March 27, 2012 

The Honorable Dr. Henry C. Kelly 

Assistant Secretary, Energy Efficiency and Renewable Energy 

U.S. Department of Energy, 

Mail Station EE-10 

1000 Independence Avenue, SW 

Washington, DC 20585 

Via e-mail (henry.kelly@ee.doe.gov) and overnight mail 

Re: Petition for Waiver and Application for Interim Waiver concerning the 

measurement of water and energy used in the water softening 

regeneration process of Dishwashers having an Integrated Water Softener 

Dear Assistant Secretary Kelly: 

BSH Home Appliance Corporation (“BSH”) hereby submits this Petition for 

Waiver and Application for Interim Waiver pursuant to 10 CFR 430.27, 

concerning the test procedure for measuring energy consumption of 

Dishwashers. 

BSH is the manufacturer of household appliances bearing the brand names of 

Bosch, Thermador, and Gaggenau. Its appliances include dishwashers, washing 

machines, clothes dryers, refrigerator-freezers, ovens, and microwave ovens, 

and are sold worldwide, including in the United States. BSH’s United States 

operations are headquartered in Irvine, California. BSH’s appliances are 

produced in the United States and Germany. 

10 CFR 430.27(a)(1) provides that any interested person may submit a petition to 

waive for a particular basic model any requirement of Section 430.23, or of any 

appendix to this subpart, upon grounds that the basic model contains one or 

more design characteristics which either prevent testing of the basic model 

according to the prescribed test procedures, or the prescribed test procedures 

may evaluate the basic model in a manner so unrepresentative of its true energy 

consumption characteristics, or water consumption characteristics as to provide 

materially inaccurate comparative data. Additionally, 10 CFR 430.27 (b)(2) allows 

any applicant of a Petition of Waiver to also request an Interim Waiver if it can be 

demonstrated the likely success of the Petition for Waiver, while addressing the 

economic hardship and/or competitive disadvantage that is likely to result absent 

a favorable determination on the Application for Interim Waiver. 
This request for Waiver is directed to Dishwashers containing a built-in or 

integrated water softener, specifically addressing the energy and water used in 

the regeneration process of the integrated water softener. This request is 

identical to Waiver Case Number DW-005 (and a pending waiver) previously 

granted to BSH Home Appliance Corporation with the only modification being to 

add additional model numbers. Further, the water softening technology used in 

these models is identical to the models that were previously approved. 

Based on the reasoning indicated herein, BSH submits that the testing of 

Dishwashers equipped with a water softener under the current DOE test 

procedure may lead to information that could be considered misleading to 

consumers. 

1. Identification of Basic Models. 

The Dishwasher models manufactured by BSH which contain an integrated 

water softener and were not included in previous Waiver applications is as 

follows: 

Bosch brand: 

 Basic Model – SHX5ER## 

2. Background 

The design characteristic that is unique among the above listed models is 

an integrated water softener. The primary function of a water softener is to 

reduce the high mineral content of “hard” water. Hard water reduces the 

effectiveness of detergents leading to additional detergent usage. Hard 

water also causes increased water spots on dishware, resulting in the 

need to use more rinse aid to counterbalance this effect. “Hard” water can 

reduce customer satisfaction with Dishwasher performance resulting in 

increased pre-rinsing and/or hand washing as well as increased detergent 

and rinse agent usage. 

The water softening process requires water usage for both the 

regeneration process and to flush the system. For purposes of this Waiver 

request, the term “regeneration” will include the water and energy used in 

both the flushing and regeneration process of the water softener. The 

water used in the regeneration process is in addition to the water used in 

the dish washing process. The water used in the regeneration process 

does not occur with each use of the Dishwasher. The frequency of the 

regeneration process is dependent upon an adjustable water softener 

setting that is controlled by the end user, and based on the home water 

hardness. Regeneration frequency will vary greatly depending upon the 

customer setting of the water softener. Data from the U.S. Geological 

Survey shows considerable variation in the water hardness within the U.S. 

and for many locations the use of a water softener is not necessary. Water 

hardness varies throughout the U.S. with the mean hardness of 217 
mg/liter or 12.6 grains/gallon (based on information provided by the U.S. 

Geological Survey located at http://water.usgs.gov/owq/hardnessalkalinity.html). 

Calculations

Water Use

 Based on the DOE Energy Test for Dishwashers, the BSH 

Dishwashers listed in this waiver with an internal water softener use 

an average of 6.65 liters of water per dish cleaning cycle. 

 Based on an average U.S. water hardness of 12.6 grains/gallon, 

the internal BSH Dishwasher water softener system would be set 

on “4”. 

 Based on a BSH Dishwasher internal water softening system 

setting of “4” and the dishwasher using 6.65 liters of water per run, 

the water regeneration process would occur every 6th cycle. 

 When using the Dishwasher 215 times per year (per DOE test 

procedure), the regeneration process would occur 35.8 times (36). 

 The internal BSH water softening system uses 4.97 liters (5.0) per 

regeneration cycle. 

 Water usage calculation based on above data. 

o 36 x 5 = 180 liters per year (47.6 gallons) or .84 liters (.22 

gallons) each time the dishwasher is used. 

Energy Used in kWh

 Formula W= V x T x K 

o V = Weighted Average Water Usage per DOE 

o T = Nominal water heater temperature rise of 39° C 

o K = Specific heat of water 0.00115 

 Calculated Energy use – 180 x 39 x .00115 = 8.0 kWh/yr 

Summary

 A Dishwasher built by BSH with an integrated water softener in a 

home with a 12.6 grain per gallon water hardness would be cycled 

through the water softening regeneration process approximately 

every 6 dish cleaning cycles. When the water used in the water 

softener regeneration process is apportioned evenly over all 

dishwasher runs, the amount of energy and water usage per cycle 

is very low. Based on the assumptions provided, BSH estimates the 

typical water used in the internal Dishwasher water softener 

regeneration process at .84 liters (.22 gallons) per use; furthermore, 

using about 8.0 kWh per year to heat this water in the home hot 

water heater. 
Note: Contrary to current DOE direction, in BSH’s opinion 

the water used in the Water Softening regeneration process 

has the separate and distinct purpose of softening water and 

we do not feel that this water and energy should be included 

in the energy usage figures for washing dishes. EN 50242 

does not include the water or energy used in the water 

softening process in the dishwasher energy consumption 

calculation and BSH would suggest adopting a similar 

approach as used in EN50242 when the test procedure is 

updated. 

3. Requirements sought to be waived 

Dishwashers are subjected to test methods outlined in 10 CFR Part 430, 

Subpart B, App. C, Section 4.3, which specifies the method for the water 

energy calculation. 

 To stay consistent with the recently approved Dishwasher waivers 

for units with a water softener, BSH is requesting approval to 

estimate the water and energy used in the water softening process 

based on the design of the BSH Dishwasher and the calculations 

and assumptions outlined above. 

4. Grounds for Waiver and Interim Waiver 

10 CFR 430.27 (a) (1) provides that a Petition to waive a requirement of 

430.23 may be submitted upon grounds that the basic model contains one 

or more design characteristics which either prevent testing of the basic 

model according to the prescribed test procedures, or the prescribed test 

procedures may evaluate the basic model in a manner so 

unrepresentative of its true energy consumption characteristics as to 

provide materially inaccurate comparative data. 

If a water softener regeneration process was to occur while running an 

energy test, the water usage would be overstated. In this case, the water 

energy usage would be unrepresentative of the product providing 

inaccurate data resulting in a competitive disadvantage to BSH. 

 

Granting of an Interim Waiver in this case is justified since the prescribed 

test procedures would potentially evaluate the basic model in a manner so 

unrepresentative of its true energy consumption characteristics as to 

provide materially inaccurate comparative data. In addition, a similar 

Interim Waiver and Waiver have previously been granted to BSH. 

5. Manufacturers of Similar Products and Affected Manufacturers 
Web based research shows that at least two other manufacturers are 

currently selling dishwashers with an integrated water softener, Miele Inc. 

and Whirlpool Corporation (Waiver Granted). 

Manufacturers selling dishwashers in the United States include AGA 

Marvel, Arcelik A.S., ASKO Appliances, Inc., Electrolux North America, 

Inc., Fagor America, Inc., Fisher & Paykel Appliances, GE Appliances and 

Lighting, Haier America, Indesit Company Sa, Kuppersbusch USA, LG 

Electronics USA, Miele, Inc., Samsung Electronics Co., Viking Range 

Corporation and Whirlpool Corporation. 

BSH will notify all companies listed above (as well as AHAM), as required 

by the Department’s rules, providing them with a copy of this Petition for 

Waiver and Interim Waiver. 

6. Conclusion 

BSH Home Appliances Corporation hereby requests approval of the 

Waiver petition and Interim Waiver. By granting said Waivers the 

Department of Energy will further ensure that water energy is measured in 

the same way by all Dishwasher Manufacturer’s that have a integrated 

water softener. Further, BSH would request that these Waivers be in good 

standing until such time that the test procedure can be formally modified to 

account for integrated water softeners. 

BSH Home Appliances certifies that all manufacturers of domestic 

Dishwashers as listed above have been notified by letter. Copies of these 

notifications are attached. 

With Best Regards, 

Mike Edwards 

Senior Engineer, Performance and Consumption 

BSH Home Appliances Corporation (FNbG) 

100 Bosch Blvd., Building 102 

New Bern, NC 28562-6924 

mike.edwards@bshg.com 

www.boschappliances.com

Phone (252) 636 4334 

Fax (252) 636 4450