1

This is a draft document and does not represent a definitive view of the agency on the questions addressed.

This and other guidance documents are accessible on the U.S. Department of Energy, Energy Efficiency & 

Renewable Energy web site at: http://www1.eere.energy.gov/guidance/default.aspx?pid=2&spid=1.

Guidance Type: Test Procedures

Category: Residential Products

Product: Refrigerators, refrigerator-freezers, and freezers

Guidance Version: DRAFT

Issued: July 29, 2014

Comment Period Ends: August 28, 2014

The following is a draft U.S. Department of Energy (“DOE” or “the Department”) guidance document 

regarding the test procedure for refrigerators, refrigerator-freezers, and freezers (refrigeration products). 

This draft guidance document represents the Department’s interpretation of its existing regulations and is 

exempt from the notice and comment requirements of the Administrative Procedure Act. See 5 U.S.C. § 

553(b)(A). Nonetheless, the Department is accepting comments and suggestions from the public until

August 28, 2014. Comments and suggestions should be provided in WordPerfect, Microsoft Word, PDF, or 

text file format by sending an email to RefrigeratorFreezerGuidance2014GUID0028@ee.doe.gov. Please also 

include the docket number EERE-2014-BT-GUID-0028. At the end of the comment period, this draft guidance 

document may be adopted, revised, or withdrawn.

Q: When testing using section 3.3 of the appendix A test procedure for refrigerators and refrigeratorfreezers, which allows the use of three tests to determine the energy use of a basic model through 

“triangulation,” does the test require the use of the coldest, median, and warmest settings required by 

section 3.2, or may the tester use any three settings that meet the requirements of appendix M, section 

M3, paragraphs (a) through (c) of the AS/NZS 4474.1:2007 test method?

A: Section 3.3 of appendix A to subpart B of 10 CFR part 430 (Appendix A) provides that a three-setting 

“triangulation” test may be performed as an alternative to the coldest, median, and warmest temperature,

two-setting test in section 3.2 of Appendix A. Section 3.3 provides that the section 3.2 test is not required as 

long as the settings used for the triangulation test meet the requirements identified in AS/NZS 4474.1:2007 

(incorporated by reference; see §430.3) appendix M, section M3, paragraphs (a) through (c) and as 

illustrated in Figure M1. The section 3.3 test may be conducted using any three settings that satisfy these 

requirements. As noted in section 3.3, the target temperature shall be the standardized temperatures 

defined in section 3.2 of Appendix A (i.e., 0  ̊F freezer compartment temperature and 39  ̊F fresh food 

compartment temperature), but the other requirements of section 3.2 do not apply.

DOE also notes that the test data underlying the rated value of energy use, which manufacturers are 

required by 10 CFR 429.71 to maintain for each basic model of a covered product, must, for any basic model 

tested using the triangulation test in section 3.3, identify the settings used for the test and contain sufficient 

information to demonstrate that the requirements pertaining to the use of those settings were met (i.e., a 

minimum of three energy consumption measurements were performed at three setting combinations of the 

two controls being adjusted, the selected test points used to triangulate and enclose the intersection of the 

standardized temperatures for those two compartments, and the temperature in each compartment is 

within 4 K of the standardized temperature for all three settings).