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Miscellaneous Refrigeration Products

Working Group Negotiations

May 4-5, 2015

Joseph Hagerman

Department of Energy

Building Technologies Program
2

Background

• DOE published a Notice of Public Meeting and preliminary 

technical support document (preliminary TSD) for energy 

conservation standards for miscellaneous refrigeration (MRef) 

products on December 3, 2014 (79 FR 71705).

• DOE published a test procedure Notice of Proposed Rulemaking 

(NOPR) for these products on December 16, 2014 (79 FR 

74893).

• On April 1, 2015, DOE published a notice of intent to seek 

nominations for the formation of this working group to 

negotiate the energy conservation standards and test 

procedures for MRef products (80 FR 17355).
3

Scope & Definitions: Product Categories
4

Preliminary Analysis Proposal – Product Categories

• DOE proposed multiple definitions to refer to both groups of 

products and individual product categories.

Consumer Refrigeration Products

Refrigerators, RefrigeratorFreezers, or Freezers*Miscellaneous 

Refrigeration Products

Cooled Cabinets Non-Compressor 

Refrigerators

Hybrid Products Ice Makers

* DOE did not propose new definitions for refrigerators, refrigerator-freezers, or freezers, but did propose 

clarifications to better differentiate between these and the newly defined MRef products.
5

Preliminary Analysis Proposal – Product Categories

• Consumer Refrigeration Product

• A refrigerator, refrigerator-freezer, freezer, or miscellaneous 

refrigeration product.

• Refrigerator, refrigerator-freezer, and freezer 

• DOE proposed amendments to the existing refrigerator, 

refrigerator-freezer, and freezer definitions to have a consistent 

structure with the newly proposed product definitions, and to 

improve clarity for distinguishing between the products.

• Added clarification that the products are capable of maintaining 

compartment temperatures in a 72 °F ambient.

• Excluded products with characteristics typical of commercial 

refrigeration equipment:

• Permanently open compartments, separate compressors or 

condensers, and certification to ANSI/NSF 7-2009 or ANSI/UL 471-

2006
6

Preliminary Analysis Proposal – Product Categories

• DOE proposed the following definitions for MRef products:

Miscellaneous refrigeration product:

A consumer refrigeration product other than a refrigerator, 

refrigerator-freezer, or freezer, which includes hybrid 

refrigeration products, cooled cabinets, non-compressor 

refrigerators, and ice makers.
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Preliminary Analysis Proposal – Product Categories

Cooled cabinet:

A cabinet that has a source of refrigeration requiring electric 

energy input only and is capable of maintaining compartment 

temperatures either (a) no lower than 39 °F (3.9 °C), or (b) in a 

range that extends no lower than 37 °F (2.8 °C) but at least as 

high as 60 °F (15.6 °C) as determined according to the 

provisions in § 429.61(c)(2) [determined in a 72 °F ambient 

temperature].
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Preliminary Analysis Proposal – Product Categories

Hybrid refrigeration product:

A hybrid refrigerator, hybrid refrigerator-freezer, hybrid freezer, or 

hybrid non-compressor refrigerator.

Generally for hybrid products, at least half but not all of the 

product’s refrigerated volume comprises one or more cellar 

compartments. The remaining product compartments would 

satisfy the definitions for refrigerator, refrigerator-freezer, freezer, 

or non-compressor refrigerator.
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Preliminary Analysis Proposal – Product Categories

Non-compressor refrigerator:

A cabinet that has a source of refrigeration that does not 

include a compressor and condenser unit, requires electric 

energy input only, and is capable of maintaining compartment 

temperatures above 32 °F (0 °C) and below 39 °F (3.9 °C).

Non-compressor cooled cabinet:

A cooled cabinet that has a source of refrigeration that does 

not include a compressor and condenser unit. 
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Preliminary Analysis Proposal – Product Categories

Ice maker:

A consumer product other than a refrigerator, refrigeratorfreezer, freezer, hybrid refrigeration product, non-compressor 

refrigerator, or cooled cabinet designed to automatically 

produce and harvest ice, but excluding any basic model that is 

certified under NSF/ANSI 12-2012 Automatic Ice Making 

Equipment. Such a product may also include a means for storing 

ice, dispensing ice, or storing and dispensing ice.
11

Stakeholder Feedback – Product Categories

• Some stakeholders commented that the proposed 

definitions required further clarification so as not to allow 

the use of ANSI, NSF, and UL standards for food storage 

equipment to be used as a loophole to avoid coverage. 

• One stakeholder noted that the range of products covered 

by this rule are not one type of consumer product, but are 

designed and marketed for very different purposes. 
12

Stakeholder Feedback – Product Categories

• Stakeholders commented that the 50% cellar compartment 

threshold to differentiate hybrid products from other 

consumer refrigeration products is an arbitrary cutoff. 

• Many stakeholders commented to oppose DOE’s grouping of 

ice makers with the other MREF products. They stated that 

ice makers serve a different consumer need and are 

sufficiently different in their operation from the other 

product categories that grouping them is not appropriate.
13

Stakeholder Feedback – Product Categories 

• One stakeholder pointed out that the product definitions, 

and the standard, as proposed only cover electricity usage, 

whereas many of these products – especially ice-makers –

also use large volumes of water.

• Commenters objected to using this rulemaking to amend 

definitions for residential refrigerator/freezers because those 

amendments would effectively amend coverage and 

standards for certain products.
14

Key Issues – Product Categories

• Do the definitions of each product category need to be 

amended in any way?

• How would definitions for these products be amended to 

best differentiate between consumer products and 

commercial equipment?

• Is the 72 °F ambient temperature appropriate for 

determining the compartment temperatures products are 

capable of maintaining for the purposes of product 

classification?

• Are any clarifications needed to better differentiate between 

the non-ice maker product categories?
15

Scope & Definitions: Product Classes
16

Preliminary Analysis Proposal – Product Classes

In the preliminary analysis, DOE proposed the following 

product classes for MRef products:

Product Category Product Classes

Cooled Cabinets Single product class. 

Non-Compressor 

Refrigerators

Single product class. 

Hybrid Products 40 product classes analogous to the product classes for 

refrigerators, refrigerator–freezers, and freezers. However, 

DOE is aware of hybrid products available on the market in 

only four out of these forty product classes. 

Ice Makers  Uncooled Storage

 Cooled Storage

 Portable
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Preliminary Analysis Proposal – Product Classes

• DOE identified the following hybrid product classes during 

the preliminary analysis:

Hybrid Refrigeration 

Products

H-3A-BI Built-in standard-sized* hybrid all-refrigerators 

with automatic defrost

H-9I-BI Built-in standard-sized hybrid freezers with 

automatic defrost and an automatic icemaker

H-11A Compact* hybrid all-refrigerators with manual 

defrost

H-13A Compact hybrid all-refrigerators with 

automatic defrost

* Note: “Compact” products are defined as having a total compartment volume of less than 7.75 

cubic feet; for compartment sizes larger than this, the term “standard-sized” is used.
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Preliminary Analysis Proposal – Product Classes

• DOE proposed the following definitions for ice maker 

product classes:

Portable ice maker – An ice maker that does not require 

connection to a household water supply for operation and is 

operable using one or more on-board reservoirs that must be 

manually supplied with water.

Uncooled-storage ice maker – An ice maker that does not 

maintain ice storage bin temperatures below 32 °F.

Cooled-storage ice maker – An ice maker that maintains ice 

storage bin temperatures below 32 °F.
19

Stakeholder Feedback – Product Classes

• Several stakeholders expressed agreement with DOE’s 

definitions and proposed product classes for MRef products.

• Some stakeholders commented that cooled cabinets 

required multiple product classes

• One commented that thermo-electric cooled cabinets serve a 

specific utility.

• Others commented that cooled cabinets should be separated into 

standard/compact and built-in/freestanding product classes. 

• Stakeholders noted that ice makers for ‘clear ice’ could 

require a separate product class.
20

Stakeholder Feedback – Product Classes

• Some stakeholders questioned DOE’s mapping of Hybrid 

product classes to existing refrigerator/refrigerator-freezer 

product classes, noting that of the forty classes thus defined, 

very few are actually currently on the market. 

• Further, stakeholders noted that it may be better to divide 

hybrids into product classes based on the type of cellar 

compartment door, or on the percentage of the total volume 

dedicated to cellar compartments.
21

Key Issues – Product Classes

• Is there a need to adjust the product classes DOE analyzed in 

the preliminary analysis?

• If so, what is the unique feature or consumer utility and the 

associated energy impact for each of the potential product 

classes? 

• How would these product classes be defined to clearly 

differentiation between the different product classes?

• Note: any major revisions to the proposed product class 

structure would require new standards analysis on the 

updated product class structure.
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Test Procedures
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Background

• DOE published a Test Procedure NOPR in December 2014 (79 

FR 74893) and based the preliminary analysis for energy 

conservation standards on these proposed test procedures.

• DOE proposed that the test procedures for cooled cabinets, 

hybrid refrigerators, and NCRs be incorporated into the 

existing test procedures for refrigerators and refrigeratorfreezers, and freezers in 10 CFR part 430 Appendix A and 

Appendix B, with adjusted ambient temperatures and usage 

factors as appropriate.

• DOE proposed a separate test procedure for ice makers due 

to the different measurements necessary to measure ice 

production rather than cooled air. 
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Test Procedures: Ambient Temperatures
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NOPR Proposal – Ambient Temperatures

• For the MRef test procedures incorporated into Appendix A 

and Appendix B, DOE recommended a 90 oF ambient test 

temperature, consistent with the method for refrigerators, 

refrigerator-freezers, and freezers. 

• However, DOE proposed that the ambient test temperature 

be set at 72 oF for non-compressor cooled cabinets. 

• DOE selected 72 oF in this case because the thermoelectric cooled 

cabinets were unable to meet compartment temperatures of 55 

oF at a 90 oF ambient, leading to unrepresentative energy use 

results.

• For ice makers, DOE also proposed testing in a 72 oF ambient 

due to fewer door openings and the lack of cooling warm 

food loads in these products.
26

NOPR Proposal – Ambient Temperatures

• For NCRs, DOE similarly observed that many are not capable 

of maintaining refrigerator temperatures (39 oF) in the 90 oF

ambient.

• DOE proposed that for those NCRs unable to achieve and 

maintain compartment temperatures at 90 oF, the results of 

the cold setting test be used for the overall test result, and 

that the lowest compartment temperatures maintained at 

the cold setting be reported (if above 39 oF). 

• For other product types (other than ice makers) not able to 

maintain compartment temperatures at 90 oF, DOE proposed 

an extrapolation approach similar to that included in the 

previous Appendix A1.
27

Stakeholder Feedback – Ambient Temperatures

• Some interested parties supported testing all products 

covered under this rulemaking in 72 oF ambient conditions, 

while others supported a 90 °F ambient temperature for all 

products.

• Stakeholders commented that a lower ambient temperature 

is appropriate for ice makers, but 70 oF may be more 

appropriate than the proposed 72 oF.

• Certain commenters expressed opposition to the linear 

extrapolation approach for products not able to maintain 

compartment temperatures at the 90 oF ambient.
28

Key Issues – Ambient Temperatures

• Should the ambient test temperatures for any of the 

products be amended? If so, what temperatures would be 

more representative?

• How should the test procedure address units that are unable 

to maintain standardized compartment temperatures at a 

90 °F ambient temperature?

• For NCRs, is the approach of taking the results of the cold 

setting appropriate for products unable to maintain the 39 °F 

compartment temperature? If not, should these products be 

tested at a 72 °F ambient, or should the extrapolation 

approach be applied?
29

Test Procedures: Usage Factors
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NOPR Proposal – Usage Factors

• For vapor-compression cooled cabinets, DOE proposed a 

usage factor of 0.55 to address the over-estimation of 

energy use associated with 90 °F ambient testing, based on:

• The 0.46 ratio between measured energy use at 72 °F and 90 °F 

observed in closed door testing, and 

• A 1.2 usage factor used to represent additional thermal loads, 

such as door openings or loading warm items (0.46×1.2=0.55). 

• For non-compressor cooled cabinets, DOE proposed a usage 

factor of 1.2 (i.e., only the thermal load adjustment) because 

these products would be tested at a 72 °F ambient.

• For NCR’s, DOE proposed a usage factor of 1.0, consistent 

with the usage factors in the existing refrigerators test 

procedure.
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NOPR Proposal – Usage Factors

• For hybrid products, DOE proposes a usage adjustment 

factor of 0.85. 

• Because at least half of the refrigerated volume of these products 

is occupied by the cellar compartment, which is often for wine 

storage, DOE believes that the door opening frequency for these 

products would be closer to cooled cabinets than for 

refrigerators.

• However, the 0.85 usage factor is higher than for cooled cabinets 

because the 90 °F ambient temperature likely has less of an 

impact on hybrid performance because at least one compartment 

would be at the lower refrigerator or freezer compartment 

temperatures.

• Ice makers do not have a similar usage factor adjustment, 

but the overall energy used in the test procedure is based on 

an ice consumption rate of 4 lb/day for all product classes.
32

Stakeholder Feedback – Usage Factors

• Several interested parties commented that DOE did not have 

sufficient data to determine appropriate usage factors for 

the different product types.

• One stakeholder submitted data indicating that cooled 

cabinets and hybrid products are used more similarly to 

freezers than to refrigerators, with respect to door openings.

• Many stakeholders felt that it would be preferable to use a 

90 oF ambient test temperature than to test at 72 °F with an 

adjustment factor for door openings. 
33

Key Issues – Usage Factors

• What usage factors best represent field usage of these 

products?

• Are the ambient temperature impacts and additional 

thermal load impacts quantified correctly?

• Do working group members have any additional test data to 

inform appropriate usage factors?

• Note: if the test procedures are revised from the NOPR, this 

will in turn affect the analysis conducted for energy 

conservation standards.