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APPENDIX 12A. MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDE

TABLE OF CONTENTS

12A.1 MISCELLANEOUS REFRIGERATION PRODUCTS................................................1
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APPENDIX 12A. MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDE
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QUESTIONS FOR PRELIMINARY MANUFACTURER IMPACT ANALYSIS

PRELIMINARY MANUFACTURER IMPACT ANALYSIS TOPICS

1 KEY ISSUES

1.1 What are the key issues for your company regarding this product rulemaking?

1.2 Are there any patent, technology, or other issues that you are aware of that would prevent 

you or your competitors from implementing higher-efficiency designs?

2 SHIPMENT PROJECTIONS

2.1 To help DOE understand the market and the relative importance of various product types 

to specific manufacturers, please disaggregate your annual unit shipments for each product 

category as shown in the table below. Here we define “wine/beverage coolers” as 

refrigeration products that are not designed to achieve a compartment temperature of 39°F 

or lower. Please indicate whether you purchase these products from other manufacturers 

(i.e. private label), and what fraction of your product is manufactured in the United States. 

Please provide your answers in the table below (Table 2.1)

Table 2.1 Market Share and Domestic Manufacturing

Product Type

Yearly 

Shipments

Market 

Share 

(%)

% 

Made

% 

Bought % Made 

in U.S.A

Vapor compression wine 

chillers/

beverage coolers with 

manual defrost

Vapor compression wine 

chillers/

beverage coolers with 

automatic defrost

Thermoelectric wine chillers

Thermoelectric refrigerators
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Absorption refrigerators

Absorption wine chillers

Hybrid Refrigeratorsa

Residential Ice Makers

 

2.2 Would you expect your market share to change once standards become effective?

2.3 Does your outlook change with higher efficiency levels?

2.4 How would you expect shipments to change for the industry as a whole as a function of 

standards, and why?

2.5 Looking at price/cost effects only, how would you expect shipments to change for a 5%, 

10%, 25%, or 50% manufacturer price/cost increase?

3 CONVERSION COSTS

3.1 What levels of investment in research & development and manufacturing capital would 

you anticipate making to manufacture products compliant with higher efficiency 

standards? Please describe what they are and provide your best estimate of their respective 

magnitudes.

3.2 How would the imposition of new energy conservation standards affect capacity utilization 

and manufacturing assets at your domestic production facilities? Would a new standard 

 

a Hybrid refrigeration products are refrigerators or freezers that contain one or more wine/beverage cooler 

compartment
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result in stranded capital assets? Would any facilities be closed or downsized? Added or 

upgraded?

3.3 If you do not manufacture products domestically, do you own the factories in which you 

manufacture products overseas, or do you OEM from other product manufacturers?

3.4 How might a new standard impact product innovation?

3.5 At what efficiency levels do you expect to:

 Retire lower-efficiency platforms? How many?

 Close current manufacturing plants rather than upgrade them to make higherefficiency products? (e.g. moving production to new facilities, out-sourcing, or 

ceasing operations altogether).

 Require the development of a “clean sheet” product platform to meet higher 

efficiency levels?

3.6 How would manufacturer tax credits for higher efficiency products affect your decisions 

regarding research and development for highly-efficient wine chillers and residential ice 

makers? Could manufacturer tax credits influence any of the above manufacturing 

decisions? 

4 PRODUCT MIX AND PROFITABILITY

4.1 How would your company’s product mix and marketing strategy change with changes in

the efficiency standard?
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4.2 How would you expect manufacturer tax credits for highly-efficient wine chillers and 

residential ice makers to affect your current product mix and profitability?

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

share of product going through each distribution channel?

4.4 Generally, how would new product standards affect your customer mix, distribution 

channels, and corresponding profit margins?

4.5 What is the approximate percentage of shipments for each product across your portfolio?

5 MARKET SHARES AND INDUSTRY CONSOLIDATION

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

5.2 How would new standards affect your ability to compete?

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

some firms?

5.4 Do you or any of your competitors own intellectual property that confers a significant cost 

advantage regarding achieving certain energy efficiency levels?
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5.5 Could new standards result in disproportionate economic or performance penalties for 

particular consumer/user subgroups?

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

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

other features?

6 CUMULATIVE REGULATORY BURDEN

6.1 Are there recent or impending regulations on your specific product or other products that 

impose a cumulative burden on the industry?

6.2 If so, what is the total expected impact of those other regulations in terms of required 

capital investments, engineering hours spent addressing these issues, and/or product costs?

6.3 Under what circumstances would you be able to coordinate any expenditure related to this 

and other regulations, thereby lessening the cumulative burden?