 

data, the expected energy savings would be less than originally reported and would have 

increased cost. These data were averaged with the original data and included in the previous 

analysis. The increase in efficiency is estimated to be 0.23 absolute percentage points. 

Improved magnetron efficiency 

Magnetrons convert electrical energy input into electromagnetic energy at microwave 

frequency. The conversion efficiency of a magnetron, also known as the oscillation efficiency, is 

expressed as output power divided by the power delivered to the anode. In the range of output 

powers typical of residential-scale microwave ovens (700–1300 W), nominal magnetron 

efficiency is approximately 73 percent.102 Technologies are being investigated by manufacturers 

to increase efficiencies by several percentage points. Strategies to boost efficiency include 

improving the permanent magnet to reduce its demagnetization over time and reducing the 

magnetron dark current. Oscillation efficiencies of up to 78 percent have been reported.103 

Improved power supply efficiency 

In order to operate a magnetron, a transformer must be used to increase the input line 

voltage from 120 volts to about 4,000 volts. A controller, which may dissipate as much as 30 W, 

controls the power supply. There are two types of high voltage power supplies that are used in 

microwave ovens. The predominant type is the inductive-capacitance transformer, known as the 

LC power supply, which has an efficiency of about 82 percent. The other type is the invertertype, which is more expensive but has an efficiency of about 84 percent.104 An improved power 

supply can be obtained through reduced losses in the controller and in the iron core of the 

transformer. An efficiency as high as 96 percent is theoretically possible,105 but does not appear 

practicable at reasonable cost. Higher efficiency general purpose transformers do not have stable 

enough output power for microwave oven application. Earlier estimates of efficiency increase 

were 7 percent. However, data supplied by Sharp showed this estimate is much too high.106 The 

value used for the current analysis is a 2.9-percent increase in power supply efficiency. 

Low-standby-loss electronic controls 

Electronic controls may consume power even when the microwave oven is not 

performing its intended function. Depending on the implementation of the controller, standby 

power is required to enable the electronic controls to detect user input without the user first 

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having to turn on a mechanical power switch or to enable displays, illuminate switches, etc. 

Reducing the standby power consumption of electronic controls would reduce the annual energy 

consumption of the microwave oven, but would not impact the energy consumption of the 

microwave oven during cooking operation. DOE is unaware of any standby power data to 

quantify the impact on energy savings. 

Modified wave guide 

Wave guides provide the interface between the microwave oven cavity and the 

magnetron. They have very high efficiencies in current models of microwave ovens. A small 

improvement (about 1 percent) is possible through the use of special coatings on the interior 

surface.107 According to AHAM, the losses associated with the wave guide are typically less 

than 0.5 percent of the overall energy consumption.108 

Reflective surfaces 

Microwave ovens are designed to have surfaces that are highly reflective of microwave 

energy. A high-grade stainless steel cavity would be more reflective than a painted or 

porcelainized cavity interior. Testing by manufacturers has shown that high-grade stainless steel 

(or reflective material steel coating) would be more efficient than painted cold-rolled steel by 

approximately 0.5 percent.109 

Although combination microwave ovens were not analyzed due to difficulties in testing 

multiple cooking modes, a brief discussion is included due to the potential energy efficiency 

improvement and increase in consumer utility under real-world conditions. 

One of the primary limitations of microwave cooking is that the food load heats internally 

faster than the exterior, which is in contact with the relatively cold air in the oven cavity. This 

leads to an undesirable moisture distribution, where the exterior remains soggy when the interior 

is cooked. Therefore, methods have been developed to combine microwave with other modes of 

heating to mitigate surface moisture accumulation, provide a browning function that more 

closely replicates traditional cooking processes, and reduce overall cooking times. 

Microwave and thermal or convection heating combines the features of a microwave 

oven and a conventional or convection oven. The GE Profile Oven with Trivection utilizes 

electric radiant heating elements augmented by convection and microwave systems to speed 

cooking. While it is possible to cook in conventional thermal mode with or without convection, 

the microwave function cannot be utilized alone. According to GE, cooking times can be reduced 

by 50–75 percent compared to a conventional oven for a wide variety of foods.110 This oven is 

also advertised as compatible with all types of cookware including metal, glass, and stoneware. 

Microwave and jet air-impingement is the combination of microwave energy delivery 

plus high velocity hot air impacting the food load. This technology is widely used in commercial 

combination ovens for preparing such food products as pizzas. A residential version of this type 

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of oven began shipping in the fourth quarter of 2006.t According to Appliance Design magazine, 

the TurboChef Speed Cook Oven cooks up to 15 times faster than a conventional oven.111 The 

air jets are arrayed at the top and bottom of the cavity, and those at the top pass through the 

magnetron mode stirrer fan to enhance uniformity. The oven also employs dual magnetrons and 

top and bottom electric heating elements for faster heatup and broil functions. 

For microwave oven standby power, DOE investigated technology options for 

decreasing standby power. DOE identified lower-power display technologies, cooking sensors 

with no standby power requirement, improved power supplies, improved control boards, and 

automatic power-down from research, literature review, and reverse-engineering conducted as 

part of the microwave oven analysis discussed in chapter 5 of this TSD. 

Table 3.14.6 Technology Options for Microwave Oven – Standby Power 

1. Lower-power display technologies 

2. Cooking sensors with no standby power requirement 

3. Improved power supply and control board options 

4. Automatic power-down 

Lower-power display technologies 

Microwave ovens are generally constructed using one of the following display types to 

show clock time and other parameters: (1) vacuum fluorescent display (VFD); (2) backlit and 

non-backlit liquid crystal display (LCD); and (3) light-emitting diode (LED) display. Within the 

32-unit sample that DOE examined as part of the supplemental microwave oven analysis, 

microwave ovens equipped with VFDs consumed the most power on average, followed by units 

featuring backlit LCDs, LED displays and non-backlit LCDs. Data gathered by DOE show that 

standby power levels between 1.1 W and 1.4 W have been achieved in microwave ovens using 

either LED displays or LCDs, and standby power as low as 1.7 W has been achieved using a 

backlit LCD. The lowest standby power observed for a microwave oven with a VFD was 2.5 W. 

One display manufacturer stated to DOE that backlit LCDs can consume up to 50 percent less 

energy than VFDs in sizes applicable to microwave ovens, depending on the number of LED 

backlights used to light the display. The manufacturer also stated that power requirements for 

LED displays are generally lower than for VFDs, but the difference depends considerably on the 

number of diode segments being lit. 

The display format on each microwave oven can be characterized as either numeric, 

alphanumeric, or dot matrix. Whereas numeric displays can only show time, alphanumeric 

displays can also display letters, though usually in simplified format. Dot matrix displays can 

show various fonts, letters, and symbols via matrices of pixels, making them the most flexible 

display technology. In the reverse-engineering analysis DOE conducted as part of chapter 5 of 

this TSD, DOE observed that LED displays found in microwave ovens generally contain four 

numeric characters and a row of small words. LCDs and VFDs allow for more flexibility in the 

numbers and words being displayed by using alphanumeric characters without increasing the 

t

 For more information, visit www.turbochef.com. 

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power requirements. LED displays could conceivably achieve this, but would require more diode 

segments, increasing the cost of the display. However, this would not affect standby power, 

assuming that in standby mode only the clock time is being displayed. 

Cooking sensors with no standby power requirement 

Cooking sensors detect that a desired cooking state of the food load has been reached and 

then signal the controller to shut off the microwave oven, thereby preventing excess energy 

consumption in addition to optimizing food quality. During product teardowns (see chapter 5 of 

this TSD), DOE found that the most common identifiable cooking sensors are absolute humidity 

sensors, which infer the cooking state of the food load from the amount of water vapor being 

released into the cavity. This sensor technology requires standby power in the range of 1–2 W to 

maintain a resistive heating element, whose conductivity changes in response to the presence of 

water vapor or other gases, at operating temperature. If the power to the sensor is switched off 

and back on, warm-up times in excess of two minutes may be required. Standby testing by DOE 

and AHAM revealed no microwave ovens with cooking sensors that consume less than 2 W in 

standby mode. One Japanese microwave oven manufacturer stated during discussions with DOE 

that they are unaware of any humidity sensors that do not require standby power to stay warm. 

DOE has conducted research of cooking sensor technologies and has identified cooking 

sensors with zero standby power requirements and little to no warm-up time. During the reverseengineering analysis for microwave ovens (discussed in more detail in chapter 5 of this TSD), 

DOE observed that microwave ovens from one manufacturer use a piezoelectric steam sensor 

which requires zero power in standby mode. This sensor technology functions by detecting a 

burst of steam created from moisture in the food as it cooks. Low frequency (approximately 10 

hertz) components of the output signal of the device correlate with the amount of hot steam 

emitted from the load. In addition to steam sensors, DOE has identified infrared and weight 

sensors with little to no warm-up time that do not consume standby power and that have been 

applied in microwave ovens currently on the Japanese market. Infrared cooking sensors detect 

the temperature of the load in the field of view of the sensing element. These sensors may require 

multiple elements or a motor to rotate the sensor in order to expand the field of view to 

accurately measure the temperature of the food load depending on where it is placed in the oven 

cavity. Weight sensors determine the cooking state based upon the reduction in weight of the 

food load, which results from moisture evaporating from the load. DOE has also identified 

relative humidity sensors as a type of zero-standby power sensor that can be applied in a 

microwave oven, but is unaware of any microwave ovens on the market that use this type of 

sensor. Lastly, DOE was made aware of an absolute humidity sensor that requires no standby 

power, has zero incremental cost above that of a conventional absolute humidity sensor, and is in 

the process of being phased into production for a major microwave oven supplier to the US 

market. 

Improved power supply and control board options 

A potential area for standby power improvements is the power supplies on the control 

board. Multiple improvement paths with varying risk to manufacturers are available, including 

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the selective upgrading of power supply components to boost efficiency, the reduction of peak 

power demand through the use of lower-power components, and the transition to switching 

power supplies. 

Typically, microwave ovens incorporate unregulated plus regulated control board power 

supplies. The unregulated portion consists of a small transformer, a bridge rectifier, and an 

electrolytic capacitor. Voltage regulators then step down the voltage(s) to the level(s) required by 

the control logic, display, and cooking sensor. This approach results in a rugged power supply 

which is reliable, but typically has an efficiency of about 55 percent. 

According to power supply topology experts that DOE consulted, the quality of the 

transformer core material, diode type, capacitor quality, and voltage regulator selection could cut 

no-load standby power for the power supply in half and boost conversion efficiency from 55 to 

70 percent. For a typical 5 W-output microwave oven power supply, that no-load power 

consumption improvement is approximately 0.4 W. 

Switching power supplies offer the highest conversion efficiencies (up to 75 percent) and 

lowest no-load standby losses (0.2 W or less), though at a higher cost, higher part count, and 

greater complexity. Besides being as-yet unproven in long-term microwave oven applications, 

switching power supplies greater complexity may also result in lower overall reliability and take 

greater care to implement. For example, among other issues, a switching power supply can be 

prone to causing electromagnetic interference. DOE notes that there already are some premium 

microwave ovens on the U.S. market that incorporate switching power supplies. However, due to 

the incremental cost of such a power supply over a conventional power supply and the price 

competition in the microwave oven market, it is unlikely that switching power supplies will find 

wider application unless low standby power budgets force manufacturers to consider them. 

Automatic power-down 

 Manufacturers could also meet very low (i.e., less than 1 W) standby power levels 

according to the EISA 2007 and IEC Standard 62301 definition of “standby mode” by 

incorporating an automatic function that turns off most power-consuming components once a 

period of inactivity has elapsed. Such a low-consumption state could be user-selectable on 

demand, or could be the default condition in which the microwave oven is shipped such that the 

consumer would be required to opt in to maintaining the display, cooking sensor, or other utility 

feature during standby. DOE has determined that some microwave oven suppliers to the U.S. 

market have already taken such approaches to meet prescriptive standby power standards in 

other markets such as Japan. 

3.14.2.2 Commercial Clothes Washers 

For commercial clothes washers, DOE considered technologies taken from its most 

recent analysis of amended energy conservation standards for RCWs as well as from information 

provided in recent trade publications. Other than the exceptions noted hereafter, the following 

technologies are taken from a 1996 report prepared for DOE, entitled Design Options for Clothes 

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Washers.

112 Steam washing and improved front-loading-washer drum design were identified in 

the September 2005 edition of Appliance Magazine.

113 DOE identified the low-standby-power 

technology option during its engineering analysis review of all AHAM product classes. Spray 

rinse and advanced agitator technology options were added in response to comments received by 

DOE following the Framework public meeting. 

Technology options that allow CCW platforms to potentially reach higher efficiency 

levels are listed in Table 3.14.7. 

Table 3.14.7 Technology Options for Commercial Clothes Washers 

1. Adaptive control systems 

2. Added insulation 

3. Advanced agitation concepts for top-loading machines 

4. Automatic fill control 

5. Bubble action 

6. Direct-drive motor 

7. Electrolytic disassociation of water 

8. Front-loading design with recirculation 

9. Improved fill control 

10. Improved front-loading-washer drum design 

11. Improved water extraction to lower remaining moisture content 

12. Increased motor efficiency 

13. Low-standby-power electronic controls 

14. Ozonated laundering 

15. Reduced thermal mass 

16. Spray rinse or similar water-reducing rinse technology 

17. Steam washing 

18. Suds saving 

19. Thermostatically controlled mixing valves 

20. Tighter tub tolerance 

21. Ultrasonic washing 

Adaptive control system 

According to the DOE test procedure (10 CFR part 430, subpart B, appendix J1), “an 

adaptive control system refers to a clothes washer control system which is capable of 

automatically adjusting washer operation or washing conditions based on characteristics of the 

clothes load placed in the clothes container, without allowing or requiring consumer intervention 

or actions.” This technology option uses sensors to measure the soil load to adjust the wash 

temperature, agitation and/or tumble cycle time, number of rinse cycles, spin speed, and other 

parameters. Water and energy use can then be tailored to the load, thereby avoiding washing the 

clothes more than necessary. Although the DOE test procedure does not provide a means for 

determining the energy consumption of a clothes washer with an adaptive control system, the test 

procedure does allow for specific field test procedures to measure energy consumption. 

RCWs have used fuzzy logic to weigh laundry loads and regulate the length of the cycle, 

water level, number of rinses, and drying time.114 Specific clothes washer designs have 

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incorporated fuzzy logic to optimize the washing process while conserving water usage. The 

fuzzy-logic control determines the absorbency of the items being washed at the earliest stage 

possible after the start of the washing cycle. The system determines the correct water quantity for 

clear-water washing and subsequent rinsing.115 

Added insulation 

This technology option adds insulation around the outer wash tub. Because some heat 

energy is lost through the shell of the clothes washer, adding insulation around the outer tub 

slightly reduces the water temperature needed for a hot wash. However, since the wash cycle is 

relatively short and the thermal mass of the water is very high, there is very little change in water 

temperature from adding insulation. Computer simulations performed on a traditional toploading clothes washer for a 20-minute wash cycle at 140 °F showed that adding 1 inch of 

fiberglass insulation relative to no insulation resulted in only a 1–2 °F increase in water 

temperature during parts of the wash.116 

Advanced agitation concepts for top-loading machines 

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

machines with an alternative manipulator to agitate clothes and thus mechanically remove soil. 

In the RCW market, these alternatives to agitators have taken different forms, including nutating 

plates, rotating disks, and side-mounted agitators. In some instances, such agitation concepts 

allow a top-loading washer to avoid the need to cover all clothes completely with water, rotating 

them in and out of the water-filled portion of the basket, much like front-loading washers. 

Advanced agitation systems add considerable complexity to a top-loading clothes washer, and 

RCWs that feature these technologies are sold for prices comparable to front-loading clothes 

washers. 

Since the DOE test procedure captures the amount of water that a clothes washer 

consumes, the benefits of an advanced agitation concept washer can be directly measured and 

quantified via the WF. Potential energy savings are captured by the MEF as long as a portion of 

the washing cycle consumes heated water. 

Automatic fill control 

This technology option incorporates advanced control technologies to sense the clothes 

load and adjust the water level accordingly. For a traditional top-loading machine, this may mean 

setting the water level to just submerge the clothes load. This technology option can overcome 

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

The implementation of this feature varies. While this feature is inexpensive to implement 

in all front-loading washers, top-loading washers do not benefit from the same advantages 

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regarding drum geometry and rotation axis.u As a result, automatic fill control is typically only 

found in higher-end top-loading models that have electronic controls and proprietary designs, 

limiting adoption to a small percentage of the top-loading market. Energy is saved in either topor front-loading designs by reducing the amount of hot water used in the wash cycle. 

Bubble action 

Daewoo has developed an air-bubble washing machine. This machine uses a low-profile 

impeller typical in Asian-style top-loading washers and combines it with a six-winged, rotating 

pulsator shaped to direct water in four directions. This pulsator also distributes air bubbles in 

different directions. The bubbles are generated by a vibrating bellows, which is driven by an 

electromagnet. Bubbles are reported to increase the cleaning power of the washer in several 

ways: (1) by inducing a high-frequency pressure fluctuation near the clothes, (2) by increasing 

the dissolution of detergent, (3) by increasing the amount of dissolved oxygen which increases 

the activity of the detergent, and (4) by lowering the viscosity of the wash water.117, 118 Daewoo 

washers that utilize air-bubble washing action are available in the European market, but are not 

available to U.S. consumers.119 

Sharp also developed a bubble washer in which the bubble-generating device uses neurofuzzy-logic controls. From a nozzle located at the bottom of the washer, air bubbles are 

generated by a computer-controlled pulsator and circulated upward in vertical and horizontal 

swirling motions. The controls adjust the amount of water used, so that a single-tub design that 

washes the same load size as a conventional dual-tub (inner and outer) configuration uses only. 

70 percent as much water and detergent.120 Although it is mentioned on the manufacturer’s 

website, this washer is not available in the U.S.121 Standardized and independent tests have yet 

to be conducted on the performance of the bubble-action system; therefore, the energy savings 

potential and wash performance of the bubble-action technology option is unknown. 

Although bubble washing has been incorporated into commercial equipment in Europe 

and Asia, production is still extremely limited and further commercialization in the U.S. would 

require manufacturers to develop entirely new platforms. 

Direct-drive motor 

This technology option is primarily intended for use in traditional top-loading machines. 

A traditional top-loading clothes washer uses an induction motor, a mechanical transmission, 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 motor could be directly connected to the 

agitator, thereby avoiding transmission (gearbox) losses. In the past, Eaton, a motor 

u

 Front-loading washers can incorporate a fill switch in the sump to monitor water levels as the wash basket and its 

contents are rotated slowly at the beginning of the wash cycle. As dry clothes drop into the wash water, they absorb 

some of it and the water level in the sump drops. The fill switch then opens the fill valve(s) to raise the water level 

until the sump is full again. This approach does not work with top-loading washers because the clothes are always 

immersed in the water. Proprietary solutions have been implemented on some top-loading washers, however. 

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manufacturer, claimed that this will result in less mechanical energy required, i.e., less energy 

needed to run the agitator motor. This is accomplished by using a brushless direct-current 

(BLDC) motor with electronic controls. 

Potential differences in cleaning performance due to the direct-drive substitution were not 

measured by Eaton. In addition, other parameters such as cycle time or spin speed were not held 

constant in a comparison test with a conventional washer. For the machines tested, Eaton found 

savings of about 140 Wh per cycle, or 64 percent of motor energy use122. 

In the past, some manufacturers have stated that a limiting performance factor for this 

technology option was physical size. However, GE uses direct-drive motors on some of their 

residential top-loading washers.123 Fisher & Paykel manufactures two top-loading direct-drive 

washing machines available in the U.S. market.124 Some front-loading machines also use a 

direct-drive motor, including models manufactured by LG.125 

Electrolytic disassociation of water 

The goal of electrolytic disassociation of water is to reduce hot water usage by 

substituting the electrolytic production of bleaching agents for activation of bleaching chemical 

reactions in detergents by hot water. A prototype clothes washer with electrolytic disassociation 

of water has been successfully tested.126 Although commercial detergents perform better at high 

temperatures, the same hypochlorite concentrations obtained by adding bleaching agents to water 

can be achieved at low temperatures if the agents are produced by electrolytic disassociation 

within the machine. The bleaching action is due to the chemical reaction of the oxygen (derived 

from the chemical decomposition of the hypochlorite) with the insoluble organic compounds that 

constitute the soil in the clothes. Together they make soluble compounds that are dissolved in the 

water. 

Electrolytic disassociation was tested in a laboratory electrochemical cell. Medium-soiled 

clothes and white materials were used in the test. The washing cycle test compared the energy 

consumption of electrolytic cleaning versus conventional detergents. The first test cycle, utilizing 

electrolytic action, was performed by adding four grams per liter of salt to the room-temperature 

wash water in the machine. The second test cycle was run with a commercial detergent at a wash 

water temperature of 95 °F to 113 °F. For both wash methods, a normal cycle was run. Initial 

tests showed that energy use dropped from about 2.65 kWh/cycle for a typical washing machine 

to 1.35 kWh/cycle for the new electrochemical method. This technology is still at the research 

stage. 

In the past, manufacturers have stated that electrolytic disassociation is not a workable 

approach. Primary concerns are negative effects on garments resulting from the bleaching 

process and poor consumer acceptance due to their inability to control the chemistry and 

temperature in the wash portion of the cycle.127 

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Front-loading design with recirculation 

This technology option for front-loading washers uses a small pump to recirculate water 

out of the sump and spray it into the drum. The small amount of standing water in a standard 

front-loading washer is thus further minimized. Less hot water is needed per wash cycle, thereby 

saving energy. 

In the previous RCW rulemaking, manufacturers commented that they have not been able 

to verify that a savings exists with recirculation.128 Limiting factors mentioned by these 

manufacturers include (1) soil removal, (2) tangling, (3) cycle time, (4) rinsing, and (5) suds 

sensitivity. 

In the past, Electrolux has produced models that sprayed 8 liters per minute of 

water/detergent solution into the drum by means of a supply valve above the door.129 

Improved fill control 

This technology option is defined as improving the tolerance on existing wash-water fill 

sensing, which can be accomplished by reducing tolerances of presently used pressure sensors or 

improving switch design. This technology option relates primarily to top-loading washers, 

although it is sometimes applicable to front-loading washers, depending on the fill control used 

on the washer design. 

In a traditional top-loading washer, one end of an air hose is connected to an air chamber 

near the bottom of the washer tub and the other end is connected to a pressure switch. As water 

fills the tub, air in the hose and chamber is forced into a smaller volume, thereby increasing the 

air pressure. The air pressure increases until it activates a pressure switch, which in turn shuts off 

the water inlet valve. A more accurate water-level-setting system would avoid overfilling the 

wash tub, thereby reducing the amount of water and energy used. In the past, manufacturers have 

stated that they were not aware of any opportunity to reduce tolerances of pressure sensors.130 

Improved front-loading-washer drum design 

Manufacturers of front-loading washers continue to research and modify existing drum 

designs to improve wash performance, reduce mass, and increase spin speeds. With each drum 

revision, manufacturers frequently make claims that their drum designs increase consumer utility 

by being gentler on clothes or by reducing the cycle time through better agitation of the clothes 

in the washer. A reduction in cycle time would have a measurable impact on washer power 

consumption, just as drums that can sustain higher spin speeds can reduce the remaining 

moisture content (RMC) and thus raise the MEF of a washer. 

RMC is defined as: 

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(WC −WI ) RMC = WI 

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. 

Implementation of this technology option varies, with drums featuring special paddles, 

drum-wall textures, or similar enhancements. 

Improved water extraction to lower remaining moisture content 

There are several ways to reduce the RMC, including: (1) increasing the spin speed of the 

wash basket for the final spin cycle; (2) changing the direction of rotation to more evenly 

distribute clothes; (3) having a longer spin cycle; and (4) increasing the size or number of 

drainage holes in the washer drum. Since mechanical water removal is more energy efficient 

than using heat to dry, energy consumption for the combined wash and dry process is reduced. 

The DOE test procedure assumes that the improved-water-extraction feature will not be 

used for 25 percent of all wash cycles. Since this feature can be consumer selectable, clothes 

subject to wrinkling can be washed with a conventional spin-cycle option to avoid a wrinkling 

problem. Some manufacturers in the past were doubtful that RMCs of 35 percent and 30 percent 

could be practically obtained. 

At the time of the 2001 TSD, laboratory testing was conducted to ascertain RMCs on 

commercially-available front-loading washers. Measured RMCs ranged from 49 percent to 36 

percent with a 50/50 cotton/polyester cloth load. For the same test load, a top-loading machine 

had a 52 percent RMC. The washers for the above testing were loaded at 3 lb/ft3

 of basket 

capacity.131 The DOE test procedure, however, specifies the test load as being closer to 4 lb/ft3 

of basket capacity. Since the size of the cloth test load has an effect on the RMC achieved, it is 

unknown whether the above laboratory-tested machines can achieve their stated RMC values 

under DOE test conditions. As of the 2001 TSD, clothes washers with a certified RMC of up to 

40 percent were available.132 

RMC data are no longer required to be published because the current test procedure 

requires the publication of only the MEF and WF for clothes washers. RMC data can be found in 

the CEC CCW database, but this database does not cover all CCWs on the market, nor is it 

completely current. Thus, DOE is unable to determine the water extraction capabilities of all 

CCWs that are currently on the market. Supporting the 2001 TSD manufacturer comments 

indicating skepticism towards achieving practical lower RMC values, none of the clothes 

washers listed in the CEC CCW database has an RMC below 39 percent. Top-loading CCWs 

typically feature an RMC of about 50 percent, while front-loading clothes washers typically 

feature an RMC of about 40 percent, according to the DOE test procedure. 

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Increased motor efficiency 

About 10 percent of the total electrical energy consumed by a typical clothes washer is 

used by the electric motor. The typical washing machine has a 1⁄2 –2⁄3 horsepower motor. In the 

past, an RCW manufacturer stated that replacing a split-phase motor with a capacitor-start motor 

may increase the efficiency of the motor by 10 percent.133 Permanent magnet motors offer even 

higher efficiencies, though the benefit of a higher efficiency motor has to be balanced with the 

higher cost and the relatively small contribution to the overall energy consumption per wash 

cycle from the motor itself. 

Low-standby-power electronic controls 

Electronic controls may consume power even when the clothes washer is not performing 

its intended function. Depending on the implementation of the controller, standby power is 

required to enable the electronic controls to detect user input without the user first having to turn 

on a mechanical power switch or to enable displays, illuminate switches, etc. Reducing the 

standby power consumption of electronic controls would reduce the annual energy consumption 

of the clothes washer, but would not impact the energy consumption of the clothes washer during 

operation. Low-standby-loss electronic controls can be implemented in a wide variety of ways. 

DOE is unaware of any data demonstrating energy savings associated with low-standby-power 

designs for CCWs. 

Ozonated laundering 

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

use. The ozone, manufactured from ambient air, is injected into the water. There is some debate 

as to how the process of the ozonated cleaning exactly works. Some claim the ozone reacts with 

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

the soils from the fabric. One manufacturer proposed that the energy inherent in ozone reduces 

water tension, making the water a better solvent. Energy is saved with this system because the 

water is not heated for lightly to moderately soiled laundry. In fact, colder water retains a higher 

concentration of ozone for a longer time than warmer water. For heavily soiled laundry, 

temperatures of 100–110 °F are used, which are lower than the temperatures required in a 

conventional washer. Also, since fewer chemicals are used, the rinse time is minimized, thereby 

reducing the total cycle time and water consumption. Economical ozone production is critical to 

the potential energy savings. One manufacturer estimates savings of 25 percent on “utility 

expenses” with installation of its system.134 However, in addition to the ozone generator, a new 

or reprogrammed controller would be required, adding to the cost of this technology option. 

Reduced thermal mass 

This technology option uses a plastic tub specially designed to minimize the thermal 

mass that is heated by the water. Tests by manufacturers indicate that very little energy can be 

saved this way because the bulk of the thermal mass is contained in the hot water itself. One 

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manufacturer compared the impact of both porcelain-enameled steel and polypropylene outer 

tubs on water temperature. Both machines were filled with 16 gallons of 140 °F water and 

agitated for 10 minutes. After 10 minutes, there was no significant difference in water 

temperature between the two machines. Calculations show that if there were no heat losses 

through the outer tub, the equilibrium temperature for the tested steel tub described above would 

be 138.9 °F. Therefore, there is little to be gained by decreasing the thermal mass of the outer 

tub.135 

Plastic outer tubs are commonly used by manufacturers and can be considered as part of 

the baseline model. There is no practicable way to manufacture washing machines with plastic 

tubs with a lower thermal mass beyond the current practice. 

Spray rinse or similar water-reducing rinse technology 

 Traditional top-loading 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. When using hot rinse water, this 

reduces energy consumption by reducing the amount of hot water required for the rinse cycle. 

DOE is unaware of any commercial top-loading clothes washers currently available that utilize 

spray rinse. 

Manufacturers caution that spray rinse or similar rinse-water reduction technology 

options are not embraced by all customers. For example, spray rinse technologies allegedly do 

not function well if a washer is overloaded, requiring a consumer behavior change which is more 

easily achieved in a residential than a commercial setting. Previously available top-loading 

CCWs with spray rinse technology were withdrawn from the market, though other CCW models 

currently use spray-rinsing. 

AHAM recently developed a rinse performance standard for clothes washers that could 

limit the use of rinse-water reduction technologies. The current DOE test procedure, though, 

captures the benefit of this technology option, as any reduction in water consumption improves 

WF and any reduction in heated water consumption improves MEF. 

Steam washing 

With steam washing, steam is sprayed on the laundry to help clean and sanitize the 

clothes without requiring the tub to be filled with water that is heated to sanitizing temperatures. 

Since less water must be heated to complete a steam washing cycle compared to a traditional 

washer, which immerses clothes in hot water, steam washing can reduce the energy and water 

consumption of clothes washers.136 However, some manufacturers have indicated to DOE that a 

steam generator increases net energy use. 

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LG began offering two RCWs in the U.S. market that use steam washing in 2005, and 

Whirlpool launched a steam clothes washer in the United States in 2008. 137,138 All models are 

ENERGY STAR-qualified. 

Suds saving 

A suds-saving feature allows water from one wash cycle to be reused in the next wash 

cycle. After agitation, sudsy wash water is pumped into a separate storage tub, remaining there 

until the next wash cycle. While the water is stored, soil settles to the bottom of the tub. During 

the next wash cycle, all but an inch of the water is pumped back into the washer tub for use 

again139. Manufacturers believe that there is low consumer demand for this option and it would 

therefore not be used often. In addition, this option cannot be used for all loads or soil conditions. 

This option is useful only when there is more than one wash cycle per load of laundry, e.g., a 

pre-wash (which is not typically the case), or if the consumer washes more than one load in 

sequence. Subsequent washes could receive diminishing benefits if they are not completed 

immediately after the previous load, since the water in the holding tub would cool if left standing 

too long. Another limiting performance factor mentioned by more than one manufacturer for this 

technology option was soil removal. In addition, because this option requires an adjacent 

external wash tub to store suds in between wash cycles, consumer utility is affected. In a 

commercial setting, this could limit the number of clothes washers that may be installed. 

This technology option is no longer commercially available. Electrolux formerly had a 

residential model that saved water from the final rinse of one load to use again as the prewash of 

the next cycle140. Maytag had also featured this technology as a water saving option on one of its 

washers. However, neither model is still in production. 

Thermostatically controlled mixing valves 

Thermostatically controlled water valves (TCWVs) are defined by the DOE test 

procedure as “clothes washer controls 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; 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. In 

the warm wash mode, fixed fractions of hot and cold water are controlled by flow-control 

devices. For example, a manufacturer may decide to specify warm water as 50 percent hot water 

and 50 percent cold water. To reduce hot water energy use, some manufacturers have reduced 

the warm water temperature by using other ratios such as 40 percent hot and 60 percent cold. 

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 

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

selected temperature of the warm water. 

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, 

whereas this is generally not the case in either a residence or commercial laundry setting. As a 

result of the distance between the hot water source and the clothes washer, there is a 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. A 

limiting performance factor mentioned by more than one manufacturer is soil removal with 

lower wash temperatures. 

Tighter tub tolerance 

This technology option reduces the annular volume between the inner wash basket and 

the outer tub. This annulus fills with water, but does not add to the clothes washer capacity. 

Having less space between the inner wash basket and the outer tub reduces the amount of water 

required for a fill, thereby saving the energy required to heat that water. This option applies 

primarily to traditional top-loading washers. In a high-efficiency top-loading or front-loading 

washer, water only occupies the lower portion of the annulus. Since most of the annulus in a 

high-efficiency top-loading or front-loading washer is filled with air, a smaller annulus does not 

yield significant energy savings. 

Other considerations are also important in determining an appropriate clearance between 

basket and tub. In the past rulemaking, RCW manufacturers stated that if the annulus is too small 

there may be problems with “suds lock”, where suds from the wash water remain between the 

inner wash basket and outer tub. Clearance is also needed to drain water during the spin-dry 

cycle and to allow for deflection of baskets with out-of-balance loads. Increasing the spin speed 

of the washer basket during the spin dry cycle may also require a larger space between tub and 

basket to allow for greater deflection at higher spin speeds. For this latter reason, tighter tub 

tolerance was not combined with the improved-water-extraction technology option. Other 

limiting performance factors mentioned by RCW manufacturers in the past include: (1) noise; (2) 

vibration; and (3) sand removal. 

Ultrasonic washing 

The addition of mechanical energy to the wash cycle can reduce the need for hot water 

(or chemical energy) in the cleaning action of clothes washers. One potential method of 

3-82 

EERE-2006-STD-0127 COMMENT 69.1
delivering the mechanical energy is through ultrasonic vibrations that loosen and remove some 

of the dirt on the soiled clothes. Such washing machines have been produced by a Japanese firm 

and were to be marketed in the United States. One U.S. clothes washer manufacturer investigated 

the Japanese product and found that it did not successfully clean clothes. The U.S. firm stated 

that the Japanese company is an excellent manufacturer of ultrasonic transducers, but does not 

have experience with clothes washing. 

One of the problems with ultrasonic washing is that clothes are not uniformly exposed to 

the vibrations generated by the transducers, which means that some areas may remain soiled. 

Additionally, the wash solution and the submerged clothes appear to dissipate much of the 

energy without the clothes being cleaned. A design producing adequate cleaning action does not 

appear to have been developed.141 

3.14.3 Energy Efficiency 

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

energy efficiency of residential cooking products and CCWs currently available in the 

marketplace. These data were taken from databases maintained by a variety of regulatory 

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

efficiency of all appliances currently available and in use, it does provide an overview of the 

energy efficiency of each product covered by this rulemaking. 

3.14.3.1 Cooking Products 

Conventional Cooking Products 

The DOE test procedure for cooktops is based on measuring the amount of energy 

required to raise an aluminum test block from room temperature to a specified temperature above 

room temperature. Of the efficiency data available, many are based on tests measuring the 

amount of energy that is required to boil a specified amount of water. The amount of water and 

length of time to boiling varies, depending on the researcher or manufacturer conducting the test. 

In addition, boil times vary with altitude, as increasing altitude decreases the length of time 

required to boil water. Only efficiency data based on the DOE test are used in the analysis 

because “boiling water” tests being conducted currently do not use a standardized water load or 

boiling time. 

Although not completely representative of the current U.S. cooking products market, 

Natural Resources Canada (NRCan) publishes a database of electric cooking appliance 

performance as measured by the applicable Canadian Standards Association test procedures. 

This database covers products available in the Canadian market, which overlaps with the U.S. 

market. Data from the NRCan database are presented as the distribution of listed models as a 

function of EF, which is calculated by dividing the annual useful cooking energy output from the 

DOE test procedure by the rated annual energy consumption from the database. 

3-83 

EERE-2006-STD-0127 COMMENT 69.1
<0.34 

0.34 to 0.36 

>0.36 to 0.38 

>0.38 to 0.40 

>0.40 to 0.42 

>0.42 to 0.44 

>0.44 to 0.46 

>0.46 to 0.48 

>0.48 to 0.50 

>0.50 

Figure 3.14.1 displays the EFs of standard open (coil)- and smooth-element electric 

ranges listed in the NRCan database. # of Models 

45 

40 

35 

30 

25 

20 

15 

10 

5 

0 

0 

13 13 

42 

37 

6 6 

3 3 

0 0 0

5 

24 

5 

3 

10 

0 0 0 

Co il T o p 

Sm ooth T o p 

Energy Factor 

Figure 3.14.1 Standard Electric Ranges in the NRCan Database142 

Figure 3.14.2 displays the EFs of self-cleaning open (coil)- and smooth-element electric 

ranges listed in the NRCan database. 

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EERE-2006-STD-0127 COMMENT 69.1
<0.34 

0.34 to 0.36 

>0.36 to 0.38 

>0.38 to 0.40 

>0.40 to 0.42 

>0.42 to 0.44 

>0.44 to 0.46 

>0.46 to 0.48 

>0.48 to 0.50 

>0.50 

1 0 

21 

13 

32 

19 

4 2 0 0 

9 

18 

62 

58 

62 

36 

16 

0 1 2 

0 

10 

20 

30 

40 

50 

60 

70 

# of Models 

Coil Top 

Smooth Top 

Energy Factor 

Figure 3.14.2 Self-Cleaning Electric Ranges in the NRCan Database143 

Figure 3.14.3 displays the EFs of open (coil)- and smooth-element electric cooktops 

listed in the NRCan database. 

25 

0 0 0 

2 

4 

1 

0 

5 

4 

0 

1 1 1

9 

4 

17 

7 

17 17 

21 

17 

0 0 0 

0.69 0.7 0.71 0.72 0.73 0.74 0.75 0.76 0.77 0.78 0.79 0.8 

Energy Factor 

Coil 

Smooth 

# of Models 

20 

15 

10 

5 

0 

Figure 3.14.3 Electric Cooktops in the NRCan Database144 

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EERE-2006-STD-0127 COMMENT 69.1
<0.08 

0.08 to 0.09 

>0.09 to 0.10 

>0.10 to 0.11 

>0.11 to 0.12 

>0.12 to 0.13 

>0.13 to 0.14 

>0.14 to 0.15 

>0.15 to 0.16 

>0.16 

Figure 3.14.4 displays the EFs of self-cleaning electric ovens listed in the NRCan 

database for both single and double ovens, while Figure 3.14.5 displays the EFs of non-selfcleaning electric ovens listed in the NRCan database for both single and double ovens. 

97 

29 

65 

17 20 

14 

1 0 0 3 

0 

20 

40 

60 

80 

10 0 

12 0 

# of Models 

Energy Factor 

Figure 3.14.4 Self-Cleaning Electric Ovens in the NRCan Database145 

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EERE-2006-STD-0127 COMMENT 69.1
<0.08 

0.08 to 0.09 

>0.09 to 0.10 

>0.10 to 0.11 

>0.11 to 0.12 

>0.12 to 0.13 

>0.13 to 0.14 

>0.14 to 0.15 

>0.15 to 0.16 

>0.16 

5 

4 

3 

2 

1 

0 

0 

3 

0 

2 

0 

4 

1 

2 

0 0 

Energy Factor 

Figure 3.14.5 Non-Self-Cleaning Electric Ovens in the NRCan Database146 

While self-cleaning ovens tend to be more efficient than non-self-cleaning ovens, due to 

the thicker insulation required to maintain safe exterior temperatures during oven cleaning 

cycles, some non-self-cleaning ovens exhibit EFs comparable to self-cleaning electric ovens. 

However, no non-self-cleaning electric ovens have EFs above 0.15, while three self-cleaning 

electric ovens have EFs exceeding 0.16. 

Microwave Ovens 

For microwave ovens, the DOE test procedure utilizes the test procedures specified in 

IEC Standard 705. It should be noted that IEC Standard 705 has been superseded by IEC 

Standard 60705. DOE does not plan to revise the test procedure to incorporate IEC Standard 

60705 to measure the cooking efficiency because, as discussed in chapter 5 of the TSD, DOE 

conducted analyses on a sample of microwave ovens which indicated that the efficiency 

measurements obtained with IEC Standard 705 were more stable and repeatable than those 

obtained using IEC Standard 60705. 

Microwave ovens consume energy in cooking mode, when heating food, and in standby 

mode, while powering the clock and electronic controls. AHAM recently provided data on 

microwave oven efficiency and standby power for a sample of microwave ovens available in the 

U.S. market.147 Microwave oven efficiency was tested according to DOE’s test procedure. 

Standby power was tested according to IEC Standard 62301. Although AHAM only tested 21 

units from 9 manufacturers, the units were selected to represent a broad spectrum of units # of Models 

3-87 

EERE-2006-STD-0127 COMMENT 69.1
available in the market place, and had varying capacities and features. Figure 3.14.6 and Figure 

3.14.7 display the AHAM microwave oven efficiency data. 

50% 

55% 

60% 

65% 

Efficiency 

600 700 800 900 1000 1100 1200 1300 1400 

Rated Output Power (W) 

Figure 3.14.6 AHAM Microwave Oven Efficiency versus Rated Output Power148 

Figure 3.14.6 illustrates the lack of a correlation between microwave oven rated output 

power and microwave oven efficiency. Efficiency remains nearly linear across the tested output 

power range. Figure 3.14.7 illustrates the relationship between microwave oven volume and 

microwave oven efficiency. Again, microwave oven efficiency remains constant and nearly 

linear regardless of microwave oven volume. 

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EERE-2006-STD-0127 COMMENT 69.1
50% 

55% 

60% 

65% 

Efficiency 

0.0 0.5 1.0 1.5 2.0 2.5 

Microwave Oven Volume (ft^3) 

Figure 3.14.7 AHAM Microwave Oven Efficiency versus Oven Volume149 

Figure 3.14.8 displays AHAM-measured microwave oven standby power data as a 

function of rated output power. Figure 3.14.8 also contains standby power measurements made 

by the Canadian Building Energy End-Use Data and Analysis Center (CBEEDAC) at the 

University of Alberta. The data show a wide range of standby power, but there is no correlation 

between standby power and rated output power. 

3-89 

EERE-2006-STD-0127 COMMENT 69.1
0.0 

1.0 

2.0 

3.0 

4.0 

5.0 

6.0 

7.0 

Standby Power Consumption (W) 

600 800 1000 1200 1400 1600 

Rated Output Power (W) 

AHAM Data CBEEDAC Data 

Figure 3.14.8 AHAM and CBEEDAC Microwave Oven Standby Power versus Rated 

Output Power150,151 

FEMP publishes a database of microwave ovens, sorted by standby power, although this 

database is also not completely representative of microwave ovens available in the U.S. market. 

Figure 3.14.9 displays the number of microwave oven models available with different standby 

power levels as listed in the FEMP standby power database. 

3-90 

EERE-2006-STD-0127 COMMENT 69.1
1 

28 

56 

33 

0 

10 

20 

30 

40 

50 

60 

Number of Models 

0 to 1 W 1.1 to 2 W 2.1 to 3 W >3 W 

Standby Power 

Figure 3.14.9 Microwave Oven Standby Power Consumption from the FEMP Database152 

FEMP does not specify microwave oven rated output power. Therefore, it is not possible 

to make a direct comparison between the FEMP microwave oven standby power data and the 

AHAM microwave oven test data. However, the distributions of standby power in the FEMP 

database and the AHAM data are similar. Very few microwave ovens consume less than 1 W of 

standby power, some microwave ovens consume less than 2 W of standby power, but the large 

majority of microwave ovens consume between 2.1 and 3 W of standby power. 

3.14.3.2 Commercial Clothes Washers 

Although not completely representative of the current CCW market, the CEC publishes a 

list of “certified” products. Even though the Federal standard only recently was raised to an MEF 

of 1.26, California had previously enacted a minimum standard at that level, so the database only 

contains products with MEFs of 1.26 and higher. ENERGY STAR and CEE also publish lists of 

certified products. Figure 3.14.10 displays the distribution of CCWs in the combined CEC, 

ENERGY STAR, and CEE databases as a function of MEF. 

3-91 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

Figure 3.14.10 Commercial Clothes Washer MEFs in the CEC, ENERGY STAR, and CEE 

Databases153 154 155 

Figure 3.14.10 illustrates the difference in MEF between top-loading CCWs and frontloading CCWs. All of the CCWs with an MEF below 1.5 are front-loading units, whereas all but 

one of the washers with an MEF above 1.5 are front-loading washers. No commercial toploading washer has a rated MEF above 1.76v

, while 142 front-loading CCW models have a rated 

MEF above 2.0. 

The CEC, ENERGY STAR, and CEE databases of certified CCWs also contain data on 

WF. The databases contain products with WF of 13 or lower. Figure 3.14.11 displays the 

distribution of CCWs in the combined CEC, ENERGY STAR, and CEE databases as a function 

of WF. 

v

 The rating of this unit was the subject of DOE review and testing, based on comments from interested parties on 

the October 2008 NOPR. See chapter 5 (engineering analysis) for discussion of the maximum available efficiency 

determined for the November 2009 SNOPR and this final rule. 

3-92 

EERE-2006-STD-0127 COMMENT 69.1
Figure 3.14.11 Commercial Clothes Washer WFs in the CEC, ENERGY STAR, and CEE 

Databases156 157 158
 

Figure 3.14.11 illustrates the difference in WF between top- and front-loading CCWs. All 

of the CCWs with a WF greater than 9.0 are top-loading units, whereas all of the washers with 

WF below 7.0 are front-loading units. No top-loading CCW has a WF below 7.0, while 147 

front-loading models have a WF below 7.0. 

3-93 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

 

 

 

 

 

 

 

 

 

REFERENCES 

1	 “The Share-of-Market Picture for 2007.” 31st Annual Portrait of the U.S. Appliance Industry, 

Appliance Magazine, September 2008. 

2	 Ibid. 

3	 “The Share-of-Market Picture for 2006.” 30th Annual Portrait of the U.S. Appliance Industry, 

Appliance Magazine, September 2007. 

4	 Consortium for Energy Efficiency (CEE). 1998. Commercial, Family-Sized Washers: An 

Initiative Description of the Consortium for Energy Efficiency. 

5	 “The Share-of-Market Picture for 2007.” 2008. Op. Cit. 

6	 Maytag. 2005. “Whirlpool Corporation and Maytag Corporation Sign Definitive Merger 

Agreement.” Maytag Press Release, August 22, 2005. 

7	 P. Hussmann. 2006. “Justice to Extend Maytag-Whirlpool Merger Review.” Newton Daily 

News Online, February 14, 2006. 

8	 W. Ryberg. 2006. “Harkin, Boswell want Maytag sale blocked.” Des Moines Register, January 

13, 2006. 

9	 Ibid. 

10 U.S. Department of Justice (U.S. DOJ). 2006. Department of Justice Antitrust Division 

Statement on the Closing of its Investigation of Whirlpool’s Acquisition of Maytag, March 29, 

2006. 

11 Ibid.
 

12 Association of Home Appliance Manufacturers (AHAM) Fact Book 2005. 

13 AHAM Fact Book 2003.
 

14 CEE. 1998. Op. Cit. 

15 Ibid.
 

16 Ibid. 

17 DOE Docket No. EE-RM-PET-100, submitted by the California Energy Commission January 

29, 2007. 

3-94 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

 

18 California Energy Commission versus DOE, Case No. 07-71576 (October 28, 2009). 

19 Tiele, Simone. 2008. Australia’s Approach to Standby Power. Department of the 

Environment, Water, Heritage and the Arts, Australia, April 2, 2008. Available online at: 

www.iea.org/textbase/work/workshopdetail.asp?WS_ID=352. (Accessed August, 2008) 

20 Yungrae, K. 2008. New Energy Efficiency Policy Tool: Standby Warning Label. Korea 

Energy Management Corporation, April 2, 2008. Available online at: 

www.iea.org/textbase/work/workshopdetail.asp?WS_ID=352. (Accessed August, 2008.) 

21 Japan’s Top Runner Program. 2005. Final Report by Microwave Oven Evaluation Standard 

Subcommittee. Prepared by Japan’s Energy Efficiency Standards Subcommittee of the 

Advisory Committee for Natural Resources and Energy. November 2005. Available online at: 

www.eccj.or.jp/top_runner/pdf/tr_microwaveoven.pdf. (Accessed February, 2008.) 

22 U.S. Census Bureau. 2009. “Table Q-1. New Privately Owned Housing Units Started in the 

United States by Purpose and Design.” New Residential Construction, 2009. 

23 Ibid. 

24 AHAM Fact Book 2005. 

25 Northwest Energy Star Partners. 2006. “Projected 2005 Energy Star Product Sales by State.” 

2006 Market Share Report. Available online at 

www.northwestenergystar.com/index.php?cID=226. (Accessed September 21, 2008.) 

26 AHAM Fact Book 2005. 

27 U.S. Census Bureau. 2006. “Statistics for Industry Groups and Industries: 2006 and Earlier 

Years” (Statistics). 2006 Annual Survey of Manufacturers (ASM), December 2006. 

28 AHAM Fact Book 2003. 

29 U.S. Census Bureau. 2006. Statistics. 

30 AHAM. 2008. 2008 Preliminary Year End Import/Export Trade Report. AHAM, 

Washington, DC, December 2008. 

31 Ibid. 

32 Ibid. 

33 Ibid. 

3-95 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

 

 

 

 

 

 

34 AHAM Fact Book 2005. 

35 Ibid. 

36	 General Electric Company. GE 30” Free-Standing Range, Model # JGBS07PEHWW. 

http://products.geappliances.com/ApplProducts/Dispatcher?REQUEST=SPECPAGE&SKU 

=JGBS07PEHWW&SITEID=GEA&CATEGORY=CA0084 (Accessed December 15, 2008) 

37	 General Electric Company. Hotpoint 30” Free-Standing Range. 

http://products.geappliances.com/ProdContent/Dispatcher?REQUEST=HPTPRODUCTSEL 

ECTORINDEX&prodline=Cooking%20Products_Electric%20Cooking&prodline=Cooking 

%20Products_Gas%20Cooking&prodline=Ventilation%20Systems&MASK=Approved%20 

Models_SalesNet_CustomerNet_Consumer%20Ready_Full%20Hotpoint%20Collection_Hot 

point.com (Accessed December 15, 2008) 

38	 General Electric Company. Hotpoint 24” Free-Standing Range. 

http://products.geappliances.com/ProdContent/Dispatcher?REQUEST=HPTPRODUCTSEL 

ECTORINDEX&prodline=Cooking%20Products_Electric%20Cooking&prodline=Cooking 

%20Products_Gas%20Cooking&prodline=Ventilation%20Systems&MASK=Approved%20 

Models_SalesNet_CustomerNet_Consumer%20Ready_Full%20Hotpoint%20Collection_Hot 

point.com (Accessed December 15, 2008) 

39	 General Electric Company. Hotpoint 20” Free-Standing Range. 

http://products.geappliances.com/ProdContent/Dispatcher?REQUEST=HPTPRODUCTSEL 

ECTORINDEX&prodline=Cooking%20Products_Electric%20Cooking&prodline=Cooking 

%20Products_Gas%20Cooking&prodline=Ventilation%20Systems&MASK=Approved%20 

Models_SalesNet_CustomerNet_Consumer%20Ready_Full%20Hotpoint%20Collection_Hot 

point.com (Accessed December 15, 2008) 

40	 Electrolux Home Products. Frigidaire Cooking, Free-Standing Gas. 

www.frigidaire.com/products/cooking/ranges/free-standing_gas/prod_FGF316D.asp 

(Accessed December 15, 2008) 

41	 Peerless-Premier Appliance Company. Range SAK 1000 or GAK 100. 

www.peerless-premier.com/rangeSAK100.htm and 

www.bestbuy.com/site/olspage.jsp?skuId=7296936&st=GAK1000&lp=1&type=product&cp 

=1&id=1149207790444 and 

www.bestbuy.com/site/olspage.jsp?skuId=7299194&st=Gas+Range+Peerless&lp=34&type 

=product&cp=1&id=1149207791116 (Accessed December 15, 2008) 

42	 Peerless-Premier Appliance Company. Range SCK 1000 or GCK 1000 Range SCK 100T or 

GCK 100T. 

www.peerless-premier.com/rangeSCK100.htm and 

www.bestbuy.com/site/olspage.jsp?skuId=7296972&st=Gas+Range+Peerless&lp=40&type 

3-96 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

 

 

 

=product&cp=1&id=1118845618839 and 

www.bestbuy.com/site/olspage.jsp?skuId=7299265&st=Gas+Range+Peerless&lp=29&type 

=product&cp=1&id=1149207791396 (Accessed December 15, 2008) 

43	 Peerless-Premier Appliance Company. Range SFK 1000 or GFK 1000. 

www.peerless-premier.com/rangeSFK1000.htm and 

www.bestbuy.com/site/olspage.jsp?skuId=7297016&st=Gas+Range+Peerless&lp=38&type 

=product&cp=1&id=1118845618889 and 

www.bestbuy.com/site/olspage.jsp?skuId=7299309&st=Gas+Range+Peerless&lp=25&type 

=product&cp=1&id=1149207791620 (Accessed December 15, 2008) 

44	 Peerless-Premier Appliance Company. Range SLK 100 or GLK 100. 

www.peerless-premier.com/rangeSLK100.htm and 

www.bestbuy.com/site/olspage.jsp?skuId=7297052&st=Gas+Range+Peerless&lp=35&type 

=product&cp=1&id=1149207790668 and 

www.bestbuy.com/site/olspage.jsp?skuId=7299452&st=Gas+Range+Peerless&lp=20&type 

=product&cp=1&id=1149207792068 (Accessed December 15, 2008) 

45	 Brown Stove Works, Inc. 20” Free Standing Gas Range. 

www.brownstoveworksinc.com/20in/nm110.html and 

www.brownstoveworksinc.com/20in/nm1107f.html (Accessed December 15, 2008) 

46	 Brown Stove Works, Inc. 24” Free Standing Gas Range. 

www.brownstoveworksinc.com/24in/nm610x.html and 

www.brownstoveworksinc.com/24in/nm6107.html (Accessed December 15, 2008) 

47	 Brown Stove Works, Inc. 30” Free Standing Gas Range. 

www.brownstoveworksinc.com/30in/nm210hr.html and 

www.brownstoveworksinc.com/30in/nm2107.html (Accessed December 15, 2008) 

48	 Brown Stove Works, Inc. 36” Free Standing Gas Range. 

www.brownstoveworksinc.com/36in/nm430.html and 

www.brownstoveworksinc.com/36in/nm4307.html (Accessed December 15, 2008) 

49 AbsoluteHome.com–Home Décor Products, Inc. Appliances—Laundry—Commercial 

Washers. Available online at 

www.absolutehome.com/web/catalog/ethumbs.aspx?N=102+2204250+4294954347&Ns=P_P 

ricedFrom|1&Nu=P_UniqueID. (Accessed October 16, 2006.) 

50 Abt Electronics, Inc. Appliances—Laundry Products—Commercial Washers. Glenview, IL. 

Available online at www.abtelectronics.com/category/528.html. (Accessed October 16, 2006.) 

51 AJMadison. Laundry—Washers. Glenview, IL. Available online at 

3-97 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

www.ajmadison.com/cgi-bin/ajmadison/category/cat00174/Laundry.html. (Accessed October 16, 

2006.) 

52 J. Cole. 2006. Personal Communications. Commercial & Coin Laundry Equipment Company, 

Gulf Breeze, FL. Telephone call with Lawrence Berkeley National Laboratory (LBNL), 

September 18, 2006. 

53 E. Grimshaw. 2006. Personal Communications. Commercial Laundry Equipment, Arroyo 

Grande, CA. Telephone call with LBNL, September 15 and 19, 2006. 

54 D. Hoffman. 2006. Personal Communications. Gold Coin Laundry Equipment, Inc., Jamaica, 

NY. Telephone call with LBNL, September 15 and 25, 2006. 

55 D. Smith. 2006. Personal Communications. Mac-Gray Services, Inc., Albany, GA. Telephone 

call with LBNL, September 25, 2006. 

56 L. Mears. 2006. Personal Communications. Texas Laundry Service Company, Pasadena, TX. 

Telephone call with LBNL, September 13, 2006. 

57 Laundry Systems. Products. Medina, OH. Available online at 

www.laundrysystems.com/index.html. (Accessed September 25, 2006.) 

58 U.S. Census Bureau. 2006. “Statistics for Industry Groups and Industries: 2006 and Earlier 

Years.” 2006 Annual Survey of Manufacturers (ASM), December 2006. 

59 Ibid. 

60 Ibid. 

61 U.S. Census Bureau, Survey of Plant Capacity: 2006 to 1994. 

62 Y. Yamada, T. Sobue, M. Oyaizu, 2003. “Glass-Ceramic Top Plate Gas Cooking Hob with 

High Efficiency.” Proceedings of the 22nd World Gas Conference, Tokyo, Japan, June 2003. 

63 U.S. DOE. 1980. Engineering Analysis. Washington, DC, DOE/CS-0166, June 1980, pp. D7­

1 to D7-28. 

64 J. Flood and T. Enga. 1983. “Energy Conservation Aspects of Cooking Appliances.” 

Proceedings of the 1983 International Gas Research Conference, London, UK, June 13, 1983, 

pp. 741–754. 

65 M. Shepard, A. Lovins, J. Neymark, D. Houghton, and H. Heede. 1990. The State of the Art: 

Appliances. Rocky Mountain Institute, COMPETITEK Information Service, Snowmass, CO, 

August 1990, pp. 132–151. 

3-98 

EERE-2006-STD-0127 COMMENT 69.1
 

66 ADM Associates Inc. (ADM). 1987. Costing Analysis of Design Options for Residential 

Appliances and Space-Conditioning Equipment. Prepared by ADM Associates Inc., 

Sacramento, CA, for LBNL, Purchase No. 4541710, December 1987, pp. 9-1 to 9-20. 

67 ORTECH International (ORTECH). 1989. Energy-Efficient Electrical Product Knowledge 

Base. Prepared by ORTECH International, Mississauga, Ontario, Canada, for the Canadian 

Electrical Association, Number 821 U 678, October 1989, pp. 25–39. 

68 Arthur D. Little Inc. (ADL). 1994. Electric Oven and Cooktop Data Analysis. Prepared by 

ADL, Cambridge, MA, for AHAM, Reference 47066, Comment Number 001 to the NOPR, 

July 15, 1994. 

69 ORTECH. 1989. Op. cit. 

70 U.S. DOE. 1980. Op. cit. 

71 Shepard et al. 1990. Op. cit. 

72 L. Andrews. 1978. Proposed Test Procedure for Induction Cooking Tops. National Bureau of 

Standards, Washington, DC, October 1978. 

73 K.C. Datwyler and J.R. McFadden. 1992. “A Comparative Analysis of Performance 

Characteristics of Gas and Electric Cooktops.” Proceedings of the 43rd Annual International 

Appliance Technical Conference, West Lafayette, IN, May 5, 1992, pp. 485–496. 

74 D. DeWitt and M. Peart. 1982. Bi-Radiant Oven: A Low-Energy Oven System. Purdue 

University, West Lafayette, IN. Prepared for Oak Ridge National Laboratory, Oak Ridge, TN, 

ORNL/Sub-80/0082/1, ORNL/Sub-80/0082/2, ORNL/Sub-80/0082/3, March 1982. 

75 GE Appliances (GE) Product Literature. Available online at 

www.geappliances.com/products/introductions/trivection/overview/compare_cook_times.htm. 

(Accessed September 21, 2008.) 

76 D. McFadden, R. Topping, D. Frizche, and R. Hemphill. 1991. “Advanced Residential Gas 

Oven Development.” Proceedings of the 42nd International Appliance Technical Conference, 

Madison, WI, May 1991, pp. 83–94. 

77 ORTECH. 1989. Op. cit. 

78 Gas Research Institute (GRI). 1994. Topical Report: Technical Input to NAECA Rulemaking 

for Gas-Fired Ranges. Prepared by Battelle, Columbus, OH, American Gas Association 

Laboratories, Cleveland, OH, and ADL, Cambridge, MA for Gas Appliance Technology 

Center, Chicago, IL. Comment No. 001 to the NOPR, GRI-94/0195, July 1994. 

3-99 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

79 ADL. 1994. Op. cit.
 

80 GE Advantium Product Literature. Available online at 

www.geappliances.com/products/introductions/advantium/. (Accessed September 21, 2008.) 

81 GE Advantium Product Literature. Available online at 

www.geappliances.com/products/introductions/advantium/saving_you_time.htm. (Accessed 

September 21, 2008.) 

82 ADM. 1987. Op. cit. 

83 ORTECH. 1989. Op. cit. 

84 U.S. DOE. 1980. Op. cit. 

85 Ibid. 

86 GRI. 1994. Op. cit. 

87 ORTECH. 1989. Op. cit. 

88 GRI. 1994. Op. cit. 

89 Ibid. 

90 P. Seibold. 1995. Personal Communications. Norton Company. Worcester, MA, March 1995. 

91 ADM. 1987. Op. cit. 

92 ORTECH. 1989. Op. cit. 

93 GRI. 1994. Op. cit. 

94 ADM. 1987. Op. cit. 

95 GRI. 1994. Op. cit. 

96 ADL. 1994. Op. cit. 

97 M. Lowe. 2006. “Cooking Technologies: Overachieving Ovens.” Appliance Design, 

February 1, 2006. 

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98 “Sharp Unveils Fat-Busting Superheated Steam Oven.” Appliance Magazine, August 23, 

2005. 

99 Lowe. Op. cit. 

100 AHAM. 1990. Comments on the Advanced Notice of Proposed Rulemaking Regarding 

Energy Conservation Standards for Room Air Conditioners and Kitchen Ranges and Ovens. 

55 FR 39624, September 28, 1990, Docket Number CE-RM-90-201, Comment Number 61, 

December 12, 1990, p. 30. 

101 AHAM. 1990. Op. cit. p. 35. 

102 AHAM. 2006. AHAM Test Data on Microwave Ovens. October 23, 2006, Docket Number 

EE-2006-STD-0127, Comment Number 17, November 30, 2006. 

103 T. Ishii, T. Handa, M. Aiga, N. Kuwahara. 2006. “Magnetron.” U.S. Patent Number 

7,023,137, assigned to Matsushita Electrical Industrial Co., Ltd., Osaka, Japan, April 4, 2006. 

104 AHAM. 2006. Op. cit. 

105 C.R. Buffler and R. McNutt. 1978. “Efficiency Improvement Techniques for Microwave 

Ovens.” Proceedings of the Conference on Major Home Appliance Technology for Energy 

Conservation, Lafayette, IN, February 1978. 

106 Sharp Electronics Corporation. 1994. Comments on the Notice of Proposed Rulemaking for 

Microwave Ovens. 59 FR 10464, March 4, 1994, Docket Number EE-RM-90-201, Comment 

Number 521, July 18, 1994. 

107 AHAM. 1990. Op. cit. p 35. 

108 Ibid. 

109 AHAM. 1990. Op. cit. p 31. 

110 GE Product Literature. Available online at 

www.geappliances.com/products/introductions/trivection/overview/compare_cook_times.htm 

(Accessed September 21, 2008.) 

111 Lowe. 2006. Op. cit. 

112 P. Biermayer et al. 1996. Design Options for Clothes Washers. LBNL, Berkeley, CA, LBL47888, October 1996. 

113 E. Biesen. 2005. “An Expanding Laundry List.” Appliance Magazine, September 2005. 

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114 Appliance Manufacturer, April 1995, p. 27. 

115 Appliance Manufacturer, February 1995, p. E-58. 

116 Science Applications Inc. 1977. Energy Efficiency Program for Clothes Washers, Clothes 

Dryers and Dishwashers, SAI-77-839, La Jolla, CA, pp. 4–45. 

117 “Big Plans for Tiny Bubbles.” Appliance Manufacturer, December 1994, p. 32. 

118 “Sorting Through Laundry.” Appliance, September 1994, p. 35. 

119 Daewoo Product Literature. Available online at 

www.daewoo-electronics.de/eu/products/living_washing_prod.asp?idprod=235 (Accessed 

September 21, 2008.) 

120 I. Turiel, et al. 1995. Evaluation of Advanced Technologies for Residential Appliances and 

Residential and Commercial Lighting. LBNL, Berkeley, CA, LBL-35982, January 1995. 

121 Sharp Product Timeline. Available online at 

http://sharp-world.com/corporate/info/his/chronology/p10.html (Accessed September 21, 

2008.) 

122 S. Kristic et al. 1993. “Direct Comparison: Assessing the Energy Efficiency Impact of a 

Transmissionless Motor/Drive System for Conventional Clothes Washers.” Proceedings of 

the 44th Annual International Appliance Technical Conference, May 1993, p.101. 

123 GE Product Literature. Available online at 

http://products.geappliances.com/ApplProducts/Dispatcher?REQUEST=RESULTSPAGE&C 

ATEGORY=CA0096&CATEGORY=CA0095&SITEID=GEA. (Accessed September 21, 

2008.) 

124 Fisher & Paykel Product Literature. Available online at 

www.fisherpaykel.com/global/laundry-products/clothes-washers/clothes-washer.cfm 

(Accessed September 21, 2008.) 

125 LG Electronics Product Literature. Available online at 

http://us.lge.com/download/product/file/1000003879/WM2688Hss.pdf (Accessed September 

21, 2008.) 

126 U.S. DOE. 1990. Technical Support Document: Energy Conservation Standards for 

Consumer Products: Dishwashers, Clothes Washers, and Clothes Dryers. DOE/CE-0299P, 

December 1990, p. 3-14. 

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127 Ibid. 

128 Ibid.
 

129 “New for ’93.” Electrolux Product Literature, Domotechnica. 

130 Biermayer et al. 1996. Op. cit. 

131 ADL. 1995. Op. cit.
 

132 Biermayer et al. 1996. Op. cit. 

133 AHAM. 1995. Op. cit. 

134 EPRI. 1996. Ozone Laundering: A Better Wash Process for Commercial Laundries. 

Technical Brief RP2890, March 1996. 

135 U.S. DOE. 1990. Op. cit. 

136 “LG Washing Machines Incorporate Steam Technology.” Appliance Magazine, June 29, 

2005. 

137 Ibid. 

138 “Whirlpool to Introduce New Products at Builders Show.” Appliance Magazine, February 

13, 2008. 

139 “New Ways of Washing.” Appliance, September 1992, p. 75. 

140 Appliance, September 1995, p. 51. 

141 Turiel et al. Op. cit. 

142 Natural Resources Canada (NRCan) Database of Major Appliances. Available online at 

http://oee.nrcan.gc.ca/residential/personal/appliances.cfm?attr=4. (Accessed September 21, 

2008.) 

143 Ibid. 

144 Ibid. 

145 Ibid. 

146 Ibid. 

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147 AHAM. 2006. Op. cit. 

148 Ibid. 

149 Ibid. 

150 Ibid. 

151 N. Fish, D. White, and D. Ryan. 2006. Standby Power Energy Use of Common Household 

Appliances. Canadian Building Energy End-Use Data and Analysis Center, University of 

Alberta, Canada, July 2006. 

152 FEMP Microwave Standby Power Database. Available online at 

http://oahu.lbl.gov/cgi-bin/search_data.pl. (Accessed September 21, 2008.) 

153 CEC Appliance Efficiency Database. Available online at 

http://www.energy.ca.gov/appliances/database/index.html. (Accessed June 4, 2009.). 

154 Energy Star Commercial Clothes Washer Database. Available online at 

www.energystar.gov/index.cfm?fuseaction=clotheswash.display_commercial_cw. 

(Accessed June 4, 2009.) 

155 CEE Commercial Clothes Washer Database. Available online at 

www.cee1.org/com/cwsh/cwsh-main.php3. (Accessed June 4, 2009.) 

156 CEC Appliance Efficiency Database. Op. cit. 

157 Energy Star Commercial Clothes Washer Database. Op. cit. 

158 CEE Commercial Clothes Washer Database. Op. cit. 

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