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APPENDIX 12-A: RESIDENTIAL DISHWASHER RULEMAKING 

DIRECT FINAL RULE TECHNICAL SUPPORT DOCUMENT 

Manufacturer Impact Analysis Interview Guide
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The Department of Energy (DOE) conducts the manufacturer impact analysis (MIA) as part of 

the rulemaking process for amended energy conservation standards for dishwashers. In this 

analysis, DOE uses publicly available information and information provided by manufacturers 

during interviews to assess possible impacts on manufacturers due to amended energy 

conservation standards. 

The Association of Home Appliance Manufacturers (AHAM) and the American Council for an 

Energy Efficient Economy (ACEEE) released a multi-product standards agreement (Consensus 

Agreement) that addressed negotiated standards for refrigerators/freezers, clothes washers, 

clothes dryers, room air conditioners, and dishwashers. For dishwashers, the Consensus 

Agreement proposes updated standards for standard and compact product classes (Table 1.1). 

DOE’s rulemaking process allows for a direct publication of a final rule if DOE concludes that 

standards proposed in the Consensus Agreement meet certain statutory criteria. In order to 

evaluate the product classes and standards proposed in the Consensus Agreement for 

dishwashers, DOE is requesting information on the topics in this questionnaire.

DOE is requesting information on the product classes in the table below

 

Table 1.1 AHAM-ACEEE Multi-Product Standards Agreement - Dishwashers

Product Class Product Class Description

Annual Energy 

Use

(kWh/year)

Water Use

(gallons/cycle)

1. Standard Standard (≥ 8 place settings 

plus 6 serving pieces) 307 5.0

2. Compact Compact (< 8 place settings 

plus 6 serving pieces) 222 3.5

1 KEY ISSUES

1.1 In general, what are the key issues for your company regarding amended energy

conservation standards for dishwashers and this rulemaking?

1.2 Are any of the issues more or less significant for the compact versus standard-size 

product classes? 

1.3 Do any of the issues become more significant at higher efficiency levels? 

1.4 Do you have any suggestions for incorporating any of these issues into the into DOE’s 

manufacturing impact model? 
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2 COMPANY OVERVIEW AND ORGANIZATIONAL CHARACTERISTICS

DOE is interested in understanding manufacturer impacts at the plant or profit center level 

directly pertinent to dishwasher production. However, the context within which this profit center 

operates and the details of plant production are not always readily available from public sources. 

Understanding the organizational setting around the dishwasher industry profit center will help 

DOE understand the probable future of the manufacturing activity with and without amended 

energy conservation standards.

2.1 What percentage of your dishwasher manufacturing corresponds to each product class, 

both in terms of revenue and shipments? Please indicate if you do not manufacture products in 

any given product class. Please also indicate whether you purchase your dishwashers from other 

manufacturers (i.e. private label), and whether the factory that supplies the product is located in 

the United States.

Table 2.2 Dishwasher Revenue and Shipment Volumes by Product Class

Product 

Class 

Number 

Product 

Type 2010 Revenue

2010 

Shipments

% Private 

Label

% Made in 

U.S.

1 Standard

2 Compact

2.2 What is your company’s approximate market share in the dishwasher market?

3 ENGINEERING AND LIFE-CYCLE COST ANALYSIS

The following series of exhibits and questions address technical characteristics of key residential 

dishwasher components for both baseline and improved-efficiency products.

3.1 Baseline Dishwashers

Based on preliminary observation, DOE expects a “baseline” dishwasher (i.e. one that just meets 

existing AEU and water consumption standards) to include the following design features 

impacting energy use: electromechanical controls, no soil sensor, a non-insulated plastic tub, a 

tubular in-tub heater (with a normal power dry feature), a temperature switch, a tub float for fill 

control, a plastic filter for large particles plus a macerator, one lower spray arm with a spray 

tower, and a single-speed pump motor.

• Are these features consistent with what you would expect for a baseline standard-size 

dishwasher? 

• Would you expect the same design features to be incorporated in a baseline compact 

dishwasher?

• How do the design features found in baseline dishwashers address customer utility?
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3.2 Incremental Efficiency Levels

DOE proposes to evaluate efficiency levels based on the AEU and water use specifications 

prescribed by ENERGY STAR and the Consortium for Energy Efficiency (CEE), along with 

certain gap-fill and maximum levels that are currently available on the market as listed in the 

ENERGY STAR and California Energy Commission (CEC) product databases.

Table 3.1 and Table 3.2 show the proposed efficiency levels for both product classes.

Table 3.3 Dishwasher Efficiency Levels – Standard-Size Product Class

Level Efficiency Level Description

Annual Energy 

Use

(kWh/year)

Water 

Consumption

(gallons/cycle)

Baseline DOE Standard 355 6.5

1 ENERGY STAR (current) 324 5.8

2 ENERGY STAR (July 1, 2011)/CEE Tier 

1/Consensus Agreement 307 5.0

3 CEE Tier 2 295 4.25

4 Gap Fill* 234 3.8

5 Maximum Available* 180 1.6

*Source: ENERGY STAR-qualified dishwashers as of January 30, 2011.

Table 3.4 Dishwasher Efficiency levels -- Compact Product Class

Level Efficiency Level Description

Annual Energy 

Use

(kWh/year)

Water 

Consumption

(gallons/cycle)

Baseline DOE Standard 260 4.5

1 ENERGY STAR (current) 234 4.0

2 ENERGY STAR (July 1, 2011)/CEE Tier 

1/Consensus Agreement 222 3.5

3 Gap Fill* 200 2.8

4 Gap Fill* 174 2.7

5 Maximum Available* 154 2.1

*Source: ENERGY STAR-qualified dishwashers as of January 30, 2011.

• Are the proposed efficiency levels appropriate?

• Can you suggest more appropriate “max-tech” efficiency levels?

3.3 Are the design options listed in Table 3.3 below for each efficiency level representative 

of the features your company incorporates at each of these levels? Also, please indicate the 

incremental costs associated with the design options your company uses at each efficiency level.

The design options listed at each efficiency level reflect the incremental changes made to the unit 

at the previous level. These are based on DOE’s preliminary observations, and do not 

necessarily represent the final list of design options DOE will analyze for this rulemaking. These 

incremental changes assume a baseline unit as described in section 3.1.
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Table 3.5 Standard-Size Dishwasher Design Options and Incremental Costs

Level Design Options Description Design Options (if 

different)

Incremental 

Costs

1

Electronic controls with a linear power supply, stainless steel 

large and fine particle filters with no macerator, and multiple 

spray arms.

2 A turbidity sensor for soil sensing, insulation around the plastic 

tub, a switch mode power supply, and a 3-speed pump motor.

3

An in-line flow-through water heater, no power dry feature, a 

circulation fan to aid condensation drying, a stainless steel tub 

with complete bitumen insulation plus cotton insulation for the 

door, a temperature sensor, a flow meter, a small heat exchanger 

for inlet water pre-heating, a diverter valve for the multiple spray 

arms, and a variable speed pump motor.

4 Similar to EL3, with a humidity sensor controlling the circulation 

fan, and lower wash and rinse temperatures.

5

No circulation fan to aid condensation drying, a flow-through 

heater integrated in the pump, cotton insulation around the entire 

tub, and a larger heat exchanger for inlet water pre-heating.

• What tradeoffs can be made between the wash and dry cycles to achieve higher efficiencies?

• Do you find the reliability/life of electronic controls to differ from mechanical ones?

• What are the impacts on customer utility of the design changes used to increase efficiency?

• Are these design options and associated costs different for compact dishwashers?

3.4 Are installation costs a function of efficiency? Maintenance costs? Repair costs?

• If yes, would you please characterize this relationship by providing incremental installation, 

maintenance, and/or repair cost data?

• How are these costs different for standard vs. compact dishwashers?

4 MARKUPS AND PROFITABILITY

One of the primary objectives of the MIA is to assess the impact of amended energy 

conservation standards on industry profitability. In this section, DOE would like to understand 

the current markup structure of the industry and how amended energy conservation standards 

would impact your company’s markup structure and profitability. 

DOE estimated the manufacturer production costs for the two product classes of dishwashers. 

DOE defines manufacturer production cost as all direct costs associated with manufacturing a 

product: direct labor, direct materials, and overhead (which includes depreciation). The 

manufacturer markup is a multiplier applied to manufacturer production cost to cover nonproduction costs, such as SG&A and R&D, as well as profit. It does not reflect a “profit 

margin.” 

The manufacturer production cost times the manufacturer markup equals the manufacturer 

selling price. Manufacturer selling price is the price manufacturers charge their first customers, 

but does not include additional costs along the distribution channels. 
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DOE estimated a baseline markup of 1.24 for dishwashers. 

4.1 Is the 1.24 baseline markup representative of an average industry markup?

4.2 Please comment on the baseline markups DOE calculated as compared to your 

company’s baseline markups for the dishwasher product classes.

Table 4.6 Residential Dishwasher Baseline Manufacturer Markups by Product Class

Product 

Class 

Product 

Type

Estimated 

Baseline 

Markup

Manufacturer Comments or Revised Estimates

1 Standard 1.24

2 Compact 1.24

4.3 How are markups and margins determined in this industry? How would standards 

potentially impact this pricing/margin structure? Please indicate if profit levels vary between 

product classes or product line. If yes, please explain why.

4.4 One of the possible scenarios DOE uses to model impacts on industry profitability is the 

impact of commoditization of premium products. Because the market disruption caused by 

standards can alter the pricing of premium products, DOE is interested in understanding if 

efficiency is a feature that earns a premium. Within each product class, do markups vary by 

efficiency level? If yes, please provide estimates for your markups by product class and 

efficiency level in Table 4.2 and Table 4.3.

Table 4.2 Estimated Markups for Standard Size Dishwashers

Efficiency

Level

Annual Energy 

Use

(kWh/year)

Estimated 

Markup Manufacturer Comments

1 324

2 307

3 295

4 234

5 180

Table 4.3 Estimated Markups for Compact Dishwashers

Efficiency

Level

Annual Energy 

Use

(kWh/year)

Estimated 

Markup Manufacturer Comments

1 234

2 222

3 200

4 174

5 154
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4.5 What factors or product attributes besides efficiency affect the profitability of 

dishwashers within a product class?

4.6 Does your markup change with selected design options? Is the markup on incremental 

costs for more efficient designs different than the markup on the baseline models (as is assumed 

for retailer markups used in the analyses)?

4.7 Would you expect changes in your estimated profitability following an amended energy 

conservation standard? If so, please explain why. Can you suggest any scenarios that would 

model these expected changes?

4.8 What is the structure of your distribution channel and how does that influence your 

markup? Does that change between product classes or across the industry?

5 FINANCIAL PARAMETERS

DOE’s contractor has developed a “strawman” model of the dishwasher industry financial 

performance called the Government Regulatory Impact Model (GRIM), using publicly available 

data. However, this public information might not be reflective of manufacturing at the 

dishwasher profit center. This section attempts to understand the financial parameters for 

dishwasher manufacturing and how your company’s financial situation could differ from the 

industry aggregate picture.

5.1 In order to accurately collect information about dishwasher manufacturing, please 

compare your financial parameters to the GRIM parameters tabulated below.
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Table 5.7 Financial Parameters for Residential Dishwasher Manufacturing

GRIM Input Definition

Industry 

Estimated

Value (%)

Your Actual (If 

Different from 

DOE’s 

Estimate)

Income Tax 

Rate

Corporate effective income tax paid (percentage of 

earnings before taxes, EBT) 33.3%

Discount Rate

Weighted average cost of capital (inflationadjusted weighted average of corporate cost of 

debt and return on equity)

8.1%

Working 

Capital

Current assets less current liabilities (percentage of 

revenues) 7.0%

Net PPE Net plant property and equipment (percentage of 

revenues) 16.7%

SG&A Selling, general, and administrative expenses 

(percentage of revenues) 13.3%

R&D Research and development expenses (percentage 

of revenues) 2.3%

Depreciation Amortization of fixed assets (percentage of 

revenues) 7.4%

Capital 

Expenditures

Outlay of cash to acquire or improve capital assets 

(percentage of revenues, not including acquisition 

or sale of business units)

3.2%

Cost of Goods 

Sold

Includes material, labor, overhead, and 

depreciation (percentage of revenues) 80.6%

5.2 Do any of the financial parameters in Table 5.1 change based on product class? Please 

describe any differences. 

5.3 Do any of the financial parameters in Table 5.1 change for a particular subgroup of 

manufacturers? Please describe any differences. 

5.4 DOE accounts for one time product and capital conversion costs including research and 

development, as well as capital expenditures for facility changes and the depreciation of these 

fixed assets. Beyond these short term changes in cost structure, how would you expect an 

amended energy conservation standard to impact any of the financial parameters for the industry 

over time?

6 CONVERSION COSTS

Amended energy conservation standards may cause your company to incur capital and product 

conversion costs to redesign existing products and make changes to existing production lines to 

be compliant with the amended energy conservation standard. Depending on their magnitude, the 

conversion costs can have a substantial impact on the outputs used by DOE to evaluate the 

industry impacts. Understanding the nature and magnitude of the conversion costs is critical 

portion of the MIA. The MIA considers two types of conversion costs:

• Capital conversion costs are one-time investments in plant, property, and equipment 
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(PPE) necessitated by an amended energy conservation standard. These may be 

incremental changes to existing PPE or the replacement of existing PPE. Included are 

expenditures on buildings, equipment, and tooling.

• Product conversion costs are costs related research, product development, testing, 

marketing and other costs for redesigning products necessitated by an amended energy 

conservation standard.

DOE asks a number of questions to understand the nature and magnitude of your expected 

capital and product conversion costs.

6.1 Table 6.1 through Table 6.4 show the efficiency levels analyzed in the Engineering 

Analysis for the product categories covered by this rulemaking. Because DOE is using an 

efficiency level approach for the Engineering Analysis, the design options described in section 3 

represent one possible path to reach these efficiency levels. If you would apply different design 

options to reach each efficiency level, please describe those changes in detail. 

Please provide estimates for your capital conversion costs by product class and efficiency level 

in Table 6.1 and Table 6.2. In the description column, DOE is interested in understanding the 

kinds of changes that would need to be implemented to production lines and production facilities 

at each efficiency level. Where applicable, please quantify the number and cost of new 

production equipment, molds, etc. that would be required to implement the specified design 

changes. 

Table 6.8 Expected Capital Conversion Costs for Standard Size Dishwashers

Efficiency

Level

Annual Energy 

Use

(kWh/year)

Total Capital 

Conversion 

Costs

Description

1 324

2 307

3 295

4 234

5 180

Table 6.9 Expected Capital Conversion Costs for Compact Dishwashers

Efficiency

Level

Annual Energy 

Use

(kWh/year)

Total Capital 

Conversion 

Costs

Description

1 234

2 222

3 200

4 174

5 154
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6.2 Would the changes in question 6.1 be similar across all of your production lines and 

factories for each product class?

6.3 Are there certain efficiency levels that would require relatively minor changes to existing 

products? Are there certain efficiency levels where the capital or product conversion costs 

significantly increase over the previous efficiency levels? Would your answer change for 

different product classes? Please describe these changes qualitatively. 

6.4 For each of the product categories shown in Table 6.1 and Table 6.2, which efficiency 

level changes could be made within existing platform designs and which would result in major 

product redesigns?

6.5 For the efficiency levels put forth, which design options would require only minor 

changes to production lines, major changes to production lines, substantial modifications to 

existing facilities, or the development of entirely new manufacturing facilities? 

6.6 What level of product conversion costs would you expect to incur at each of these 

efficiency levels for each product class? Please provide your estimates in Table 6.3 and Table 6.4

considering such expenses as product development expenses, prototyping, testing, certification, 

and marketing. In the description column, please describe the assumptions behind the estimates 

provided. 

Table 6.3 Expected Product Conversion Costs for Standard Size Dishwashers

Efficiency

Level

Annual Energy 

Use

(kWh/year)

Total Product 

Conversion 

Costs

Description

1 324

2 307

3 295

4 234

5 180

Table 6.4 Expected Product Conversion Costs for Compact Dishwashers

Efficiency

Level

Annual Energy 

Use

(kWh/year)

Total Product 

Conversion 

Costs

Description

1 234

2 222

3 200

4 174

5 154

6.7 Please provide additional qualitative information to help DOE understand the types and 

nature of your investments, including the plant and tooling changes and the product development 

effort required at different efficiency levels.
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7 CUMULATIVE REGULATORY BURDEN

In assessing the impact to industry, DOE seeks to understand the cumulative regulatory burden 

facing manufacturers. Cumulative regulatory burden refers to the financial burden that stems 

from overlapping effects of new or revised DOE standards and/or other regulatory actions 

affecting the same product or industry. In this regard, DOE will consider other regulations 

(beyond efficiency) such as materials regulations and building codes that will adversely impact 

the cost to either the manufacturer or consumer. 

7.1 Have you had any r&d expenditures related to complying with the dishwasher energy 

conservation standards enacted by the Energy Independence and Security Act of 2007, which 

became effective in January 2010? What r&d, product development, and testing expenses were 

required to make your dishwasher compliant? Did you incur any capital expenses to make your 

products comply? Will any of these changes be coordinated with the changes required by this 

rulemaking?

7.2 In assessing cumulative regulatory burden, DOE considers the impacts of other 

regulations for which the starting effective date falls within a six year timeframe extending from 

three years before to three years after the proposed dishwasher standards become effective. 

Below is a list of other relevant regulations that could affect manufacturers of dishwashers. 

Please provide any comments on the listed regulations and provide an estimate for your expected 

compliance cost.

Table 7.10 Other Regulations Identified by DOE

Regulation Estimated or Actual 

Effective Date(s) Comments Expected Expense for Compliance

Residential clothes dryer energy 

conservation standards 2014

Residential clothes washer energy 

conservation standards 2015

Phosphate regulations in detergent 

in 16 states 2009-2010

ENERGY STAR draft qualifying 

criteria, potentially including wash 

performance

TBD

7.3 Are there any other recent or impending regulations that dishwasher manufacturers face 

(from DOE or otherwise)? If so, please identify the regulation, the corresponding effective dates, 

and your expected compliance cost. 

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

these other regulations with an amended energy conservation standard?

8 DIRECT EMPLOYMENT IMPACT ASSESSMENT

The impact of amended energy conservation standards on employment is an important 

consideration in the rulemaking process. This section of the interview guide seeks to explore 
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current trends in dishwasher manufacturer employment and solicit manufacturer views on how 

domestic employment patterns might be affected by amended energy conservation standards.

8.1 Where are your dishwasher manufacturing facilities that produce products for the United 

States located? What types of products are manufactured at each location? Please provide annual 

shipment figures for your company’s dishwasher manufacturing at each location by product 

class. Please also provide employment levels at each of these facilities.

Table 8.11 Dishwasher Revenue and Shipment Volumes by Product Class

Facility Location Product Types Manufactured Employees Annual 

Shipments

Example Sheboygan, WI Standard Size Dishwashers 200 100,000 

1

2

3

4

5

8.2 Would your domestic employment levels be expected to change significantly under 

amended energy conservation standards? If so, please explain how they would change if higher 

efficiency levels are required.

8.3 Would the workforce skills necessary under amended energy conservation standards 

require extensive retraining or replacement of employees at your manufacturing facilities?

8.4 Would amended energy conservation standards require extensive retraining of your 

service/field technicians? If so, could you expand on how your service infrastructure would be 

impacted in general as a result of amended energy conservation standards?

9 MANUFACTURING CAPACITY AND NON-US SALES

9.1 How would amended energy conservation standards impact your company’s 

manufacturing capacity?

9.2 For any design changes that would require new production equipment, please describe 

how much downtime would be required. What impact would downtime have on your business? 

Are there any design changes that could not be implemented before the compliance date of the 

final rule for certain product classes?

9.3 What percentage of your company’s dishwasher sales is made within the United States? 

9.4 What percentage of your dishwashers is produced in the United States? 

9.5 What percentage of your U.S. production of dishwashers is exported? 
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9.6 Are there any foreign companies with North American production facilities?

9.7 Would amended energy conservation standards impact your domestic vs. foreign 

manufacturing or sourcing decisions? Is there an efficiency level that would cause you to move 

exiting domestic production facilities outside the U.S.?

10 IMPACT ON COMPETITION

Amended energy conservation standards can alter the competitive dynamics of the market. This 

can include prompting companies to enter or exit the market, or to merge. DOE and the 

Department of Justice are both interested in any potential reduction in competition that would 

result from an amended energy conservation standard.

10.1 How would amended energy conservation standards affect your ability to compete in the 

marketplace? Would the effects on your company be different than others in the industry?

10.2 Would you expect your market share to change if amended energy conservation standards 

become effective?

10.3 Do any firms hold intellectual property that gives them a competitive advantage 

following amended energy conservation standards? 

10.4 How would industry competition change as a result of amended energy conservation 

standards?

11 IMPACTS ON SMALL BUSINESS

11.1 The Small Business Administration (SBA) denotes a small business in the dishwasher

manufacturing industry as having less than 500 total employees, including the parent company 

and all subsidiaries.1 By this definition, is your company considered a small business?

11.2 Are there any reasons that a small business manufacturer might be at a disadvantage 

relative to a larger business under amended energy conservation standards? Please consider such 

factors as technical expertise, access to capital, bulk purchasing power for materials/components, 

engineering resources, and any other relevant issues.

 1 DOE uses the small business size standards published on August 22, 2008, as amended, by the SBA to determine 

whether a company is a small business. To be categorized as a small business, a manufacturer of “other major 

household appliances” (NAICS #335228, which includes residential dishwasher manufacturers) and its affiliates 

may employ a maximum of 500 employees. The 500 employee threshold includes all employees in a business’s 

parent company and any other subsidiaries. 
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11.3 To your knowledge, are there any small businesses for which the adoption of amended 

energy conservation standards would have a particularly severe impact? If so, why? 

11.4 To your knowledge, are there any niche manufacturers or component manufacturers for 

which the adoption of amended energy conservation standards would have a particularly severe 

impact? If so, why?