5-i

CHAPTER 5. ENGINEERING ANALYSIS

TABLE OF CONTENTS

5.1 INTRODUCTION ........................................................................................................... 5-1

5.2 PRODUCT CLASSES ANALYZED.............................................................................. 5-1

5.3 EFFICIENCY LEVELS................................................................................................... 5-3

5.3.1 Baseline Efficiency Levels .............................................................................................. 5-4

5.3.2 Incremental Efficiency Levels......................................................................................... 5-7

5.3.2.1 Portable Dehumidifier Product Classes......................................................... 5-7

5.3.2.2 Whole-Home Dehumidifier Product Classes................................................. 5-9

5.4 METHODOLOGY OVERVIEW.................................................................................. 5-10

5.4.1 Review of Previous Technical Support Documents and Models................................... 5-11

5.4.2 Manufacturer Interviews................................................................................................ 5-11

5.4.3 Product Testing .............................................................................................................. 5-12

5.4.4 Product Teardowns ........................................................................................................ 5-12

5.4.4.1 Selection of Units......................................................................................... 5-12

5.4.4.2 Generation of Bill of Materials.................................................................... 5-13

5.4.4.3 Cost Structure of the Spreadsheet Models................................................... 5-13

5.4.4.4 Cost Model and Definitions......................................................................... 5-14

5.4.4.5 Cost Model Assumptions............................................................................. 5-15

5.5 ANALYSIS AND RESULTS........................................................................................ 5-16

5.5.1 Manufacturer Interviews................................................................................................ 5-16

5.5.1.1 Product Classes............................................................................................ 5-16

5.5.1.2 Design Features of Current Baseline Products ............................................ 5-16

5.5.1.3 Proposed Incremental Efficiency Levels..................................................... 5-17

5.5.1.4 Design Options Required to Meet Each Efficiency Level........................... 5-17

5.5.1.5 Performance at Reduced Ambient Temperatures........................................ 5-17

5.5.1.6 Impact on Consumer Utility......................................................................... 5-18

5.5.1.7 Installation and Repair Costs as a Function of Efficiency........................... 5-18

5.5.2 Product Testing .............................................................................................................. 5-18

5.5.2.1 Product Selection ......................................................................................... 5-18

5.5.2.2 Test Approach and Results.......................................................................... 5-18

5.5.3 Product Teardowns ........................................................................................................ 5-21

5.5.3.1 Baseline Construction .................................................................................. 5-21

5.5.3.2 Design Options to Reach Higher Efficiency Levels.................................... 5-22

5.5.4 Numerical Model ........................................................................................................... 5-28

5.5.4.1 Summary...................................................................................................... 5-28

5.5.4.2 Analysis Method .......................................................................................... 5-29

5.5.5 Cost Estimates................................................................................................................ 5-31

5.5.5.1 Baseline Cost Estimates............................................................................... 5-32

5.5.5.2 Incremental Cost Estimates.......................................................................... 5-33
5-ii

LIST OF TABLES

Table 5.3.1.1 Dehumidifier Baseline Unit Efficiencies Based on EISA 2007 Standards ........... 5-4

Table 5.3.1.2 Proposed Portable Dehumidifier Baseline Capacities and Efficiencies ................ 5-6

Table 5.3.1.3 Whole-Home Dehumidifier Baseline Efficiencies................................................ 5-6

Table 5.3.2.1 Portable Dehumidifier Efficiency Levels at 80 °F................................................. 5-7

Table 5.3.2.2 Proposed Portable Dehumidifier Efficiency Levels for the Preliminary 

Analysis................................................................................................................ 5-9

Table 5.3.2.3 Whole-Home Dehumidifier Efficiency Levels at 80 °F...................................... 5-10

Table 5.3.2.4 Proposed Whole-Home Dehumidifier Efficiency Levels for the Preliminary 

Analysis.............................................................................................................. 5-10

Table 5.4.4.1 Major Manufacturing Processes .......................................................................... 5-14

Table 5.5.5.1 Baseline Dehumidifier Manufacturing Cost Distribution.................................... 5-33

Table 5.5.5.3 Incremental Dehumidifier Manufacturing Costs at Higher Efficiencies............. 5-33

LIST OF FIGURES

Figure 5.4.4.1 Manufacturing Cost Assessment Stages............................................................. 5-13

Figure 5.5.2.1 Measured EF at 80 °F and 65 °F for Portable Dehumidifiers with 

Capacities Up to 75 pints/day at 80 °F .............................................................. 5-19

Figure 5.5.2.2 Measured EF at 80 °F and 65 °F for Portable Dehumidifiers with 

Capacities Greater than 75 pints/day at 80 °F.................................................... 5-20

Figure 5.5.2.3 Measured EF at 80 °F and 65 °F for Whole-Home Dehumidifiers.................... 5-21

Figure 5.5.4.1 R-410A Compressor Performance Characteristics............................................. 5-30

Figure 5.5.5.1 R-410A Compressor Cost from Room Air Conditioner Direct Final Rule 

Analysis.............................................................................................................. 5-32
5-1

CHAPTER 5. ENGINEERING ANALYSIS

5.1 INTRODUCTION

After conducting the screening analysis, the U.S. Department of Energy (DOE) 

performed an engineering analysis based on the remaining design options. The engineering 

analysis consists of estimating the energy consumption and costs of dehumidifiers at various 

levels of increased efficiency. This section provides an overview of the engineering analysis 

(section 5.1), discusses product classes (section 5.2), establishes baseline and incremental 

efficiency levels (section 5.3), explains the methodology used during data gathering (section 5.4) 

and discusses the analysis and results (section 5.5).

The primary inputs to the engineering analysis are baseline information from the market 

and technology assessment (chapter 3 of this preliminary technical support document (TSD)) and 

technology options from the screening analysis (chapter 4). Additional inputs were determined

through teardown analysis and manufacturer interviews. The primary output of the engineering 

analysis is a set of cost-efficiency curves. In the subsequent markups analysis (chapter 6), DOE 

determined customer (i.e. product purchaser) prices by applying distribution markups, sales tax 

and contractor markups. After applying these markups, the cost-efficiency curves serve as the 

input to the building energy-use and end-use load characterization (chapter 7), and the life-cycle 

cost (LCC) and payback period (PBP) analyses (chapter 8). 

DOE typically structures its engineering analysis around one of three methodologies.

These are: (1) the design-option approach, which calculates the incremental costs of adding 

specific design options to a baseline model; (2) the efficiency-level approach, which calculates 

the relative costs of achieving increases in energy efficiency levels, without regard to the 

particular design options used to achieve such increases; and/or (3) the reverse-engineering or 

cost-assessment approach, which involves a “bottom-up” manufacturing cost assessment based 

on a detailed bill of materials (BOM) derived from teardowns of the product or equipment being 

analyzed. Deciding which methodology to use for the engineering analysis depends on the 

covered product, the design options under study, and any historical data that DOE can draw on. 

5.2 PRODUCT CLASSES ANALYZED

The Energy Policy Act of 2005 (EPACT 2005), Pub. L. 109-58 (42 U.S.C. 6291–6309), 

amended the Energy Policy and Conservation Act (EPCA) of 1975, Pub. L. 94-163 (42 United 

States Code (U.S.C.) 6291–6309) to establish energy conservation standards for dehumidifiers 

manufactured as of October 1, 2007. (Section 135(c)(4)) These standards specified five product 

classes: 

• 25.00 pints/day or less;
5-2

• 25.01–35.00 pints/day;

• 35.01–54.00 pints/day;

• 54.01–74.99 pints/day; and

• 75.00 or more pints/day.

The Energy Independence and Security Act of 2007 (EISA 2007), Pub. L. 110-140 (EISA 

2007), in section 311(a)(1), amended EPCA to prescribe a new set of standards for 

dehumidifiers, which took effect on October 1, 2012. DOE codified the EISA 2007 standards at 

10 CFR 430.32(v)(2). 74 FR 12058 (Mar. 23, 2009). These updated standards consolidated the 

two smallest product classes (25.00 pints/day or less and 25.01 – 35.00 pints/day) and subdivided 

the 35.01–54.00 pints/day product class into two product classes as follows:

• Up to 35.00 pints/day;

• 35.01 to 45.00 pints/day;

• 45.01 to 54.00 pints/day;

• 54.01 to 75.00 pints/day; and

• Greater than 75.00 pints/day.

In the framework document for this rulemaking, DOE proposed maintaining these 

product classes. In response to comments, DOE also considered consolidating all portable 

products less than 75 pints/day into one product class, with efficiency levels determined from an 

equation relating efficiency as a function of capacity. While there is a general trend between 

product capacity and efficiency, DOE does not expect an equation to accurately reflect the 

capacity-efficiency relationship because it does not believe there is an inherent single 

relationship between capacity and efficiency. Rather, these relationships are also driven by 

different manufacturers’ range of product chassis sizes. DOE is aware that manufacturers 

typically offer multiple products over a range of capacities, but these products are generally 

constructed on one or two standardized chassis. These standardized cases may limit a 

manufacturer’s ability to optimize blower or heat exchanger configuration for a particular 

capacity, and significant changes in efficiency may require a manufacturer to move to a larger 

case.

Therefore, DOE expects manufacturers to reach an efficiency limit within a given case 

size for products at a certain capacity, although each manufacturer’s threshold for moving to a 

larger case size may be different. By maintaining product classes over a range of capacities,

DOE can consider standards uniquely for each product class, taking into consideration the ability 

that manufacturers have to adjust capacity within a given case in order to meet the minimum 

energy conservation standards. Moving to a single portable dehumidifier product class with an 

equation-based approach may force manufacturers to limit the range of products available on the 

market, or require a substantial investment to establish new production lines for product classes 

in which their existing range of chassis sizes would not allow the standards to be met. For these 

reasons, DOE maintained in this preliminary analysis the portable dehumidifier product classes 

that are the basis of the current dehumidifier standards, although as discussed later in this section 

the capacity ranges were adjusted to account for proposed changes in DOE’s test procedure.
5-3

In the framework document for this rulemaking, DOE noted that whole-home units 

generally use similar dehumidification technologies to portable units, but are designed to operate 

in a ducted installation. 77 FR 49739 (Aug. 17, 2012). To address the impacts of ducting on 

whole-home dehumidifier performance, DOE proposed a definition and test procedure for 

whole-home dehumidifiers in a test procedure notice of proposed rulemaking (NOPR) published 

in the Federal Register on May 21, 2014 (May 2014 Test Procedure NOPR). 79 FR 29272. The 

proposed definition in the May 2014 Test Procedure NOPR specifies that a whole-home 

dehumidifier is a dehumidifier that is designed to be installed with ducting to deliver return 

process air to its inlet and to supply conditioned process air from its outlet to one or more 

locations in the conditioned space. 79 FR 29272, 29275 (May 21, 2014). Testing in support of 

the whole-home testing methodology proposed in the May 2014 Test Procedure NOPR showed 

that the pressure restrictions imposed by a representative ducted configuration impact the

performance of whole-home units such that a whole-home dehumidifier would not be able to 

achieve the same efficiency as portable units with the same capacity. In addition, whole-home 

dehumidifiers must be designed with larger blowers and motors to accommodate the pressure 

restrictions inherent with ducting, thus further reducing energy efficiency. Due to these 

performance differences, DOE considered whole-home dehumidifiers as a separate product class 

for this analysis.

DOE further divided the whole-home product class into two separate product classes by 

case volume: (1) less than or equal to 8.0 cubic feet (ft3

) and (2) and greater than 8.0 ft3. During 

interviews, manufacturers indicated that various installation locations, including attics, crawls 

spaces, utility closets, and others, impose case size restrictions for whole-home dehumidifiers. 

These spaces each impose different size restrictions on the dehumidifier floor footprint and 

overall case volume. The proposed product class case volume differentiation is intended to 

capture the various applications for these whole-home products where installation location may 

impose certain size restrictions and associated performance restrictions. Based on teardowns and 

market research, DOE concluded that 8.0 ft3 is an appropriate threshold case size for models that 

represent different utility in terms of installation location. 

5.3 EFFICIENCY LEVELS

For dehumidifiers, energy conservation standard levels are currently defined by the 

energy factor (EF) for each product class. However, section 310 of EISA 2007 amended EPCA

to require that the test procedure for dehumidifiers be amended to include measurement of 

standby mode and off mode energy use, taking into consideration the most current versions of 

Standards 62301 and 62087 of the International Electrotechnical Commission (IEC).a EPCA, as 

 

a The most current version is IEC Standard 62301, “Household electrical appliances–Measurement of standby 

power”, Second Edition, 2011. IEC Standard 62087, “Methods of measurement for the power consumption of audio, 

video, and related equipment,” Second Edition, 2008-2010, is not applicable to this rulemaking. IEC standards may 

be purchased online at http://www.iec.ch.
5-4

amended by EISA 2007, also required that any final rule establishing or revising a standard for a 

covered product, adopted after July 1, 2010, shall incorporate standby mode and off mode energy 

use into a single amended or new standard, if feasible. If not feasible, the Secretary shall 

prescribe within the final rule a separate standard for standby mode and off mode energy 

consumption. (42 U.S.C. 6295(gg))

The DOE dehumidifier test procedure established in a final rule published on October 31, 

2012, and presently codified at 10 CFR part 430, subpart B, appendix X (Appendix Xb), includes 

a measure of standby mode energy use, based on the methods in IEC Standard 62301. 77 FR 

65942. Appendix X defines an integrated energy factor (IEF) metric that combines the active 

mode energy consumption with low-power mode energy consumption, which includes standby

mode or off mode energy consumption. The annual combined low-power mode energy 

consumption is calculated based on an annual hourly usage assumption for all identified lowpower modes. The low-power modes identified in Appendix X are off mode or inactive mode, 

and off-cycle mode.

In accordance with the EISA 2007 requirements, this analysis was conducted using 

efficiency levels based on IEF, which accounts for dehumidifier standby mode and off mode 

energy use.

5.3.1 Baseline Efficiency Levels

Typically, a baseline unit is a unit that just meets current energy conservation standards 

and provides basic consumer utility. DOE analyzed the baseline units for each product class in 

the engineering analysis, and the subsequent LCC and PBP analyses. To determine energy 

savings and changes in price, DOE compared more energy-efficient units to the baseline unit. 

Table 5.3.1.1 summarizes the October 1, 2012 prescribed by EISA 2007. Each energy 

efficiency level is expressed as a minimum EF, which is defined in liters per kilowatt-hour 

(L/kWh).

Table 5.3.1.1 Dehumidifier Baseline Unit Efficiencies Based on EISA 2007 Standards

Dehumidifier Capacity EF (L/kWh)

35.00 pints/day or less 1.35

35.01–45.00 pints/day 1.50

45.01–54.00 pints/day 1.60

54.01–75.00 pints/day 1.70

75.01 pints/day or more 2.50

 

b The final rule published on October 31, 2012 established this test procedure as Appendix X1. In a subsequent final 

rule published on February 7, 2014, DOE removed the dehumidifier test procedure codified at that time at 10 CFR 

part 430, subpart B, appendix X, and redesignated the appendix established by the October 2012 final rule as 

Appendix X. 79 FR 7366.
5-5

However, as described above, the analysis for this rulemaking must consider standby 

mode and off mode energy consumption. Accordingly, DOE conducted its analysis on efficiency 

levels defined by IEF rather than EF. In addition to considering standby mode and off mode 

energy use, the May 2014 Test Procedure NOPR proposes adding a measure of energy use in an 

additional active mode, fan-only mode, in which the fan remains active after the relative 

humidity setpoint has been reached and the compressor is inactive. 79 FR 29272, 29290–91 

(May 21, 2014). The proposed IEF calculation replaces the measure of off-cycle mode energy 

consumption with a measure of fan-only mode energy consumption for units capable of 

operating in fan-only mode.

The May 2014 Test Procedure NOPR also proposed a modification to the active mode 

test conditions required in Appendix X. In response to public comments regarding the 

inapplicability of the current 80 degrees Fahrenheit (°F) dry-bulb test condition, DOE conducted 

additional research regarding the typical ambient conditions under which residential portable and 

whole-home dehumidifiers operate. In its analysis, DOE investigated regional and time-of-year 

usage patterns as well as typical installation locations within the home. Based on this information 

and analyses of climate and soil temperature data, DOE determined that the average annual 

operating temperature is approximately 65 °F for the representative geographic regions and

months of the year for dehumidifier usage. DOE’s analysis also confirmed that the existing 60-

percent relative humidity condition is appropriate. These results for ambient temperature and 

humidity are consistent with the conditions specified in the “Low Temperature Test” in 

ANSI/AHAM DH-1-2008 “Dehumidifiers”, which DOE believes manufacturers may already be 

conducting. Therefore, the May 2014 Test Procedure NOPR proposed reducing the ambient drybulb temperature from 80 °F to 65 °F while maintaining the same relative humidity of 60

percent. 79 FR 29272, 29276–82 (May 21, 2014).

DOE conducted extensive testing at this reduced ambient temperature condition on both 

portable and whole-home dehumidifiers and observed the associated impacts to both capacity 

and IEF. On average, capacity and IEF decreased by 35 percent and 25 percent, respectively, 

when compared to the 80 °F ambient test condition. 

Based on the conversion from EF to IEF, and on the proposed amendments in the May 

2014 Test Procedure NOPR, DOE developed adjusted product classes and IEF baseline 

efficiency levels at both the 80 °F and 65 °F ambient conditions. Because the performance 

reduction from 80 °F to 65 °F is not linear with capacity, the converted capacity and efficiency 

levels are not directly proportional to those at 80 °F.
5-6

Table 5.3.1.2 Proposed Portable Dehumidifier Baseline Capacities and Efficiencies

Capacity at 80 °F 

(pints/day)

Capacity at 65 °F*

(pints/day)

IEF at 80 °F

(L/kWh)

IEF at 65 °F*

(L/kWh)

35.00 or less 20.00 or less 1.05 0.77

35.01–45.00 20.01 – 30.00 1.16 0.80

45.01–54.00 30.01 – 35.00 1.29 0.94

54.01–75.00 35.01 – 45.00 1.35 1.00

75.01 or more 45.01 or more 2.44 2.07

* Capacity and IEF used for the preliminary analysis beyond the engineering analysis

As shown in Table 5.3.1.2, the baseline IEF values at 80 °F for the product classes up to 

75.00 pints/day are on average approximately 20 percent lower than the baseline EF values due 

to the additional standby mode, off mode, and fan-only mode energy consumption. Because units 

with a fan-only mode have a lower IEF than those without fan-only mode, DOE proposes the 

baseline IEF based on units with fan-only mode. DOE observed that the impacts of adding 

standby mode or off mode energy consumption were within the rounding error of the overall IEF 

value for portable units with a fan-only mode, so the entire decrease from EF to IEF is 

attributable to fan-only mode energy consumption. DOE did not observe fan-only mode for 

products in the 75.01 pints/day (as measured at 80 °F) or more product class, so the baseline IEF 

values for that product class adjust the current baseline EF using the maximum standby mode

and off mode power observed for that product class in DOE’s test sample.

As discussed in section 5.2, DOE considered units that ship with ducting collars and are

intended by manufacturers for ducted operation to be classified separately as whole-home 

dehumidifiers. DOE further separated this product type into two product classes based on case 

size. As part of the May 2014 Test Procedure NOPR, DOE proposed a representative and 

repeatable method for testing these whole-home units with ducting installed. 79 FR 29272, 

29283–89 (May 21, 2014). DOE found that ducting generally decreases capacity and efficiency 

of these units when compared with the unducted test setup in Appendix X. In determining 

appropriate baseline levels for the whole-home product classes, DOE considered the effects of 

the ducted installation as proposed in the May 2014 Test Procedure NOPR in addition to the 

other changes associated with IEF discussed above. Table 5.3.1.3 presents the proposed baseline 

levels for the two whole-home product classes at 80 °F and 65 °F.

Table 5.3.1.3 Whole-Home Dehumidifier Baseline Efficiencies

Product Class 

(Case Volume)

IEF at 80 °F

(L/kWh)

IEF at 65 °F*

(L/kWh)

Less than or 

equal to 8.0 ft3 1.90 1.10

Greater than 8.0

ft3 2.50 1.68

* IEF used for the preliminary analysis beyond the engineering analysis
5-7

DOE observes that the impact of the reduced ambient temperature on IEF is greater for 

whole-home dehumidifiers than for portable units. IEF decreased by 33 percent for whole-home 

dehumidifiers greater than 8.0 ft3 and decreased by 42 percent for whole-home units less than or 

equal to 8.0 ft3.

5.3.2 Incremental Efficiency Levels

5.3.2.1 Portable Dehumidifier Product Classes

DOE analyzed several efficiency levels for portable dehumidifiers, and obtained 

incremental cost data at each of these levels. DOE first identified potential IEF levels based on 

the integration of standby mode, off mode, and fan-only energy use into current EF levels based 

on the existing test procedure. Table 5.3.2.1 includes the analyzed efficiency levels based on the 

80 °F ambient condition and the reference source of each level for the portable product classes.

Table 5.3.2.1 Portable Dehumidifier Efficiency Levels at 80 °F

Efficiency

Level Efficiency Level Source

Integrated Energy Factor Efficiency Levels (L/kWh)

35.00 

pints/day 

or less**

35.01–

45.00 

pints/day

45.01–

54.00 

pints/day

54.01–

75.00 

pints/day

75.01 

pints/day 

or more

Baseline Baseline 1.05 1.16 1.29 1.35 2.44

1

Baseline with no Fan-only 

Mode (ENERGY STAR* for 

75.01 pints/day or more)

1.50 1.50 1.60 1.70 2.80

2

ENERGY STAR (Gap Fill 

for 35.00 or less, 35.01–

45.00 pints/day, and 75.01 

pints/day or more)

1.70 1.70 1.85 1.85 3.50

3

Gap Fill (ENERGY STAR 

for 35.00 or less, and 35.01–

45.00 pints/day, Maximum 

Available for 75.01 pints/day 

or more)

1.85 1.85 1.95 1.95 4.2

4 Maximum Available 1.93 1.93 2.06 2.06 N/A

* ENERGY STAR qualification criteria effective October 1, 2012, require all dehumidifiers less than 75 pints per 

day to have an EF of at least 1.85 L/kWh. Units with 75.01 –185 pints/day capacity must have an EF of at least 2.80 

L/kWh, while dehumidifiers with a capacity greater than 185 pints/day are excluded.

** Although the DOE standard is 1.40 for dehumidifiers of 35.00 pints/day or less, a baseline efficiency level of 

1.50 is used based units available on the market and similarity to the 35.01 – 45.00 pints/day product class.
5-8

For the product classes with up to 75 pints/day capacity at 80 °F, DOE analyzed four 

incrementally more efficient levels beyond the baseline. The first level above the baseline for 

capacities up to 75.00 pints/day assumes a modification in the control scheme to remove fanonly mode. DOE observed test units in all product classes that operated with no fan-only mode. 

These units cycled off the fan along with the compressor when the humidity control setpoint was 

met. DOE observed that the two lowest capacity product classes achieved the same baseline IEF 

performance without fan-only mode; therefore, Efficiency Level (EL) 1 was set at 1.50 for both 

of these product classes. The baseline units without fan-only mode for the higher capacity 

product classes had higher IEF’s, as required by the current DOE Standards. EL 1 for these 

product classes reflects these higher efficiencies.

DOE considered the current ENERGY STAR levels as one of the higher efficiency levels 

for each product class. For the two lowest capacity product classes, the ENERGY STAR 

qualification level represents a large jump in efficiency from the baseline without fan-only mode, 

so DOE used a gap-fill level for EL 2 and used the ENERGY STAR qualification level as EL 3. 

For the three higher capacity product classes, the ENERGY STAR level represents EL 2. DOE 

considered a gap-fill as EL 3 for these product classes before the maximum available at EL 4.

EL 4 is based on the maximum efficiency that is currently commercially available (which 

DOE used as a proxy for the maximum technologically feasible level) as determined from data 

contained within the California Energy Commission (CEC), DOE Compliance Certification 

Management System (CCMS), and ENERGY STAR product databases.

Table 5.3.2.2 shows the adjusted capacity ranges and efficiency levels for each portable 

dehumidifier product class under the proposed 65 °F test condition. The adjusted IEF values 

reflect the average decreases in IEF that DOE observed for each product class during testing.
5-9

Table 5.3.2.2 Proposed Portable Dehumidifier Efficiency Levels for the Preliminary 

Analysis

Efficiency

Level Efficiency Level Source

Integrated Energy Factor Efficiency Levels (L/kWh)

20.00 

pints/day 

or less

20.01–

30.00 

pints/day

30.01–

35.00 

pints/day

35.01–

45.00 

pints/day

45.01 

pints/day 

or more

Baseline DOE Standard with Fanonly Mode 0.77 0.80 0.94 1.00 2.07

1 DOE Standard with no 

Fan-only Mode 1.10 1.10 1.20 1.30 2.40

2 Gap Fill 1* 1.20 1.20 1.40 1.40 2.80

3 Gap Fill 2 1.30 1.30 1.60 1.60 3.52

4 Maximum Available 1.42 1.52 1.75 1.75 N/A

* At the 65 °F test condition, there was little correlation to performance at the 80 °F test. Therefore, instead of using 

an efficiency level at the ENERGY STAR qualification criteria, DOE identified two gap fill levels between the 

equivalent DOE standards performance level and the maximum available.

5.3.2.2 Whole-Home Dehumidifier Product Classes

DOE analyzed several efficiency levels for whole-home dehumidifiers, and obtained 

incremental cost data at each of these levels. To determine efficiency levels for these ducted 

products, DOE investigated whole-home dehumidifiers according to the test setup proposed in 

the May 2014 Test Procedure NOPR, which includes a ducted test configuration. 79 FR 29272, 

29283–89 (May 21, 2014). The additional ducting and static pressure drop across the unit 

generally reduce the efficiency and capacity when compared with the results from an unducted 

test setup. The efficiency levels that DOE selected for the preliminary analysis are based on the 

range of efficiencies observed during testing according to the May 2014 Test Procedure NOPR 

provisions. Table 5.3.2.3 includes the analyzed efficiency levels based on the 80 °F test 

condition and the reference source of each level for the two whole-home product classes.
5-10

Table 5.3.2.3 Whole-Home Dehumidifier Efficiency Levels at 80 °F

Level Efficiency Level Source

Integrated Energy Factor Efficiency Levels 

(L/kWh)

Less than or equal 

to 8.0 ft3 (Case 

Volume)

Greater than 8.0 ft3

(Case Volume)

Baseline Minimum Available 1.90 2.50

1 Gap Fill 1 2.20 2.80

2 Gap Fill 2/Maximum 

Available 2.50 3.50

3 Maximum Available N/A 4.20

As with the portable product classes, DOE also determined appropriate efficiency levels 

at the 65 °F test condition. Table 5.3.2.4 includes the reduced efficiency levels at 65 °F based on 

testing, which DOE used for the preliminary analysis.

Table 5.3.2.4 Proposed Whole-Home Dehumidifier Efficiency Levels for the Preliminary 

Analysis

Efficiency 

Level Efficiency Level Source

Integrated Energy Factor Efficiency Levels 

(L/kWh)

Less than or equal 

to 8.0 ft3 (Case 

Volume)

Greater than 8.0 ft3

(Case Volume)

Baseline Minimum Available 1.10 1.68

1 Gap Fill 1 1.40 1.90

2 Gap Fill 2/Maximum 

Available 1.59 2.80

3 Maximum Available N/A 3.41

5.4 METHODOLOGY OVERVIEW

As discussed in Section 5.1, DOE typically follows one of three methodologies to 

perform the engineering analysis. In this case, DOE followed a hybrid approach that combined 

all three methodologies. DOE primarily followed the reverse engineering or cost-assessment 
5-11

approach with occasional input from the other two approaches, efficiency-level and designoption, where necessary. The reverse engineering approach established detailed manufacturer 

cost estimates for units in the teardown sample. For units at different efficiency levels, DOE 

assumed the differences in manufacturing costs were associated with the changes in efficiency, 

similar to the efficiency-level approach. However, the units in DOE’s sample did not cover the 

range of capacities and efficiency levels analyzed. To cover these gaps, DOE relied on the 

design-option approach by adding certain design features to the units torn down, and accounting 

for the associated changes in efficiency, capacity, and cost.

DOE relied on multiple sources of information for this engineering analysis. These 

sources include a review of TSDs from previous rulemakings, manufacturer interviews, internal 

product testing, and product teardowns.

5.4.1 Review of Previous Technical Support Documents and Models

DOE reviewed previous rulemaking TSDs to assess their applicability to the current 

standard setting process for residential dehumidifiers. These previous rulemaking TSDs served 

as a source for design options and energy consumption analysis, in addition to other sources. For 

dehumidifiers, the previous rulemaking TSD was developed in support of an advance notice of 

proposed rulemaking (ANOPR) published in 2007. 72 FR 64432 (Nov. 15, 2007).

5.4.2 Manufacturer Interviews

DOE understands that there is variability among manufacturers in baseline units, design 

strategies, and cost structures. To better understand and explain these variances, DOE conducted

manufacturer interviews. These confidential interviews provided a deeper understanding of the 

various combinations of technologies used to increase residential dehumidifier efficiency, and 

their associated manufacturing costs. Sample questions for the engineering analysis that were 

initially submitted to AHAM in advance of DOE’s interviews are contained in appendix 5A of 

this preliminary TSD. This questionnaire was subsequently updated to reflect the introduction of 

dehumidifier models meeting the October 2012 energy conservation standards, and was included 

as part of the interviews conducted in support of the preliminary analysis. Sample questions from 

the preliminary analysis interviews are contained in appendix 12A of this preliminary TSD.

During the interviews, DOE also gathered information about the capital expenditures 

required to increase the efficiency of the baseline units to various efficiency levels (i.e., 

conversion capital expenditures by efficiency or energy-use level). The interviews provided 

information about the size and the nature of the capital investments. DOE also requested 

information about the depreciation method used to expense the conversion capital. The 

preliminary manufacturer impact analysis in chapter 12 of the preliminary TSD includes a 

discussion of this information obtained during manufacturer interviews.
5-12

5.4.3 Product Testing

Much of the analysis in this chapter incorporates data from publicly available sources 

such as the CEC, DOE CCMS, and ENERGY STAR databases. However, DOE also conducted 

its own investigative testing according to the current and proposed DOE test procedures for the 

following purposes:

• Verify performance trends that are apparent in the publicly available data;

• Develop a better understanding of the design options and product features 

currently available on the market; 

• Investigate ducted performance for whole-home dehumidifiers; and

• Develop a better understanding of the operational characteristics of residential 

dehumidifiers.

5.4.4 Product Teardowns

Other than obtaining detailed manufacturing costs directly from a manufacturer, the most 

accurate method for determining the production cost of a product is to disassemble representative

units piece-by-piece and estimate the material, labor, and overhead costs associated with each 

component using a process commonly called a physical teardown. A supplementary method, 

called a catalog teardown, uses published manufacturer catalogs and supplementary component 

data to estimate the major physical differences between a product that has been physically 

disassembled and another similar product. DOE performed physical teardown analysis on 

dehumidifiers in all product classes. The teardown methodology is explained in the following 

sections.

5.4.4.1 Selection of Units

DOE generally adopts the following criteria for selecting units for teardown analysis:

• The selected products should span the full range of efficiency levels for each product class 

under consideration;

• Within each product class, the selected products should, if possible, come from the same 

manufacturer and belong to the same product platform;

• The selected products should, if possible, come from manufacturers with large market shares

in that product class, although the highest efficiency products are chosen irrespective of 

manufacturer; and

• The selected products should have non-efficiency-related features that are the same as, or 

similar to, features of other products in the same class and at the same efficiency level.
5-13

5.4.4.2 Generation of Bill of Materials

The end result of each teardown is a structured BOM, which describes each product part

and its relationship to the other parts, in the estimated order of assembly. The BOMs describe 

each fabrication and assembly operation in detail, including the type of value—added equipment 

needed (e.g., stamping presses, injection molding machines, spot-welders, etc.) and the estimated

cycle times associated with each conversion step. The result is a thorough and explicit model of 

the production process.

Materials in the BOM are divided between raw materials that require conversion steps to 

be made ready for assembly, while purchased parts are typically delivered ready for installation.

The classification into raw materials or purchased parts is based on DOE’s previous industry 

experience, recent information in trade publications, and discussions with original equipment 

manufacturers (OEMs). For purchased parts, the purchase price is based on volume-variable 

price quotations and detailed discussions with suppliers.

For parts fabricated in-house, the prices of the underlying “raw” metals (e.g., tube, sheet 

metal) are estimated on the basis of 5-year averages to smooth out spikes in demand. Other 

“raw” materials such as plastic resins, insulation materials, etc. are estimated on a current-market 

basis. The costs of raw materials are based on manufacturer interviews, quotes from suppliers, 

secondary research, and by subscriptions to publications including the American Metals Marketc

(AMM). Past price quotes are indexed using applicable Bureau of Labor Statistics producer price 

index tables as well as AMM monthly data. 

5.4.4.3 Cost Structure of the Spreadsheet Models

The manufacturing cost assessment methodology used is a detailed, component-focused 

technique for rigorously calculating the manufacturing cost of a product (direct materials, direct 

labor and some overhead costs). Figure 5.4.4.1 shows the three major steps in generating the 

manufacturing cost.

Figure 5.4.4.1 Manufacturing Cost Assessment Stages

The first step in the manufacturing cost assessment was the creation of a complete and 

structured BOM from the disassembly of the units selected for teardown. The units were 

 

c For information on American Metals Market, please visit: http://www.amm.com.
5-14

dismantled, and each part was characterized according to weight, manufacturing processes used, 

dimensions, material, and quantity. The BOM incorporates all materials, components, and 

fasteners with estimates of raw material costs and purchased part costs. Assumptions on the 

sourcing of parts and in-house fabrication were based on industry experience, information in 

trade publications, and discussions with manufacturers. Interviews and plant visits were 

conducted with manufacturers to ensure accuracy on methodology and pricing.

Following the development of a detailed BOM, the major manufacturing processes were

identified and developed for the spreadsheet model. Some of these processes are listed in Table 

5.4.4.1.

Table 5.4.4.1 Major Manufacturing Processes

Fabrication Finishing Assembly/Joining Quality Control

Fixturing

Stamping/Pressing

Brake Forming

Cutting and Shearing

Insulating

Turret Punch

Tube Forming

Enameling

Washing

Powder Coating

De-burring

Polishing

Refrigerant Charging

Adhesive Bonding

Spot Welding

Seam Welding

Packaging

Inspecting & Testing

Fabrication process cycle times for each part made in-house were estimated and entered 

into the BOM. Based on estimated assembly and fabrication time requirements, the labor content 

of each appliance could be estimated. For this analysis, DOE estimated labor costs based on 

typical annual wages and benefits of industry employees.

Cycle requirements for fabrication steps were similarly aggregated by fabrication 

machine type while accounting for dedicated vs. non-dedicated machinery and/or change-over 

times (die swaps in a press, for example). Once the cost estimate for each teardown unit was 

finalized, a detailed summary was prepared for relevant components, subassemblies and 

processes. The BOM thus details all aspects of unit costs: material, labor, and overhead. 

Design options used in units subject to teardown are noted in the summary sheet of each 

cost model and are cost-estimated individually. Thus, various implementations of design options 

can be accommodated, ranging from assemblies that are entirely purchased to units that are made 

entirely from raw materials. Hybrid assemblies, consisting of purchased parts and parts made on 

site are thus also accommodated.

5.4.4.4 Cost Model and Definitions

The cost model is based on production activities and divides factory costs into the 

following categories:

• Materials: Purchased parts (i.e., motors, valves, etc.), raw materials, (i.e., cold rolled 

steel, copper tube, etc.), and indirect materials that are used for processing and 

fabrication.
5-15

• Labor: Fabrication, assembly, indirect, and supervisor labor. Fabrication and assembly 

labor cost are burdened with benefits and supervisory costs.

• Overhead: Equipment, tooling, and building depreciation, as well as utilities, equipment 

and tooling maintenance, insurance, and property taxes.

Cost Definitions

Because there are many different accounting systems and methods to monitor costs, DOE 

defined the above terms as follows:

• Direct material: Purchased parts (out-sourced) plus manufactured parts (made in-house 

from raw materials).

• Indirect material: Material used during manufacturing (e.g., welding rods, adhesives).

• Fabrication labor: Labor associated with in-house piece manufacturing.

• Assembly labor: Labor associated with final assembly.

• Supervisory labor: Labor associated with fabrication and assembly basis. Assigned on a 

span basis (x number of employees per supervisor) that depends on the industry.

• Indirect labor: Labor costs that scale with fabrication and assembly labor. These included 

the cost of technicians, manufacturing engineering support, stocking, etc. that are 

proportional to all other labor. 

• Equipment depreciation: Money allocated to pay for initial equipment installation and 

replacement as the production equipment is amortized. All depreciation is assigned in a 

linear fashion and affected equipment life depends on the type of equipment.

• Tooling depreciation: Cost for initial tooling (including non-recurring engineering and 

debugging of the tools) and tooling replacement as it wears out or is rendered obsolete.

• Building depreciation: Money allocated to pay for the building space and the conveyors 

that feed and/or make up the assembly line.

• Utilities: Electricity, gas, telephones, etc.

• Maintenance: Annual money spent on maintaining tooling and equipment.

• Insurance: Appropriated as a function of unit cost.

• Property Tax: Appropriated as a function of unit cost.

5.4.4.5 Cost Model Assumptions

As discussed in the previous section, assumptions about manufacturer practices and cost 

structure played an important role in estimating the final product cost. In converting physical 

information about the product into cost information, DOE reconstructed manufacturing processes 

for each component using internal expertise and knowledge of the methods used by the industry.

Site visits allowed DOE to confirm its cost model assumptions through direct observation of the 

manufacturing plant, as well as through manufacturer interviews, reviews of current Bureau of 

Labor Statistics data, etc.
5-16

5.5 ANALYSIS AND RESULTS

5.5.1 Manufacturer Interviews

DOE conducted interviews with residential dehumidifier manufacturers to develop a 

better understanding of current product features and the technologies used to improve energy 

efficiency. The manufacturers interviewed represent a wide range of U.S. market share and 

included both domestic and international companies that sell residential portable and wholehome dehumidifiers in the United States. During these interviews, DOE asked manufacturers 

questions about the following topics related to the engineering analysis:

• Product classes

• Design features of current baseline products

• Proposed incremental efficiency levels

• Design options required to meet each efficiency level

• Performance at reduced ambient temperatures

• Impacts on consumer utility

• Installation and repair costs as a function of efficiency

The discussion helped DOE understand what proposed design options have already been 

implemented and what additional design options DOE should consider. 

The discussion below represents a consolidation of the manufacturer responses.

5.5.1.1 Product Classes

DOE asked manufacturers if the current product class divisions are appropriate. 

Manufacturers suggested various alternate product classes, none of which were consistent with 

the current product classes. The general response was that the current product classes are too 

granular, leading manufacturers to produce various models with different capacities yet identical 

efficiency ratings. Additionally, products with capacities near the end of the range of a product 

class are required to meet different minimum efficiency levels than similar units with slightly 

different capacities that would be classified in the adjacent product class. These products 

typically feature similar constructions and design features despite falling into separate product 

classes, so the units required to meet the higher minimum efficiency level may be penalized.

Manufacturers indicated that product classes should not only reflect overall performance but also 

include design option restrictions for case volume and installation location.

5.5.1.2 Design Features of Current Baseline Products

DOE discussed with manufacturers the features of baseline products identified during the 

reverse-engineering analysis. The manufacturers generally agreed with DOE’s assumptions for a 

baseline unit, discussed in section 5.5.3.1 although not all manufacturers produce products at the 

baseline efficiency level. Manufacturers indicated that baseline dehumidifiers typically include 
5-17

the same components as units at higher efficiencies, perhaps with smaller heat exchangers or less 

efficient compressors.

5.5.1.3 Proposed Incremental Efficiency Levels

DOE asked manufacturers to comment on the proposed efficiency levels for the portable 

and whole-home product classes. Manufacturers were asked to comment on the appropriateness 

of each incremental efficiency level, including the gap-fill levels and the max-tech levels. In 

general, manufacturers did not object to the efficiency levels DOE selected for analysis; 

however, there was some concern that certain larger increments in efficiency between levels 

could be difficult to achieve. Also, some manufacturers were concerned about meeting the 

maximum IEF levels with current materials and components. They suggested that higher 

efficiency products are currently being investigated, but the necessary changes are not 

completely understood at this time. 

5.5.1.4 Design Options Required to Meet Each Efficiency Level

DOE asked manufacturers to describe the changes associated with each active mode 

efficiency level relative to the baseline units in each product class. From the reverse-engineering 

analysis, DOE predicted the key design options would be increased compressor efficiency and 

heat exchanger sizes. DOE highlighted these options during discussions with manufacturers to 

determine the necessary design options to meet incrementally increased IEF levels. 

Manufacturers generally agreed with DOE’s initial association of design options with the 

efficiency levels. They confirmed that the primary changes required to meet higher efficiency 

levels will likely be more efficient compressors and optimized heat exchangers. Manufacturers

stressed that making these changes would, for certain existing products, require a shift to larger 

cases and therefore would increase the manufacturing costs and also require investments to 

update the manufacturing facilities. These added costs would be passed down to the consumer, 

which could impact low-income consumers.

5.5.1.5 Performance at Reduced Ambient Temperatures

DOE asked manufacturers if the current 80 °F ambient dry-bulb temperature required in 

Appendix X is appropriate for dehumidifier testing. Manufacturers generally agreed that the 

current test conditions specify a higher dry-bulb temperature than those typically seen in the 

field; however, they did not provide additional consumer usage data to indicate a more 

appropriate test condition. Based on experience, manufacturers indicated that an ambient

temperature in the range of 65 °F to 70 °F may be more appropriate than the current test 

condition. In addition to suggesting that the test procedure should be conducted at a lower 

ambient temperature, manufacturers further indicated that they test their units at even lower 

ambient temperatures to ensure they will operate acceptably in low-temperature consumer 

installations. 
5-18

5.5.1.6 Impact on Consumer Utility

DOE asked manufacturers how these design option changes may impact consumer utility. 

Manufacturers indicated that overall performance would not be impacted; however, larger fans 

may increase the fan operating noise, and larger components and cases would increase the 

overall unit weight.

5.5.1.7 Installation and Repair Costs as a Function of Efficiency

Manufacturers generally indicated that typical product lifetime was the same for all 

dehumidifiers regardless of efficiency and component size. They also stated that repair and 

maintenance costs would not significantly change with improvements in efficiency.

5.5.2 Product Testing

DOE conducted extensive testing on dehumidifiers in each product class, including 

refrigerant-based and refrigerant-desiccant whole-home dehumidifiers. These units were tested 

under varying conditions and test setups to investigate impacts on performance when compared 

to the current test procedure. DOE used the data obtained during testing to identify appropriate 

test conditions and setups as discussed in the May 2014 Test Procedure NOPR. For this 

engineering analysis, DOE used the data to determine appropriate product classes, efficiency 

levels, and the design changes necessary to achieve those levels.

5.5.2.1 Product Selection

DOE tested a total of 24 portable units with rated capacities up to 75 pints/day, 13 largecapacity (i.e. portable dehumidifiers with rated capacities greater than 75 pints/day) and 

refrigerant-based whole-home units, and 2 refrigerant-desiccant whole-home dehumidifiers. The 

test units spanned the range of capacities and efficiencies available on the market from multiple

manufacturers. The testing consisted of a series of investigations using various subsets of units in 

the test sample. However, all units were at minimum tested according to the existing test 

procedure in Appendix X. The test results informed both the proposals presented in the May 

2014 Test Procedure NOPR and this preliminary engineering analysis.

5.5.2.2 Test Approach and Results

During testing, DOE investigated changes to dehumidifier performance under various 

operating conditions. To fully understand the dehumidifier operation at these different 

conditions, DOE gathered additional data compared to that required in Appendix X. The tests 

separately monitored the power consumption of the compressor and fan over the course of the 

tests. This component monitoring allowed DOE to easily observe modifications to the 

compressor or fan cycling in response to changes in test setup and/or test conditions. For the 

majority of testing, DOE also monitored the evaporator temperature to identify the points in 
5-19

operation at which condensate on the evaporator would freeze, which could impact 

dehumidification performance or require a defrost event.

In response to comments received regarding the inapplicability of the 80 °F test 

condition, DOE tested 20 of the 24 portable units with less than 75 pints/day rated capacity at 

reduced ambient temperatures. Figure 5.5.2.1 and Figure 5.5.2.2 present the test results for 

portable dehumidifiers at the 80 °F and 65 °F test conditions. The figures present the efficiency 

results in terms of EF to show the impact of the reduced temperature on active mode operation. 

DOE does not expect any effect on inactive mode, off mode, or fan-only mode performance due 

to the proposed lower ambient temperature.

Figure 5.5.2.1 Measured EF at 80 °F and 65 °F for Portable Dehumidifiers with Capacities 

Up to 75 pints/day at 80 °F

0.75

0.95

1.15

1.35

1.55

1.75

1.95

2.15

0 20 40 60 80

EF (L/kWh)

Product Capacity (pints/day)

80 F

65 F
5-20

Figure 5.5.2.2 Measured EF at 80 °F and 65 °F for Portable Dehumidifiers with Capacities 

Greater than 75 pints/day at 80 °F

As discussed above in Section 5.3, and shown in Figure 5.5.2.1 and Figure 5.5.2.2, DOE 

observed a decrease in both capacity and efficiency at the 65 °F test condition when compared to 

the 80 °F test condition. DOE conducted additional testing at 55 °F; however, the majority of 

units tested at this condition were unable to continuously operate the compressor, and initiated 

defrosts during the test period by operating the fan without the compressor to remove frost from 

the evaporator. DOE confirmed the change in cycling through compressor power monitoring and 

verified frosting by placing a thermocouple on an evaporator tube bend midway between the 

evaporator inlet and outlet. As discussed in the May 2014 Test Procedure NOPR, DOE expects 

that dehumidifiers typically operate in locations with ambient temperatures higher than 55 °F. 79 

FR 29272, 29277–79 (May 21, 2014).

As also described in the May 2014 Test Procedure NOPR, DOE developed a proposed 

ducted test setup for whole-home dehumidifiers. 79 FR 29272, 29283–89 (May 21, 2014). 

DOE’s investigative testing monitored air flow, dry-bulb and wet-bulb temperatures, and 

pressure at multiple locations in the test ducting. Tests were conducted at various external static 

pressures and temperatures to determine the associated impacts on capacity and efficiency. 

Figure 5.5.2.3 shows the test results for the whole-home dehumidifiers tested at both 80 °F and 

65 °F according to the ducted setup proposed in the May 2014 Test Procedure NOPR. As 

observed with the portable units, both capacity and EF are reduced at lower ambient 

temperatures.

1.5

2

2.5

3

3.5

4

4.5

0 50 100 150 200

EF (L/kWh)

Product Capacity (pints/day)

80 F

65 F
5-21

Figure 5.5.2.3 Measured EF at 80 °F and 65 °F for Whole-Home Dehumidifiers

As discussed in the following sections, DOE utilized test data when conducting 

teardowns and modeling to correlate efficiency gains with certain design features or components 

included in the units in the test sample. In particular, the testing informed the appropriate 

capacity and efficiency effects of the design features at the lower ambient temperatures, since 

there is limited publicly available information regarding dehumidifier operation at these

temperatures.

5.5.3 Product Teardowns

After conducting the investigative testing described in the previous section, DOE 

conducted teardowns on 32 out of its 39 test units, including both portable and whole-home 

products. The test units spanned the range of product efficiencies and features available on the 

market from multiple manufacturers. DOE relied on the dehumidifier teardowns to supplement 

the information gained through manufacturer interviews and to investigate performance observed 

during testing. Specifically, the teardowns allowed DOE to identify design features for 

improving efficiency and to develop corresponding manufacturing costs for products at different 

efficiency levels. 

5.5.3.1 Baseline Construction

DOE observed that the baseline portable dehumidifiers in the teardown sample for the 

product classes with capacities up to 75.00 pints/day at 80 °F, equivalent to 45.00 pints/day at 65 

°F, had similar constructions. All of the units were housed in a plastic case with a removable 

bucket. They featured rotary R-410A compressors at the base of the unit, with the evaporator and 

condenser housed in the top of the unit along with the fan and air filter. DOE observed that the 

0.5

1

1.5

2

2.5

3

3.5

0 50 100 150 200 250

EF (L/kWh)

Product Capacity (pints/day)

80 F

65 F
5-22

blowers all used permanent split capacitor (PSC) motors. The evaporator and condenser within a 

unit were similar in construction, with similar dimensions and number of tube passes, and they 

were connected via capillary tubes. The copper tubing exiting the evaporator and entering the 

compressor was typically insulated, though the thickness and length of insulation varied among 

units. All of the units in DOE’s sample for these lower-capacity portable product classes featured 

electronic controls, although DOE is aware that certain units may still use electromechanical 

controls.

For the high-capacity portable dehumidifier product class and both whole-home 

dehumidifier product classes, the baseline product shifted to a different design, but still contained 

most of the same general components. As expected for these product classes, the internal 

components related to the product capacity were noticeably larger than for the other portable 

product classes. In particular, these units used higher capacity compressors, larger heat 

exchangers, and more powerful blowers. One key difference when compared to the other 

portable product classes is the elimination of the internal condensate collection bucket. All of the 

high-capacity units in DOE’s teardown sample were designed to be connected to a drain. Also, 

the units in these product classes featured metal cases with more insulation than the plastic cases 

for the other portable dehumidifier product classes.

DOE observed that manufacturers that produce high-capacity portable units also typically 

produce whole-home dehumidifiers. For products from the same manufacturer in the same 

capacity range, DOE observed that the high-capacity portable and whole-home products 

contained almost identical internal components. The only major differences between these 

products were the ducting attachments for whole-home units (and lack of ducting attachments for 

portable units) and the differences in controls. Whole-home products are typically controlled via 

a remote humidistat with no on-board user controls, while the portable products are controlled 

through the user interface on the unit. High-capacity portable products typically used 

electromechanical controls, unlike lower-capacity portables units, most likely due to simplicity, 

high reliability, and minimal expected consumer interaction.

5.5.3.2 Design Options to Reach Higher Efficiency Levels

In chapter 3 of this preliminary TSD, DOE identified technology options that could 

potentially improve the efficiency of dehumidifiers. As discussed in chapter 4 of this preliminary

TSD, certain of these technology options were eliminated from further consideration in the 

engineering analysis. DOE considered the technology options meeting all of the screening 

criteria in this engineering analysis, although not all of these design options factored into the 

final estimated incremental costs. This section explains how DOE addressed each of the 

technology options that were not screened out.

Retained Design Options to Meet Higher Efficiency Levels

Based on testing, manufacturer interviews, and product teardowns, DOE identified the 

following key design changes to reach higher efficiency levels: improved compressor efficiency, 
5-23

improved evaporator and condenser performance (i.e., larger heat exchangers), and pre-cooling 

air-to-air heat exchangers. 

Improved compressor efficiency

Improved compressor efficiency is one of the primary ways dehumidifiers can achieve 

higher efficiencies. The compressor typically represents 80 to 90 percent of a dehumidifier’s 

energy consumption, so small improvements in compressor efficiency translate directly to 

measurable improvements in IEF. DOE is aware that rotary R-410A compressors are available

with a range of efficiencies, and manufacturers will likely move to a more efficient compressor 

to achieve higher IEFs.

In chapter 3 of the preliminary TSD, DOE also identified inertia-reciprocating, scroll, and 

variable speed compressors to further increase efficiency beyond traditional rotary compressors. 

DOE notes that inertia-reciprocating and scroll compressors are substantially larger, heavier, and 

noisier than rotary compressors, and therefore are not suited for residential dehumidifiers. 

Variable-speed compressors present an opportunity for a dehumidifier to adjust the compressor 

and refrigeration system operation to varying conditions. However, because the DOE test 

procedure is conducted at constant ambient conditions with continuous operation, it would not 

capture efficiency gains associated with variable-speed compressors. Therefore, DOE did not 

consider inertia-reciprocating, scroll, or variable-speed compressors in the remainder of its 

analysis.

Improved condenser and evaporator performance 

DOE also observed that manufacturers may use larger heat exchangers at the higher 

efficiency levels. Compressor efficiencies can only improve a dehumidifier’s performance to a 

certain extent for a given refrigeration system. Larger heat exchangers can help to further 

improve the performance of the refrigeration system by more effectively converting the work 

performed by the compressor into heat transfer. As more heat is absorbed in the evaporator and 

rejected via the condenser, the refrigerant cycle operates more efficiently and less compressor 

power is required to achieve a similar capacity.

As discussed in chapter 3 of this preliminary TSD, many parameters affect a heat 

exchanger’s performance. Based on manufacturer interviews and product teardowns, DOE found 

that manufacturers may adjust the cross-sectional area of the heat exchangers to increase heat 

transfer. DOE observed that the condenser and evaporator in all of its teardown units had similar 

construction, but the cross-sectional area was the key parameter that changed from unit to unit. 

In its analysis, DOE assumed that manufacturers would rely on increased heat exchanger sizes to 

improve condenser and evaporator performance.

Pre-cooling air-to-air heat exchanger

Pre-cooling air-to-air heat exchangers further increase the efficiency of whole-home and 

high-capacity portable dehumidifiers. By cooling the inlet air stream using the low-temperature 

air exiting the evaporator, the air-to-air heat exchanger decreases the amount of sensible heat the 

evaporator must remove from the air stream before condensation occurs. Because the heat 
5-24

exchanger uses evaporator outlet air to cool the inlet airstream, the air entering the condenser is a 

higher temperature. The result is a slightly higher temperature exhaust air off of the condenser, 

but overall improved dehumidifier energy efficiency.

DOE considered pre-cooling air-to-air heat exchangers as a design option for the wholehome and high-capacity portable dehumidifier product classes, but screened out this technology 

option for the smaller-capacity portable dehumidifier product classes for the reasons described in 

chapter 4 of this preliminary TSD.

Design Options Not Used to Meet Higher Efficiency Levels

DOE observed that manufacturers typically implement the design options discussed 

above to improve dehumidifier efficiency. Additionally, while many of the technology options 

identified in chapter 3 of this preliminary TSD may produce energy savings in certain real-world 

situations, DOE did not further consider them in this analysis because the DOE test procedure 

would not capture those potential improvements. DOE considered the following design options 

in this engineering analysis, but does not expect manufacturers to rely on these features to meet 

higher efficiency levels.

Built-in hygrometer/humidistat

All portable dehumidifiers in DOE’s teardown sample featured a built-in humidity 

controller. These units all included electronic controls, but DOE is aware that certain units may 

still feature electromechanical humidistats. The humidistat cycles the compressor and fan power 

supply as a function of relative humidity. Both electronic and electromechanical controllers 

measure the expansion of a reference material as a function of relative humidity. DOE notes that 

whole-home dehumidifiers are often designed to be used in conjunction with a remote 

humidistat. The humidistat is placed in the portion of the home that requires dehumidification, 

and cycles the whole-home dehumidifier compressor and fan power supply as needed. Although 

this control is external to the unit, DOE does not expect significant differences in efficiency or 

operation when compared to the built-in controls on portable units.

While electronic humidistats may provide more flexible control in cycling the 

refrigeration system as-needed in varying conditions, DOE does not expect the type or presence 

of a hygrometer or humidistat to affect dehumidifier efficiency. The DOE test procedure requires 

continuous unit operation at constant ambient conditions, and therefore does not reflect 

performance of the humidity sensor. Because DOE does not expect the type of humidity 

controller to result in efficiency gains, and because the test procedure would not capture any 

efficiency improvements, DOE did not further consider changes to the hygrometer or humidistat 

in this preliminary analysis.

Improved controls

Similar to the built-in hygrometer/humidistat discussed above, improved controls may 

allow dehumidifiers to better adjust their operation in response to changing conditions. Improved 

controllers may consider multiple inputs, such as ambient temperature, ambient humidity, and 

evaporator temperature, when adjusting unit operation. Because the DOE test procedure requires 
5-25

continuous unit operation at constant ambient conditions, it therefore would not reflect improved 

control schemes and DOE did not further consider improved controls in this preliminary 

analysis.

Improved defrost methods

In chapter 3 of this preliminary TSD, DOE identified four defrost types: passive, fanonly, electric, and hot-gas. DOE is not aware of any units on the market that feature an electric or 

hot-gas defrost, although there are no technical limitations that would preclude these in 

dehumidifiers. DOE also did not observe passive defrost in its testing. DOE observed that units 

typically use a fan-only defrost when necessary.

The current DOE test procedure does not test at ambient conditions where defrost cycles 

are likely to occur. However, DOE did observe that some units in the test sample entered fanonly mode when tested at the 65 °F ambient temperature proposed in the May 2014 Test 

Procedure NOPR. While improved defrost methods could improve energy consumption in these 

units when tested at 65 °F ambient temperature, DOE expects that manufacturers would likely 

adjust the unit controls or refrigeration system operation to avoid triggering a defrost at these 

reduced ambient temperatures rather than improving the defrost. DOE did not observe different 

design features between the units that did or did not defrost at the reduced ambient temperature, 

so the difference in operation is likely due to different control schemes or refrigeration system 

operating parameters. Because manufacturers would likely adjust their units to avoid defrosts 

when operating at 65 °F ambient temperature, DOE did not further consider different defrost 

methods in determining how manufacturers may achieve higher efficiency levels.

Improved demand-defrost controls

Defrost controls determine when a defrost cycle is needed, and the duration of the defrost 

cycle. As described in chapter 3 of this preliminary TSD, time-based defrosts occur at regular 

intervals for constant duration as a unit operates. Sensor-controlled defrosts occur as needed 

based on evaporator coil temperatures. DOE observed that all units in the teardown sample 

featured temperature sensors on the evaporator coil, and therefore likely employ a sensorcontrolled defrost. DOE also observed that units did not enter a defrost cycle when tested at 80 

°F ambient temperature, some units defrosted at 65 °F, and nearly all units defrosted at 55 °F. 

This also suggests a sensor-based defrost.

Because DOE expects that units available on the market already feature sensor-based 

defrost control, and because DOE expects that the test procedure likely would not capture defrost 

cycles as described in the section above, DOE did further consider this feature in this preliminary 

analysis.

Improved fan and fan-motor efficiency

DOE is aware that efficiency gains may be possible through improvements to the fan and 

fan-motor. DOE noted that all units in its teardown sample used permanent split capacitor (PSC) 

PSC fan motors, which have improved efficiencies compared to shaded-pole motors. However, 

permanent-magnet motors would provide slightly higher motor efficiencies compared to PSC 
5-26

motors, but the overall improvements to IEF would be small due to the relatively small portion 

of energy consumed by the fan motor compared to the compressor. Manufacturers would also 

incur significant costs with employing permanent-magnet motors; the motors themselves cost 

over two times as much as a comparable PSC motor, and the different shape and weight of the 

motor may require product redesign. 

Manufacturer interviews and product teardowns also showed that there were no 

significant changes to the blowers and fan motors at different product efficiencies. For these 

reasons, DOE did not further consider improved fan and fan-motor efficiency in developing the 

cost-efficiency relationships. DOE notes that because it conducted a hybrid analysis, including 

the efficiency-level approach, changes in the fan and fan-motor between units in the teardown 

sample are reflected in DOE’s cost estimates. Improved fan and fan-motor efficiency was not 

considered as a design option for the portion of the analysis that relied on the design-option 

approach.

Improved flow-control devices

DOE observed that all units in the teardown sample used a wound capillary tube as the 

expansion device to control refrigerant flow to the evaporator, though the length and size of 

tubing varied. In chapter 3 of this preliminary TSD, DOE described how thermostatic expansion 

valves or electronic expansion valves would allow dehumidifiers to regulate refrigerant flow to 

the evaporator based on changes in operating conditions.

As discussed for previous design options, the DOE test procedure is performed under 

constant ambient conditions, and any benefit associated with a unit’s ability to adjust to varying 

ambient conditions would not captured in the test. Therefore, DOE did not further consider 

improved flow-control devices as a design option.

Low-standby-loss electronic controls

In its test and teardown sample, DOE observed that the presence of a fan-only mode had 

the most significant impact on the conversion from EF to IEF based on the calculations to 

incorporate low-power mode energy consumption as proposed in the May 2014 Test Procedure 

NOPR. 79 FR 29272, 29290–91 (May 21, 2014). For units without a fan-only mode, DOE 

observed that low-power mode energy consumption resulted in an average decrease from EF to 

IEF of 0.02 L/kWh. For all units in the test sample, the average inactive mode or off mode power 

consumption was 0.9 Watts (W).

DOE observed two types of power supplies in its teardown sample: linear and switchmode. Switch-mode power supplies typically require lower standby power compared to linear 

power supplies. In the test sample, DOE found an average off-mode power of 0.37 W for switchmode power supplies compared to 1.2 W for linear power supplies. In off-cycle mode, for units 

without fan-only mode, units with switch-mode power supplies required on average 1.14 W 

compared to 1.63 W for units with linear power supplies. DOE notes that based on these average 

power inputs, the effect of changing from a linear to a switch-mode power supply has very little 

impact on IEF. For example, the IEF of a baseline 50 pint/day unit with an EF of 1.6, at 80 °F 
5-27

ambient temperature, would be rounded to 1.59 with either a linear or switch-mode power 

supply.

DOE also observed a range of power inputs for each power supply type. While switchmode power supplies required less power on average than linear power supplies, DOE observed 

linear power supplies with off-mode and off-cycle mode power inputs as low as 0.51 W and 0.72 

W, respectively.

Because of the relatively small impact of standby mode and off mode energy 

consumption on IEF, and the range of power inputs associated with each power supply, DOE did 

not consider this a specific design option in its analysis. However, because DOE relied on a 

hybrid analysis approach, including the efficiency-level approach, DOE’s cost estimates reflect 

both power supply types based on the units torn down at each efficiency level and product class. 

DOE did not use low-standby controls as a design option in the design-option approach portion 

of the analysis because of the relatively large jumps in efficiency between the analyzed IEF 

levels. DOE tentatively concludes that manufacturers would rely on other changes, such as 

improved compressor efficiency and heat exchanger effectiveness, to achieve the higher 

efficiencies. 

Washable air filters

DOE found that all portable dehumidifiers in its test and teardown sample include a 

washable air filter. The manufacturer instructions suggest that the consumer periodically clean 

the filter to minimize particulate build up and ensure optimal performance. However, because all 

units use a washable air filter, DOE did not consider this as a design option to improve 

efficiency. 

Heat pipes

As discussed in chapter 4 of this preliminary TSD, DOE screened out heat pipes as 

design option for portable dehumidifiers with up to 75 pints/day capacity at 80 °F. The size and 

weight of added heat pipes would have less of an impact on consumer utility for portable units 

with more than 75 pints/day capacity at 80 °F and for whole-home dehumidifiers.

DOE was unable to find any residential dehumidifiers that use heat pipes to boost 

performance by pre-cooling the inlet evaporator air. DOE is aware that units existed on the 

market until 2010, at which point the manufacturer chose to discontinue the product line for 

reasons unknown to DOE. Although heat pipes have been incorporated in the past, DOE does not 

expect manufacturers to use this design option to achieve higher efficiencies because pre-cooling 

air-to-air heat exchangers accomplish the same function of pre-cooling the air entering the 

evaporator, likely with similar efficiency improvements. However, pre-cooling air-to-air heat 

exchangers lower the temperature of the incoming air using a simpler design. They do not 

require a heat transfer liquid, and can be made of less costly materials. Accordingly, the air-to-air 

heat exchangers are likely lower cost than equivalent heat pipes that accomplish the same 

function. Therefore, DOE did not further consider heat pipes in its analysis because it tentatively 
5-28

concludes that manufacturers of whole-home and higher-capacity portable dehumidifiers would 

likely use pre-cooling air-to-air heat exchangers in their place.

Improved refrigeration system insulation

Through teardowns, DOE observed that manufacturers typically include insulation on the 

refrigeration system. The most commonly insulated part of the system is the evaporator outlet 

and compressor inlet. However, DOE did not observe that the products at higher efficiency levels 

include different insulation types or quantities. Further, manufacturers did not indicate that 

higher efficiencies could be achieved with more insulation, although some manufacturers 

commented that insulating the product’s case typically helps the unit’s noise performance. 

Because DOE did not observe a relationship between product efficiency and refrigeration system 

insulation, it did not consider this as a design option when developing cost-efficiency curves.

However, because DOE used a hybrid approach for this analysis, the estimated costs for each 

product torn down reflect the type and quantity of insulation included in those products.

Refrigerant-desiccant systems

DOE is aware that refrigerant-desiccant systems may offer improved performance, 

particularly in low-temperature installations where defrosting may be a concern for refrigerantonly dehumidifiers. DOE investigated the potential improvements in efficiency and capacity 

from incorporating a desiccant wheel in a whole-home dehumidifier. Based on testing, DOE did 

not observe any efficiency or capacity improvement with incorporating a desiccant wheel. 

However, DOE notes that testing is conducted at ambient temperatures where defrosting is likely 

not a concern, so it may not reflect the improvements associated with a refrigerant-desiccant 

system at low temperatures. Because DOE did not observe higher efficiencies for refrigerantdesiccant units under representative ambient conditions, it did not further consider these units in 

this preliminary analysis.

5.5.4 Numerical Model

Although DOE tested and tore down a large sample of units from different manufacturers

at varying capacities and efficiencies, the sample did not cover the entire range capacities and 

efficiency levels that DOE is proposing to analyze for potential standards. To fill in gaps in the 

teardown sample, DOE used a numerical model to estimate unit performance at different 

efficiency levels and capacities.

5.5.4.1 Summary

To conduct the energy modeling, DOE used the MarkN program developed for use in the 

most recent room air conditioners direct final rule. 76 FR 22454 (Apr. 21, 2011). The MarkN 

program was itself an update of an adaptation to the Oak Ridge National Laboratory Mark III 

Heat Pump program for modeling room air conditioner cooling performance. This program was 

originally used in support of the 1997 room air conditioners final rule. 62 FR 50122 (Sept. 24, 
5-29

1997). The 1997 final rule and 2011 TSDd provide further details regarding the use of these 

programs in support of the room air conditioners energy conservation standards rulemakings. 

DOE modified the room air conditioner numerical model for this dehumidifier analysis 

because both product types use similar technologies—an evaporator to absorb heat from an air 

stream, a compressor, a condenser to eject heat to an air stream, and an expansion device 

between the two heat exchangers. The only major difference in the operation of the two product 

types is the airflow through the unit. Room air conditioners have two separate air streams 

through the unit, one for the indoor air to be cooled over the evaporator and the other for the 

external air that absorbs the heat rejected by the condenser. Dehumidifiers pass the same air 

stream over the evaporator and condenser, first cooling the air on the evaporator to condense 

water, then re-heating the air over the condenser before exhausting the drier air back to the room 

or return air stream.

To account for this difference in operation, DOE adjusted the MarkN model to set the 

condenser inlet air conditions (typically the outdoor air conditions for room air conditioners) 

equal to the evaporator outlet air conditions (typically the indoor return air conditions for room 

air conditioners). Through an iterative process, the revised program adjusts the condenser inputs 

for the MarkN program until they are within a tolerance of the evaporator outlet conditions, 

effectively modeling one air stream through both heat exchangers.

5.5.4.2 Analysis Method

DOE first used the numerical model to simulate unit performance for the models in the 

test and teardown sample. The model inputs include product component specifications and the 

ambient operating conditions. DOE obtained component information from the product 

teardowns, including heat exchanger construction (number of rows, tube passes, tube spacing, fin 

spacing, etc.), refrigerant tubing (lengths and diameters of inlet/outlet tubes and capillary tubes), 

and compressor specifications. 

The model requires detailed compressor operating information, including the mapping 

coefficients for refrigerant mass flow and power input at varying evaporator and condenser 

operating temperatures. DOE lacked this information for almost all units in the teardown and test 

sample. However, DOE used the data from testing to calibrate the model for each individual unit 

using a base case of compressor mapping inputs. After calibrating the model, DOE achieved 

close agreement between the model outputs and test data at both 80 °F and 65 °F ambient 

conditions.

DOE then used the model to determine the design changes necessary to reach different 

efficiency levels or capacity ranges not covered by the models in the teardown sample. For most 

portable dehumidifiers, DOE observed that manufacturers typically use two methods to increase 

 

d The TSD in support of the 2011 room air conditioners final rule can be found at: 

http://www.regulations.gov/#!documentDetail;D=EERE-2007-BT-STD-0010-0053
5-30

product efficiency: (1) improving the compressor efficiency, and (2) increasing the heat 

exchanger cross-sectional areas. Based on inputs from manufacturer interviews, DOE is aware 

that improving compressor efficiency is likely the first option to improve a unit’s efficiency 

before increasing the heat exchanger sizes. Increasing heat exchanger area could also require a 

change to a larger case size, which requires a higher material cost per unit, significant conversion 

costs to update the manufacturing facilities, and can increase shipping costs if fewer units can be 

transported in shipping containers. So, DOE assumed that manufacturers would first maximize 

the compressor efficiency within a unit to achieve higher efficiencies.

To determine appropriate ranges of compressor efficiencies, DOE surveyed available 

ratings for rotary R-410A compressors over the range of typical compressor capacities observed 

in dehumidifiers. As shown in Figure 5.5.4.1, compressors are available within this capacity 

range at rated energy efficiency ratios (EERs) ranging from roughly 8.5 to 10.5 British thermal 

units per hour per Watt (Btu/h/W). DOE notes that this range represents a limited number of 

compressors based on a survey of the market, not necessarily those observed during teardowns. 

DOE lacked rated information on the compressors found during teardowns, but expects the range 

presented in Figure 5.5.4.1 to be representative of compressors available to dehumidifier 

manufacturers.

Figure 5.5.4.1 R-410A Compressor Performance Characteristics

When increasing compressor EER to 10.5 Btu/h/W did not result in a sufficient increase

in IEF to reach a certain efficiency level, DOE then increased the condenser and evaporator 

cross-sectional areas in the model inputs. Manufacturers generally informed DOE that increasing 

the heat exchanger cross-sectional areas had the most significant impact on dehumidifier 

efficiency when compared to other heat exchanger changes, such as increasing the number of 

7.5

8

8.5

9

9.5

10

10.5

11

0 5000 10000 15000 20000

Rated Compressor EER (Btu/h/W)

Rated Compressor Capacity (Btu/h)
5-31

tube rows or return bends in a heat exchanger of the same cross-sectional area. DOE investigated 

these other changes using the model, and the results were consistent with the manufacturer

information. 

Improved compressor efficiencies and increased heat exchanger areas allowed DOE to 

analyze the design changes needed to meet each efficiency level for the lower-capacity portable 

and smaller-volume whole-home dehumidifier product classes. At higher efficiency levels, the 

highest-capacity portable and large-volume whole-home dehumidifier product classes 

incorporate inlet air-to-air heat exchangers. The numerical model did not incorporate a feature to 

simulate an inlet air-to-air heat exchanger, so DOE relied only on unit teardowns for the analysis 

at these higher efficiency levels.

5.5.5 Cost Estimates

For the models in the teardown sample, DOE developed manufacturer cost estimates 

based on the method outlined in section 5.4.4. As discussed above, DOE did not tear down units 

from each manufacturer at each capacity and efficiency level. In these cases, DOE relied on the 

numerical model to determine the design changes needed for a model in the teardown sample to 

reach a given efficiency or capacity level. DOE estimated that if a switch to a more efficient 

compressor was the only necessary design change, there would be no additional changes to the 

rest of the product. However, for units requiring larger heat exchangers, DOE scaled the size of 

the case and other related components to accommodate the larger coils.

In developing its cost estimates, DOE lacked detailed compressor pricing information. 

The compressor is often the most costly component in a dehumidifier, typically representing 20 

to 30 percent of the product’s material cost. DOE requested compressor pricing information 

during manufacturer interviews, but did not receive enough detailed feedback to develop cost 

estimates for all of the compressors found during teardowns or specified through the numerical 

model.

DOE did, however, receive compressor pricing information from manufacturers during 

the 2011 energy conservation standards rulemaking for room air conditioners. Dehumidifiers and 

certain room air conditioners both use similar rotary compressors for R-410A refrigerant. Figure 

5.5.5.1 presents the compressor cost information gathered during the room air conditioner 

rulemaking, and presented in chapter 5 of that direct final rule TSD.
5-32

Figure 5.5.5.1 R-410A Compressor Cost from Room Air Conditioner Direct Final Rule 

Analysis

DOE observed in this rulemaking that certain dehumidifiers use compressors with 

capacities less than 5,000 Btu/h, which are not represented by the curve. If the curve in Figure 

5.5.5.1 were extrapolated to lower than 5,000 Btu/h, the resulting costs would not appear to be 

representative. For example, a 3,000 Btu/h compressor (roughly the lowest observed in the 

teardown sample) would be estimated to cost less than $7; a 2,500 Btu/h compressor would have

a negative estimated cost. To model these lower compressor capacities, therefore, DOE 

extrapolated the curve using a linear relationship between $0 and 0 Btu/h capacity and the 

endpoint of the curve at 5,000 Btu/h capacity.

5.5.5.1 Baseline Cost Estimates

From product teardowns and the numerical model, DOE developed the following 

baseline manufacturer product costs for each of the dehumidifier product classes. All costs 

presented are in 2012 dollars.

0

20

40

60

80

100

120

0 5000 10000 15000 20000 25000 30000

Compressor Cost ($)

Capacity (Btu/h)
5-33

Table 5.5.5.1 Baseline Dehumidifier Manufacturing Cost Distribution

Portable Product Class Capacities 

(pints/day at 80 °F and 65° F)

Whole-Home Product 

Class Case Volume 

(ft3)

Cost Category ≤ 35 35.01-45 45.01-54 54.01-75 > 75≤ 8.0 > 8.0

≤ 20 20.01-30 30.01-35 35.01-45 > 45

Raw Materials $24.49 $24.10 $28.08 $33.46 $75.29 $54.59 $109.46

Purchased Parts $66.47 $72.88 $79.91 $84.50 $194.72 $192.84 $239.96

Assembly Labor Cost $1.61 $1.58 $1.66 $1.78 $24.60 $20.95 $32.38

Fab Labor Cost $1.05 $1.04 $1.28 $1.28 $35.52 $33.58 $40.37

Supervision Cost $0.14 $0.14 $0.15 $0.16 $3.13 $2.84 $3.78

Indirect Labor Cost $0.92 $0.91 $1.02 $1.06 $20.87 $18.93 $25.26

Equipment Dep. Cost $3.83 $3.83 $4.92 $4.91 $37.75 $34.20 $41.09

Tooling Dep. Cost $3.85 $3.81 $4.99 $4.85 $11.73 $11.40 $10.99

Building Dep. Cost $1.59 $1.59 $1.98 $2.12 $14.68 $14.11 $13.52

Indirect Process Costs $2.27 $2.27 $2.35 $2.34 $6.39 $5.71 $10.77

Total $106.22 $112.14 $126.36 $136.47 $424.67 $389.13 $527.59

5.5.5.2 Incremental Cost Estimates

As discussed in the previous sections, DOE either tore down or developed simulations for 

models at each efficiency level for the different product classes. DOE developed manufacturing 

cost estimates for each product, and determined the incremental manufacturing cost needed to 

meet each efficiency level when compared to the baseline for a given product class. Table 5.5.5.3

presents these incremental manufacturing costs.

Table 5.5.5.2 Incremental Dehumidifier Manufacturing Costs at Higher Efficiencies

Portable Product Class Capacities

(pints/day at 80 °F and 65° F)

Whole-Home Product 

Class Case Volume (ft3)

Efficiency Level ≤ 35 35.01-45 45.01-54 54.01-75 > 75≤ 8.0 > 8.0

≤ 20 20.01-30 30.01-35 35.01-45 > 45

EL1 $- $- $- $- $38.40 $15.22 $6.14

EL2 $1.56 $1.85 $2.94 $1.98 $49.16 $76.18 $37.05

EL3 $4.64 $3.78 $8.72 $7.56 $100.13 $112.01

EL4 $7.77 $10.82 $13.40 $11.24

DOE notes that the portable dehumidifier product classes with capacities at or below 75 

pints/day at 80 °F, equivalent to 45 pints/day at 65 °F, have zero incremental cost for reaching 

the first efficiency level. As discussed in section 5.3.1, the baseline IEF’s for these product 
5-34

classes assume the presence of a fan-only mode. DOE did not observe any unique design features 

associated with the presence or absence of fan-only mode operation, and expects the only cost 

associated with eliminating fan-only mode to be the cost of reprogramming the unit controls. 

Because this is only a design cost, DOE does not expect any additional production cost for 

eliminating fan-only mode. Accordingly, DOE estimated zero incremental cost to reach EL1 for 

these product classes.