CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT 

TABLE OF CONTENTS 

3.1 INTRODUCTION ........................................................................................................... 3-1 

3.2 PRODUCT DEFINITIONS ............................................................................................. 3-1 

3.3 PRODUCT CLASSES..................................................................................................... 3-2 

3.4 PRODUCT TEST PROCEDURES ................................................................................. 3-5 

3.5 MANUFACTURER TRADE GROUPS ......................................................................... 3-6 

3.5.1 Association of Home Appliance Manufacturers.............................................................. 3-6 

3.5.2 Coin Laundry Association ............................................................................................... 3-6 

3.5.3 Multi-housing Laundry Association ................................................................................ 3-7 

3.6 MANUFACTURER INFORMATION ........................................................................... 3-7 

3.6.1 Manufacturers and Market Shares ................................................................................... 3-7 

3.6.2 Mergers and Acquisitions .............................................................................................. 3-14 

3.6.3 Small Business Impacts ................................................................................................. 3-16 

3.6.4 Distribution Channels .................................................................................................... 3-17 

3.7 REGULATORY PROGRAMS ..................................................................................... 3-18 

3.7.1 Current Federal Energy Conservation Standards Prior to EPACT 2005 ....................... 3-18 

3.7.2 Energy Policy Act of 2005............................................................................................. 3-19 

3.7.3 State Energy Conservation Standards ............................................................................ 3-21 

3.7.4 Canadian Energy Conservation Standards..................................................................... 3-22 

3.8 VOLUNTARY PROGRAMS........................................................................................ 3-24 

3.8.1 Consortium for Energy Efficiency................................................................................. 3-24 

3.8.2 Energy Star..................................................................................................................... 3-25 

3.8.3 Federal Energy Management Program .......................................................................... 3-26 

3.9 HISTORICAL SHIPMENTS......................................................................................... 3-27 

3.9.1 New Home Starts ........................................................................................................... 3-27 

3.9.2 Unit Shipments............................................................................................................... 3-28 

3.9.3 Value of Shipments........................................................................................................ 3-30 

3.9.4 Imports and Exports....................................................................................................... 3-31 

3.10 MARKET SATURATION ............................................................................................ 3-33 

3.11 PRODUCT RETAIL PRICES ....................................................................................... 3-34 

3.12 INDUSTRY COST STRUCTURE................................................................................ 3-37 

3.13 INVENTORY LEVELS AND CAPACITY UTILIZATION RATES.......................... 3-39 

3.14 TECHNOLOGY ASSESSMENT.................................................................................. 3-40 

3.14.1 Product Operations and Components............................................................................. 3-40 

3.14.1.1 Dishwashers ................................................................................................. 3-40 

3.14.1.2 Dehumidifiers .............................................................................................. 3-42 

3.14.1.3 Cooking Products......................................................................................... 3-43 

3.14.1.4 Commercial Clothes Washers...................................................................... 3-46 

3.14.2 Technology Options....................................................................................................... 3-47 

3.14.2.1 Dishwashers ................................................................................................. 3-47 

3.14.2.2 Dehumidifiers .............................................................................................. 3-54 

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EE-2006-STD-0127 COMMENT 39.2
3.14.2.3 Cooking Products......................................................................................... 3-63 

3.14.2.4 Commercial Clothes Washers...................................................................... 3-83 

3.14.3 Energy Efficiency .......................................................................................................... 3-94 

3.14.3.1 Dishwashers ................................................................................................. 3-95 

3.14.3.2 Dehumidifiers .............................................................................................. 3-95 

3.14.3.3 Cooking Products......................................................................................... 3-97 

3.14.3.4 Commercial Clothes Washers.................................................................... 3-105 

LIST OF TABLES 

Table 3.6.1 Major and Other Commercial Clothes Washer Manufacturers ........................... 3-7 

Table 3.6.2 Major and Other Dishwasher Manufacturers....................................................... 3-8 

Table 3.6.3 Major and Other Dehumidifier Manufacturers .................................................. 3-10 

Table 3.6.4 Major and Other Range, Oven and Cooktop Manufacturers ............................. 3-13 

Table 3.6.5 Major and Other Microwave Oven Manufacturers............................................ 3-13 

Table 3.6.6 Core Appliance Manufacturers .......................................................................... 3-15 

Table 3.7.1 Federal Energy Conservation Standards for Residential Dishwashers.............. 3-19 

Table 3.7.2 EPACT 2005 Standards for Residential Dehumidifiers .................................... 3-20 

Table 3.7.3 EPACT 2005 Default 2012 Standards for Residential Dehumidifiers .............. 3-20 

Table 3.7.4 EPACT 2005 Standards for Commercial Clothes Washers............................... 3-21 

Table 3.7.5 State Commercial Clothes Washer Regulations Similar to EPACT 2005......... 3-21 

Table 3.7.6 California State Efficiency Standards for Commercial Clothes Washers ......... 3-22 

Table 3.7.7 California Water Conservation Standards for Residential Clothes Washers..... 3-22 

Table 3.7.8 Canadian Energy Conservation Standards for Electric Cooking Products ........ 3-23 

Table 3.7.9 Canadian Energy Conservation Standards for Residential Clothes Washers .... 3-23 

Table 3.8.1 CEE Criteria for Residential Dishwashers......................................................... 3-24 

Table 3.8.2 CEE Criteria for Commercial Clothes Washers ................................................ 3-25 

Table 3.8.3 Energy Star Criteria for Residential Dishwashers ............................................. 3-25 

Table 3.8.4 Energy Star Criteria for Standard Capacity Dehumidifiers ............................... 3-25 

Table 3.8.5 Energy Star Criteria for High Capacity Dehumidifiers ..................................... 3-25 

Table 3.8.6 Energy Star Criteria for Commercial Clothes Washers..................................... 3-26 

Table 3.8.7 FEMP Recommendations for Residential Dishwashers .................................... 3-26 

Table 3.8.8 FEMP Recommendations for Microwave Ovens .............................................. 3-26 

Table 3.8.9 FEMP Recommendations for Commercial Clothes Washers ............................ 3-27 

Table 3.9.1 Industry Shipments of Dishwashers and Dehumidifiers (Domestic and 

Import in Thousands of Units)........................................................................... 3-29 

Table 3.9.2 Industry Shipments of Cooking Products (Domestic and Import in 

Thousands of Units)........................................................................................... 3-29 

Table 3.9.3 2005 Energy Star Shipments by Product (Domestic and Import)...................... 3-30 

Table 3.9.4 Household Appliance Manufacturing Statistics by Year................................... 3-30 

Table 3.9.5 Disposition of Previous Appliance (Percentage) ............................................... 3-31 

Table 3.9.6 Household Cooking Appliance Manufacturing Statistics by Year .................... 3-31 

Table 3.9.7 2004-2005 Imports of Appliances Covered by this Rulemaking ...................... 3-32 

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EE-2006-STD-0127 COMMENT 39.2
Table 3.9.8 2004-2005 Exports of Appliances Covered by this Rulemaking ..................... 3-33 

Table 3.10.1 Appliance Saturation (Number in Millions) and Percentage of U.S. 

Households with Product ................................................................................... 3-33 

Table 3.11.1 Residential Appliance Retail Prices................................................................... 3-34 

........................................................ 3-35 

............................... 3-37 

..................................................... 3-38 

........................................................... 3-38 

..................................................... 3-39 

....................................................... 3-40 

................................................................ 3-48 

............................................................. 3-55 

.............................................................. 3-63 

..................... 3-67 

............................ 3-69 

.............................................. 3-71 

....................................................... 3-80 

.................................... 3-84 

Table 3.11.2 Commercial Clothes Washer Retail Prices 

Table 3.12.1 Household Appliance Industry Employment and Earnings

Table 3.12.2 Household Appliance Industry Census Data 

Table 3.12.3 Industry Cost Structure Using SEC Data

Table 3.13.1 Household Appliance Industry Census Data 

Table 3.13.2 Full Production Capacity Utilization Rates 

Table 3.14.1 Technology Options for Dishwashers

Table 3.14.2 Technology Options for Dehumidifiers 

Table 3.14.3 Technology Options for Gas Cooktops

Table 3.14.4 Technology Options for Open (Coil) Element Electric Cooktops

Table 3.14.5 Technology Options for Smooth Element Electric Cooktops

Table 3.14.6 Technology Options for Gas and Electric Ovens 

Table 3.14.7 Technology Options for Microwave Ovens

Table 3.14.8 Technology Options for Commercial Clothes Washers 

Figure 3.6.1 2005 Market Shares for the Domestic Residential Dishwasher Market .............. 3-9 

Figure 3.6.2 2005 Market Shares for the Domestic Residential Dehumidifier Market ......... 3-10 

Figure 3.6.3 2005 Market Shares for the Domestic Electric Range Market .......................... 3-11 

Figure 3.6.4 2005 Market Shares for the Domestic Gas Range Market ................................ 3-12 

Figure 3.6.5 2005 Market Shares for the Domestic Microwave Oven Market ...................... 3-14 

Figure 3.6.6 2005 Core Appliance Market Shares ................................................................. 3-15 

Figure 3.6.7 Commercial Clothes Washer Distribution Channels ......................................... 3-18 

Figure 3.9.1 New Privately Owned Single-Family and Multi-Family Housing Unit 

Starts in the U.S. from 1998-2005 .................................................................... 3-28 

LIST OF FIGURE 

Figure 3.11.1 Commercial Clothes Washer Retail Prices as a Function of Loading-Type 

and Presence of Coin Box.................................................................................. 3-36 

Figure 3.14.1 Dehumidifier Operation Schematic ................................................................... 3-42 

Figure 3.14.2 Dishwashers in the CEC Directory .................................................................... 3-95 

Figure 3.14.3 Energy Star-Qualified Dehumidifiers and the EPACT 2005 Dehumidifier 

Standards............................................................................................................ 3-96 

Figure 3.14.4 AHAM-Qualified Dehumidifiers and the EPACT 2005 Dehumidifier 

Standards............................................................................................................ 3-97 

Figure 3.14.5 Standard Electric Ranges in the NRCan Database ............................................ 3-98 

Figure 3.14.6 Self-Cleaning Electric Ranges in the NRCan Database .................................... 3-99 

Figure 3.14.7 Cooktops in the NRCan Database...................................................................... 3-99 

Figure 3.14.8 Self-Cleaning Electric Ovens in the NRCan Database .................................... 3-100 

Figure 3.14.9 Non-Self-Cleaning Electric Ovens in the NRCan Database............................ 3-101 

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EE-2006-STD-0127 COMMENT 39.2
Figure 3.14.10 AHAM Microwave Oven Efficiency versus Rated Output Power ................. 3-102 

Figure 3.14.11 AHAM Microwave Oven Efficiency versus Oven Volume ............................ 3-103 

Figure 3.14.12 AHAM Microwave Oven Standby Power Consumption,................................ 3-104 

Figure 3.14.13 Microwave Oven Standby Power Consumption from the FEMP Database .... 3-105 

Figure 3.14.14 MEF of Commercial Clothes Washers in the CEC Directory ......................... 3-106 

Figure 3.14.15 WF of Commercial Clothes Washers in the CEC Directory ........................... 3-107 

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EE-2006-STD-0127 COMMENT 39.2
CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT 

3.1 INTRODUCTION 

This chapter provides a profile of the residential dishwasher, dehumidifier, and cooking 

product and commercial clothes washer industries in the United States. The U.S. Department of 

Energy (DOE) developed the preliminary market and technology assessment presented in this 

chapter primarily from publicly available information. This assessment is helpful in identifying 

the major manufacturers and their product characteristics, which form the basis for the 

engineering and the life-cycle cost (LCC) analyses. Present and past industry structure and 

industry financial information help DOE in the process of conducting the manufacturer impact 

analysis. 

3.2 PRODUCT DEFINITIONS 

DOE defines “dishwasher” under the Energy Policy and Conservation Act (EPCA) of 

1975 (42 U.S.C. 6291–6309) as “a cabinet-like appliance which with the aid of water and 

detergent, washes, rinses, and dries (when a drying process is included) dishware, glassware, 

eating utensils, and most cooking utensils by chemical, mechanical and/or electrical means and 

discharges to the plumbing drainage system.” (10 CFR 430.2) 

The Energy Policy Act of 2005 (EPACT 2005) (P.L. 109-58) established the definition of 

a dehumidifier as follows: 

The term ‘dehumidifier’ means a self-contained, electrically operated, and mechanically 

encased assembly consisting of: 

A) a refrigerated surface (evaporator) that condenses moisture from the atmosphere; 

B) a refrigerating system, including an electric motor; 

C) an air-circulating fan; and 

D) means for collecting or disposing of the condensate. 

DOE defines “cooking products” under EPCA as “consumer products that are used as 

the major household cooking appliances. They are designed to cook or heat different types of 

food by one or more of the following sources of heat: gas, electricity, or microwave energy. 

Each product may consist of a horizontal cooking top containing one or more surface units 

and/or one or more heating compartments. They must be one of the following classes: 

conventional ranges, conventional cooking tops, conventional ovens, microwave ovens, 

microwave/conventional ranges and other cooking products.” (10 CFR 430.2) 

EPACT 2005 established the definition of a commercial clothes washer as follows: 

The term ‘commercial clothes washer’ means a soft-mount, front-loading or soft-mount, 

top-loading clothes washer that: 

A) has a clothes compartment that: 

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EE-2006-STD-0127 COMMENT 39.2
i) for horizontal-axis clothes washers, is not more than 3.5 cubic feet; and 

ii) for vertical-axis clothes washers, is not more than 4.0 cubic feet; and 

B) is defined for use in: 

i) applications in which the occupants of more than 1 household will be using the 

clothes washer, such as multi-family housing common areas and coin laundries; or 

ii) other commercial applications. 

EPACT 2005 also defines commercial clothes washers as products designed for 

applications in which the occupants of more than one household will be using the clothes washer, 

such as multi-family housing common areas, coin laundries, or other commercial applications. 

(EPACT 2005, section 136(a)(4)) 

3.3 PRODUCT CLASSES 

DOE intends to separate each product (residential dishwashers, dehumidifiers, and 

cooking products and commercial clothes washers) into product classes. Because DOE will 

formulate a separate energy conservation standard for each product class, the criteria for 

separation into different classes are: (1) type of energy used, and (2) capacity or other 

performance-related features such as those that provide utility to the consumer or others deemed 

appropriate by the Secretary that would justify the establishment of a separate energy 

conservation standard. (42 U.S.C. 6295 (q) and 6316(a)) 

For dishwashers, the size of the unit significantly impacts the energy consumed. In other 

words, standard-sized dishwashers with relatively greater water consumption have significantly 

greater energy use than compact units. Because standard dishwashers offer enhanced consumer 

utility over compact units (i.e., the ability to wash more dishes), DOE has established the 

following product classes, which are based on the size of the dishwasher (as specified in 

American National Standards Institute (ANSI)/Association of Home Appliance Manufacturers 

(AHAM) Standard DW-1-2005, Dishwashers): 

• Compact, (capacity less than eight place settings plus six serving pieces); and 

• Standard, (capacity equal to or greater than eight place settings plus six serving 

pieces). 

For dehumidifiers, EPACT 2005 sets energy conservation standards based on the 

capacity of the unit as measured in pints of water extracted per day. (EPACT 2005, section 

135(c); 42 U.S.C. 6295(cc)) DOE believes that there are unique design constraints associated 

with a unit’s capacity that warrant the creation of these separate classes. As part of the standards 

rulemaking analysis, DOE will seek comment as to whether all the product classes established by 

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EE-2006-STD-0127 COMMENT 39.2
EPACT 2005 are warranted. Until then, DOE is proposing the following product classes as they 

are established by EPACT 2005:a 

• 25.00 pints/day or less; 

• 25.01–35.00 pints/day; 

• 35.01–45.00 pints/day; 

• 45.01–54.00 pints/day; 

• 54.01–74.99 pints/day; and 

• 75.00 pints/day or more. 

For cooking products, the proposed product classes are based on energy source (i.e., gas 

or electric) and the cooking method (i.e., cooktops, ovens, and microwave ovens). There are five 

cooking product classes: gas cooktops, electric cooktops, gas ovens, electric ovens, and 

microwave ovens. DOE’s proposed product classes are based on the list of classes defined by 

DOE in its 1996 Technical Support Document for Residential Cooking Products (1996 TSD), 

which was released as part of the previous standards rulemaking.b Gas and electric rangesc

 are 

not listed below as product classes. Because ranges consist of both a cooktop and oven, any 

potential cooktop and oven standards would apply to the individual components of the range. As 

a result, product classes for ranges are not necessary. 

For gas cooktops, DOE’s proposed product class is: 

• Conventional burners. 

Commercial-style gas burners, which are characterized by firing rates greater than 14,000 

British thermal units (Btu)/h will not be considered for analysis due to a lack of available data for 

determining efficiency characteristics. In addition, the test procedure for gas cooktops is based 

on measuring temperature rise in an aluminum block with a diameter dictated by the firing rate 

of the burner. The maximum diameter of the test block is sufficient to measure higher output 

residential-scale burners. For commercial-type burners that must have larger diameter burner 

rings to accomplish complete combustion, however, this maximum test block diameter may be 

too small to achieve proper heat transfer and may not be representative of the dimensions of 

suitable cookware. 

For electric cooktops, DOE’s 1996 TSD determined that the ease of cleaning smooth 

elements provides enhanced consumer utility over coil elements. Because smooth elements 

a

 For standards effective October 1, 2007, EPACT 2005, in section 135(c), names five product classes for 

dehumidifiers: 25.00 pints/day or less, 25.01-35.00 pints/day, 35.01-54.00 pints/day, 54.01-74.99 pints/day, and 

75.00 pints/day or more. EPACT 2005 also prescribes a new set of amended standards for dehumidifiers in the 

event that DOE fails to publish a final rule requiring new standards to take effect by October 1, 2012. In providing a 

new set of standards, EPACT 2005, in section 135(c), subdivides the 35.01-54.00 pints/day product class into two 

product classes: 35.01-45.00 pints/day and 45.01-54.00 pints/day. 

b

 Available online at http://www.eere.energy.gov/buildings/appliance_standards/residential/cooking_products.html 

c

 DOE defines a “conventional range” under EPCA as “a class of kitchen ranges and ovens which is a household 

cooking appliance consisting of a conventional cooking top and one or more conventional ovens.” (10 CFR 430.2) 

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EE-2006-STD-0127 COMMENT 39.2
typically use more energy than coil elements, DOE is proposing the following product classes for 

electric cooktops: 

• Low or high wattage open (coil) elements; and 

• Smooth elements. 

Gas and electric grills and griddles will not be analyzed because DOE is not aware of any 

data upon which it can base a determination of either adequacy of the test procedure to measure 

energy efficiency or energy efficiency characteristics of products in these niche classes. 

For electric ovens, the 1996 TSD determined that the type of oven-cleaning system is a 

utility feature that affects performance. DOE found that standard ovens and ovens using a 

catalytic continuous-cleaning process use roughly the same amount of energy. On the other 

hand, self-cleaning ovens use a pyrolytic process that provides enhanced consumer utility with 

lower overall energy consumption as compared to either standard or catalytically lined ovens. 

Thus, DOE is proposing the following product classes for electric ovens: 

• Standard oven with or without a catalytic line; and 

• Self-clean oven. 

For gas ovens, for the same reasons as for electric ovens, DOE is proposing the following 

product classes: 

• Standard oven with or without a catalytic line; and 

• Self-clean oven. 

Commercial-style gas ovens, with larger cavity volumes (i.e., those that correspond to 

cabinet widths of 36 inches) and higher firing rate burners (i.e., greater than 22,500 Btu/h), will 

not be analyzed as a separate product class. DOE recognizes that the test procedure may not 

adequately measure performance of commercial-style ovens because the single test block may 

not adequately measure the temperature distribution that is inherent with these products. Further, 

DOE is unaware of efficiency data or data evaluating the adequacy of the test procedure, so 

therefore will not conduct an analysis on this product class at this time. 

For microwave ovens, DOE proposes no further class breakdown. This product class 

can encompass microwave ovens with and without browning elements, but does not include 

microwave ovens that incorporate convection systems (combination ovens). DOE will not 

conduct an analysis at this time of combination microwave ovens due to a lack of data evaluating 

the applicability of the test procedure to microwave ovens incoporating convection systems. 

For commercial clothes washers, DOE is proposing one product class, in accordance 

with EPACT 2005 amendments to EPCA and the determination by Congress, which 

encompasses both top- and front-loading units. 

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EE-2006-STD-0127 COMMENT 39.2
3.4 PRODUCT TEST PROCEDURES 

Test procedures exist for all four products covered by this rulemaking to determine 

energy efficiency and annual energy use as the basis for representation and determination of 

compliance with energy conservation standards. DOE established test procedures for residential 

dishwashers, cooking products, and clothes washers through the rulemaking process. EPACT 

2005 established test procedures for residential dehumidifiers and commercial clothes washers. 

In 2003, DOE revised its test procedure for dishwashers to more accurately measure 

their efficiency, energy use, and water use. The 2003 dishwasher test procedure amendments 

included the following revisions: (1) addition of a method to rate the efficiency of soil-sensing 

products; (2) addition of a method to measure standby power; and (3) a reduction in the averageuse cycles per year. (68 FR 51887, (August 29, 2003); 10 CFR Part 430, Subpart B, Appendix 

C) 

EPACT 2005 amended EPCA to specify that the U.S. Environmental Protection Agency 

(EPA)’s test criteria used under the Energy Star program must serve as the basis for the test 

procedure for dehumidifiers. (EPACT 2005, section 135(b); 42 U.S.C. 6293(b)(13)) The 

Energy Star test criteria require that ANSI/AHAM Standard DH-1-2003, Dehumidifiers, be used 

to measure energy use while the Canadian Standards Association (CAN/CSA standard CAN/ 

CSA-C749-1994 (R2005), Performance of Dehumidifiers, be used to calculate the energy factor. 

DOE has adopted these test criteria, along with related definitions and tolerances, as its test 

procedure for dehumidifiers (71 FR 71340, 71347, 71366, 713667-68 (Dec. 8, 2006); 10 CFR 

Part 430, Subpart B, Appendix X). 

DOE also revised its test procedure for cooking products to more accurately measure 

their efficiency and energy use. For DOE’s cooking products test procedure, DOE published the 

revisions as a final rule in 1997; these included: (1) a reduction in the annual useful cooking 

energy; (2) a reduction in the number of self-cleaning oven cycles per year; and (3) incorporation 

of portions of the International Electrotechnical Commission (IEC) Standard 705-1998 and 

Amendment 2-1993 for the testing of microwave ovens. (62 FR 51976, (October 3, 1997); 10 

CFR Part 430, Subpart B, Appendix I) Note that as of 1997, IEC has established a new 

numbering convention for standards. This test procedure has accordingly been assigned the 

publication number IEC 60705, and the current test procedure is IEC 60705-2006d

. 

EPACT 2005 amended EPCA to require that commercial clothes washers be rated with 

the same test procedure established for residential clothes washers. (EPACT 2005, section 

136(f); 42 U.S.C. 6314(a)(8)) DOE adopted test procedures for commercial clothes washers in a 

final rule published on October 18, 2005. (70 FR 60407, 60416) 

EPACT 2005 instructs DOE, in its rulemaking, to consider revising test procedures for all 

products that are major sources of standby mode energy consumption compared to overall 

product energy consumption. (EPACT 2005, section 135(c)) Standby power measurement is 

already incorporated into DOE test procedures for dishwashers, gas and electric ovens, and gas 

d

 For more information, please visit www.iec.ch. 

3-5 

EE-2006-STD-0127 COMMENT 39.2
cooktops. In the event that DOE proposes a test procedure change to incorporate standby power 

measurement for other products covered under this rulemaking, a standby power test procedure 

exists that could be incorporated by reference. IEC 62301-2005. Household electrical appliances 

– Measurement of standby power.e 

3.5 MANUFACTURER TRADE GROUPS 

DOE recognizes the importance of trade groups in disseminating information and 

promoting the interests of the industry that they support. To gain insight into the residential 

dishwasher, dehumidifier, and cooking product and commercial clothes washer industries, DOE 

researched various associations available to manufacturers, suppliers, and users of such 

equipment. DOE also used the member lists of these groups in the construction of an exhaustive 

database containing domestic manufacturers. 

DOE identified several trade groups that support, or have an interest in, the residential 

dishwasher, dehumidifier, and/or cooking product and/or commercial clothes washer industries, 

including AHAM, the Coin Laundry Association (CLA), and the Multi-housing Laundry 

Association (MLA). 

3.5.1 Association of Home Appliance Manufacturers 

The Association of Home Appliance Manufacturersf

 (AHAM), formed in 1967, aims to 

enhance the value of the home appliance industry through leadership, public education and 

advocacy. AHAM provides services to its members including government relations; certification 

programs for room air conditioners, dehumidifiers and room air cleaners; an active 

communications program; and technical services and research. In addition, AHAM conducts 

other market and consumer research studies and publishes a biennial Major Appliance Fact 

Book. AHAM also develops and maintains technical standards for various appliances to provide 

uniform, repeatable procedures for measuring specific product characteristics and performance 

features. 

3.5.2 Coin Laundry Association 

The Coin Laundry Associationg (CLA), based in Downers Grove, Illinois, is a trade 

association representing the 30,000 coin laundry owners in the United States and around the 

world. Since 1960, the CLA has provided education and service to the entrepreneurs of the coin 

laundry industry; promoted their business interests; and promoted the industry to the general 

public. 

e

 For more information, please visit www.iec.ch. 

f

 For more information, please visit www.aham.org. 

g

 For more information, please visit www.coinlaundry.org. 

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EE-2006-STD-0127 COMMENT 39.2
3.5.3 Multi-housing Laundry Association 

The Multi-housing Laundry Associationh (MLA), founded in 1959, is a trade association 

of operator and supplier companies providing professional laundry services for the multi-housing 

industry. The MLA works for a favorable legislative and regulatory climate for the industry, 

facilitates the exchange of technical and business information among members, and demonstrates 

the value of the industry to target markets. 

3.6 MANUFACTURER INFORMATION 

The following section details information regarding domestic manufacturers of 

residential dishwashers, dehumidifiers, and cooking products and commercial clothes washers, 

including estimated market shares (section 3.6.1), industry mergers and acquisitions (section 

3.6.2), potential small business impacts (section 3.6.3), and product distribution channels 

(section 3.6.4). 

3.6.1 Manufacturers and Market Shares 

Using publicly available data (e.g. Appliance Magazine and market assessments done by 

third parties), DOE estimates the market shares for domestic manufacturers of each of the four 

products contained in this standards rulemaking. Manufacturers may offer multiple brand 

names. Some of the brand names come from independent appliance manufacturers which have 

been acquired over time, and domestic manufacturers may put their brand on a product 

manufactured overseas. Companies included in this analysis may also be off-shore 

manufacturers that maintain a significant domestic presence via a U.S. entity. 

For commercial clothes washers, DOE estimates that there are eight domestic 

manufacturers. The majority of market share is held by four major manufacturers, including 

Alliance Laundry Systems LLC (Alliance), Maytag Corporation (Maytag), Whirlpool 

Corporation (Whirlpool), and GE Consumer & Industrial (GE).1

 As will be discussed in section 

3.6.2, Maytag and Whirlpool merged in 2006 but have continued to maintain both product lines 

to this date. Other manufacturers include AB Electrolux (Electrolux)i. Table 3.6.1 lists these 

manufacturers. 

Table 3.6.1 Major and Other Commercial Clothes Washer Manufacturers 

Major Manufacturers Other Manufacturers 

Alliance Electrolux 

Maytag 

Whirlpool 

GE 

h

 For more information, please visit www.mla-online.com.

i

 Commercial clothes washers are marketed under the Electrolux Professional brand, as opposed to residential 

clothes washers which are primarily marketed under the Frigidaire brand. 

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EE-2006-STD-0127 COMMENT 39.2
 For residential dishwashers, DOE estimates that there are approximately 13 domestic 

manufacturers. Nearly the entire domestic market, or 94 percent, is controlled by four domestic 

manufacturers: Whirlpool, GE, AB Electrolux (Frigidaire)j

, and Maytag. The merger between 

Whirlpool and Maytag resulted in the combined company accounting for 51 percent of the 

domestic dishwasher market. The remaining three percent of domestic market share is made up 

of companies including AM Appliance Group (formerly ASKO, Inc.), BSH Home Appliances 

Corporation (Bosch-Siemens), Dacor Inc. (Dacor), Equator Corporation (Equator), Fagor 

America Inc. (Fagor), Fisher & Paykel Appliances Limited (Fisher & Paykel), Haier America 

Trading, LLC (Haier), Miele, Inc. (Miele), Viking Range Corporation (Viking) and others. 

Table 3.6.2 lists these manufacturers. Figure 3.6.1 illustrates the 2005 market shares for the 

domestic residential dishwasher market. 

Table 3.6.2 Major and Other Dishwasher Manufacturers 

Major Manufacturers Other Manufacturers 

Whirlpool AM Appliance Group 

GE Bosch-Siemens 

Frigidaire Dacor 

Maytag Equator 

Fagor 

Fischer & Paykel 

Haier 

Miele 

Viking 

j

 AB Electrolux also markets residential dishwashers in much smaller volumes under the Electrolux brand. 

3-8

EE-2006-STD-0127 COMMENT 39.2
Others 

3% 

Bosch-Siemens

Hausgeräte

3%

Maytag 

17% Whirlpool 

34% 

Electrolux 

(Frigidaire) 

18% 

GE 

25% 

Figure 3.6.1 2005 Market Shares for the Domestic Residential 

Dishwasher Market2 

For residential dehumidifiers, two thirds of the United States market is comprised of two 

manufacturers: Whirlpool and LG Electronics, Inc. (LG). The remaining one third of the market 

is represented by Fedders Corporation (Fedders), W.C. Wood Company (W.C. Wood), 

Frigidaire, Samsung Electronics America, Inc. (Samsung), Oasis Corporation (Ebco), and others, 

including Daewoo Electronics Company, Ltd. (Daewoo), De’Longhi America, Inc. (De’Longhi), 

Dri-Eaz Products, Inc. (Dri-Eaz), Friedrich Air Conditioning Company (Friedrich), GD Midea 

Air-conditioning Equipment Company, Ltd. (Midea), GE, Haier, Heat Controller, Inc. (Heat 

Controller), Research Products Corporation (Aprilaire), Jarden Corporation (Bionaire), and 

Therma-Stor LLC (Therma-Stor). Table 3.6.3 lists these manufacturers and Figure 3.6.2 

illustrates the 2005 market shares for the domestic residential dehumidifier market. 

3-9

EE-2006-STD-0127 COMMENT 39.2
Table 3.6.3 Major and Other Dehumidifier Manufacturers 

Whirlpool Fedders 

LG W.C. Wood 

Ebco 

Daewoo 

De’Longhi 

Dri-Eaz 

Friedrich 

GE 

Haier 

Heat Controller 

Bionaire 

Others 

4% 

Major Manufacturers Other Manufacturers 

Frigidaire 

Samsung 

Aprilaire 

Therma-Stor 

7% 

W.C. Wood 

6% 

Fedders 

10% 

35% 

Electrolux 

(Frigidaire) 

4% 

3% 

Whirlpool 

Samsung 

Ebco 

LG 

31% 

Figure 3.6.2 2005 Market Shares for the Domestic Residential 

Dehumidifier Market3 

3-10

EE-2006-STD-0127 COMMENT 39.2
 For cooking products (including ovens, cooktops, and ranges) DOE estimates that there 

are approximately 14 domestic manufacturers. GE and Whirlpool represent nearly three quarters 

of the electric range products market. GE represents over a third of the gas range products 

market, while the combined Whirlpool and Maytag comprise over a quarter. Frigidaire, 

Peerless-Premier Appliance Co. (Peerless-Premier), and other small manufacturers make up the 

difference in both markets. Figure 3.6.3 and Figure 3.6.4 illustrate the 2005 market shares for 

the domestic residential electric and gas range markets, respectively. 

Others 

GE 

49% 

23% 

10% 

(Frigidaire) 

10% 

4% 

4% 

Whirlpool 

Maytag 

Electrolux 

Peerless Premier 

Figure 3.6.3 2005 Market Shares for the Domestic Electric Range 

Market4 

3-11

EE-2006-STD-0127 COMMENT 39.2
Others 

GE 

37% 

17% 

11% 

6% 

4% 

Maytag 

Whirlpool 

Peerless Premier 

Electrolux 

(Frigidaire) 

25% 

Figure 3.6.4 2005 Market Shares for the Domestic Gas Range Market5 

In addition to the manufacturers of ranges presented above, manufacturers of ovens and 

cooktops also include Bosch-Siemens (which acquired Thermador Corporation), Dacor, 

De’Longhi, Fisher & Paykel (which acquired Dynamic Cooking Systems Inc.), Miele, Kenyon 

International, Inc. (Kenyon), Sub-Zero Freezer Company, Inc. (Sub-Zero) (which acquired the 

residential division of the Wolf Appliance Company (Wolf)), Felix Storch, Inc. (Summit), and 

Viking. Table 3.6.4 lists these manufacturers. 

3-12

EE-2006-STD-0127 COMMENT 39.2
Table 3.6.4 Major and Other Range, Oven and Cooktop Manufacturers 

Major Manufacturers 

GE 

Whirlpool 

Maytag 

Frigidaire 

Other Manufacturers 

Peerless-Premier 

Bosch-Siemens 

Dacor 

De’Longhi 

Fisher & Paykel 

Miele 

Kenyon 

Sub-Zero 

Summit 

Viking 

The 

Figure 3.6.5 lists microwave 

Table 3.6.5 

LG Daewoo 

Sharp 

(Panasonic) 

Whirlpool 

Guangdong Galanz Enterprise Co., Ltd. 

(Galanz) 

Midea 

Sanyo 

Sub-Zero 

Viking 

microwave oven market differs from the rest of the domestic cooking product 

market in that many of the manufacturers are foreign-owned companies with manufacturing 

facilities outside of the United States, and many of the domestic appliance manufacturers rebrand 

foreign-manufactured products. Table 3.6.5 illustrates the 2005 market shares for the United 

States microwave oven market. Microwave oven manufacturers with facilities inside the U.S. 

include Maytag, SANYO North America Corporation (Sanyo), the Sharp Electronics 

Corporation (Sharp), Sub-Zero, Summit, and Viking. 

manufacturers active in the domestic market. 

Major and Other Microwave Oven Manufacturers 

Major Manufacturers Other Manufacturers 

Panasonic Corporation of America 

Samsung 

Summit 

3-13

EE-2006-STD-0127 COMMENT 39.2
Midea Others 

2% 7% 

i

35% 

Sharp 12% 

9% 

8% 

4% 

3% 

LG Electron cs 

Samsung 

Daewoo 

Matsushita 

Whirlpool 

Galanz 

20% 

Figure 3.6.5 2005 Market Shares for the Domestic Microwave Oven 

Market6 

3.6.2 Mergers and Acquisitions 

Due to mergers and acquisitions, the home appliance industry continues to consolidate. 

While this phenomenon varies from product to product within the industry, the large market 

shares of a few companies provide evidence in support of this characterization. 

According to the September 2006 issue of Appliance Magazine, four manufacturers 

comprise 92 percent of the core appliance market share. “Core appliances” include dishwashers, 

freezers, ranges, refrigerators, and clothes washers. Table 3.6.6 lists these core appliance 

manufacturers, and Figure 3.6.6 illustrates the breakdown of 2005 market shares in the core 

appliance category. 

3-14

EE-2006-STD-0127 COMMENT 39.2
Table 3.6.6 Core Appliance Manufacturers 

Core Appliance Manufacturers 

Whirlpool 

GE 

Frigidaire 

Maytag 

Others 

8% 

34% 

15% Whirlpool 

Electrolux 

(Frigidaire) 

18% 

Maytag 

GE 

25% 

Figure 3.6.6 2005 Core Appliance Market Shares7 

On August 22, 2005, Whirlpool, headquartered in Benton Harbor, Michigan, and Maytag, 

based in Newton, Iowa, announced plans to merge in a deal worth $2.7 billion.8 Maytag 

shareholders approved the merger on December 22, 2005. Shortly after announcing the merger, 

Whirlpool submitted a pre-merger notification to the U.S. Department of Justice (DOJ). The 

DOJ Antitrust Division initiated an investigation, scheduled to end February 27, 2006, into the 

effects of the merger, including potential lessening of competition or the creation of a monopoly. 

Following this initial review, the DOJ asked for additional materials from each company and 

extended the review to March 30, 2006. 

Opponents of the merger asserted that the combined companies would control as much as 

70 percent of the residential laundry market and as much as 50 percent of the residential 

dishwasher market.9

 Whirlpool claimed that their large potential residential laundry market 

share was skewed because the company produces washing machines for Sears, which sells them 

3-15

EE-2006-STD-0127 COMMENT 39.2
under their Kenmore in-house brand. Whirlpool went on to say that they must periodically bid 

with other manufacturers to keep the Kenmore contract and that Sears controls the pricing of the 

Kenmore units.10 

In early January 2006, U.S. Senator Tom Harkin and U.S. Representative Leonard 

Boswell, both of Iowa, called upon the DOJ to block the merger, claiming it would give 

Whirlpool an unfair advantage in the home appliance industry. The Congressmen wrote, that if 

the DOJ does not block the deal, the agency should at least “require that Whirlpool divest the 

washer and dryer portions of Maytag to a viable purchaser who will have the financial capability 

and desire to continue to operate that business.”11 

On March 29, 2006, DOJ closed its investigation and approved the merger. DOJ claims 

“that the proposed transaction is not likely to reduce competition substantially. The combination 

of strong rival suppliers with the ability to expand sales significantly and large cost savings and 

other efficiencies that Whirlpool appears likely to achieve indicates that this transaction is not 

likely to harm consumer welfare.”12 

The DOJ Antitrust Division focused its investigation on residential laundry, although it 

considered impacts across all products offered by the two companies. DOJ determined that the 

merger would not give Whirlpool excessive market power in the sale of its products and that any 

attempt to raise prices would likely be unsuccessful. In support of this claim, DOJ noted: (1) 

other U.S. brands, including Kenmore, GE, and Frigidaire, are well established; (2) foreign 

manufacturers, including LG and Samsung, are gaining market share; (3) existing U.S. 

manufacturers are below production capacity; (4) the large home appliance retailers have 

alternatives available to resist price increase attempts; and (5) Whirlpool and Maytag 

substantiated large cost savings and other efficiencies that would benefit consumers.13 

Whirlpool and Maytag completed the merger on March 31, 2006. This large merger 

follows several other mergers and acquisitions in the home appliance industry. For example, 

Maytag acquired Jenn-Air Corporation (Jenn-Air) in 1982, Magic Chef, Inc. (Magic Chef) in 

1986, and Amana Appliances (Amana) in 2001. Whirlpool acquired the KitchenAid division of 

Hobart Corporation (KitchenAid) in 1986. White Consolidated Industries (WCI) acquired the 

Frigidaire division of General Motors Corporation in 1979, and AB Electrolux acquired WCI 

(and therefore Frigidaire) in 1986. 

3.6.3 Small Business Impacts 

DOE considers the possibility of small businesses being impacted by the promulgation of 

energy conservation standards for residential dishwashers, dehumidifiers, and cooking products 

and commercial clothes washers. At this time, DOE is not aware of any small manufacturers, 

defined by the Small Business Association as having 750 employees or fewer, who produce 

products that fall under this rulemaking and who therefore would be impacted by a minimum 

efficiency standard. Should any small business manufacturers of the four appliance products be 

identified, DOE will study the potential impacts on these small businesses in greater detail 

during the manufacturer impact analysis (MIA), which it will conduct as a part of the notice of 

proposed rulemaking (NOPR) analysis. 

3-16

EE-2006-STD-0127 COMMENT 39.2
3.6.4 Distribution Channels 

Understanding the distribution channels of products covered by this rulemaking is an 

important facet of the market assessment. DOE gathered information regarding the distribution 

channels for residential dishwashers, dehumidifiers, and cooking products and commercial 

clothes washers from publicly available sources. This section contains distribution channel 

information for residential appliances and commercial clothes washers. 

The distribution chain for residential appliances, including dishwashers, dehumidifiers, 

and cooking products, differs from commercial products, as the majority of consumers purchase 

their appliances directly from retailers. These retailers include: (1)home improvement, 

appliance, and department stores; (2) Internet retailers; (3) membership warehouse clubs; and (4) 

kitchen remodelers. The AHAM 2005 Fact Book reports that home improvement stores claim 

nearly one out of every four dollars spent on appliances.14 

Home appliance retailers generally obtain products directly from manufacturers. The 

AHAM 2003 Fact Book shows that over 93 percent of residential appliances are distributed from 

the manufacturer directly to a retailer.15 

For commercial clothes washers, DOE used a 1998 Consortium for Energy Efficiency 

(CEE) report describing their Commercial, Family-Sized Clothes Washer Initiative (see section 

3.8.1).16 This report includes an assessment of the commercial clothes washer market. Figure 

3.6.7 illustrates the commercial clothes washer distribution channels identified in this report, 

which DOE believes are representative of the current market as well. 

CEE reports that the commercial clothes washer market can be divided into three areas, 

including laundromats, private multi-family housing, and large institutions (e.g., military 

barracks, universities, and housing authorities). Most large institutions and a majority of private 

multi-family housing (between 50 and 90 percent) do not purchase clothes washers directly. 

Rather, these organizations lease their laundry space to a third party known as a route operator. 

Route operators supply laundry equipment and maintain facilities in exchange for a percentage 

of the laundry revenue. Laundromats and some private building managers, conversely, will 

purchase clothes washers directly from distributors. The main difference between route 

operators and distributors is the length of service provided to their clients. Route operators 

provide on-going support while distributor support ends at the point of sale.17 

According to CEE’s report, there are between 2 and 3 million commercial clothes 

washers installed in the United States. In general, these washers are replaced at a rate of 10 

percent per year, resulting in a replacement of approximately 200,000 to 300,000 washers 

annually. In its 2007 commercial clothes washer data submittal, AHAM reported somewhat 

lower shipment volumes of 175,000 to 190,000 units per year from 2002-2005. CEE also reports 

that, of this annual replacement total, approximately 15 percent go to laundromats while 85 

percent goes to the multi-family sector.18 

3-17

EE-2006-STD-0127 COMMENT 39.2
Manufacturer

Route Operator

Distributor (some

overlap with route

operators)

Private &

Institutional 

Building Manager

(~85%)

Laundromat

(~15%)

Manufacturer 

Route Operator 

Distributor (some 

overlap with route 

operators) 

Private & 

Institutional 

Building Manager 

(~85%) 

Laundromat 

(~15%) 

Source: CEE, Commercial, Family-Sized Washers: An Initiative

Description of the Consortium for Energy Efficiency, 1998. Description of the Consortium for Energy Efficiency, 1998.

Figure 3.6.7 Commercial Clothes Washer Distribution Channels 

3.7 REGULATORY PROGRAMS 

The following section details current regulatory programs mandating energy conservation 

standards for residential dishwashers, dehumidifiers, cooking products and/or commercial 

clothes washers. Section 3.7.1 discusses Federal energy conservation standards prior to EPACT 

2005, section 3.7.2 reviews new standards issued by EPACT 2005, and section 3.7.3 provides an 

overview of existing State standards. In addition, section 3.7.4 reviews standards in Canada that 

may impact the companies servicing the North American market. 

3.7.1 Current Federal Energy Conservation Standards Prior to EPACT 2005 

Current Federal standards exist for residential dishwashers. The National Appliance 

Energy Conservation Act of 1987 (NAECA) (42 U.S.C. 6291-6309) amended EPCA to establish 

prescriptive standards for dishwashers, requiring that they be equipped with an option to dry 

without heat and further requiring that DOE conduct two cycles of rulemakings to determine if 

more stringent standards are justified. (42 U.S.C. 6295 (g)(1), (4) and (5)) On May 14, 1991, 

DOE issued a final rule establishing the first set of performance standards for dishwashers (56 

FR 22250); the new standards became effective on May 14, 1994. (10 CFR 430.32(f)) Table 

3.7.1 presents these standards for residential dishwashers. DOE initiated a second standards 

3-18 

EE-2006-STD-0127 COMMENT 39.2
(59 FR 56423) 

61 FR 36974 (July 15, 1996); 10 CFR Part 430, 

Table 3.7.1 

Minimum Energy Factor (EF) (cycles/kWh) 

0.62 

Standard dishwasher 0.46 

cooking products, requiring gas 

are justified. 

ovens. (59 FR 10464) 

analysis of cooking products. 

Partially due to the difficulty of 

(63 FR 48038) 

justified for electric cooking products. 

cooking products. 

3.7.2 Energy Policy Act of 2005 

This legislation 

Table 3.7.2 and Table 3.7.4 

respectively. 

subsection (cc) for 

These 

effect on October 1, 2007. 

rulemaking for dishwashers by issuing an advance notice of proposed rulemaking (ANOPR) on 

November 14, 1994. However, as a result of the priority-setting process outlined 

in its (Procedures for Consideration of New or Revised Energy Conservation Standards for 

Consumer Products (the “Process Rule”) (

Subpart C, Appendix A), DOE suspended the standards rulemaking for dishwashers. 

Federal Energy Conservation Standards for Residential Dishwashers 

Dishwasher Classification 

Compact dishwasher 

NAECA established prescriptive standards for gas 

ranges and ovens with an electrical supply cord not to be equipped with constant burning pilots 

and directed DOE to conduct two cycles of rulemakings to determine if more stringent standards 

(42 U.S.C. 6295 (h)(1)-(2)) DOE initially analyzed standards for cooking products 

as part of an eight-product standards rulemaking. It issued a NOPR on March 4, 1994, proposing 

performance standards for gas and electric residential cooking products, including microwave 

In accordance with its 1996 Process Rule, DOE refined its standards 

With regard to gas cooking products, DOE focused on the 

economic justification for eliminating standing pilots. 

conclusively demonstrating that elimination of standing pilots was economically justified, DOE 

issued a final rule on September 8, 1998, that covered only electric cooking products, including 

microwave ovens. The final rule found that standards were not economically 

DOE never completed its standards rulemaking for gas 

On August 8th, 2005 the President signed into law EPACT 2005. 

establishes energy conservation standards for several residential and commercial products, 

including residential dehumidifiers and commercial clothes washers. 

provide EPACT 2005 standards for residential dehumidifiers and commercial clothes washers, 

Section 135(c)(4) of EPACT 2005 amends section 325 of EPCS, 42 U.S.C. 6295, to add 

dehumidifiers, which establishes energy conservation standards for 

dehumidifiers based on the unit’s capacity to extract moisture from the surrounding air (in 

pints/day) with EF measured in liters (L) of water removed per kilowatt-hour (kWh). 

Federally-mandated standards for dehumidifiers will be the national standards when they take 

Table 3.7.2 provides EPACT 2005 standards for residential 

dehumidifiers. 

3-19

EE-2006-STD-0127 COMMENT 39.2
Table 3.7.2 EPACT 2005 Standards for Residential Dehumidifiers 

Dehumidifier Capacity Standards Effective October 1, 2007 

EF (liters/kWh) 

25.00 pints/day or less 1.00 

25.01–35.00 pints/day 1.20 

35.01–54.00 pints/day 1.30 

54.01–74.99 pints/day 1.50 

75.00 pints/day or more 2.25 

In addition, EPACT 2005 requires that DOE issue a final rule for dehumidifiers to 

determine whether these standards should be amended. The final rule is due by October 1, 2009. 

(EPACT 2005, section 135(c)(4)) Further, in the event that DOE fails to publish a final rule 

requiring new standards to take effect by October 1, 2012, EPACT 2005 also prescribes a new 

set of amended standards for dehumidifiers. (Id.) This default 2012 standard subdivides the 

35.01—54.00 pints/day product class into two product classes: 35.01—45.00 pints/day and 

45.01—54.00 pints/day. (Id.) Table 3.7.3 provides the default 2012 standards for residential 

dehumidifiers. 

Table 3.7.3 EPACT 2005 Default 2012 Standards for Residential Dehumidifiers 

Dehumidifier Capacity Standards Effective January 1, 2012k 

EF (liters/kWh) 

25.00 pints/day or less 1.20 

25.01–35.00 pints/day 1.30 

35.01–45.00 pints/day 1.40 

45.01–54.00 pints/day 1.50 

54.01–74.99 pints/day 1.60 

75.00 pints/day or more 2.50 

Without consideration for product classes, section 135(e) of EPACT 2005 amends section 

342 of EPCA, 42 U.S.C. 6313, to add subsection (e) for commercial clothes washers, which 

establishes energy and water conservation standards. These Federally-mandated standards for 

commercial clothes washers became the national standards when they took effect on January 1, 

2007. (EPACT 2005, section 136(e)) Table 3.7.4 provides EPACT 2005 standards for 

commercial clothes washers. 

k

 These residential dehumidifier standards take effect on January 1, 2012 only if DOE fails to publish a final rule 

requiring new standards to take effect by October 1, 2012. (EPACT 2005, section 135(c)(4)) 

3-20

EE-2006-STD-0127 COMMENT 39.2
Table 3.7.4 EPACT 2005 Standards for Commercial Clothes Washers 

Clothes Washer Classification 

Standards Effective January 1, 2007 

MEF* 

(ft3

/kWh/cycle) 

WF* (gallons/ 

ft3/cycle) 

Top- and front-loading 1.26 9.5 

*The Modified Energy Factor (MEF), is a measure of how many kWh are required to wash each cubic foot of 

washer capacity. It measures the total energy consumption of the washer and also accounts for the amount of energy 

required to dry clothes based on the remaining moisture content of the clothes. Water Factor (WF) is measured in 

gallons of water required per cycle per cubic foot of washer capacity. 

New subsection 342(e), 42 U.S.C. 6313(e) also requires that DOE issue a final rule by 

January 1, 2010 to determine whether these standards for commercial clothes washers should be 

amended. (EPACT 2005, section 136(e) 

3.7.3 State Energy Conservation Standards 

Prior to the passage of EPACT 2005, several States proposed and adopted State-level 

efficiency regulations for commercial clothes washers that are identical, or very similar, to 

EPACT 2005 regulations. The EPACT 2005 energy and water use standards for commercial 

clothes washers preempt any State efficiency standards since they became effective January 1, 

2007. Table 3.7.5 presents information regarding States adopting commercial clothes washer 

standards comparable to EPACT 2005. 

Table 3.7.5 State Commercial Clothes Washer Regulations Similar to EPACT 2005 

State Effective Date Difference from EPACT 2005 

Arizona MEF and WF: 1/1/08 Standards effective one year later than EPACT 2005 

California MEF: 1/1/05 

WF: 1/1/07 

MEF standard effective two years earlier than EPACT 

2005 

Connecticut MEF and WF: 7/1/06 Standards effective six months earlier than EPACT 

2005 

Maryland MEF and WF: 3/1/07 Standards effective two months later than EPACT 2005 

New Jersey MEF: 1/1/07 

WF: 1/1/10 

Water factor standard effective three years later than 

EPACT 2005 

Oregon MEF and WF: 1/1/08 Standards effective one year later than EPACT 2005 

Rhode Island MEF and WF: 1/1/07 Identical to EPACT 2005 

Washington MEF - For Sale: 1/1/07 

MEF - Installation: 1/1/08 Does not address water factor 

As presented in the table above, the State of California mandates energy and water 

conservation standards for commercial front-loading and commercial top-loading automatic 

clothes washers. Table 3.7.6 provides the State’s commercial clothes washer energy 

conservation standards, which are dependent on clothes container capacity, and the water 

conservation standards, which became effective two years after the MEF standards. 

3-21

EE-2006-STD-0127 COMMENT 39.2
Table 3.7.6 California State Efficiency Standards for Commercial Clothes Washers 

Clothes Washer 

Classification 

Clothes Container 

Compartment 

Capacity (ft3

) 

Minimum MEF 

Effective 

January 1, 2005 

Maximum WF 

Effective January 1, 

2007 

Front-loading < 3.5 ft3

 1.26 9.5 

Top-loading < 1.6 ft3 

≥ 1.6 ft3 and < 4.0 ft3 

0.65 

1.26 

9.5 

9.5 

In addition to the efficiency standards discussed above, the State of California requires 

that commercial top-loading semi-automatic clothes washers and commercial suds-saving 

clothes washers manufactured on or after January 1, 2005 have an unheated rinse water option. 

 Additionally, California issued minimum water conservation standards for residential 

clothes washers. While this does not directly affect products covered by the rulemakings, DOE 

is aware that this standard may have impacts on manufacturers of commercial clothes washers 

and other household appliances. Although Federal standards exist for the energy consumption of 

residential clothes washers, no such standard exists for the water efficiency. On September 16, 

2005, the California Energy Commission (CEC) issued a petition for an exemption from Federal 

preemption to seek to apply its own State regulation for residential clothes washer WF. DOE 

accepted written comments regarding this California petition until April 7, 2006. Table 3.7.7 

provides the State’s proposed residential clothes washer water conservation standards and their 

respective effective dates. 

Table 3.7.7 California Water Conservation Standards for Residential Clothes Washers 

Clothes Washer Maximum WF 

Classification Effective January 1, 2007 Effective January 1, 2010 

Top-loading 8.5 6.0 

Front-loading 8.5 6.0 

On December 28, 2006, DOE issued a decision denying the California petition. (71 FR 

78157) The denial of the petition was based on three factors. First, DOE determined that it does 

not have the statutory authority to prescribe a rule for California that would become effective by 

January 1, 2007, the first of two compliance dates contained in Title 20, section 1605.2(p)(1) of 

the California Code of Regulations. Second, DOE ruled that CEC had not established by a 

preponderance of the evidence that the State of California has unusual and compelling water 

interests, a condition required by EPCA for DOE to grant California a waiver from Federal 

preemption. (42 USC 6297(d)(1)(B)) Finally, a preponderance of evidence showed that the 

California regulation would likely result in the unavailability of a class of residential clothes 

washers, specifically top-loader machines, in California. The State has submitted to DOE a 

request for reconsideration.19 

3.7.4 Canadian Energy Conservation Standards 

Canada’s Energy Efficiency Regulations (hereafter Regulations) mandate minimum 

energy conservation standards for dishwashers, dehumidifiers, cooking products, and residential 

clothes washers. 

3-22

EE-2006-STD-0127 COMMENT 39.2
Canadian Regulations stipulate minimum efficiency levels and definitions for residential 

dishwashers which are identical to U.S. Federal standards, mandating an EF of at least 0.46 for 

standard dishwashers and an EF of at least 0.62 for compact dishwashers. 

For dehumidifiers, Canada’s Regulations refer to CAN/CSA-C749-1994 (R2005), 

Performance of Dehumidifiers, which applies to units with capacities 30 L/day (63.4 pints/day) 

or lower, and mandates that the EF for all covered dehumidifiers must be greater than or equal to 

1.00 L/kWh, effective December 31, 1998. 

Canadian Regulations also exist for certain residential cooking products, including 

electric and gas ranges, cooktops, and ovens. The Regulations do not cover microwave ovens. 

Like U.S. DOE standards, Canadian Regulations require that gas cooking products, including 

ranges, ovens, and cooktops, with an electrical supply cord not be equipped with constant 

burning pilots. Table 3.7.8 presents the Regulations for electric cooking products. 

Table 3.7.8 Canadian Energy Conservation Standards for Electric Cooking Products 

Cooking Product Classification Maximum Allowable Energy 

Consumption (kWh/year)* 

Free-standing or built-in ranges with one or more surface 

elements and one or more ovens 2.0V + 458 

Built-in or wall-mounted ranges without surface elements and 

with one or more ovens 2.0V + 200 

Counter-mounted ranges without ovens and with one or more 

surface elements on a conventional (i.e., not modular) cooktop 258 

* Where V = volume of oven in liters 

The Canadian government regulates the efficiency of residential clothes washers. While 

this standard does not directly apply to products covered by this rulemaking, DOE understands 

that this standard may still impact some North American manufacturers in the home appliance 

industry. This Regulation applies to standard or compact electrically operated household clothes 

washers that are top- or front-loaded, and that have an internal control system that regulates the 

water temperature without the need for user intervention subsequent to initiation of machine 

operation. Table 3.7.9 lists the current standards that went into effect January 1, 2007, along 

with the previous standards that went into effect January, 1 2004. 

Table 3.7.9 Canadian Energy Conservation Standards for Residential Clothes Washers 

Clothes Washer Classification Minimum MEF (L/kWh/cycle) 

January 1, 2004 January 1, 2007 

Vertical-axis compact (< 45 liter capacity) 18.40 18.40 

Vertical-axis standard (≥ 45 liter capacity) 29.45 35.68 

Horizontal-axis* 29.45 35.68 

Suds-saving* NA NA 

* These product classes shall be equipped with an unheated rinse water option. 

3-23 

EE-2006-STD-0127 COMMENT 39.2
3.8 VOLUNTARY PROGRAMS 

DOE reviewed several voluntary programs promoting energy-efficient residential 

dishwashers, dehumidifiers and cooking products and commercial clothes washers in the U.S. 

Many programs, including the CEE, Energy Star, and the Federal Energy Management Program 

(FEMP), establish voluntary energy conservation standards for these products. 

3.8.1 Consortium for Energy Efficiency 

 The CEEl

 develops initiatives for its North American members to promote the 

manufacture and purchase of energy efficient products and services. The goal of the 

organization is to induce lasting structural and behavioral changes in the marketplace, resulting 

in the increased adoption of energy-efficient technologies. 

CEE issues voluntary specifications for residential standard-sized dishwashers. Table 

3.8.1 presents the dishwasher efficiency specifications, effective January 2006, under its SuperEfficient Home Appliance Initiative (SEHA). 

Table 3.8.1 CEE Criteria for Residential Dishwashers 

Standard-sized Dishwashers 

Level EF Maximum kWh/yr 

Tier 1 0.65 339 

Tier 2 0.68 325 

Compact-sized Dishwashers 

Level EF Maximum kWh/yr 

Tier 1 0.88 252 

In 1998, CEE launched the Commercial, Family-Sized Washer Initiative as an offshoot of 

its Residential Clothes Washer Initiative. The initiative encourages the purchase and use of 

energy- and water-efficient commercial clothes washers for laundromats, multi-family 

buildings and institutions. Table 3.8.2 presents the current voluntary efficiency specifications for 

the program. In order to qualify, a commercial clothes washer must exceed the minimum MEF 

and remain below a specified WF. 

l

 For more information, please visit www.cee1.org. 

3-24 

EE-2006-STD-0127 COMMENT 39.2
Table 3.8.2 CEE Criteria for Commercial Clothes Washers 

Level MEF WF 

Tier 1 1.80 7.5 

Tier 2 2.00 6.0 

Tier 3 2.20 4.5 

3.8.2 Energy Star 

Energy Star, a voluntary labeling program backed by the EPA and DOE, identifies 

energy-efficient products through a qualification processm. To qualify, a product must exceed 

Federal minimum standards by a specified amount, or if no Federal standard exists, exhibit 

selected energy-saving features. The Energy Star program works to recognize the top quartile of 

products on the market, meaning that approximately 25% of products on the market meet or 

exceed the Energy Star levels. Energy Star specifications exist for several products, including 

dishwashers, dehumidifiers, and commercial clothes washers. 

Prior to January 1, 2007, Energy Star residential dishwasher criteria existed for only 

standard-sized dishwashers. New criteria which became effective January 1, 2007 cover 

standard-sized and compact-sized dishwashers. The current and previous Energy Star criteria for 

residential dishwashers are listed in Table 3.8.3. 

Table 3.8.3 Energy Star Criteria for Residential Dishwashers 

Dishwasher Classification Previous Criteria Level Current Criteria Levels 

Standard dishwasher EF ≥ 0.58 EF ≥ 0.65 

Compact dishwasher NA EF ≥ 0.88 

Energy Star criteria also currently exist for residential dehumidifiers. The criteria, 

divided based on product capacity, are contained in Table 3.8.4 and Table 3.8.5. 

Table 3.8.4 Energy Star Criteria for Standard Capacity Dehumidifiers 

Dehumidifier Capacity (L/day) Current Criteria Levels (L/kWh) 

L/day < 10 EF ≥ 1.20 

10 ≤ L/day < 25 EF ≥ 1.30 

25 ≤ L/day ≤ 35 EF ≥ 1.50 

Table 3.8.5 

Current Criteria Level (L/kWh) 

36 ≤ L/day ≤ 57 EF ≥ 2.25 

Energy Star Criteria for High Capacity Dehumidifiers 

Dehumidifier Capacity (L/day) 

Energy Star criteria exist for top- and front-loading commercial clothes washers with 

capacities greater than 1.6 cubic feet. New Energy Star criteria for commercial clothes washers, 

which include energy and water consumption ratings, became effective January 1, 2007. The 

current criteria and previous criteria are contained in Table 3.8.6. 

m For more information, please visit www.energystar.gov. 

3-25 

EE-2006-STD-0127 COMMENT 39.2
Table 3.8.6 Energy Star Criteria for Commercial Clothes Washers 

Clothes Washer Current Criteria Levels 

Top- and front-loading clothes 

washers MEF ≥ 1.42 MEF ≥ 1.72 WF ≤ 8.0 

3.8.3 

n

 (FEMP) works to reduce the cost and 

commercial clothes washers. 

. 

Table 3.8.7 

Classification Previous Criteria Level 

Federal Energy Management Program 

DOE’s Federal Energy Management Program

environmental impact of the Federal government by advancing energy efficiency and water 

conservation, promoting the use of distributed and renewable energy, and improving utility 

management decisions at Federal sites. FEMP helps Federal buyers identify and purchase 

energy-efficient equipment, including residential dishwashers, microwave ovens, and 

FEMP issues energy-efficiency recommendations for residential standard-sized 

dishwashers Table 3.8.7 presents the dishwasher recommendations. 

FEMP Recommendations for Residential Dishwashers 

Dishwasher Classification Annual Energy Use 

(kWh/yr)* EF 

Standard Dishwasher 380 or less 0.58 

* Based on 215 wash cycles per year 

FEMP estimates that a typical household using electric water heating and upgrading from 

a dishwasher with an EF of 0.46 (DOE minimum standard) to a dishwasher with an EF of 0.58 

will save $70 over the lifetime of the unit (assuming Federal average energy prices). Under the 

same assumptions, a typical household using gas water heating will save $45 over the lifetime of 

the dishwasher. 

Executive Order 13221 Energy Efficient Standby Power Devices, signed July 31, 2001, 

requires that Federal agencies purchase commercially-available products with low standby 

power. (66 FR 40571) FEMP therefore issues standby power recommendations for microwave 

ovens. Table 3.8.8 presents the microwave oven recommendations. 

Table 3.8.8 FEMP Recommendations for Microwave Ovens 

Microwave Oven Classification Standby Power (W)* 

Standard Microwave Oven ≤ 2 

* Based on test procedures specified in IEC 62301

 For commercial clothes washers, FEMP issues energy-efficiency recommendations 

based on washer volume. Table 3.8.9 presents the commercial clothes washer recommendations. 

n

 For more information, please visit www.eere.energy.gov/femp. 

3-26 

EE-2006-STD-0127 COMMENT 39.2
Table 3.8.9 FEMP Recommendations for Commercial Clothes Washers 

Clothes Washer Tub 

Volume 

Annual Energy Use 

(kWh/yr)* MEF 

1.9 - 2.5 cu. ft. 410 or less 2.5 or higher 

2.6 – 3.3 cu. ft. 520 or less 2.5 or higher 

* Based on 392 wash cycles per year (10 CFR Part 430, Subpart B, Appendix J1) 

FEMP estimates that, with electric water heating, replacing a 2.48 ft3. commercial clothes 

washer exhibiting an MEF of 1.80 with a clothes washer exhibiting an MEF of 2.50 will save 

$1,400 over the lifetime of the unit (assuming Federal average energy prices). The same 

replacement with gas water heating will save $800 over the lifetime of the clothes washer. 

3.9 HISTORICAL SHIPMENTS 

Awareness of annual product shipment trends is an important aspect of the market 

assessment and in the development of the standards rulemaking. DOE reviewed data collected 

by the U.S. Census Bureau, EPA, and AHAM to evaluate residential appliance product shipment 

trends and the value of these shipments. Knowledge of such trends will be used during the 

shipments analysis (Chapter 9 of this TSD). 

3.9.1 New Home Starts 

Trends in new home starts may directly affect shipments of certain home appliances. 

While there is certainly both a replacement and remodeling market for some appliances 

including dishwashers and cooking products, these products are also fixtures in virtually all new 

homes. Dehumidifier shipments are not as greatly impacted by new home starts, as they are 

often purchased for use in existing construction. Multi-family unit starts can also affect 

shipments of commercial clothes washers. 

Figure 3.9.1 presents the number of new single-family and multi-family housing units 

started in the U.S. from 1998 to 2005. Over the five-year period from 2000-2005, single-family 

home starts increased 39.4 percent, to 1,716,000 units annually. Multi-family unit starts have 

remained relatively flat over the past seven years, hovering around 350,000 units annually.20 

3-27

EE-2006-STD-0127 COMMENT 39.2
0 

200 

400 

600 

800 

( ) 1,000 

1,200 

1,400 

1,600 

1,800 

2,000 

Housing Units Started thousands of units

1998 1999 2000 2001 2002 2003 2004 2005 

Si il ngle-Fam y Units Mult -Family Units i

Figure 3.9.1 New Privately Owned Single-Family and Multi-Family 

Housing Unit Starts in the U.S. from 1998-2005 21 

3.9.2 Unit Shipments 

AHAM’s 2005 Fact Book provides annual unit shipments for residential dishwashers, 

dehumidifiers, and cooking products. Table 3.9.1 presents the annual shipments of dishwashers 

and dehumidifiers for the 10-year period from 1995 to 2005. The shipments of built-in 

dishwashers increased over 76 percent from 1995 to 2005, while the shipments of portable 

dishwashers have declined 35 percent from 1995 to 2005. After a period of decline from 1995 to 

2002, shipments of dehumidifiers increased sharply in 2003 and have continued to rise through 

2005. Shipments of dehumidifiers nearly doubled between 1995 and 2005. 

3-28

EE-2006-STD-0127 COMMENT 39.2
Table 3.9.1 Industry Shipments of Dishwashers and Dehumidifiers (Domestic and 

Import in Thousands of Units) 22 

Year Dishwashers Dehumidifiers Built-In Portable Total 

2005 7,294 133 7,428 1,957 

2004 6,953 153 7,106 1,672 

2003 6,280 148 6,428 1,311 

2002 6,049 158 6,207 799 

2001 5,478 149 5,627 806 

2000 5,663 164 5,827 975 

1999 5,542 170 5,712 950 

1998 4,969 175 5,144 1,031 

1997 4,653 173 4,826 820 

1996 4,417 189 4,606 977 

1995 4,141 205 4,346 1,003 

Table 3.9.2 presents annual shipments of cooking products. In the 10-year period from 

1995 to 2005, shipments of electric and gas free-standing ranges and surface cooking units, 

electric built-in ranges, and microwave ovens increased, while shipments of built-in gas ranges 

decreased. 

Table 3.9.2 Industry Shipments of Cooking Products (Domestic and Import in 

Thousands of Units) 23 

Year 

Cooking Products 

Electric Ranges Gas Ranges 

Microwave 

Ovens 

FreeStanding 

Built-In 

Surface 

Cooking 

Units 

Total FreeStanding 

BuiltIn 

Surface 

Cooking 

Units 

Total 

2005 4,685 973 542 6,201 3,139 64 560 3,762 13,862 

2004 4,612 963 570 6,145 3,124 67 528 3,719 15,526 

2003 4,238 841 543 5,622 2,897 67 455 3,419 14,274 

2002 4,030 780 528 5,338 2,781 71 416 3,268 13,311 

2001 3,842 726 498 5,066 2,580 72 384 3,036 13,446 

2000 3,826 706 494 5,026 2,729 70 377 3,176 12,644 

1999 3,785 705 493 4,983 2,698 72 367 3,137 11,422 

1998 3,481 652 506 4,639 2,543 71 336 2,950 10,365 

1997 3,177 617 446 4,240 2,391 73 280 2,744 8,883 

1996 3,123 614 418 4,155 2,366 72 272 2,710 8,771 

1995 2,931 598 389 3,917 2,391 84 240 2,715 8,162 

Energy Star shipment data for residential dishwashers and clothes washers may also 

prove useful during this standards rulemaking. Table 3.9.3 presents the 2005 breakdown of 

Energy Star versus non-Energy Star shipments for residential dishwashers and clothes washers. 

3-29 

EE-2006-STD-0127 COMMENT 39.2
Table 3.9.3 2005 Energy Star Shipments by Product (Domestic and Import) 

Product 

Shipments % Energy 

Star of 

Total24 Energy StarQualified Other Total25 

Dishwashers 

(Built-In and 

Portable) 

6,092,000 1,336,000 7,428,000 82.0% 

Residential 

Clothes Washers 3,424,000 5,970,000 9,394,000 36.5 

3.9.3 Value of Shipments 

Table 3.9.4 provides the value of shipments for the household appliance industry from 

1994 to 2005 based upon data from the U.S. Census Bureau Annual Survey of Manufacturers 

(ASM)o

, to develop this data set. The ASM expresses all dollar values in nominal dollars, i.e., 

2005 data are expressed in 2005 dollars, and 2004 dollars are expressed in 2004 dollars. Using 

the Gross Domestic Product Implicit Price Deflator, DOE converted each year’s value of 

shipments to 2005 dollars. In constant 2005 dollars, the value of shipments has declined by 

nearly 14 percent over the 12-year period. 

Table 3.9.4 Household Appliance Manufacturing Statistics by Year26 

Year Value of Shipments in 

Nominal Dollars ($1000) 

Value of Shipments in 2005 

Dollars ($1000) 

2005 24,620,117 24,620,117 

2004 23,501,067 24,393,186 

2003 23,026,196 24,489,495 

2002 22,269,541 24,117,884 

2001 22,298,897 24,548,244 

2000 23,414,965 26,396,138 

1999 22,372,219 25,770,856 

1998 22,471,878 26,259,645 

1997 21,394,445 25,277,836 

1996 22,156,900 26,614,687 

1995 21,776,200 26,652,765 

1994 22,793,900 28,469,992 

The increase in shipment volumes combined with an overall decrease in constant-dollar 

shipment values indicates that the U.S. appliance industry is very competitive. 

According to data presented in the AHAM 2003 Fact Book, many old appliances are still 

being used after consumers purchase new units of same product. Table 3.9.5 presents the various 

methods by which consumers dispose of their older appliances. 

o

 Available online at http://www.census.gov/mcd/asm-as1.html. 

3-30 

EE-2006-STD-0127 COMMENT 39.2
Table 3.9.5 Disposition of Previous Appliance (Percentage)27 

Product Kept It 

Left with 

Previous 

Home 

Sold / 

Gave 

Away 

Recycling 

Facility 

Left at 

Curb for 

Disposal 

Retailer 

Took 

Away 

Dishwashers 4 37 15 14 11 20 

Dehumidifiers 18 14 23 13 24 4 

Ranges 6 37 21 13 8 15 

Built-In Ranges 4 46 11 15 12 13 

Microwave Ovens 17 11 32 12 23 4 

Shipments of residential cooking products, a subset of the household appliance industry 

as defined in the ASM, have fluctuated over the last 12 years when viewed in 2005 real dollars. 

Overall, the real value of shipments increased over 7 percent over the 12 year period from 1994­

2005, however this is not representative of a steady upwards trend in shipment values. Table 

3.9.6 provides the industry value of shipments for household cooking appliance manufacturing 

for the 12-year period from 1994-2005. 

Table 3.9.6 Household Cooking Appliance Manufacturing Statistics by Year28 

Year Value of Shipments in 

Nominal Dollars ($1000) 

Value of Shipments in 2005 

Dollars ($1000) 

2005 5,114,677 5,114,677 

2004 4,699,530 4,877,928 

2003 4,691,713 4,989,868 

2002 4,327,908 4,687,119 

2001 3,773,442 4,154,079 

2000 4,178,958 4,711,019 

1999 3,915,499 4,510,315 

1998 3,849,167 4,497,967 

1997 3,520,635 4,159,680 

1996 3,564,700 4,281,889 

1995 3,917,600 4,794,908 

1994 3,813,900 4,763,630 

3.9.4 Imports and Exports 

There is a large market for the import and export of home appliances. Each month 

AHAM publishes import and export data for certain home appliances. This data is released by 

the U.S. Census Bureau and aggregated by a third party. On the whole, major appliance unit 

imports increased 1.8 percent in 2005 as compared to 2004. Major appliance unit exports 

increased 13.5 percent over the same period. 

Table 3.9.7 shows selected import data from AHAM’s 2005 Year End Import Export 

Report.

29 For microwave ovens less than or equal to 22.5 inches in width, the number of units 

decreased, while the value of units increased. For dishwashers and microwave ovens greater 

than 22.5 inches in width, both the number and value of units imported increased from 2004 to 

2005. For non-portable cooking products, dehumidifiers, coin-operated washing machines, and 

3-31

EE-2006-STD-0127 COMMENT 39.2
electric stoves, ranges, and ovens, both the number and value of units imported decreased over 

the one-year period. 

Table 3.9.7 2004-2005 Imports of Appliances Covered by this Rulemaking 30 

Appliance 

Description 

Jan. – 

Dec. 2005 

Jan. – 

Dec. 2004 % 

Change 

Jan. – 

Dec. 2005 

Jan. – 

Dec. 2004 % 

Change Units $ Mil (Nominal) 

Non-portable cooking 

products 1,394,743 1,564,979 -10.9 328.194 355.584 -7.7 

Refrigeration-based 

dehumidifiers <35 

pints/day 

47,930 66,820 -28.3 5.436 6.549 -17.0 

Refrigeration-based 

dehumidifiers ≥35 

pints/day 

17,544 33,339 -47.4 22.343 23.498 -4.9 

Household 

dishwashers 345,125 278,599 23.9 131.383 95.721 37.3 

Coin-operated washing 

machines 3,499 3,793 -7.8 4.900 4.968 -1.4 

Microwave ovens ≤

22.5 inches 5,613,888 6,292,741 -10.8 175.928 170.289 3.3 

Microwave ovens > 

22.5-31.0 inches 3,810,091 3,769,801 1.1 159.326 156.767 1.6 

Microwave ovens > 

31.0 inches 7,471,712 6,288,165 18.8 660.397 561.663 17.6 

Electric stoves, ranges, 

and ovens 2,803,897 3,436,301 -18.4 391.214 420.899 -4.8 

Table 3.9.8 shows selected export data from AHAM’s 2005 Year End Import Export 

Report.

31 For the one-year period from 2004 to 2005, unit exports of non-portable cooking 

products decreased, and the value of exports decreased. For the same time period, the number of 

microwave oven exports increased, but the value of microwave ovens exported decreased. For 

dehumidifiers, dishwashers, and electric stoves, ranges, and ovens, both the number and value of 

exports increased from 2004 to 2005. Overall, the total value of exports increased over 21 

percent. 

3-32

EE-2006-STD-0127 COMMENT 39.2
Table 3.9.8 2004-2005 Exports of Appliances Covered by this Rulemaking 32 

Appliance 

Description 

Jan. – 

Dec. 2005 

Jan. – 

Dec. 2004 % 

Change 

Jan. – 

Dec. 2005 

Jan. – 

Dec. 2004 % 

Change Units $ Mil (Nominal) 

Non-portable cooking 

products 105,894 117,226 -9.7 55.302 57.566 -3.9 

Refrigeration-based 

dehumidifiers 14,125 8,554 65.1 10.914 7.961 37.1 

Household 

dishwashers 527,983 517,223 2.1 134.299 127.123 5.6 

Coin-operated washing 

machines 120,958 109,737 10.2 43.259 36.859 17.4 

Microwave ovens 276,523 258,515 7.0 36.841 39.020 -5.6 

Electric stoves, ranges, 

and ovens 444,685 290,901 52.9 242.602 162.346 49.4 

3.10 MARKET SATURATION 

AHAM’s 2005 Fact Book presents the market saturation for dishwashers, dehumidifiers, 

and cooking products. While the percentage of U.S. households with electric ranges and/or 

cooktops and microwave ovens has decreased slightly since 2001, the market saturation of 

dishwashers, dehumidifiers, and gas cooking products has increased. Table 3.10.1 presents the 

appliance saturation and percentage of U.S. households with each product as reported in the 

AHAM 2005 Fact Book. The number of U.S. households with each product is based on U.S. 

Census Bureau projections of occupied units in the relevant year. 

Table 3.10.1 Appliance Saturation (Number in Millions) and Percentage of U.S. 

Households with Product 33 

Product 

1970 1982 1990 2001 2005 

# % # % # % # % # % 

Dishwashers 12 18.9 37.2 44.5 50.3 53.9 61.8 59.3 80.2 73.7 

Dehumidifiers NA NA 9.2 11 15.6 16.7 14.7 14.1 20.6 18.9 

Electric Ranges 

/ Cooktops* 25.8 40.6 48.4 58 58.4 62.6 69.2 66.3 71 65.3 

Gas Ranges / 

Cooktops* 36.6 57.7 35.7 42.7 36.1 38.7 39.4 37.8 42.2 39 

Microwave 

Ovens Neg. Neg. 21.4 25.6 77.2 82.7 94.6 90.7** 97.2 89.3 

* Cooktops not included in 1970 or 1982 data 

** Includes over-the-range and countertop microwave ovens 

3-33 

EE-2006-STD-0127 COMMENT 39.2
3.11 PRODUCT RETAIL PRICES 

Table 3.11.1 presents the average retail prices (in nominal dollars) of several residential 

appliances and the consumer price index (CPI) of each year (1982-84 = 100). Although prices 

for electric and gas ranges have increased since 1980, the increase has been at a much slower rate 

than the annual rate of inflation. Prices of residential dishwashers, dehumidifiers, microwave 

ovens, and automatic clothes washers have decreased in the same time period. 

Table 3.11.1 Residential Appliance Retail Prices 34 

Product Average Retail Prices (Nominal $) Percent 

Change 

1980 1994 2002 2005 1980-2005 

Dishwashers 353 395 400 284 -19.5% 

Dehumidifiers 154 177 112 102 -33.8% 

Electric Ranges 412 503 508 444 7.8% 

Gas Ranges 380 499 497 462 21.6% 

Microwave Ovens 450 239 145 99 -78.0% 

Automatic Clothes Washers 386 394 426 359 -7.0% 

Consumer Price Index* 82.4 148.2 179.9 195.3 137.0% 

* U.S. Department of Labor, Bureau of Labor Statistics, Consumer Price Index: U.S. city average. 1982-84 = 100. 

In the above table, automatic clothes washers pertain to residential clothes washers, not 

commercial clothes washers. As a result, DOE conducted a limited search of consumer retail 

prices for commercial clothes washers by telephoning five commercial laundry distributors and 

gathering data from four internet retailers. Table 3.11.2 summarizes the data collected by DOE. 

Most of the distributors and internet retailers provided a range of prices for each washer model. 

Only the average price for each model is provided in the table below. 

3-34

EE-2006-STD-0127 COMMENT 39.2
Table 3.11.2 Commercial Clothes Washer Retail Prices 

Source Source Type Manufacturer Brand Model Number Coin Box Loading AbsoluteHome.com35 Internet Whirlpool Whirlpool CAM2752RQ Yes Top-Load 

AbtElectronics.com36 Internet General Electric Roper RAK2751WWH Yes Top-Load 

AbtElectronics.com Internet Whirlpool Whirlpool CAM2752WH Yes Top-Load 

AbtElectronics.com Internet Whirlpool Maytag MAT12CSWH Yes Top-Load 

AJMadison.com37 Internet Whirlpool Whirlpool CAM2752RQ Yes Top-Load 

Commercial & Coin Laundry Equip.38 Distributor Whirlpool Whirlpool N/A Yes Top-Load 

Commercial & Coin Laundry Equip. Distributor Alliance Speed Queen N/A Yes Top-Load Commercial Laundry Equipment39 Distributor Alliance Speed Queen SWTBA1WN Yes Top-Load 

Gold Coin Laundry Equipment40 Distributor General Electric General Electric WCCB1030F Yes Top-Load 

Gold Coin Laundry Equipment Distributor General Electric General Electric WCCB2050 Yes Top-Load 

Mac-Gray Services41 Distributor Whirlpool Maytag MAT12PDSWW Yes Top-Load 

Texas Laundry Service42 Distributor Alliance Speed Queen JWT110, SWTB20 Yes Top-Load 

AbtElectronics.com Internet Frigidaire Frigidaire FCCW3000WH Yes Front-Load 

Commercial Laundry Equipment Distributor Alliance Speed Queen SWFB61WN Yes Front-Load 

Gold Coin Laundry Equipment Distributor General Electric General Electric WCCH404VWW Yes Front-Load Laundry Systems43 Internet Electrolux Wascomat WE16 Yes Front-Load 

Mac-Gray Services Distributor Whirlpool Maytag MAH21PDAWW Yes Front-Load 

Texas Laundry Service Distributor Alliance Speed Queen SWRF961, SWFB63 Yes Front-Load 

AbsoluteHome.com Internet General Electric General Electric WNRD2050DWC No Top-Load 

AbtElectronics.com Internet Whirlpool Maytag MAT13MNWH No Top-Load 

AJMadison.com Internet General Electric General Electric WNRD2050D No Top-Load 

Commercial & Coin Laundry Equip. Distributor N/A N/A N/A No Top-Load 

Commercial Laundry Equipment Distributor Alliance Speed Queen LWF02N No Top-Load 

Gold Coin Laundry Equipment Distributor General Electric General Electric WNRD2050D No Top-Load 

Mac-Gray Services Distributor Whirlpool Maytag MAT12PN No Top-Load 

Texas Laundry Service Distributor Alliance Speed Queen LWS01, LWS49 No Top-Load 

Commercial & Coin Laundry Equip. Distributor Alliance Speed Queen N/A No Front-Load Commercial Laundry Equipment Distributor Alliance Speed Queen LTF90AWM No Front-Load 

Laundry Systems Internet Frigidaire Wascomat WE16 No Front-Load 

Laundry Systems Internet Alliance Huebsch FTZ91AWN11 No Front-Load Laundry Systems Internet Alliance Huebsch HWFT61 No Front-Load 

Mac-Gray Services Distributor Whirlpool Maytag MAH21PNAWW No Front-Load 

Texas Laundry Service Distributor Alliance Speed Queen LTS90, FTS90 No Front-Load 

3-35 

EE-2006-STD-0127 COMMENT 39.2
DOE was unable to establish either the energy or water efficiency of all the washers for 

which it collected retail prices. Therefore, a retail price and efficiency relationship could not be 

established. But based on the price data collected, it was evident that price was a function of the 

type of loading (i.e., top-loading or front-loading). Thus, DOE was able to determine a gross 

estimate of the retail price difference between a relatively inefficient top-loading washer and a 

high-efficiency front-loading washer. DOE also determined that price was a function of whether 

the washer was equipped with a coin box. As a result, DOE grouped the retail price data into 

four categories based on loading type and the presence of a coin box. To demonstrate the impact 

of the loading type and coin box on retail price, Figure 3.11.1 depicts the price data listed in 

Table 3.11.2. Noted in Figure 3.11.1 is the average retail price of each of the four groups into 

which DOE segregated the data. Consumer Price 

$1,750 

$1,500 

$1,250 

$1,000 

$750 

$500 

Coin Box 

No Coin Box 

Avg Price = $824 

Average Price = $697 

Average Price = $1355 Avg Price = $1332 

Top-Loading Front-Loading 

Figure 3.11.1 Commercial Clothes Washer Retail Prices as a Function of LoadingType and Presence of Coin Box 

Figure 3.11.1 demonstrates that the average price difference between top-loading and 

front-loading washers varies between $531 for washers with coin boxes and $625 for washers 

without coin boxes. The above difference provides a rough estimate of the impact on current 

retail pricing from moving to a conventional top-loading washer (i.e., a washer with a verticalaxis agitator that submerges the clothes into a tub filled with water) to a conventional frontloading washer (i.e., a washer with a horizontal axis that tumbles the clothes through a pool of 

water). 

As will be shown in Chapter 8 of the TSD, DOE used manufacturing costs developed for 

specific standard levels in combination with manufacturer and distributor markups, sales taxes, 

and installation costs to establish the total installed cost differences between baseline and more 

3-36 

EE-2006-STD-0127 COMMENT 39.2
efficient commercial clothes washers. DOE used the above range in current retail price 

differences between top-loading and front-loading washers as an indication of the reasonableness 

of the total installed cost estimates that it developed for commercial clothes washers. 

3.12 INDUSTRY COST STRUCTURE 

DOE developed the household appliance industry cost structure from publicly available 

information from the ASM, (Table 3.12.1 and Table 3.12.2) and the Securities and Exchange 

Commission (SEC) 10-K reports filed by publicly owned manufacturers (summarized in Table 

3.12.3). Table 3.12.1 presents the home appliance industry employment levels and earnings 

from 1994-2005. The statistics illustrate a steady decline in the number of production and nonproduction workers in the industry. 

Because the ASM expresses all dollar values in constant 2005 dollars, the following table 

shows that as industry employment levels decline, the industry payroll is also decreasing. The 

percent decrease in total industry employees tracks closely with the percent decrease in payroll 

for all employees. 

Table 3.12.1 Household Appliance Industry Employment and Earnings

 44 

Year Production Workers 

(‘000) 

All Employees 

(‘000) 

Payroll for All Employees 

(2005 $ Mil) 

2005 64.3 76.9 2,699.2 

2004 69.4 83.7 3,003.8 

2003 71.0 85.3 3,068.4 

2002 73.5 89.7 3,242.0 

2001 76.6 92.6 3,397.6 

2000 82.7 99.5 3,706.4 

1999 82.3 97.9 3,586.0 

1998 82.4 99.5 3,610.3 

1997 79.8 97.2 3,446.2 

1996 87.1 108.1 3,689.8 

1995 87.7 110.1 3,744.3 

1994 90.4 110.4 3,736.4 

Table 3.12.2 presents the costs of materials and industry payroll as a percentage of value 

of shipments from 1994-2005. The cost of materials as a percentage of value of shipments has 

fluctuated slightly over the 12-year period. DOE notes that fluctuations in raw material costs are 

common from year to year. The cost of payroll for production workers as a percentage of value 

of shipments has declined since 2000. Similarly, the cost of total payroll as a percentage of 

value of shipments has declined since 2000. 

3-37 

EE-2006-STD-0127 COMMENT 39.2
Table 3.12.2 Household Appliance Industry Census Data 45 

Year 

Cost of Materials as 

a Percentage of 

Value of Shipments 

(%) 

Cost of Payroll for 

Production Workers as 

a Percentage of Value of 

Shipments (%) 

Cost of Total Payroll 

(Production + Admin.) 

as a Percentage of Value 

of Shipments (%) 

2005 56.9 8.3 11.0 

2004 57.3 9.1 12.2 

2003 56.5 9.2 12.5 

2002 55.3 9.7 13.4 

2001 56.8 10.1 13.8 

2000 55.8 10.2 14.0 

1999 54.7 10.2 13.9 

1998 56.0 10.0 13.7 

1997 52.8 9.9 13.6 

1996 56.8 9.9 13.9 

1995 55.1 9.7 14.0 

1994 55.5 9.2 13.1 

Table 3.12.3 presents the industry cost structure derived from SEC 10-K reports of 

publicly-owned home appliance manufacturers. DOE averaged the financial data from 2002­

2005 of several companies to obtain an industry average. Each financial statement entry is 

presented as a percentage of total revenues. 

Table 3.12.3 Industry Cost Structure Using SEC Data 

Financial Statement Entry Percent of 

Revenues 

Cost of sales 79.5% 

Net income 1.2% 

Selling, general and administrative 13.2% 

Capital expenditure 3.2% 

Research and development 2.1% 

Depreciation and amortization 3.1% 

Net plant, property and equipment 17.8% 

Working capital 1.0% 

A detailed financial analysis of each of the four products covered by this rulemaking is 

presented in the MIA (Chapter 12 of this TSD). This analysis identifies key financial inputs 

including cost of capital, working capital, depreciation, capital expenditures, etc. 

3-38 

EE-2006-STD-0127 COMMENT 39.2
3.13 INVENTORY LEVELS AND CAPACITY UTILIZATION RATES 

Table 3.13.1 shows the year-end inventory for the household appliance industry, 

according to the ASM. Both in dollars and as a percentage of value of shipments, the end-ofyear inventory for the industry has steadily declined since 1995. This data illustrates that 

domestic manufacturers are retaining less of their inventories each consecutive year. 

Table 3.13.1 Household Appliance Industry Census Data 46 

Year End-of-Year Inventory 

(2005 $ Mil) 

End-of-Year Inventory as a 

Percentage of Value 

of Shipments (%) 

2005 1,633.0 6.6 

2004 1,746.9 7.2 

2003 1,811.9 7.4 

2002 1,942.0 8.1 

2001 2,159.6 8.8 

2000 2,440.2 9.2 

1999 2,431.9 9.4 

1998 2,621.4 10.0 

1997 2,519.0 10.0 

1996 2,761.7 10.4 

1995 3,049.9 11.4 

1994 3,035.2 10.7 

DOE obtained full production capacity utilization rates from the U.S. Census Bureau, 

Survey of Plant Capacity from 1994 to 2004. Table 3.13.2 presents utilization rates for various 

sectors of the household appliance industry. Full production capacity is defined as the maximum 

level of production an establishment could attain under normal operating conditions. In the 

Survey of Plant Capacity report, the full production utilization rate is a ratio of the actual level of 

operations to the full production level. The full production capacity utilization rate for 

household appliances in aggregate, along with the rates for cooking appliances and household 

laundry appliances, show a decrease in utilization from 1994 to 2004, although trends in subsets 

of that time period have fluctuated. 

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Table 3.13.2 Full Production Capacity Utilization Rates47 

Year Rates (%) 

Household Appliances Cooking Appliances Household Laundry 

2004 76 61 77 

2003 78 57 85 

2002 72 56 87 

2001 70 50 90 

2000 70 55 88 

1999 75 59 87 

1998 73 66 75 

1997 73 61 80 

1996 76 66 81 

1995 79 66 83 

1994 82 72 89 

3.14 TECHNOLOGY ASSESSMENT 

This section provides a technology assessment for residential dishwashers, dehumidifiers, 

and cooking products and commercial clothes washers. Contained in this technology assessment 

are details about product characteristics and operation (section 3.14.1), an examination of 

possible technological improvements for each product (section 3.14.2) and a characterization of 

the product efficiency levels currently commercially-available (section 3.14.3). 

3.14.1 Product Operations and Components 

In preparation for the screening and engineering analyses, DOE prepared a brief 

description of the characteristics and operation of each product covered by this rulemaking. 

These descriptions provide a basis for understanding the technologies used to improve product 

efficiency. 

3.14.1.1 Dishwashers 

Residential dishwashers are a product designed to clean dishes, utensils, and cookware by 

using a solution of detergent and heated water. Dishwashers spray this solution from rotating 

spray arms onto the dishes in order to clean and sterilize them. Dishwashers use electricity to 

power an electric motor for the pump system that circulates the wash solution, a heating element 

which heats the wash solution and assists in drying the dishes, and an optional drain pump. In 

addition, dishwasher controls consume some electricity and some dishwashers contain a drying 

fan which circulates hot air through the dishwasher to aid dish drying. Although most 

dishwashers are capable of heating water with their internal heating element, dishwashers in the 

U.S. are connected to the hot water line to supply hot water. Water is automatically fed to the 

dishwasher through an electrically-operated water valve connected to the hot water pipe. The 

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dishes, utensils, and cookware are washed, rinsed and dried within a tub that is inside the 

dishwasher cabinet. 

Dishwashers are traditionally front-loading appliances. The door on the front of the 

cabinet cantilevers down, and the washer racks slide out on railings for loading and unloading. 

When the dishwasher is loaded and the washer racks are slid into the dishwasher cabinet, the 

cabinet door is closed, sealing the tub, and a door switch indicates that the door latch has sealed 

the cabinet door. The dishwasher controls, which may be electromechanical or electronic, can 

then begin the wash cycle. 

The wash cycle begins when the water fill valve fills the dishwasher tub until the control 

timer indicates a complete fill, or the dishwasher float switch indicates that the tub is full, or a 

water meter indicates a sufficient amount of water has entered the tub.. The main pump, which 

provides pressurized fluid to the dishwasher spray arms, is attached to the sump of the tub, where 

water accumulates. The pump, which uses a rotating impeller to pressurize the fluid and deliver 

it to the spray arms, is connected directly to the electric motor, or connected by a belt or other 

form of transmission. The heating element can be part of the sump or installed above it. The 

heating element ensures the water is heated to an adequate temperature for cleaning. The 

detergent is released from an electrically-controlled detergent container which is filled with 

detergent prior to initiating the dishwashing cycle. 

Dishwashers can be further segregated, depending on whether they feature one or two 

pumps. On a one-pump model, the main pump not only pressurizes the wash and rinse system, 

but it can also be used to drain the wash fluid, either by reversing the pump direction (forcing the 

fluid out the drain), or by using a diverting valve located on the pump output line. Dishwashers 

with two pumps use one pump optimized for cleaning and rinsing procedures and a second pump 

optimized for draining. After each drain cycle (until the cleaning cycle ends), the tub is refilled 

with water for rinse or wash operations. Dishwashers may drain and refill the tub multiple times 

during the dishwashing cycle as the washing and rinsing water becomes soiled. In some 

dishwashers this process is controlled by a timer, while other dishwashers use sensors and 

electronic controls to determine when to change the water, the amount of water for each fill, 

water temperatures in each cycle, and other variables. 

The heating element is activated to heat the dishwasher cabinet and speed up drying once 

the dishwasher completes the rinse and drain cycles. Dishwashers with an additional drying fan 

and air heater utilize these devices during the drying phase of the wash cycle. 

Some dishwashers use separate drawers for each washing rack, instead of one large tub 

with two or more racks running on extensible rails. These multi-drawer dishwashers are 

essentially two small dishwashers stacked on top of each other. This two-drawer system allows 

users to run the dishwasher with smaller loads without wasting the water or energy a full-size 

dishwasher would use on a half-empty load. 

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3.14.1.2 Dehumidifiers 

Residential dehumidifiers are portable, refrigeration-based appliances that enable 

homeowners to reduce indoor relative humidity (RH). RH is defined as the amount of water 

vapor present in the air compared to the maximum amount of water vapor the air can hold at that 

temperature. A desirable indoor RH is typically between 30 and 50 percent. Dehumidifiers are 

classified according to the amount of water that can be extracted from the air in a 24-hour period. 

Dehumidifiers contain refrigeration systems that remove latent heat, and therefore 

moisture, from ambient air. Components of the refrigeration system include an evaporator, a 

condenser, and a compressor. 

Refrigeration-based dehumidifiers operate as follows: 

1. A circulating fan draws air into the dehumidifier via an intake vent, and pulls it across 

an evaporator heat exchanger that is cooled by an electrically-powered vapor 

compression refrigeration system; 

2. The evaporator cools the air, and moisture from the air condenses on the surface of 

the evaporator and drains either into a bin or a floor drain; and 

3. The drier air is then typically pulled over a warm condenser heat exchanger and the 

compressor. It subsequently exits the dehumidifier via an outlet. 

This process is illustrated in Figure 3.14.1. 

Expansion

Humid Air Dry Air 

Evaporator Condenser 

Compressor 

Condensate 

Bin 

Fan 

Humid Air Dry Air

Evaporator Condenser

Compressor

Condensate 

Bin

Fan

Figure 3.14.1 Dehumidifier Operation Schematic 

When the surface temperature of the evaporator is lower than the dew point of the air 

passing over it, the removal of latent heat occurs through condensation. All residential 

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dehumidifiers are equipped with an automatic shut-off function that halts operation of the device 

once the condensate collection tank is full. They may also include a direct drain hose 

connection, allowing for direct drainage of condensate into a sump pump or floor drain. 

There is a wide scope of control strategies, ranging from simple on/off mechanical 

humidistats and single-speed fans to electronic controllers that use multiple sensors, liquidsolenoid controls, and other devices to maximize unit performance. All dehumidifiers sense the 

evaporator coil or liquid line temperature to prevent icing, though the sensors can vary from 

simple on/off devices to thermistors potted in sensor wells. 

The electrically-powered components of the refrigeration-based dehumidifier system 

include: the fan motor; the compressor that powers the refrigeration system; any electronic 

sensors or controls; and a (optional) built-in sump pump or similar accessory. 

3.14.1.3 Cooking Products 

Residential cooking products are appliances that enable the homeowner to heat and cook 

foods by means of transfer of input energy to the food load. Input energy may be electricity, gas, 

or a combination of the two. Cooktops consist of a horizontal surface comprising one or more 

heating elements. A cooking vessel is placed on the top surface of the cooktop over the element 

to facilitate heat transfer to the food load. In conventional and microwave ovens, the cooking 

vessel is placed inside a cavity within which the energy transfer takes place. Ranges incorporate 

both an oven and a cooktop in a single unit. 

In a gas cooktop, pressurized natural gas or propane is supplied to each burner by means 

of an orifice and venturi on the underside of the cooktop surface. A sheet metal box encloses the 

array of burner supply lines as well as the controls for gas delivery and ignition, if provided. 

Primary air drawn from within the enclosure mixes with the gas at the venturis and is delivered 

to the ports typically arrayed radially on the burners above the cooktop surface. Gas flow and 

thus burner turndown is controlled by individual, typically rotary, valves connected to the burner 

supply lines. Upon ignition of the gas-air mixture, secondary air is entrained near the burner 

ports to produce a substantially radial distribution of flames. For sealed burners in which the 

cooktop surface interfaces directly with the base of each burner, all secondary air is introduced 

above the cooktop surface. Open burners can derive some secondary air from the box as well. 

Grates positioned above the burners allow a cooking vessel to be placed at the proper spacing to 

ensure adequate secondary air for complete combustion, minimization of carbon monoxide 

emissions, and adequate convective heat transfer for cooking efficiency. 

The simplest ignition scheme for a gas cooktop utilizes a standing pilot, through which a 

small amount of gas is continuously supplied and burned as the ignition source for the burners. 

Gas cooktops equipped with electrical cords cannot have a constant burning pilot (42 U.S.C. 

6295 (h)(1)) and instead utilize some form of electrically-powered ignition, typically an 

intermittently-activated spark ignitor. An electronic control module may automatically energize 

the spark electrode whenever flame extinction is detected; otherwise the spark ignitor must be 

manually reactivated by means of switches on the burner valve controls in the event of flame 

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loss. Controls for the burners typically consist of manual burner adjustment as dictated by the 

rotary valve position. In order to achieve very low firing rates associated with such cooking 

processes as simmering, melting chocolate or heating delicate sauces, some cooktops incorporate 

electronic controls that cycle burners on and off. 

An electric cooktop consists of a horizontal surface with one or more electricallypowered heating elements located either above or below the cooktop surface. When the 

elements are located above the cooktop surface, the cooking vessel is placed directly on an 

element to heat the vessel and contents through conductive heat transfer. The elements are 

resistively heated by means of the current supplied to them. An open coil-type cooktop utilizes a 

spiral-wound sheathed heating element. Removable drip bowls beneath each element serve as 

catch basins for spills. Solid disk elements contain a similar resistive element embedded in a 

flat, circular cast iron housing to provide a more even heating surface and greater cleanability 

than for a coil element. Due to this difference in cleanability, solid disk elements are classified 

as a separate product class from open coil elements. 

Heating elements may also be located under a glass-ceramic cooktop surface. Such 

elements may be of a radiant, halogen, or inductive type, which will be described in more detail 

under the technology options in section 3.14.2.3. Each of these technologies is categorized in the 

smooth cooktop product class along with solid disk elements. Electronic control systems are 

provided to energize the desired heating elements. These controls may incorporate algorithms 

for modulation of the element according to cooktop and cooking process parameters. 

Gas ovens are appliances designed to bake, roast, or broil foods within an insulated 

cavity by means of the combustion of natural gas or propane. The major components of the oven 

include the cavity, the gas burners, an ignition system, and a control system. If the oven 

incorporates a convection cooking mode, one or more fans are situated within the cavity to 

provide a means for forced-air distribution. 

The oven cavity is a formed sheet metal enclosure with provision for holding cooking 

racks at varying positions. The interior surface of the cavity may be bare metal (stainless steel), 

or it may have a porcelainized coating for durability and cleanability. Additives in the porcelain 

coating can provide catalytic conversion of food spilled on the surface under normal cooking 

temperatures, thus enabling a continuous cleaning process. Alternatively, the oven may have 

features that allow it to be operated under a special self-clean mode, which heats the cavity to 

higher temperatures than those used for cooking. In the process, food spills are pyrolized, 

leaving an ash residue that is easily wiped off when the cavity cools down. 

Accessories such as lights and sensors for control of cooking processes are located within 

the cavity, while an insulated glass window in the oven door allows observation of the cooking 

processes without requiring the door to be opened (which would incur substantial heat loss). The 

outside of the cavity is wrapped with insulation to minimize heat loss to ambient surroundings. 

The space between the cavity and the outer sheet metal enclosure which is filled by the insulation 

typically is made as small as practically possible in order to maximize the cavity volume. 

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Gas burners are situated at the bottom of the cavity for the bake function and the top for 

broiling. They are typically shielded by baffles or covers to protect the burners from spills and to 

help distribute heat evenly. Broil elements may also be of a radiant type in which the 

combustion of the fuel-air mixture heats a perforated ceramic matrix or a metal mesh. As the 

ceramic or metal heats, it emits infrared radiation that can produce heating and surface browning 

of the cooking load. Combustion products from each burner and gases released during the 

cooking process are vented from the top of the cavity. 

Ignition may be achieved through the use of a pilot or a hot surface ignitor. In the case of 

a pilot, it may be a continuously burning standing pilot type, or an intermittently actuated spark 

ignitor may be used to light the pilot when the oven controls are turned on. In either case, the 

pilot serves to heat a thermally-actuated switch that keeps the main gas valve open. With hot 

surface ignition, a ceramic heating element is placed in a location where the incoming gas-air 

mixture will impinge on it. As the element is heated electrically, its resistance goes down and 

current draw goes up. A bi-metallic gas valve in electrical series with the ignitor deforms as its 

corresponding current increases, allowing gas flow as long as the hot surface ignitor is energized 

by the burner controller. 

Like gas ovens, electric ovens are designed to bake, roast, or broil food. The cavity is 

similar to those of gas ovens as well, in that the surface finishes may be bare or porcelainized, 

with or without the catalytic properties. In addition, electric ovens may incorporate a self-clean 

mode for pyrolysis of food matter on in the interior surfaces. Accessories and insulation tend to 

be similar between gas and electric ovens, and electric ovens also incorporate venting although 

the demands of such venting are lower than those for gas ovens since there are no combustion 

products. 

The heat source for the cooking process is typically provided by radiant elements. Bake 

elements are located at the bottom of the cavity, and may be either exposed or covered to provide 

spill protection and improve cleanability. Broil elements are situated at the top of the cavity. Far 

less common than radiant elements, halogen elements are also used to promote faster cooking. 

An additional cooking feature on many electric ovens and certain gas ovens is convection 

mode, in which hot air within the cavity is circulated by means of one or more fans to speed the 

cooking process, promote surface crisping, and increase cooking uniformity. Supplemental 

heating of this recirculated air is accomplished by means of a radiant heating element located near 

the fan. 

Additional electrically-powered components in electric ovens may include cavity lights, 

electronic controls incorporating various types of displays, and cooking sensors. 

A microwave oven is an appliance which heats foods and beverages through the 

conversion of electric energy to electromagnetic (microwave) energy. The food load is placed 

inside the oven where it is subjected to the microwave energy. In the portion of the 

electromagnetic spectrum where microwave ovens operate, typically 2.45 gigahertz, water, fats, 

and sugars have high absorptivity and thus food heats readily. Glass, ceramic, and paper have 

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low absorptivity at these wavelengths, while metals reflect the microwaves. Therefore 

microwave ovens efficiently heat foods while the cavity and utensils remain cool. 

The microwave energy is generated by an electrically-powered magnetron. Line voltage 

is converted to the high voltage required by the magnetron through the use of a high-voltage 

transformer. The microwaves are directed from the magnetron into the cavity via a metal duct, 

or waveguide. To produce a more uniform distribution of energy in the cavity, one or more sets 

of rotating metal blades may be inserted in the waveguide to alter the microwave patterns 

temporally. Additionally, a turntable or translating tray may be provided in the cavity to move 

the load and thus promote even input energy distribution to the food. Some microwave ovens 

are equipped with electrically-powered resistive or halogen heating elements for surface 

browning, and in the case of combination microwave ovens, an additional fan for forced air 

distribution to enhance cooking performance. 

To achieve reduced power levels for cooking processes such as defrosting, the magnetron 

is typically cycled at an appropriate duty cycle which results in a time-averaged power at the 

desired level. Electronic controls may include a clock/timer function as well as a humidity or 

infrared sensor for detecting when the desired level of cooking is achieved. Standby power 

consumption associated with these electronics may be several watts. In addition, a light is 

typically provided that is turned on when the door is opened or when the microwave oven is in 

operation. 

Installation configurations include countertop and over-the-range. Over-the-range 

microwave ovens may include a ventilation fan that turns on automatically when the temperature 

from the cooktop below it rises; however, such an option is not required for certification under 

the Underwriters Laboratories (UL) standard UL 923 - Edition 5, Standard for Microwave 

Cooking Appliances. 

3.14.1.4 Commercial Clothes Washers 

Commercial clothes washers are appliances designed to clean clothes by using a solution 

of soap and/or detergent and water with mechanical agitation. Clothes washers use electricity to 

operate one or more pumps and to power an electric motor that agitates and spins the clothes. 

Clothes are washed, rinsed, and spun within a tub that is inside a cabinet. Because clothes 

washers require heated water for hot and warm water wash cycles, a separate water heater is 

usually needed to supply hot water. Most of the energy used by clothes washers is for water 

heating. Water is fed into the clothes washer through electrically-operated water valves, one 

connected to a hot water supply line and the second to a cold water supply line. 

Traditional top-loading clothes washers have an opening, covered by a door, which gives 

access to the inner basket where the load to be washed is placed. The inner basket is typically 

perforated and is surrounded by a larger outer tub which holds the water when the machine is 

running. The inner basket contains an agitator along a vertical-axis, which undergoes a reversing 

circular motion. The motion of the agitator, which is powered by an electric motor, circulates 

the clothes vertically from the bottom to the top of the basket. The spinning action of the inner 

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basket and the drain pump are also powered by the motor. Traditional top-loading clothes 

washers use more water than other types of washers, and therefore, consume more energy during 

heated wash cycles. They also typically extract less water from laundry during the spin cycle, 

which results in longer drying time and greater energy consumption. 

Non-agitator top-loading clothes washers may have a “wash plate”, rather than an 

agitator, to move the clothes within the basket. These top-loading clothes washers function by 

partially filling the tub with water for wash and rinse cycles and using very high spin speeds to 

extract rinse water from the clothes during the spin cycle. These top-loading clothes washers 

are more efficient with water and energy than traditional top-loaders, but the high spin speeds 

that reduce drying time (and dryer energy consumption) may wrinkle clothing more than 

traditional top-loaders. These machines work best with low-foaming, high-efficiency detergent. 

Front-loading clothes washers utilize a cylindrical tub or drum rotating on a horizontal or 

nearly-horizontal axis to wash clothes. The clothes are cleaned by tumbling them in the water 

(i.e., clothes are lifted to the top of the drum by the rotation of the cylinder and then dropped into 

the water below). The cylindrical drum is only partially filled with water for wash and rinse 

cycles. High spin speeds are used to extract the water from the clothes during the spin cycles. 

These clothes washers are typically more efficient with water and energy than traditional toploaders, but the high spin speeds that reduce drying time (and dryer energy consumption) may 

wrinkle clothing. 

Clothes are usually loaded along the axis of the cylindrical drum, which has led to this 

type of clothes washer to be called a front-loader. Although most horizontal-axis clothes 

washers are front-loading, they can be designed to be top-loading as well. In a top-loading 

horizontal-axis design, the cabinet has a door at the top that opens above the washer drum. 

Another door that slides or pivots open then provides access to the inner drum. 

3.14.2 Technology Options 

In order to gain a deeper understanding of the technological improvements used to 

increase the efficiency of residential dishwashers, dehumidifiers, and cooking products and 

commercial clothes washers, DOE identified several possible technologies and examined the 

most common improvements used in today’s market. 

3.14.2.1 Dishwashers 

For dishwashers, DOE will consider technologies identified in the following three 

sources: (1) DOE’s ANOPR initiating a standards rulemaking for dishwashers, published on 

November 14, 1994 (59 FR 56423); (2) recent information provided by trade publications; and 

(3) design data identified in manufacturer product offerings. Except where otherwise noted, the 

following technologies are taken from the 1994 ANOPR. DOE derived the variable washing 

pressure and variable-speed drive technologies from the February 2006 edition of Appliance 

Magazine. DOE grouped these technologies together because they collectively address the 

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manufacturers’ design tradeoffs between the mechanical soil removal function of the water and 

the cycle time and energy associated with the dishwasher pump. Condenser and fan/jet drying 

are technologies listed in one manufacturer’s product offerings. DOE also identified 

supercritical carbon dioxide washing from the November 2005 issue of Appliance Magazine. 

Low-standby-loss electronic controls were added based on DOE’s analysis of controller standby 

power in dishwashers currently on the market. 

The technology options for dishwashers are listed in Table 3.14.1. They are changes that 

can be incorporated into the design of a dishwasher to improve its efficiency. 

Table 3.14.1 Technology Options for Dishwashers 

1. Condenser drying 

2. Fan/jet drying 

3. Flow-through heating 

4. Improved fill control 

5. Improved food filter 

6. Improved motor efficiency 

7. Improved spray-arm geometry 

8. Increased insulation 

9. Low-standby-loss electronic controls 

10. Microprocessor controls and fuzzy logic, including adaptive or soilsensing controls 

11. Modified sump geometry, with and without dual pumps 

12. Reduced inlet-water temperature 

13. Supercritical carbon dioxide washing 

14. Ultrasonic washing 

15. Variable washing pressures and flow rates 

Condenser drying 

This technology reduces the amount of energy required to dry the dishes at the end of the 

wash cycle. Instead of using an exposed electric heating element to dry the dishes, hot rinse 

water is used to heat the dishes to a high temperature. Subsequently, room air is admitted into 

the dishwasher. Simple convection then pulls cooler, less moist air into the dishwasher from the 

bottom of the cabinet and discharges warm, moist air out of the top of the cabinet. Some designs 

do not allow outside air into the dishwasher and pull cool air over the exterior cabinet surface 

instead. As the warm, moist air inside the dishwasher encounters the cavity walls (via natural 

convection), the water condenses on the wall surface and runs into the sump. Most European 

installations connect the dishwasher to the cold water line. A reservoir of cold water can thus be 

maintained on the outside of the stainless tub, providing a chilled surface on which the moisture 

can condense. U.S. condensing systems are less effective because the condensing surface is not 

as cool. 

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Fan/jet drying 

To reduce drying times, some dishwasher designs use a fan to circulate air and to 

accelerate the drying process outlined in the condenser drying section above. Fans may be 

installed in the dishwasher door or in the cabinet itself, with the condensing water being diverted 

back into the sump. Convection fan systems are found on the highest-efficiency dishwashers 

currently available on the U.S. market. 

Flow-through heating 

As discussed in section 3.14.1.1, dishwashers use either an exposed tubular or a flowthrough supplemental water heating element to bring water inside the dishwasher up to operating 

temperature. Water is heated before being pumped and distributed to the spray arms. Typically, 

dishwashers with exposed tubular heating elements require more standing water than 

dishwashers with flow-through heaters. Flow-through heaters consist of a metallic flow tube 

around which an electrical tubular resistance heater is wrapped. The flow-through heater usually 

connects the sump to the main pump and hence forms an integral part of the water circuit. The 

volume of water required to fill a flow-through element is typically much lower than the volume 

required to at least partially submerge a tubular supplemental heating element. The potential 

water and energy savings depend upon the configuration of the sump and type of supplemental 

water heating element. 

Improved fill control 

Modifying the fill control to admit a lower volume of water can reduce hot water 

consumption and energy use. In models that use electro-mechanical controls, this could be 

accomplished by reducing the safety factor employed by manufacturers to ensure proper fill 

volumes. Safety factors, which result in overfill for some consumers, are applied to the volume 

of the sump region and also to the timer-activated water fill to ensure enough water for proper 

pump action and cleaning. The use of more accurate electronic timers would maintain a tighter 

tolerance on the fill time period. 

Dishwashers with electro-mechanical controls also employ an overfill factor to account 

for varying water pressures. Water flow rates through valves vary with water pressure, so the 

use of mechanical timer controls could cause a variation in the quantity of hot water delivered. 

Therefore, an additional overfill factor of 10 or 15 percent is traditionally used to compensate for 

the range of water pressures existing in the U.S. The use of pressure-activated water volume 

sensors could be used to control water fill rather than a mechanical timer to reduce overfills. 

Dishwashers may alternatively use a float switch mounted in the sump to terminate the 

filling process. The float switch is an electro-mechanical switch activated by the rising water 

level in the sump. Once the sump has been filled to the appropriate level, the float triggers the 

switch, terminating the fill. Since the float switch directly measures the water level, it can enable 

a high degree of fill control. However, simple float switches can only measure one fill level, 

which may be inadequate for washers with very high efficiency targets. 

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The most sophisticated water fill control option is to incorporate a water meter into the 

dishwasher. Such a device allows the controller to measure exactly how much water has been 

added and allows the washer to tailor its water input precisely to the needs of each individual 

wash or rinse cycle. By metering the water precisely, this approach gives the dishwasher 

controller greater flexibility than a timed fill or float switch. However, unlike a timed fill or a 

float switch, a water meter approach requires an electronic dishwasher controller that can make 

use of the pulses generated by the water meter. 

Improved food filter 

Improved food filters help prevent the re-deposition of food particles, possibly leading to 

one less fill for rinsing. Dishwashers utilizing fine filters have less food re-deposited on dishes, 

since the food is filtered out before being re-circulated by the pump through the spray arms. 

Another benefit is that the water supply lines, nozzles, etc. can have small cross-sections without 

the risk of clogging due to entrained food particles. Thus, a fine food filter can enable a 

manufacturer to reduce the volume of the water needed to fill all parts of the wash system. 

 Typical filter designs have a self-cleaning feature that backwashes the filter 

automatically and therefore minimizes manual filter cleaning. Although less water is required 

overall for dishware rinsing, the washing of the filter requires water use. The task can be 

changed to an intermittent event via the inclusion of a pressure transducer, which can sense how 

clogged the filter is and thus signal a rinse requirement to an electronic controller. The filter is 

cleaned whenever the need arises, allowing the designer to implement lower-volume sump 

designs. Another implementation approach could monitor the pump motor directly to detect 

excessive slip, resistance, or other parameter to infer a clogged filter condition. 

Improved motor efficiency 

An electric motor runs the main water pump and, if separate, the drain pump as well. 

Dishwashers have typically used split-phase or shaded-pole motors because of their low torque 

requirement and constant starting current condition. A capacitor-type motor, such as a 

permanent split capacitor (PSC) motor, is more efficient than a split phase or shaded-pole motor. 

It uses a capacitor in both the starting and running modes. The capacitor-type motor increases 

the power factor, and, therefore, reduces heating losses in the stator. An electric motor 

efficiency of 65 percent should be possible using a capacitor-type motor. 

A 30 percent improvement in motor efficiency produces approximately a 2.5 percent 

overall reduction in dishwasher energy consumption. Dishwashers with permanent magnet 

motors could reduce the electrical consumption of the pump motor by a further 10-20 percent 

from the levels attainable with PSC motors. 

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Improved spray-arm geometry 

Spray arms, which are typically located at the center and the bottom of a dishwasher 

cavity, are designed to rotate and spray pressurized water on the dishwasher contents. If the 

spray arms could be designed to more effectively remove food particles, dishwashers would use 

less hot water and energy. 

Increased insulation 

Dishwashers generally feature some insulation to reduce noise levels, which also reduces 

heat losses. Additional insulation around the tub or at the bottom of the dishwasher can decrease 

heat losses further. However, the marginal benefit for additional insulation is very small. Past 

testing by manufacturers has shown that increasing insulation does not allow the use of a lower 

water temperature. This has been confirmed by other researchers through both experimental 

testing and simulation modeling. The same researchers found that an increase in thermal 

capacitance had little effect on dishware temperature. They simulated a steel and porcelain tub, a 

plastic tub, and an aluminum tub. There was little difference in the temperature of the dishware 

among all three cases. 

Low-standby-loss electronic controls 

Electronic controls may consume power even when the dishwasher is not performing its 

intended function. Depending on the implementation of the controller, standby power is required 

to enable the electronic controls to detect user input without the user first having to turn on a 

mechanical power switch or to enable displays, illuminate switches, etc. Reducing the standby 

power consumption of electronic controls will reduce the annual energy consumption of the 

dishwasher, but will not impact the energy consumption of the dishwasher during operation. 

Low-standby-loss electronic controls can be implemented in a wide variety of ways. 

Microprocessor controls and fuzzy logic, including adaptive or soil-sensing controls 

Microprocessor controls and fuzzy logic, including adaptive or soil-sensing controls, are 

able to reduce the energy and water consumption of a dishwasher by allowing the machine to 

adapt to variable conditions inside the unit. Sensors located inside the dishwasher provide a 

stream of information, including turbidity, conductivity, temperature, and spray arm rotation, to 

the fuzzy logic controller which, in turn, controls the operation of the dishwasher by adjusting 

the amount of water used and/or the water temperature, based on inferred load and/or soil level. 

This is somewhat analogous to manually selecting light-, normal- or heavy-duty wash selection. 

For example, some dishwasher designs have sensors that measure the amount of food soil 

in the water and algorithms that adjust water temperature, fill levels, and cycle time accordingly. 

This design feature may also track the amount of time between loads so the controller can adjust 

for dried-on food, as well as taking into account the number of times the door has been opened to 

determine load size. According to Honeywell, a key developer and supplier of soil-sensing 

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packages, such a system can reduce energy consumption by 35 percent and water consumption 

by 45 percent.48 Most manufacturers offer dishwashers using soil-sensing controls. 

In 2003, the DOE test procedure was updated to more accurately measure energy 

efficiency for machines equipped with soil-sensing controls. For these machines, water and 

electrical energy consumption are measured under varying soil load conditions, and the results 

are averaged via a weighted formula that represents typical usage patterns. 

Modified sump geometry, with and without dual pumps 

The amount of water used for each cycle can be reduced by a change in the geometry of 

the sump and its integration with the main pump and a drain pump (if any). During the wash part 

of the cycle, approximately half of the water at any given time in the dishwasher is in the sump 

to ensure an air-free water supply to the pump. Current sump designs attempt to minimize water 

use while maintaining an adequate water supply to the pump. This technology option would 

optimize the sump to minimize the total amount of water needed per fill. Another factor in sump 

design is how quickly water can flow back to the sump after being sprayed on the dishes. 

Many dishwashers use one pump to deliver pressurized water, with detergent in solution, 

to the spray arms, and to drain the wash solution when the wash cycle is complete. This pump is 

powered by a single electric motor. By using two pumps and two electric motors, with one set 

optimized for washing and one set optimized for draining, the overall energy consumption due to 

water pumping may be decreased. 

Reduced inlet-water temperature 

This option uses cold or temperate water for some of the rinse cycles. Dishwashers with 

adequate heating elements could tap only to the cold water supply line, allowing the 

dishwasher’s heating element to heat the water as required. For reduced-temperature rinse 

cycles, the water would be heated to a lower temperature than the temperature of water typically 

available from the hot water supply line (120 °F), reducing energy consumption. The 

dishwasher’s internal water heater may also be more efficient than the household water heater. 

For an example of a dishwasher incorporating this design option, the AM Appliance Group, 

under the ASKO brand, manufactures a dishwasher capable of attaching directly to a cold water 

line.49 However, ASKO notes that a dishwasher connected to the cold water line requires more 

time to complete the washing cycle, since the dishwasher requires additional time to internally 

heat the water to operating temperatures. 

Alternatively, a dishwasher could tap both the hot and cold water lines, and mix hot and 

cold water in order to reduce inlet water temperatures. Again, because U.S. dishwashers are 

conventionally connected to a hot water line only, this option would necessitate plumbing in a 

cold water line to the dishwasher in addition to the currently-used hot water line. 

Another means to lower rinse water temperature is to lower the hot water temperature 

setting on the household water heater and use the dishwasher’s heating element to raise the water 

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to the needed temperature. But lowering the household water heater temperature below 120 °F 

may not satisfy other household hot water requirements. 

Supercritical carbon dioxide washing 

At an Electrolux-sponsored design competition, students from the University of New 

South Wales designed a dishwasher with a cleaning process based upon supercritical carbon 

dioxide instead of the conventional detergent and water solution.50 The supercritical carbon 

dioxide within the dishwasher behaves simultaneously as a liquid and a gas, completely filling 

the washing tub and covering the dishes, like a gas, but dissolving grease like a liquid. The 

supercritical carbon dioxide is used in a closed-loop process. After the wash cycle, 

contamination is removed from the carbon dioxide, which is stored for the next wash cycle. 

Ultrasonic washing 

Ultrasonic washing uses high frequency sound generators to create cavitation bubbles 

within the wash water, in which the dishware is completely submerged. These bubbles implode 

upon contact with a surface, effecting a mechanical scrubbing action that removes soil from the 

dishware. This cleaning action is not dependent on water temperature, water flow rate, or 

detergents, making the process highly energy efficient, since a standing pool of room 

temperature water may be used. However, standing ultrasonic waves within the washing cavity 

and the force of cavitation implosion can damage fragile dishware. Also, consumers may not 

perceive ultrasonic dishwashers as properly sterilizing dishes at low temperatures, resulting in a 

perceived decrease in consumer utility, even though not all current dishwashers operate at high 

enough temperatures to effectively sterilize their contents. 

Sharp introduced an ultrasonic and ionic dishwasher for the Japanese market in 

September 2002, which utilizes a different ultrasonic technique for soil removal.51 The 

dishwasher tank is partially filled with water, and a superfine mist is created using an ultrasonic 

generating element to remove food stains from dishes. Hard water ion washing is then 

performed using table salt. A prepared salt-water mixture is put through an exchange system to 

make hard water containing an abundance of calcium ions (Ca2+) and magnesium ions (Mg2+). 

This water washes the dishes using a salting-in effect to remove protein-based stains, which 

would otherwise become hardened and difficult to remove when using conventional heated tap 

water. The ion exchange system then removes calcium and magnesium ions from the tap water 

to create soft water for rinsing. The combination of the ultrasonic waves and the salt-water 

mixture is designed to wash without the need for dishwasher detergent. Unlike the technology 

described above, Sharp’s ultrasonic dishwasher does not rely on immersing the dishes in an 

ultrasonically-excited fluid. 

Variable washing pressure and flow rates 

Variable washing pressure and flow rates are being employed in some dishwasher models 

to reduce dishwashing cycle times or to accommodate the various levels of soiling. For example, 

the user can choose an option to provide a 30 percent increase in washing pressure and, thus, 

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more rapidly (and powerfully) clean dishes. The user interface usually presents this option as, 

for example, a “pots and pans” wash setting versus a “normal” setting. Higher energy 

consumption from the dishwasher pump is required to achieve the increase in washing pressure. 

Conversely, reduced washing pressure requires less energy from the dishwasher pump to 

run the cleaning cycles, reducing the energy consumption of the dishwasher as long as the cycle 

time is not increased. Such a strategy may be employed for rinse cycles, during which clean 

water is used to remove detergent from the dishes. Since the rinse cycle does not need high 

washing pressure to remove food material from soiled dishes, a reduced water pressure is 

feasible without degrading the overall cleaning performance of the dishwasher. 

Some dishwashers alternate the delivery of water to the top-rack spray arm and the 

bottom-rack spray arm. This diversion is accomplished by using a valve or other fluid control 

mechanism to route the water to one spray arm at a time. Once the active spray arm has 

completed its cycle, the water may be circulated through the other spray arm to complete a 

similar cycle. This reduces the amount of water required by the dishwasher, since the 

dishwasher only heats and circulates enough water for one spray arm. By reducing the amount 

of water required, and therefore the amount of water heating required, alternating water delivery 

to the top and bottom spray arms reduces the energy consumption of the dishwasher. 

In order to implement this feature, the dishwasher must be capable of adequately filtering 

the wash water. Since a smaller quantity of water is used to remove the same quantity of dish 

soiling, the water will contain a higher concentration of soiling. If the dishwasher filtering 

system does not adequately filter the water, re-deposition of food soiling could increase as the 

soiled water is circulated. 

In addition to reducing the energy consumption of dishwashers washing full loads, this 

technology option also lets manufacturers offer dishwashers with efficient “half-load” wash 

cycles in which water is only routed to one spray arm, which allow consumers to run the 

dishwasher when it is half-full without wasting the water and energy necessary to wash a full 

load. 

3.14.2.2 Dehumidifiers 

DOE has not previously conducted a comprehensive analysis of energy conservation 

standards for dehumidifiers, because there are currently no Federal standards for these products. 

The first such standards become effective October 2007. To identify technology options for 

dehumidifiers, DOE occasionally made comparisons to room air-conditioners and cited sources 

referring to room air-conditioner technology, due to the inherent similarities between room airconditioners and refrigeration-based dehumidifiers. Like dehumidifiers, room air-conditioners 

are portable residential appliances containing refrigeration systems. However, while 

dehumidifiers are designed to remove latent heat from the ambient air, the main function of a 

room air-conditioner is to remove sensible heat. The components of the refrigeration systems in 

both room air-conditioners and refrigeration-based dehumidifiers are usually similarly sized, and 

the refrigeration systems themselves usually have similar refrigeration capacities. However, the 

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heat exchangers in dehumidifiers will be optimized for latent heat removal, whereas the room 

air-conditioner heat exchangers will be optimized for sensible heat removal. Furthermore, room 

air-conditioners will feature an indoor and an outdoor section, whereas most dehumidifiers are 

designed for wholly indoor use. 

Because of these similarities, many of the technologies used for improving room airconditioner efficiency are relevant to refrigeration-based dehumidifiers, and will have similar 

energy efficiency impacts when used in refrigeration-based dehumidifiers. On September 24, 

1997, DOE issued a final rule establishing energy conservation standards for room airconditioners. (62 FR 50122) In support of the 1997 rulemaking, DOE published a TSD 

containing descriptions of room air-conditioner technology options. DOE used applicable 

descriptions from this 1997 TSD when establishing descriptions of dehumidifier technology 

options. 

Additional technology options were identified by DOE during teardowns conducted as 

part of reverse-engineering analyses. For more details on the reverse-engineering activities, see 

Chapter 5 of this current TSD. 

The technology options for dehumidifiers are listed in Table 3.14.2. They are features 

that can be incorporated into the design of a dehumidifier to improve its efficiency. Based on 

product literature research, stakeholder interviews, and teardown analysis, DOE has identified 

compressor, heat exchanger, and fan motor improvements as the most common ways by which 

manufacturers improve the energy efficiency of their dehumidifiers as measured by the DOE test 

procedure. 

Table 3.14.2 Technology Options for Dehumidifiers 

1. Built-in hygrometer/humidistat 

2. Improved compressor efficiency 

3. Improved condenser performance 

4. Improved controls 

5. Improved defrost methods 

6. Improved demand-defrost controls 

7. Improved evaporator performance 

8. Improved fan and fan-motor efficiency 

9. Improved flow-control devices 

10. Low-standby-loss electronic controls 

11. Washable air filters 

Built-in hygrometer/humidistat 

All dehumidifiers subjected to teardown by DOE featured some type of humidity 

controller. Electromechanically-controlled dehumidifiers featured a humidistat, which cycles the 

compressor and fan power supply as a function of relative humidity. The switch material 

consists of either hair or a nylon-film band, whose tension is set via a user-positionable dial. 

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Increases in humidity relax the hair or band, allowing the switch to close. Electronic controllers 

use hygrometers, which also measure the expansion of a reference material. 

Improved compressor efficiency 

Most dehumidifier manufacturers incorporate rotary compressors into their units, though 

some still use reciprocating compressors. “Inertia” compressors, scroll compressors, and 

variable-speed compressors all have higher efficiencies than the traditional rotary compressors 

used in dehumidifiers. However, finding a suitable high-efficiency compressor at the capacities 

and price points needed for a dehumidifier is a challenge. 

The “inertia” compressor is a technology that allows reciprocating compressors to 

approach an energy efficiency ratio (EER) of 12.0, where EER represents the cooling capacity in 

Btu/hr divided by the input wattage of the compressor. “Inertia” compressors utilize lightweight, 

responsive valve technology and an innovative refrigerant flow path to reduce losses and 

improve cylinder volumetric efficiency. 

Scroll compressors require high precision to produce their internal components and are 

typically found in higher-efficiency central air-conditioning systems. Scroll compressors 

compress gas in a fundamentally different manner from traditional compressors — between two 

spirals, one fixed and one nutating. Scroll compression is inherently more efficient than 

traditional compression methods. 

Both inertia and scroll compressors are, however, substantially larger, heavier, and 

sometimes noisier than their rotary counterparts, and, as such, are not well-suited for use in 

residential dehumidifiers. 

Variable-speed compressors are typically implemented through the use of an electronic 

control that varies the input frequency of the power supply for the compressor motor. Variablespeed compressors enable modulation of the refrigeration-system cooling power beyond simple 

on-off control, allowing the dehumidifier to better match the compressor power to the load, 

increasing compression efficiency. 

The control of variable-speed compressors is accomplished through the use of electronic 

adjustable-speed drives (ASDs) at the motor. Because electronic ASDs are compact and require 

no drive-train in order to be coupled to the motor, they can be easily retrofitted to fractional size 

horsepower motors that are typical of many home appliances, including room air-conditioners 

and dehumidifiers. Inverter-based ASDs are the most common systems for induction motors 

while converter-based ASDs are used for permanent-magnet brushless motors. In a pulse-widthmodulated (PWM) inverter, the input alternating current (AC) power supply is first converted to 

direct current (DC) by using a solid-state rectifier. This DC signal is then converted to a 

variable-frequency AC waveform by the inverter and supplied to the motor. The waveform is 

released in short steps or pulses of power. The speed of the motor will then change in proportion 

to the frequency.52 

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Variable-speed compressor technology has not yet been implemented in residential 

dehumidifiers, and it is therefore difficult to predict the energy efficiency improvements that 

could be achieved through its use. However, in the 1997 room air-conditioner TSD, DOE 

conservatively estimated that the implementation of variable-speed compressors in room airconditioners could achieve an energy savings of approximately 10 percent.53 Because of the 

inherent similarity between room air-conditioners and refrigeration-based dehumidifiers, DOE 

expects that a variable-speed compressor in a dehumidifier could achieve comparable energy 

savings as long as the fan speed or effective evaporator surface area is modulated as well to 

ensure proper coil temperature for latent heat removal. 

Improved condenser performance 

Enhancements to the condenser fin design may also improve the overall heat transfer 

capability of the dehumidifier coil. This improvement is due in part to the increase in air 

turbulence over the coil caused by the enhanced fin design. According to the 1997 room airconditioner TSD, many manufacturers are using some form of fin enhancement in their coil 

designs.54 Almost all dehumidifier models subjected by DOE to teardown analysis had heat 

exchangers with “wavy” aluminum fins for more turbulent airflow and internally-rifled copper 

tubing for optimized refrigerant heat exchange. 

It is difficult to predict the amount of energy savings that could be achieved through the 

implementation of an improved condenser design, as it is dependant on the specific dehumidifier 

model and usage characteristics. 

Improved controls 

Manufacturers have increasingly adopted digital controllers for dehumidifiers due to 

consumer demand and because such controllers allow dehumidifiers to better respond to 

changing environmental conditions. Unlike the snap-action switches and fixed-RH 

electromechanical controllers they replace, digital controllers can measure multiple inputs and 

respond to present conditions as well as trends. 

Digital controllers can use varying approaches, from rigid decision trees to fuzzy logic. 

During the reverse-engineering process, DOE observed that most electronic control boards were 

purchased parts which had been mass-customized for the specific dehumidifier. One advantage 

of digital controllers is the ease with which they can be reprogrammed, allowing a manufacturer 

to use one control board for its entire dehumidifier line, yet optimize its responses per 

dehumidifier model. 

It is difficult to predict the amount of energy savings that could be achieved through the 

implementation of improved controllers because there is no industry consensus on patterns in 

ambient conditions and usage. 

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Improved defrost methods 

As the air drawn into the dehumidifier is cooled, water vapor condenses on the surface of 

the evaporator coil. In some cases, typically when the air is below 65 °F, this water can freeze as 

it collects and form a growing layer of frost. The frost reduces cooling performance by 

increasing the thermal resistance to heat transfer from the coil to the air and by obstructing air 

flow. Both the method by which defrost is performed and control of the defrost cycle can lead to 

substantial energy savings. 

Many dehumidifiers incorporate defrost technology. In general, two types of defrost 

mechanisms are available: passive defrost and active defrost. Most dehumidifiers that feature 

defrost technology use passive defrost. Dehumidifiers that are designed and marketed for lowtemperature operation (i.e., for use in basements) generally use active defrost systems. 

Dehumidifiers using passive defrost monitor the temperature of the evaporator, and shut 

down if it drops below the freezing point of water. This is not technically “defrost,” as it actually 

prevents the formation of frost rather than eliminating frost after it forms. It is, however, an 

effective method of preventing the dehumidifier from operating under low-efficiency frosted 

conditions. This method is simple to implement and incurs no additional energy expenditure. 

Active defrost in dehumidifiers is conducted in one of three ways: off-cycle defrost, 

electric defrost, or hot-gas defrost. 

Off-cycle defrost, commonly implemented in refrigerators, involves shutting off the 

refrigeration system while keeping the air-circulation system running. The relatively warm air 

— case air in refrigerators and ambient air in dehumidifiers — melts the frost layer, and the 

refrigerator or dehumidifier subsequently resumes operation. When implemented in 

dehumidifiers, off-cycle defrost may allow much of the frozen condensate to be reabsorbed into 

the ambient air as it melts, compromising the effectiveness of the dehumidifier. 

Electric defrost, which is not generally implemented in dehumidifiers, involves melting 

frost by briefly turning on an electric resistance heater, which is in contact with or near the 

evaporator. The heater melts the frost quickly, but consumes significant energy. 

Hot-gas defrost uses the hot compressor discharge gas to warm the evaporator from the 

refrigerant side. This method can be used for a large range of air temperatures. Electricity usage 

is reduced in comparison to the electric defrost method because available heat, which would 

otherwise be rejected in the condenser, is used. Hot-gas defrost systems, however, necessitate 

more complicated piping and control than electric defrost systems. A reversing valve is required 

to change the direction of gas flow through the system so hot compressor discharge gas can be 

routed through the evaporator. In addition, hot-gas defrost systems lead to an increase in the 

thermal stress on the refrigerant piping due to the alternating flow of hot gas and cold refrigerant. 

It is difficult to predict the amount of energy savings that could be achieved through the 

implementation of more-efficient defrost technology since there is no industry consensus on 

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patterns in ambient conditions and usage, and therefore no way determine how often an 

evaporator coil may be subject to frosting. However, it is expected that this technology could 

achieve significant energy savings under real-world conditions. 

Improved demand-defrost controls 

In all active-defrost systems, control of the defrost cycle may lead to substantial energy 

savings. Defrost-cycle control involves management of the initiation and termination of defrost 

cycles, and thereby management of the frequency and duration of defrost cycles. Two different 

defrost-cycle control designs are available: timer-controlled and temperature-sensor-controlled. 

In a time-based defrost system, cycles are completely scheduled, and initiation and 

termination are timer-controlled. Cycles are initiated at regular intervals and terminated after a 

fixed amount of time. In these systems, cycle frequency and duration are not responsive to 

actual frost conditions. Under timer control, the frequency of defrost cycles is determined by the 

amount of time the manufacturer expects it to take for a large frost layer to develop in the worstcase scenario, and the cycle duration is long enough to ensure complete defrost in the worst-case 

scenario. Timer-based defrost can lead to unnecessarily frequent and unnecessarily long defrost 

cycles under anything but worst case conditions. 

Sensor-controlled defrost involves scheduled cycle initiation, determined by a timer, and 

demand-based cycle termination, determined by temperature sensors. Defrost cycles are still 

initiated at regular intervals, but are terminated when the coil temperature reaches a value 

indicating complete defrost. Temperature-sensor-controlled defrost saves energy relative to 

timer-controlled defrost by varying cycle duration based upon defrost requirements. As with all 

defrost design options, actual energy savings will be a function of ambient conditions and usage 

patterns. 

Improved evaporator performance 

Specific attention to evaporator design regarding condensate runoff and fin patterns may 

increase dehumidifier energy efficiency. Although manufacturers typically design dehumidifier 

evaporators primarily for effective heat transfer with the humid air stream, it is also useful for the 

evaporator to be designed such that condensate runs off effectively and does not adhere to the 

surface. In addition to allowing less re-absorption of condensate back into the air stream, 

effective condensate runoff results in higher heat transfer between the evaporator and the air, 

increasing evaporator and thus system efficiency. 

Additionally, enhancements to the evaporator fin design may improve the overall heattransfer capability of the coil. This improvement is due in part to the increase in air turbulence 

over the coil caused by the enhanced fin design. According to the 1997 room air-conditioner 

TSD, many manufacturers are using some form of fin enhancement in their coil designs.55 

Almost all models DOE subjected to teardown analysis for this rulemaking had heat exchangers 

with “wavy fins” and rifled copper tubing. 

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Energy savings associated with this technology will depend on the specific dehumidifier 

model and refrigerant-circuit characteristics. 

Improved fan and fan-motor efficiency 

The air-circulation system of a residential dehumidifier usually consists of a shaded-pole 

or PSC fan motor which drives either propeller-style blades or a tangential “squirrel cage” fan. 

These motors run on line voltage and typically feature one or two speeds. Multiple fan speeds 

are usually found on higher-end units. Some unit controllers can modulate fan speeds (high/low) 

whereas less complex models utilize a user-set switch. 

In the 1997 TSD for room air-conditioners, DOE stated that manufacturers primarily 

obtain fans from one fan manufacturer, leading to standardization of these air-system 

components.56 Because of this, it is extremely difficult for room air-conditioner manufacturers 

to implement any individual design improvements to raise the efficiency of their fans. 

Dehumidifiers are typically built using product platforms, where one enclosure serves 

multiple dehumidification capacities. As a result, the designers make tradeoffs to accommodate 

a wide range of capacities (35-65 pints/day, for example) within a single enclosure. While 

efficiency improvements could be achieved by optimizing fan blades for specific dehumidifier 

models, such a design change would add complexity to the manufacturing process by requiring a 

wider scope of fan blades to be stocked. Such steps would likely increase inventory, reduce fan 

blade purchase volumes and hence manufacturers see this as a relatively costly design option in 

relation to the efficiency benefit. Therefore, quantifying the efficiency improvements to the 

dehumidifier’s air-circulation system is restricted to analyzing the efficiency improvements to 

the fan motor only. 

Electric motors operate based on the interaction between a field magnet and a magnetic 

rotor. However, single-phase motors only produce a rotating magnetic field when the rotor is 

rotating, and simply powering the electromagnet is therefore not sufficient to start such a motor. 

One of the most significant differences between different types of single-phase motors is the way 

in which they handle this start-up problem. 

All dehumidifiers that DOE reverse-engineered had either shaded-pole or PSC fan 

motors. Both motor types use an electromagnet, which consists of windings of electrical wire 

through which current is driven. In a shaded-pole motor, a portion of these windings is “shaded” 

by a copper loop. The interactions between the magnetic field generated by the shaded portion 

and that generated by the un-shaded portion induce rotation when the motor is powered. 

However, because the imbalance between the shaded and un-shaded portions of the magnet 

remains throughout operation, shaded-pole motors are very inefficient, with typical motor 

efficiencies less than 20 percent. Shaded-pole motors are, however, electrically simple and 

inexpensive.57 

In a PSC motor, a smaller, start-up winding is present in addition to the main winding. 

The start-up winding is electrically connected in parallel with the main winding and in series 

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with a capacitor. At start-up, the interactions between the magnetic field generated by the startup winding and that generated by the main winding induce rotation. As the capacitor charges, 

the current flowing through the start-up winding decreases and the start-up winding becomes an 

auxiliary winding after the motor reaches running speed. Consequently, the current to the startup winding is cut off once the capacitor is fully charged and the motor reaches steady-state 

speed. Because of this, PSC motors are substantially more efficient than their shaded-pole 

counterparts, with motor efficiencies ranging from 60 to 65 percent.58 Like shaded-pole motors, 

PSC motors are produced in large quantities and are relatively inexpensive.59 Dehumidifier fan 

energy efficiency can be substantially improved by replacing shaded-pole motors with PSC 

motors. 

Electric motors with even higher efficiencies can be implemented by switching to 

permanent-magnet motors, which come in many varieties. The most widely-known variety is the 

electronically-commutated motor (ECM)p

 though DC-motors can also be used. Permanent 

magnet motors are less noisy and substantially more efficient than either shaded-pole or PSC 

motors. ECM motors convert single-phase AC input power into three-phase power, and have 

motor efficiencies approaching 80 percent.60 However, ECM motors can weigh twice as much 

as equivalent PSC motors, potentially necessitating a redesign of the dehumidifier fan-motor 

chassis. In addition, ECM motors are complex, are not currently produced in large volumes, and 

can cost from 2.5 to 5 times as much as a PSC motor.61 

Improved flow-control devices 

Nearly all portable dehumidifiers use capillary-tube expansion valves for flow control. 

The capillary-tube expansion valve is a pressure-reducing device that consists of a smalldiameter line that connects the outlet of the condenser to the inlet of the evaporator. It is 

designed to provide optimum energy characteristics at one design point. If sized properly, the 

capillary-tube expansion valve compensates automatically for load and system variations and 

gives acceptable performance over a wide range of operating conditions. Because ambient 

temperature and humidity vary, however, dehumidifiers sometimes operate under conditions 

outside of the target conditions, leading to reduced efficiency. 

The thermostatic expansion valve (TXV) — a flow-control alternative to the capillary 

tube — is commonly used in higher-efficiency central air-conditioning systems. TXVs regulate 

the flow of liquid refrigerant entering the evaporator in response to the superheat of the 

refrigerant leaving it. TXVs can adapt better to changes in operating conditions such as those 

due to variations in ambient temperature, which affect the condensing temperature. As a result, 

TXVs can lead to a somewhat increased seasonal operating efficiency. 

Electronic expansion valves (EEVs) are similar to TXVs, but unlike TXVs, they can be 

controlled actively. While a TXV relies on a single temperature sensor for feedback, digital 

p

 Also known as brushless permanent magnet (BPM) motors or electronically-commutated permanent magnet 

(ECPM) motors. 

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controllers can use multiple sensors for feedback control and respond using multiple approaches. 

For example, besides modulating the refrigerant flow, the controller may also vary the fan speed 

to optimize efficiency under varying conditions. As with TXVs, EEVs can use the superheat 

control method to regulate refrigerant flow. Other methods, such as controlling compressor 

discharge temperature, can also be used. As reported in the 1997 TSD for room air-conditioners, 

research has demonstrated that, when incorporated into air-conditioning systems using inverterdriven variable-speed compressors, EEVs improve seasonal energy efficiency beyond that of 

systems using conventional TXVs. 

During the reverse-engineering analysis, one unit was found to contain a quasi-EEV 

which consisted of a regular capillary tube coupled with a liquid line solenoid to bypass part of 

the evaporator. Such a solenoid valve allows the controller to adjust the heat exchanger surface 

area, subject to refrigerant flow, and hence its surface temperature. With active feedback loops, 

the controller can thus adjust the evaporator coil performance to maximize latent heat removal 

across a variety of environmental conditions while minimizing the possibility of freezing the 

evaporator coil. 

However, given the cost of TXVs and EEVs, it is unlikely that TXVs or EEVs will find 

wide use in the dehumidifiers. Since dehumidifiers are only used indoors, the variation in 

ambient conditions to which dehumidifiers are exposed is generally smaller than that to which 

room air-conditioners are exposed. Thus, TXVs and EEVs are likely to remain uncommon, 

except for dehumidifiers that are marketed to work in both warm and cold conditions. Many 

control boards and user interfaces feature placeholders for relays and pins to connect EEVs, if 

needed. 

Low-standby-loss electronic controls 

Electronic controls may consume power even when the dehumidifier is not performing its 

intended function. Depending on the implementation of the controller, standby power is required 

to enable the electronic controls to detect user input without the user first having to turn on a 

mechanical power switch or to enable displays, illuminate switches, etc. Reducing the standby 

power consumption of electronic controls will reduce the annual energy consumption of the 

dehumidifier, but will not impact the energy consumption of the dehumidifier during operation. 

Low-standby-loss electronic controls can be implemented in a wide variety of ways. An 

estimate of energy savings is not possible without industry consensus on usage patterns. 

Washable air filters 

The build-up of dust particles on the evaporator coil can lower the heat-transfer capability 

of the component. To minimize this possibility, most dehumidifiers incorporate an air filter at 

the air-intake vent. However, these filters can become clogged, obstructing air flow through the 

dehumidifier and reducing system performance. To prevent this, most manufacturers design the 

air filters to be removable and washable, which allows the consumer to clean the air filters on a 

regular basis. It is difficult to predict the amount of energy savings that could be realized with 

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the addition of washable air filters, as it is dependant on the specific dehumidifier model and use 

characteristics, and on the degree to which the consumer takes advantage of this feature. 

3.14.2.3 Cooking Products 

DOE most recently analyzed energy conservation standards for cooking products in 

1996 and 1997. In the 1997 analysis, DOE analyzed only gas cooking products to determine the 

technical and economic feasibility of eliminating standing pilots. DOE’s prior analysis in 1996, 

contained within the 1996 TSD for cooking products, identified technologies that have the 

potential for improving gas and electric cooking efficiency. DOE has considered all of these in 

this rulemaking. In addition, DOE identified low-standby-loss electronic controls as a 

technology option for several cooking products, based on review of standby power data for 

microwave ovens and the assumed applicability to conventional cooking products as well. 

For gas cooktops, DOE considered the technologies listed below. 

Table 3.14.3 Technology Options for Gas Cooktops 

1. Catalytic burners 

2. Electronic ignition 

3. Insulation 

4. Radiant gas burners 

5. Reduced excess air at burner 

6. Reflective surfaces 

7. Sealed burners 

8. Thermostatically-controlled burners 

Catalytic burners 

Catalytic burners consist of a porous ceramic or refractory material such as glass or 

ceramic wool, impregnated with a catalyst. The gas-air mixture or gas alone is fed to the 

catalytic matrix, whereupon additional ambient air diffuses into it. The catalyst, typically 

palladium or platinum, lowers the activation energy required for combustion such that the gas-air 

mixture subsequently oxidizes at temperatures below those normally required for combustion. 

This produces a uniform, low-intensity infrared radiation with no visible flame. The burners 

include an electric heating element to preheat the catalyst prior to initiating operation. Catalytic 

burners in residential appliances are investigated primarily as a means of reducing NOx 

emissions, since NOx formation is highly temperature dependent. DOE is not aware of any 

commercialized catalytic burners for gas cooktops or efficiency data for applications of catalytic 

burners in cooking appliances. 

Electronic ignition 

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Gas cooktops equipped without electrical power cords use a standing pilot ignition 

system. The energy factor of the cooktop can be increased by replacing the standing pilot system 

with an electronic ignition system. Actual burner efficiency is not affected by eliminating the 

standing pilot. The resulting increase in the energy factor is due only to the decrease in the 

cooktop’s annual gas energy consumption attributed to the pilot gas consumption. 

The most common type of electronic ignition used by gas cooktops is an intermittent 

ignition system, where spark ignitors replace the standing pilots. These ignitors are controlled by 

switches on each burner valve. The switches are typically rotary-actuated so that when the 

burner valve is turned to the light position, a “starter” signal is sent to the control module. 

Alternatively, the signal can be generated by electronic controls on the user interface of the 

cooktop. Once the signal is received, the control module activates the spark ignitors. The 

control module can either be a supervised or an unsupervised type. Supervised modules require 

re-activation of the burner switches for cases where burner flames are accidentally extinguished. 

Unsupervised modules use a sensor located at the burner (often the ignitor itself) to sense when 

the flame has been accidentally extinguished. The burner switches do not need to be reactivated, as the sensor sends a signal back to the control module to reactivate the ignitors. 

Though they cost more, unsupervised ignition systems are preferred over systems that use 

supervised control modules since they prevent the need to check accidentally-extinguished 

flames. Most of the currently manufactured gas cooktops that are equipped with intermittent 

ignition systems use unsupervised control modules. Because of this, unsupervised control 

systems are the type of electronic ignition devices being analyzed for gas cooktops. 

It is important to note that intermittent ignition systems consume negligible amounts of 

electricity. Since the control module is powered directly off of line voltage, there are no 24-volt 

transformer losses associated with it. The spark ignitor is activated for an extremely short time 

period so that its cumulative on-time during the course of a year, and thus its electricity 

consumption, is negligible. 

A recently-introduced ignitor technology utilizes a ceramic hot surface ignitor in place of 

the spark ignitor. With this type of ignition, the ignitor may either be constantly energized 

whenever the burner valves are open, such as on a simmer setting where the burner is cycled on 

and off to achieve very low average input rates, or turned on in response to either initial burner 

gas-flow activation or detection of flame extinction. Therefore it may be considered an 

unsupervised system. Improved cooktop utility includes elimination of the noise associated with 

spark ignition. Energy consumption during usage is higher than for spark ignition. 

Insulation 

 Added insulation is only used in a gas cooktop when it is installed as a counter-top unit 

(not above an oven). Here, the surrounding structures encompassing the cooktop might 

experience surface temperature problems that can be alleviated by adding insulation. Insulation 

underneath the cooktop reduces the surface temperature of all exposed non-cooktop surfaces to 

levels which meet UL requirements. 

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Of the information reviewed on efficiency improvements to gas cooktops, adding 

insulation was never analyzed as a method to improve cooktop performance. Manufacturers’ 

data from the previous rulemaking provided no estimate of energy efficiency improvements from 

insulating gas cooktops.. 

Radiant gas burners 

Radiant gas burners transfer heat through infrared radiation of the burner surface. The 

burner consists of a porous matrix through which a premixed gas-air mixture is fed. Upon 

ignition, the flames sit on the surface of the matrix, heating the surface and causing it to emit 

radiation at infrared wavelengths. The burner is located under a glass-ceramic cooktop surface. 

One form of radiant gas burners is termed powered Infrared Jet-Impingement (IR-Jet) 

burners. In the IR-Jet gas burner, both radiant and convective energy are transmitted for 

cooking. A forced-draft combustion fan is used to deliver the fully-premixed gas-air mixture to 

available cooktop burners. At each burner, combustion occurs at the surface of a perforated 

ceramic tile. As the tile heats, it emits radiant energy, principally in the far infrared regime. 

Combustion products are jetted through perforations in the glass-ceramic cooktop, delivering 

convective energy to the cooking vessel as well. 

As reported in the 1996 TSD, the Gas Research Institute (GRI) sponsored the 

development of the IR-Jet gas burner. With GRI’s sponsorship, the American Gas Association 

Laboratories (AGAL) has worked with a range manufacturer to produce a working IR-Jet burner. 

However, the IR-Jet burner is not currently being marketed. Data collected from a boiling water 

test indicated that the AGAL-developed IR-Jet radiant burner is more efficient than a comparable 

conventional open burner. The boiling water test indicated a 16 percent increase in efficiency 

Another type of radiant gas burner utilizes a silicon carbide-fiber burner which emits 

radiation in the near-infrared spectrum. A prototype developed jointly by Tokyo Gas and Rinnai 

Corporation utilized such material in a glass-ceramic cooktop that did not incorporate jet 

impingement. Instead, combustion products were vented from underneath a solid, nonperforated cooktop. Such a radiant burner relied entirely on radiation heat transfer and 

conduction from the glass-ceramic after it heated up. In tests conducted according to the 

Japanese Industrial Standard method, which is a water heating procedure, the efficiency was 

reported as 43.5 percent compared with an estimated 30 percent for traditional gas burners.62 

Reduced excess air at burner 

The excess-air ratio is defined as the amount of air used in the combustion process of the 

gas burner divided by the amount of air necessary for stoichiometric combustion. Excess air is 

provided to ensure high-quality flame characteristics and to create a safety margin to ensure 

complete combustion is reached under all conditions. Reducing the excess-air ratio at the burner 

through redesign and shrouding can improve its efficiency. This information was provided by 

the 1980 engineering analysis performed by DOE63 in support of developing energy efficiency 

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standards for a variety of consumer products, including cooktops and ovens. This document 

does not specify how the burner should be redesigned and shrouded. 

Reflective surfaces 

Reflective surfaces for gas cooktops utilize highly-polished or chromed drip pans 

underneath the burner. By reflecting some of the radiant heat of the burner back up to the 

cooking vessel, the efficiency of the burner is increased. The consumer must maintain the 

reflective finish by cleaning the drip pans regularly. 

Efficiency gains resulting from using reflective pans are extremely small because gas 

flames and burners have minimal infrared emissions. The primary mechanism for heat transfer 

to the cooking vessel is convection. The efficiency increase was obtained from using 

manufacturers’ data provided by AHAM and reported in the 1996 TSD. The data indicates that 

an efficiency increase of only 0.1 percent is realized due to the incorporation of reflective 

surfaces. 

Sealed burners 

 Unlike conventional (open) burners, the cooktop surface surrounding sealed burners 

interfaces directly with the base of the burner. This results in a reduced amount of secondary air 

to the burner for combustion. According to the 1996 TSD, AHAM stated that sealed burners 

often have a lower gas input rating than conventional burners due to the reduction in secondary 

air. The sealed burner must obtain all of its secondary air from above the cooktop. In order to 

obtain sufficient air for proper combustion, it becomes necessary to either raise the grate height 

or derate the burner. Contrary to these statements, a report from the 1983 International Gas 

Research Conference64 states that the reduction in secondary air results in more primary aeration 

to the sealed burner. The increased primary aeration allows for a reduced pan-to-burner 

separation and increased burner efficiency. According to the boiling water tests conducted in the 

report, the efficiency of conventional burners ranged from 42 - 48 percent, while the sealed 

burner was rated at an efficiency of 53 percent. 

Manufacturers’ data provided by AHAM were used to estimate the increase in efficiency 

due to sealed burners in the 1996 TSD. An efficiency increase of approximately 2.0 percent was 

estimated. 

Thermostatically-controlled burners 

Thermostatically-controlled gas burners control the gas flow to the burner through the use 

of a sensing element that extends through an opening in the center of the burner. This sensing 

element makes contact with the bottom of the cooking vessel, detecting the temperature and 

controlling the input rate to the burner accordingly. If the cooking vessel has an uneven bottom 

in the area where the sensor is supposed to make contact, however, any type of useful 

temperature control is lost. 

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Thermostatically-controlled burners were widely sold in the late 1950s and 1960s. But 

due to customer complaints on the operating characteristics of the burner, manufacturers dropped 

them as a feature. As reported in the 1996 TSD, manufacturers stated that the sensor’s electric 

element retains heat due to its mass. This results in the sensor being “fooled” and causing delays 

in reaction time. These delays allow wide swings in the thermostatically-controlled temperature. 

Manufacturers stated that even if improvements in sensor manufacturing resulted in no heat 

retention, the many existing variables associated with the cooking vessel (e.g., vessel material, 

food mass, type of food) make the thermostatically-controlled burners’ utility and energy 

efficiency suspect. 

For open (coil) element electric cooktops, DOE considered the technologies listed 

below. 

Table 3.14.4 Technology Options for Open (Coil) Element Electric 

Cooktops 

1. Electronic controls 

2. Improved contact conductance 

3. Insulation 

4. Low-standby-loss electronic controls 

5. Reflective surfaces 

Electronic controls 

Electronic controls using sophisticated control algorithms can use the dynamic thermal 

properties of the element to turn off the energy input to the element just in time to “coast” to the 

desired final temperature without overshooting it. 

Research has been conducted to determine the effect that electronic controls have on 

cooktop efficiency. Danish researchers, testing breadboard versions of microprocessor 

controlled electric hotplates, found a 20 to 46 percent energy savings in cooking a variety of 

foods with European recipes.65 

Improved contact conductance 

The thermal contact resistance that arises from an imperfect contact between the cooking 

vessel and the open (coil) element can be reduced by improving the flatness of the element. An 

improved contact conductance allows for more heat to be transferred to the cooking vessel and, 

thus, an improvement in the efficiency of the element. 

As stated in the 1996 TSD, manufacturers asserted that they have worked on improving 

the flatness of the element and that the types that are available currently are doing an excellent 

job. They also stated that the results obtained from DOE test measurements do not reflect the 

actual performance of the open element. The aluminum test block used in the test procedure is 

much flatter than actual cooking vessels. Because of the block’s very flat surface, test 

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efficiencies will be higher than those obtained from field measurements using “real” cooking 

vessels. Therefore, according to the manufacturers, ncreases in efficiency that can be obtained 

by improving the contact conductance under DOE test conditions will not be realized under field 

conditions. 

Sources used in assessing the efficiency gains that could be expected from improving the 

contact conductance in the 1996 analysis included: (1) manufacturers’ data provided by AHAM, 

(2) a costing analysis of technology options for residential appliances prepared by ADM 

Associates for Lawrence Berkeley National Laboratory (LBNL)66, and (3) an energy-efficient 

electrical product knowledge base prepared by ORTECH International for the Canadian 

Electrical Association67. An additional comment68 was received from Arthur D. Little, Inc. 

(ADL) following the NOPR for the previous rulemaking, which reported the major mechanism 

for heat transfer was physical contact between the vessel and coil and not contact pressure. 

Averaging the data from these sources results in a relative efficiency increase for this technology 

option of just over 3 percent. 

Insulation 

Added insulation is only used in an open (coil) element electric cooktop when it is 

installed as a counter-top unit (not above an oven). Here, the surrounding structures 

encompassing the cooktop might experience surface temperature problems that can be alleviated 

by adding insulation. Insulation underneath the cooktop reduces the surface temperature of all 

exposed non-cooktop surfaces to levels which meet UL requirements. 

Of the published information reviewed on efficiency improvements to open (coil) 

element electric cooktops, adding insulation was never mentioned as a method to improve 

cooktop performance. Manufacturers’ data provided no estimate of efficiency improvements 

from insulating cooktops. 

Low-standby-loss electronic controls 

Electronic controls may consume power even when the electric cooktop is not performing 

its intended function. Depending on the implementation of the controller, standby power is 

required to enable the electronic controls to detect user input without the user first having to turn 

on a mechanical power switch or to enable displays, illuminate switches, etc. Reducing the 

standby power consumption of electronic controls will reduce the annual energy consumption of 

the electric cooktop, but will not impact the energy consumption of the electric cooktop during 

operation. 

Reflective surfaces 

As described in the similar technology option for gas cooktops, this technology option 

utilizes highly-polished or chromed drip pans underneath the heating element. By reflecting 

some of the radiant heat of the element back up to the cooking vessel, the efficiency of the 

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element is increased. The consumer must maintain the reflective finish by cleaning the drip pans 

regularly. 

Efficiency gains resulting from using reflective pans are extremely small. The efficiency 

increase assumed in the 1996 TSD was obtained from data from the following sources: (1) 

manufacturers’ data provided by AHAM, (2) the energy-efficient electrical product knowledge 

base prepared by ORTECH International for the Canadian Electrical Association69, and (3) the 

1980 DOE Engineering Analysis for residential appliances70. Averaging the data from these 

sources results in an efficiency increase of 1 percent. 

For smooth element electric cooktops, DOE considered the technologies listed below. 

Radiant elements, which were included in the 1996 TSD, were not considered as a design option 

for this rulemaking because manufacturer data provided to DOE for the 1996 TSD indicated that 

this technology does not offer an efficiency improvement over the baseline according to the DOE 

test procedure. 

Table 3.14.5 Technology Options for Smooth Element Electric 

Cooktops 

1. Electronic controls 

2. Halogen elements 

3. Induction elements 

4. Low-standby-loss electronic controls 

Electronic controls 

 Sophisticated electronic controls can be applied to solid disk elements, radiant elements, 

and halogen elements to allow the element to “coast” to its final temperature. Electronic controls 

are not applicable to induction elements as the nature of its operation has no need for “coasting” 

controls. DOE is unaware of any efficiency data characterizing energy savings for electronic 

controls on smooth element cooktops. However, research previously cited suggests potential 

energy savings of this technology for open (coil) element cooktops and it is possible that similar 

energy savings could be achieved for smooth element cooktops. 

Halogen elements 

Halogen elements transfer energy to the cooking vessel by direct infrared radiation from 

high-powered tungsten-halogen lamps. The halogen element lies underneath a glass-ceramic 

panel and consists of one or more lamps installed horizontally within a corrosion-protected metal 

dish. The bottom of the metal dish is insulated with microtherm insulation. 

Frequently, radiant heating coils are fitted around the halogen element to provide heat 

around the element’s edge. This results in a highly responsive element that provides an even 

temperature distribution. Halogen elements can be configured to operate across a wide range of 

capacities. Parallel or series lamp arrangements can yield power outputs from 1200 to 2500 

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watts. Halogen lamp technology reported in the 1996 TSD consisted of a circular lamp that can 

provide a more optimum temperature distribution than traditional straight lamps. This circular 

lamp has the trademark name of Haloring. 

The 1996 TSD reported that with the continued development of halogen elements, 

efficiencies had increased. The circular halogen-lamp elements that had recently been developed 

at the time of the previous analysis could exceed the efficiency of solid disk elements as 

measured according to the DOE test procedure. Data provided for the 1996 rulemaking by a 

cooktop manufacturer were used to establish the efficiency gain of a circular halogen lamp 

element over that of a solid disk element. An efficiency increase of approximately 1.5 percent 

was measured. It is important to reiterate that this efficiency increase was only for the circular 

halogen lamp element. Other halogen lamp elements might not yield this efficiency increase. 

The same cooktop manufacturer mentioned above also provided efficiency data based on boiling 

water tests. These tests indicated that circular halogen lamp elements can yield even higher 

efficiency increases over that of solid disk elements. European manufacturers had also 

conducted boiling water tests indicating that halogen lamp elements (the configuration of 

halogen lamp tested was not specified) are more efficient than solid disk elements71. 

Induction elements 

Induction elements use a solid-state power supply to convert 60 Hz alternating line 

current into a high-frequency (approximately 25 kHz) alternating current. This high-frequency 

current is supplied to an inductor. The inductor is a flat spiral winding located just underneath a 

glass-ceramic panel. The high-frequency current, which is supplied to the inductor, causes it to 

generate a magnetic field which passes through the glass-ceramic panel unaffected and produces 

eddy currents in the bottom of the cooking vessel. The vessel must be made of some type of 

ferromagnetic material, and the eddy currents that are generated within the vessel cause it to heat 

up. Thus, the vessel essentially becomes the heating element. 

A sensor is placed between the inductor and the glass-ceramic panel, providing a 

continuous temperature measurement of the vessel bottom. Sensors also enable the inductor to 

only heat objects of at least four inches in diameter. This prevents any small metal objects, such 

as forks or spoons, from accidentally being heated. In addition, since the glass-ceramic panel is 

unaffected by the magnetic field, it remains relatively cool, reducing the potential for accidental 

burns. 

The primary advantages of induction elements are their fast response and control of the 

heat source, their ease of cleaning, and their ability to heat vessels that are not flat. Because 

these features have usually been associated with gas burners, induction elements are being 

marketed in competition to them. 

As just noted, the cooking vessel used with an induction element must be made from a 

ferromagnetic material. Since aluminum is not a ferromagnetic material, the current DOE test 

procedure, which specifies an aluminum test block, cannot be used to rate this equipment. In 

1978, the National Bureau of Standards (NBS), now called National Institute of Standards and 

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Technology (NIST), developed a proposed method of measuring the energy consumption of 

induction cooktops.72 The method is a modification of the current DOE test procedure. Energy 

use is determined by attaching a ferromagnetic material to the bottom of the aluminum test 

block. This modification was never formally adopted by DOE, but a source was found that 

provided data on how a typical induction element performed under the proposed method 

developed by NBS.73 An absolute efficiency of 84 percent was presented. 

Low-standby-loss electronic controls 

Electronic controls may consume power even when the electric cooktop is not performing 

its intended function. Depending on the implementation of the controller, standby power is 

required to enable the electronic controls to detect user input without the user first having to turn 

on a mechanical power switch or to enable displays, illuminate switches, etc. Reducing the 

standby power consumption of electronic controls will reduce the annual energy consumption of 

the electric cooktop, but will not impact the energy consumption of the electric cooktop during 

operation. 

For gas and electric ovens, DOE considered the technologies listed below. 

Table 3.14.6 Technology Options for Gas and Electric Ovens 

1. Bi-radiant oven (electric only) 

2. Forced convection 

3. Halogen lamp oven (electric only) 

4. Improved and added insulation 

5. Improved door seals 

6. Low-standby-loss electronic controls 

7. No oven-door window 

8. Oven separator 

9. Pilotless ignition (gas only) 

10. Radiant burner (gas only) 

11. Reduced conduction losses 

12. Reduced thermal mass 

13. Reduced vent rate 

14. Reflective surfaces 

15. Steam cooking 

Bi-radiant oven (electric only) 

A bi-radiant electric oven system was developed by Purdue University for Oak Ridge 

National Laboratory in the late 1970s74. The objective of the project was to develop an electric 

oven that offered significant energy savings without compromising food quality. The bi-radiant 

oven has three important features which provide improved performance: (1) the cavity walls are 

highly reflective rather than absorptive, thereby allowing these surfaces to operate at cooler 

temperatures; (2) the heating elements, similar in construction to those in conventional ovens but 

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operating at much lower temperatures, provide a prescribed, balanced radiant flux to the top and 

bottom surfaces of the food product; and (3) the baking and roasting utensils have a highly 

absorptive finish. 

The bi-radiant oven that was constructed was tested under a variety of cooking conditions 

(including the DOE test procedure) and also modeled (using computer thermal analysis 

programs) to determine its performance. It demonstrated a greater than 50 percent increase in 

efficiency over that of a conventional oven. In addition, the separate upper and lower heating 

elements required by the oven provided more flexibility in baking and roasting. 

Several important practical concerns have to be addressed by manufacturers in order to 

realize the demonstrated energy savings: (1) the oven lining material must be durable enough to 

maintain the low-emissivity (less than 0.1) cavity surface; (2) microprocessor controls must be 

used; and (3) as mentioned earlier, the baking and roasting utensils must have a highly absorptive 

exterior. However, given the assumption that all of these criteria are met, the 1996 analysis 

assumed a 50 percent efficiency increase. 

Forced convection 

A forced convection oven uses a fan to distribute warm air evenly throughout the oven 

cavity. The use of forced circulation can reduce fuel consumption by cooking food more 

quickly, at lower temperatures, and in larger quantities than a natural convection oven of the 

same size and rating. The fan is placed within the rear cabinet wall and a protective screen is 

placed around it. The screen prevents any items being placed in the oven from “knocking” into 

the fan and causing damage. The screen may also assist in distributing the heated air evenly 

throughout the cavity. 

Product literature from manufacturers indicates that cooking times can be reduced by 

using forced convection cooking.75 As a result, forced convection is widely used in electric 

ovens. 

For gas ovens, GRI sponsored the development of two new types of ovens that 

incorporate forced convection cooking. Both oven types, one an advanced counter-top oven and 

the other an advanced full-size oven with pyrolytic self-cleaning, also have steam-cooking 

options. The actual research and development of the ovens was being conducted at ADL at the 

time of the 1996 TSD. Of the two oven types, development of the counter-top oven was farther 

along. Test results indicated that counter-top oven cooking times are as fast as those found in 

microwave ovens.76 

More recently, Viking has introduced a gas oven with a convection fan. In product 

literature, Viking recommends reducing cooking temperatures by 25 °F and cooking time by 10 - 

15 percent.77 Wolf has also introduced gas ovens with convection cooking ability.78 

Estimates from manufacturers, researchers, and published reports (e.g., the energyefficient electrical product knowledge base prepared by ORTECH International for the Canadian 

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Electrical Association79) were included in the 1996 TSD analysis to establish the efficiency 

increase due to forced convection. Averaging these estimates results in a relative efficiency 

increase of 23 percent for gas self-cleaning ovens using forced convection cooking. For gas 

standard ovens a value of 4.8 percent was used based on more recent GRI data.80 Additional 

data submitted during the NOPR comment period of the 1996 analysis by ADL81 showed an 

increase in efficiency for electric convection ovens of only 2.4 percent. . 

It is also important to consider the added electrical energy consumption of the convection 

fan when determining the EF for ovens incorporating convection cooking. The wattage of a 

typical convection fan motor is approximately 30 watts. Since the duration of the DOE test 

procedure is approximately 30 minutes, the energy consumption of the convection fan is 

approximately 15 watt-hours. 

Additionally, ovens can use convection elements in addition to resistance and other types 

of elements to speed up the cooking process. By utilizing different cooking elements where they 

are most effective, such combination ovens can reduce the time and energy consumption 

required to cook food. For example, a convection heater and resistance element can provide 

rapid internal heating while a halogen element provides surface heating and browning. GE has 

introduced a line of combination ovens utilizing conventional resistance heating elements, 

convection heaters, and halogen elements, along with a microwave system.82 GE claims that this 

technology can reduce food preparation times by 50 percent to over 75 percent, depending on the 

item being cooked.83 However, it is unclear how much of the benefit is attributable to the forced 

convection system alone. 

Halogen lamp oven (electric only) 

Halogen elements, similar to what are used in electric cooktops, can also be used in 

electric ovens. This oven type was first introduced in Europe, but according to U.S. 

manufacturers, its acceptance has been slow in the United States. Manufacturers stated in 1996 

that the cooking performance of the halogen lamp oven is relatively poor compared to that of a 

conventional oven, though it might be advantageous for certain broiling applications. 

Alternatively, a conventional oven can use halogen elements in addition to resistance 

and/or convection elements to speed up the cooking process. By utilizing different cooking 

elements when they are most effective, combination ovens such as the GE product described 

previously for the forced convection design option can reduce the time and energy consumption 

required to cook food. However, no data were found or submitted to demonstrate how 

efficiently halogen elements alone perform relative to conventional ovens. 

Improved and added insulation 

The efficiency of an oven can be increased by either improving the insulation or adding 

more insulation to the cabinet walls and oven door. Most models can accommodate 4 inches of 

insulation in the cabinet walls and door without requiring extensive design changes to the oven. 

Most standard models have 2 inches of low-density (1.09 lb/ft3

) fiberglass insulation in the 

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cabinet walls and door, while most self-cleaning ovens use 2 inches of high-density (1.90 lb/ft3

) 

insulation. Insulation is added primarily to pass UL surface temperature tests, which explains 

why self-cleaning ovens, which require high temperatures for pyrolysis, tend to have a more 

effective insulation package. 

Data found in published papers and reports indicate that fiberglass insulation density 

levels do not exceed those found in self-cleaning ovens (1.90 lb/ft3

). Thus, while both the 

thickness and density of the insulation can be increased in most standard ovens, only the 

thickness can be increased in most self-cleaning ovens. 

Since the DOE test procedure does not require maintaining heat in the oven over an 

extended period of time, manufacturers stated in the 1996 rulemaking that increasing the 

thickness or density of the oven’s insulation will demonstrate no energy savings. But data 

provided by several sources indicate that small energy savings can be realized under the 

conditions of the DOE test procedure. 

The following sources were used in the 1996 TSD to establish the efficiency increase 

from using a denser insulation (1.09 to 1.90 lb/ft3

): (1) manufacturers’ data provided by AHAM, 

(2) the costing analysis of design options for residential appliances prepared by ADM Associates 

for LBNL84, (3) the energy-efficient electrical product knowledge base prepared by ORTECH 

International for the Canadian Electrical Association85, and (4) the 1980 DOE Engineering 

Analysis for residential appliances86. Averaging the data from these sources results in an 

efficiency increase of 4.9 percent for standard gas ovens and a 5.2 percent increase for standard 

electric ovens. 

Two sources of data were available which showed an increase in efficiency due to adding 

more insulation (2 to 4 inches): (1) manufacturers’ data provided by AHAM for the 1996 TSD 

and (2) the 1980 DOE Engineering Analysis for residential appliances87. Averaging these data 

points results in an absolute efficiency increase of approximately 1.4 percentage points. 

However, GRI88 reported no change in energy consumption by adding insulation. 

Improved door seals 

Door seals for standard ovens generally consist of a strip of silicone rubber, while selfcleaning ovens usually incorporate fiberglass seals. These seals are attached to the oven front 

frame and act as a seal for the door, which serves to reduce the loss of hot oven air through the 

door. Because some venting is required for proper cooking performance, a complete seal on the 

oven is undesirable. But the oven door seals can be improved further without sealing the oven 

completely. 

Data from the energy-efficient electrical product knowledge base prepared by ORTECH 

International for the Canadian Electrical Association89 estimates the efficiency increase from 

improving the door seals. The data indicated that an approximately 7 percent increase in 

efficiency was possible for standard electric ovens and both standard and self-cleaning gas 

ovens. However, more recent data by GRI90 show efficiency increases much less than the 7 

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percent value previously reported. A value of 1 percent, therefore, was used for the standard and 

self-cleaning gas oven analysis. The GRI report also pointed out the need for sufficient air flow 

though the oven cavity for proper heating and moisture conditions while cooking. 

Low-standby-loss electronic controls 

Electronic controls may consume power even when the oven is not performing its 

intended function. Depending on the implementation of the controller, standby power is required 

to enable the electronic controls to detect user input without the user first having to turn on a 

mechanical power switch or to enable displays, illuminate switches, etc. Since clock power is 

incorporated into the EF metric for both gas and electric ovens, reducing the standby power 

consumption of electronic controls will reduce the EF. Low-standby-loss electronic controls can 

be implemented in a wide variety of ways. 

No oven-door window 

Most ovens and ranges come equipped with windows in the door. Using the window, the 

contents of the oven can be viewed without opening the oven door. But oven-door windows 

allow more energy to be lost through the door and thus, reduce the efficiency of the oven. It 

could be argued, however, that having no window in the door necessitates frequent door 

openings to check the contents of the oven. The lost energy caused by these door openings could 

offset any energy savings that would result from eliminating the door window. 

GRI issued a topical report91 which discussed this technology option. The report was 

submitted as a written comment to the 1996 NOPR. GRI’s experimental tests showed a small 

savings in annual energy usage for both standard and self-clean ovens. However, they reported 

there could actually be a net energy loss due to consumer practices, which would be a function of 

the number of times a consumer would open the door to inspect the food while cooking. With 

four door openings per test according to the DOE test procedure, a standard oven would realize a 

net energy savings of 34 kBtu/yr. For a self-clean oven, however, GRI calculated a net energy 

loss of 3 kBtu/yr. 

Oven separator 

For loads that do not require the entire oven volume, an oven separator can be used to 

reduce the cavity volume that is used for cooking. With less oven volume to heat, the energy 

used to cook an item would be reduced. The oven separator considered here is the type that can 

be easily and quickly installed by the user. The side walls of the oven cavity would be fitted 

with “slots” that guide and hold the separator into position. Different pairs of “slots” would be 

spaced throughout the oven cavity so that the user could select different positions to place the 

separator. 

Manufacturers’ data provided by AHAM indicated that an absolute percentage point 

increase of approximately 0.82 is expected from using an oven separator in standard and selfcleaning electric ovens. For standard and self-cleaning gas ovens, percentage point increases of 

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0.1 and 0.53 are expected, respectively. No other data were provided to demonstrate whether the 

efficiency increase should be any higher or lower. 

As of January, 2007 oven separators have been researched but never been put into 

production. 

Pilotless ignition (gas only) 

Gas ovens equipped without an electrical power cord use a standing pilot ignition system. 

The EF of the oven can be increased by replacing the standing pilot system with an electric or 

electronic ignition system. Actual oven cooking efficiency is only slightly affected by 

eliminating the standing pilot. The resulting increase in the EF is primarily due to the decrease 

in the oven’s gas energy consumption during standby. 

For gas ovens equipped with a power cord, there are two types of pilotless ignition 

systems: a spark ignition system and a “glo” ignition system. The spark ignition system uses a 

spark ignitor to light a pilot. The pilot in turn ignites the oven burner. The ignitor is controlled 

by a control module, which is activated when the thermostat knob is set to a specific temperature. 

The ignitor will spark until the pilot is ignited, and the pilot will burn until the thermostat is 

turned off. If the pilot should accidentally be extinguished, a sensing circuit within the ignitor 

will reactivate the control module and cause the ignitor to spark. The spark ignition system 

consumes a negligible amount of electricity. Since the control module is powered directly off of 

line voltage, there are no 24-volt transformer losses associated with it. The spark ignitor is 

activated for an extremely short time so that its cumulative on-time during the course of a year, 

and thus its annual electricity consumption, is negligible. 

The “glo” ignition system uses a ceramic “glo”-type ignitor. When the thermostat is set 

to a specific temperature, voltage (120 volts) is applied to the ignitor. Once energized, the 

ignitor draws typically slightly over three amps and heats to a high temperature. In series with 

the ignitor is a safety valve that is electrically activated. Once the ignitor current drops to a predetermined amperage, the safety valve opens, allowing gas to flow to the oven burner. The hot 

“glo” ignitor then ignites the oven burner. Because the safety valve remains open only when the 

“glo” ignitor is drawing the correct current, the ignitor must continually draw power (typically 

around 400 watts) to keep the burner ignited.92 Thus the electrical energy consumption of a 

“glo” ignition system is significant. There are other types of ignitors which draw less wattage 

which are called “mini” hot surface ignitors (HSI). Typical mini-HSIs draw about 50 watts and 

one is reported to operate at 24 watts. However, these low-wattage ignitors draw less current 

than standard “glo” ignitors, and therefore are below the threshold current needed to open the 

safety valve. A change in design of the control systems is required to incorporate these miniHSIs into cooking oven products. 

Radiant burner (gas only) 

Viking manufactures a gas oven with a radiant burner for broiling functions. The 

infrared element is a metal screen heated by a burner until it emits infrared radiation, rapidly 

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heating food and searing the outside, while the conventional heat from the flame provides 

additional food heating. Viking claims that the infrared broiler cooks food up to 50 percent 

faster than conventional methods.93 

Reduced conduction losses 

Conduction losses from the oven can be reduced by upgrading the oven door. This 

upgrade includes an additional thermal break and a modified inner panel. In the 1996 

rulemaking, manufacturers stated that with existing instrumentation, the DOE test procedure 

cannot measure the small energy gains that can be obtained by attempting to reduce conduction 

losses. 

 However, manufacturers’ data provided by AHAM for the 1996 TSD indicated that a 

very small efficiency increase is possible. The data indicate that only an absolute percentage 

point increase of 0.05 is expected from reducing conduction losses. No other data were obtained 

to demonstrate whether the efficiency increase should be any higher or lower. 

Reduced thermal mass 

Energy is absorbed by the oven components as the oven warms to its operating 

temperature. By reducing the amount of material used in constructing the oven, the amount of 

energy that is absorbed is reduced and hence the efficiency increases. One method of achieving 

this thermal mass reduction is to reduce the gauge of sheet metal used in constructing the oven. 

Manufacturers asserted that this type of thermal mass reduction was not possible without 

compromising structural integrity (during both use and transportation) and increasing heat losses 

for electric and gas ovens manufactured at the time of the 1996 TSD. Manufacturers stated that 

the oven walls must provide strong enough support to hold racks when baking heavy items (i.e., 

turkeys or large roasts) and that oven cavity metal thickness could not be reduced any further 

without risking cracking and greater heat losses. 

Several sources of data for the 1996 TSD indicated that a 10 - 20 percent reduction in 

thermal mass is possible. The sources, which state that an efficiency increase from reducing the 

thermal mass was possible, included the following: (1) manufacturers’ data provided by AHAM, 

(2) the costing analysis of design options for residential appliances prepared by ADM Associates 

for LBNL94, and (3) the energy-efficient electrical product knowledge base prepared by 

ORTECH International for the Canadian Electrical Association95. GRI96 tests showed only a 

0.58 percent efficiency improvement for a self-cleaning oven with an equivalent of 5.52 pounds 

of wall material removed. 

Reduced vent rate 

Oven vents function primarily to remove the moisture present during the baking process. 

Self-cleaning ovens have reduced vent diameters to limit the air flow in accordance with 

combustion safety regulations during the high-temperature cleaning cycle. For safety reasons for 

the combustion process, the vent rate found in self-cleaning ovens cannot be reduced any further. 

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But the vent rate of standard ovens can be reduced to the vent rate of self-cleaning ovens. This 

can be accomplished by either reducing the vent-tube size or adding a baffle. A reduction in vent 

rate causes a corresponding increase in efficiency. 

Manufacturers stated in the 1996 TSD that reduced vent rates should only be considered 

for standard electric ovens. The vent diameters of standard and self-cleaning gas ovens are not 

significantly different, since both oven types need to maintain a satisfactory combustion 

environment. With regard to standard electric ovens, manufacturers asserted that vent sizes are 

unique to the design of the oven. The vent size is critical in maintaining the oven’s proper 

cooking and safety performance. According to the manufacturers, mandating a specific vent rate 

would require most oven models to be redesigned in order to maintain their proper performance. 

But manufacturers’ data provided by AHAM for the 1996 TSD indicated that the vent 

size of both standard electric and standard gas ovens could be reduced. Since all self-cleaning 

ovens are already designed with this technology, no new improvements are required by the 

industry to incorporate this technology option. Averaging the manufacturers’ data with data 

obtained from the costing analysis of design options for residential appliances prepared by ADM 

Associates for LBNL97 results in an increase of approximately 0.62 absolute percentage points 

for standard electric ovens and 0.5 absolute percentage points for standard gas ovens. 

Reflective surfaces 

Oven efficiency can be improved by incorporating reflective surfaces onto the walls of 

the oven cavity. Reflective surfaces improve the oven’s performance by reflecting and retaining 

infrared radiation within the oven cavity, thus increasing the percentage of heat available to be 

transferred to the food load. 

GRI98 performed tests on this technology option which resulted in a decrease in energy 

efficiency. The reflective surface interfered with the convective currents and the thermostat, thus 

fooling the thermostat into cycling. GRI reported that increased reflectance from the chromeplated inner surface of the oven caused repeated thermostat cycling that “might have contributed 

to the higher energy consumption”, which resulted in a 12.61 percent decrease in energy 

efficiency. ADL99 also commented that the reflected radiation is different from the normal 

radiation emitted by the current oven cavities in use today. 

Based on these studies, it is uncertain whether, or how much, energy savings is realizable 

with this technology option. A smarter controller for the oven seems to be a reasonable fix for 

the thermostat cycling problem. However, there is a general lack of sophistication in the 

technology to maintain clean, reflective surfaces over the lifetime of the product. Manufacturers 

stated in the previous rulemaking that reflective surfaces degrade throughout the life of the oven, 

particularly for self-cleaning ovens. 

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Steam cooking 

With steam cooking, energy is transferred to the food load by means of the condensation 

of the steam on the food surface. This may take place at essentially atmospheric pressure, or the 

cavity may be pressurized in order to allow higher steam temperatures and thus higher energy 

transfer to the food. In order to maintain the proper environment regardless of pressure, a 

“steam-tight” oven cavity must be maintained. In addition, the use of steam involves 

considerably higher demands on the oven’s design and materials. Not only are different cavity 

materials required (e.g., temperature-resistant silicone seals and chrome-nickel steel), but all 

incorporated elements and accessories have to be redesigned and intensively tested. Though 

incorporating steam cooking into oven designs is a difficult task, various manufacturers claim 

that there are advantages to using steam over conventional methods of cooking. Those 

advantages include saved energy and being able to retain more of the food’s nutritional value. 

Energy is saved because food items that normally would need to be cooked separately (e.g., a 

meat roast in an oven and vegetables on a cooktop) can be cooked together using the steam 

cooking process. 

There are several electric ovens with steam functions currently on the market. BSH 

Home Appliances has recently introduced the Gaggenau Combination Steam and Convection 

Oven. The oven utilizes a steam injection valve to control steam delivery to the cavity. The 

temperature and humidity level in the oven are user-selectable to tailor the cooking process as 

needed. Speed cooking is not advertised as the primary feature of this oven. Rather, food 

quality and nutrition is the focus. The steam capability is described as allowing vegetables to be 

cooked while retaining texture and nutritional content, meat to be roasted without drying out, and 

leftovers to be reheated without the loss of flavor and texture often associated with microwave 

reheating100. Since this is a built-in oven, water delivery and condensate drainage are provided 

via plumbing lines much like a dishwasher. 

Miele has also introduced a steam convection oven which does not require any external 

plumbing. It utilizes a refillable container for water supply and collection. 

While speed cooking is not the primary focus of steam ovens, there is evidence that there 

is time savings, particularly with larger food loads. Sharp’s counter-top Superheated Steam 

Oven, introduced in August 2004101 and which incorporates steam generators with conventional 

resistive heating elements, is described as reducing cook times for items such as chicken by 50 

percent102. 

DOE is unaware of any efficiency data for steam ovens. 

For microwave ovens, in the 1996 TSD, DOE considered all of the following 

technologies, with the exception of cooking sensors, dual magnetrons, and low-standby-loss 

electronic controls. DOE identified cooking sensors from product literature, while dual 

magnetrons were identified in the February 2006 edition of Appliance Design as a means to 

decrease cooking times. Low-standby-loss electronic controls were identified by a review of 

AHAM data for standby power. 

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Table 3.14.7 Technology Options for Microwave Ovens 

1. Added insulation 

2. Cooking sensors 

3. Dual magnetrons 

4. Eliminate or improve ceramic stirrer cover 

5. Improved fan efficiency 

6. Improved magnetron efficiency 

7. Improved power supply efficiency 

8. Low-standby-loss electronic controls 

9. Modified wave guide 

10. Reflective surfaces 

Added insulation 

Adding insulation to the outside of the reflective cavity wall of the oven would diminish 

heat flow through the walls. However, because the walls absorb a negligible fraction of the 

microwave energy, there is very little difference in temperature between the inside and the 

outside of the microwave oven. Also, during the short duration of the DOE test procedure, the 

microwave oven cavity walls do not heat up. Thus, the energy savings of this design option 

would be so small as to be not measurable. 103 

Cooking sensors 

Moisture or humidity sensors can be incorporated into the microwave oven to detect the 

cooking state of the food load during operation, inferred by the water vapor being released into 

the cavity. When the sensor detects that a desired cooking state has been reached, the controller 

shuts off the microwave oven, thereby preventing excess energy consumption in addition to 

optimizing food quality. However, DOE is unable to obtain any data to verify any energy 

efficiency impacts. 

Dual magnetrons 

Dual-magnetron microwave ovens use two magnetrons to distribute microwave energy 

within the cavity in order to more evenly heat food. Conventional microwave ovens use a single 

magnetron to generate microwaves, and a stirrer to distribute these microwaves within the 

microwave cabinet. In addition, some microwave ovens use a turntable to rotate the item being 

heated in order to increase food heating uniformity. In order to vary the power of the 

microwave, the duty cycle of the magnetron is varied. 

When food is heated unevenly in a microwave, consumers must microwave items longer 

than necessary to ensure the entire item reaches the desired temperature. When a microwave 

oven uses dual magnetrons to more evenly distribute microwaves, this additional heating to 

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ensure high temperature throughout the food may be reduced, reducing microwave energy 

consumption. 

In addition to increasing warming uniformity, dual magnetrons may reduce the need to 

cycle the single magnetron in most residential microwave ovens in order to modulate power. 

Cycling the single magnetron in most residential microwave ovens may increase wear on the 

magnetron, reducing its efficiency over its lifetime. Using two small magnetrons which together 

match the power of a single larger magnetron allows only one of these magnetrons to be engaged 

when then microwave oven is operated at reduced power levels. However, if both magnetrons 

share a single high voltage transformer, the decreased transformer efficiency at partial loading 

may offset any magnetron efficiency gains from replacing a single cycled magnetron with dual 

magnetrons. DOE is unaware of any energy efficiency data on dual magnetrons. 

Eliminate or improve ceramic stirrer cover 

Microwave ovens with fan-type mode stirrers use a cover over the fan to prevent 

inadvertent damage to the fan when inserting or removing food and to prevent degradation of the 

wave guide due to food splatter. Such models (with browning elements) sometimes use a 

ceramic mode stirrer cover because plastic types may not withstand the heat generated by the 

heating element during the browning operation104. These stirrers absorb some microwave energy 

but are needed to prevent food splatter inside the wave guide. Eliminating the ceramic cover 

would adversely affect consumer utility by requiring cleaning of the stirrer or by reducing the 

life of the stirrer. 

Improved fan efficiency 

Microwave ovens use either one or two fans. One fan is used to remove heat generated 

by the magnetron from the cavity. The second fan would be used where mode stirring is 

accomplished by using slow-moving metal blades. This allows for better distribution of the 

microwave energy. Since power demand is very low (2-3 watts), there is no opportunity for 

energy savings in models equipped with a second fan. The blower fan that is used to cool the 

magnetron and other electrical components uses about 25 watts. Increasing the efficiency of this 

fan can reduce microwave oven energy consumption. Additional data submitted during the 

NOPR comment period of the previous rulemaking were incorporated into the 1996 analysis. 

According to these data, the expected energy savings would be less than originally reported and 

would have increased cost. These data were averaged with the original data and included in the 

previous analysis. The increase in efficiency is estimated to be 0.23 absolute percentage points. 

Improved magnetron efficiency 

Magnetrons convert electrical energy input into electromagnetic energy at microwave 

frequency. The conversion efficiency of a magnetron, also known as the oscillation efficiency, is 

expressed as output power divided by the power delivered to the anode. In the range of output 

powers typical of residential-scale microwave ovens (700 – 1300 watts), nominal magnetron 

efficiency is approximately 73 percent105. Technologies are being investigated by manufacturers 

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to increase efficiencies by several percentage points. Strategies to boost efficiency include 

improving the permanent magnet to reduce its demagnetization over time and reducing the 

magnetron dark current. Oscillation efficiencies of up to 78 percent have been reported.106 

Improved power supply efficiency 

In order to operate a magnetron, a transformer must be used to increase the input line 

voltage from 120V to about 4,000V. A controller, which may dissipate as much as 30 watts, 

controls the power supply. There are two types of high voltage power supplies that are used in 

microwave ovens. The predominant type is the inductive-capacitance transformer, known as the 

LC power supply, which has an efficiency of about 82 percent. The other type is the invertertype, which is more expensive but has an efficiency of about 84 percent107. An improved power 

supply can be obtained through reduced losses in the controller and in the iron core of the 

transformer. An efficiency as high as 96 percent is theoretically possible108, but does not seem 

practicable at reasonable cost. Higher efficiency general purpose transformers do not have stable 

enough output power for microwave oven application. Earlier estimates of efficiency increase 

were 7 percent. However, data supplied by Sharp109 showed this estimate is much too high. The 

value used for the current analysis is a 2.9 percent increase in power supply efficiency. 

Low-standby-loss electronic controls 

Electronic controls may consume power even when the microwave oven is not 

performing its intended function. Depending on the implementation of the controller, standby 

power is required to enable the electronic controls to detect user input without the user first 

having to turn on a mechanical power switch or to enable displays, illuminate switches, etc. 

Reducing the standby power consumption of electronic controls will reduce the annual energy 

consumption of the microwave oven, but will not impact the energy consumption of the 

microwave oven during cooking operation. DOE is unaware of any standby power data to 

quantify the impact on energy savings. 

Modified wave guide 

Wave guides provide the interface between the microwave oven cavity and the 

magnetron. They have very high efficiencies in current models of microwave ovens. A small 

improvement (about 1 percent) is possible through the use of special coatings on the interior 

surface110. According to AHAM, the losses associated with the wave guide are typically less 

than 0.5 percent of the overall energy consumption111. 

Reflective surfaces 

Microwave ovens are designed to have surfaces that are highly reflective of microwave 

energy. A high-grade stainless steel cavity would be more reflective than a painted or 

porcelainized cavity interior. Testing by manufacturers has shown that high-grade stainless steel 

(or reflective material steel coating) would be more efficient than painted cold-rolled steel by 

approximately 0.5 percent112. 

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Although combination microwave ovens will not be analyzed due to difficulties in 

testing multiple cooking modes, a brief discussion will be included due to the potential energy 

efficiency improvement and increase in consumer utility under real-world conditions. 

One of the primary limitations of microwave cooking is that the food load heats internally 

faster than the exterior, which is in contact with the relatively cold air in the oven cavity. This 

leads to an undesirable moisture distribution, where the exterior remains soggy when the interior 

is cooked. Therefore, methods have been developed to combine microwave with other modes of 

heating to mitigate surface moisture accumulation, provide a browning function that more 

closely replicates traditional cooking processes, and reduces overall cooking times. 

Microwave and thermal or convection heating combines the features of a microwave 

oven and a conventional or convection oven. The GE Profile Oven with Trivection® utilizes 

electric radiant heating elements augmented by convection and microwave systems to speed 

cooking. While it is possible to cook in conventional thermal mode with or without convection, 

the microwave function cannot be utilized alone. According to GE, cooking times can be 

reduced by 50 – 75 percent compared to a conventional oven for foods ranging from turkey and 

beef tenderloin to lasagna, cookies, bread, and baked potatoes113. This oven is also advertised as 

compatible with all types of cookware including metal, glass, and stoneware. 

Microwave and jet air-impingement is the combination of microwave energy delivery 

plus high velocity hot air impacting the food load. This technology is widely used in commercial 

combination ovens for preparing such food products as pizzas. A residential version of this type 

of oven began shipping in the fourth quarter of 2006q

. According to Appliance Design 

magazine, the TurboChef® 30” Double Wall Speed Cook Oven cooks up to 15 times faster than 

a conventional oven114. The air jets are arrayed at the top and bottom of the cavity, and those at 

the top pass through the magnetron mode stirrer fan to enhance uniformity. The oven also 

employs dual magnetrons and top and bottom electric heating elements for faster heatup and 

broil functions. 

3.14.2.4 Commercial Clothes Washers 

For commercial clothes washers, DOE will consider technologies taken from its most 

recent analysis of amended energy conservation standards for residential clothes washers as well 

as from information provided in recent trade publications. Other than the exceptions noted 

hereafter, the following technologies are taken from a 1996 report prepared for DOE, entitled 

Design Options for Clothes Washers115. Steam washing and improved horizontal-axis-washer 

drum design were identified in the September 2005 edition of Appliance Magazine116. DOE 

identified the low-standby-power design option during its engineering analysis review of all 

AHAM product classes. Spray rinse and advanced agitator technology options were added in 

response to comments received by DOE following the Framework public meeting. 

q

 For more information, please visit www.turbochef.com. 

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Technology options that allow commercial clothes washer platforms to potentially reach 

higher efficiency levels are listed in Table 3.14.8. 

Table 3.14.8 Technology Options for Commercial Clothes Washers 

1. Adaptive control systems 

2. Added insulation 

3. Advanced agitation concepts for vertical-axis machines 

4. Automatic fill control 

5. Bubble action 

6. Direct-drive motor 

7. Electrolytic disassociation of water 

8. Horizontal-axis design 

9. Horizontal-axis design with recirculation 

10. Improved fill control 

11. Improved horizontal-axis-washer drum design 

12. Improved water extraction to lower remaining moisture content 

13. Increased motor efficiency 

14. Low-standby-power design 

15. Ozonated laundering 

16. Reduced thermal mass 

17. Spray rinse or similar water-reducing rinse technology 

18. Steam washing 

19. Suds saving 

20. Thermostatically-controlled mixing valves 

21. Tighter tub tolerance 

22. Ultrasonic washing 

Adaptive control system 

According to the DOE test procedure (10 CFR Part 430, Subpart B, Appendix J1), “an 

adaptive control system refers to a clothes washer control system which is capable of 

automatically adjusting washer operation or washing conditions based on characteristics of the 

clothes load placed in the clothes container, without allowing or requiring consumer intervention 

or actions.” This technology option uses sensors to measure the soil load to adjust the wash 

temperature, agitation and/or tumble cycle time, number of rinse cycles, spin speed, and other 

parameters. Water and energy use can then be tailored to the load, thereby avoiding washing the 

clothes more than necessary. Although the DOE test procedure does not provide a means for 

determining the energy consumption of a clothes washer with an adaptive control system, the test 

procedure does allow for specific field test procedures to measure energy consumption. 

Residential clothes washers have used fuzzy logic to weigh laundry loads and regulate 

the length of the cycle, water level, number of rinses, and drying time117. Specific clothes 

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washer designs have incorporated fuzzy logic to optimize the washing process while conserving 

water usage. The fuzzy-logic control determines the absorbency of the items being washed at the 

earliest stage possible after the start of the washing cycle. The system determines the correct 

water quantity for clear-water washing and subsequent rinsing118. 

Added insulation 

This technology option adds insulation around the outer wash tub. Because some heat 

energy is lost through the shell of the clothes washer, adding insulation around the outer tub 

slightly reduces the water temperature needed for a hot wash. However, since the wash cycle is 

relatively short and the thermal mass of the water is very high, there is very little change in water 

temperature from adding insulation. Computer simulations performed on a traditional toploading vertical-axis clothes washer for a 20-minute wash cycle at 140 °F showed that adding 

one inch of fiberglass insulation relative to no insulation resulted in only a 1-2 °F increase in 

water temperature during parts of the wash119. 

Advanced agitation concepts for vertical-axis machines 

Advanced agitation concepts replace the standard agitator found in traditional top-loading 

vertical-axis machines with an alternative manipulator to agitate clothes and thus mechanically 

remove soil. In the residential clothes washer market, these alternatives to agitators have taken 

different forms, including nutating plates, rotating disks, and side-mounted agitators. In some 

instances, such agitation concepts allow a vertical-axis washer to avoid the need to cover all 

clothes completely with water, rotating them in and out of the water-filled portion of the basket, 

much like horizontal-axis washers. Advanced agitation systems add considerable complexity to 

a vertical-axis clothes washer, and residential clothes washers that feature these technologies are 

sold for prices comparable to horizontal-axis clothes washers. 

Since the DOE test procedure captures the amount of water that a clothes washer 

consumes, the benefits of an advanced agitation concept washer can be directly measured and 

quantified via the WF. Potential energy savings are captured by the MEF as long as a portion of 

the washing cycle consumes heated water. 

Automatic fill control 

This technology option incorporates advanced control technologies to sense the clothes 

load and adjust the water level accordingly. For a traditional top-loading vertical-axis machine, 

this may mean setting the water level to just submerge the clothes load. This technology option 

can overcome the tendency of consumers to manually select a water level greater than required 

for a given load. 

The implementation of this feature varies. While this feature is inexpensive to implement 

in all horizontal-axis washers, vertical-axis washers do not benefit from the same advantages 

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regarding drum geometry and rotation axisr

. As a result, automatic fill control is typically only 

found in higher-end vertical-axis models that have electronic controls and proprietary designs, 

limiting adoption to a small percentage of the vertical-axis market. Energy is saved in either 

vertical- or horizontal-axis designs by reducing the amount of hot water used in the wash cycle. 

Bubble action 

Daewoo has developed an air-bubble washing machine. This machine uses a low-profile, 

bottom-hugging impeller typical in Asian-style vertical-axis washers and combines it with a sixwinged, rotating pulsator shaped to direct water in four directions. This pulsator also distributes 

air bubbles in different directions. The bubbles are generated by a vibrating bellows, which is 

driven by an electromagnet. Bubbles are reported to increase the cleaning power of the washer 

in several ways: (1) by inducing a high-frequency pressure fluctuation near the clothes, (2) by 

increasing the dissolution of detergent, (3) by increasing the amount of dissolved oxygen which 

increases the activity of the detergent, and (4) by lowering the viscosity of the wash water120, 121. 

Daewoo washers that utilize air-bubble washing action are available in the European market, but 

are not available to U.S. consumers.122 

Sharp also developed a bubble washer in which the bubble-generating device uses neurofuzzy-logic controls. From a nozzle located at the bottom of the washer, air bubbles are 

generated by a computer-controlled pulsator and circulated upward in vertical and horizontal 

swirling motions. The controls adjust the amount of water used, so that a single-tub design that 

washes the same load size as a conventional dual-tub (inner and outer) configuration uses only. 

70 percent as much water and detergent.123 Although it is mentioned on the manufacturer’s 

website, this washer is not available in the U.S.124 Standardized and independent tests have yet 

to be conducted on the performance of the bubble-action system; therefore, the energy savings 

potential and wash performance of a bubble-action technology option is unknown. 

Although bubble washing has been incorporated into commercial products in Europe and 

Asia, production is still extremely limited and further commercialization in the U.S. would 

require manufacturers to develop entirely new platforms. 

Direct-drive motor 

This technology option is primarily intended for use in traditional top-loading verticalaxis machines. A traditional top-loading vertical-axis clothes washer uses an induction motor, a 

mechanical transmission, and sometimes a pulley belt. A direct-drive motor can replace this 

conventional motor/transmission system. Rather than using a belt and/or transmission, a motor 

could be directly connected to the agitator, thereby avoiding transmission (gearbox) losses. In 

r

 Horizontal-axis washers can incorporate a fill switch in the sump to monitor water levels as the wash basket and its 

contents are rotated slowly at the beginning of the wash cycle. As dry clothes drop into the wash water, they absorb 

some of it and the water level in the sump drops. The fill switch then opens the fill valve(s) to raise the water level 

until the sump is full again. This approach does not work with vertical-axis washers because the clothes are always 

immersed in the water. Proprietary solutions have been implemented on some vertical-axis washers, however. 

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the past, Eaton, a motor manufacturer, claimed that this will result in less mechanical energy 

required, i.e., less energy needed to run the agitator motor. This is accomplished by using a 

brushless direct-current (BLDC) motor with electronic controls. 

Potential differences in cleaning performance due to the direct-drive substitution were not 

measured by Eaton. In addition, other parameters such as cycle time or spin speed were not held 

constant in a comparison test with a conventional washer. For the machines tested, Eaton found 

savings of about 140 watt-hours per cycle, or 64 percent of motor energy use. When adjusted for 

the direct-drive standby power, this difference drops to about 35 watt-hours per cycle or 16 

percent of motor energy use. The direct-drive standby power is the energy consumption when 

the machine is “off”. In the “off” mode, the direct-drive motor system has a power drain of 4.78 

watts. While the current DOE test procedure does not account for standby power use, real-world 

energy savings could be improved if the standby power consumption was decreased125. 

In the past, some manufacturers have stated that a limiting performance factor for this 

technology option was physical size. However, GE uses direct-drive motors on their stationary 

consumer vertical-axis washers.126 Fisher & Paykel manufactures two top-loading, vertical-axis 

direct-drive washing machines available in the U.S. market.127 Some front-loading, horizontalaxis machines also use a direct-drive motor, including models manufactured by LG.128 

Electrolytic disassociation of water 

The goal of electrolytic disassociation of water is to reduce hot water usage by 

substituting the electrolytic production of bleaching agents for activation of bleaching chemical 

reactions in detergents by hot water. A prototype clothes washer with electrolytic disassociation 

of water has been successfully tested129. Although commercial detergents perform better at high 

temperatures, the same hypochlorite concentrations obtained by adding bleaching agents to water 

can be achieved at low temperatures if the agents are produced by electrolytic disassociation 

within the machine. The bleaching action is due to the chemical reaction of the oxygen (derived 

from the chemical decomposition of the hypochlorite) with the insoluble organic compounds that 

constitute the soil in the clothes. Together they make soluble compounds that are dissolved in 

the water. 

Electrolytic disassociation was tested in a laboratory electrochemical cell. Mediumsoiled clothes and white materials were used in the test. The washing cycle test compared the 

energy consumption of electrolytic cleaning versus conventional detergents. The first test cycle, 

utilizing electrolytic action, was performed by adding four grams per liter of salt to the roomtemperature wash water in the machine. The second test cycle was run with a commercial 

detergent at a wash water temperature of 95 °F to 113 °F. For both wash methods, a normal 

cycle was run. Initial tests showed that energy use dropped from about 2.65 kWh/cycle for a 

typical washing machine to 1.35 kWh/cycle for the new electrochemical method. This 

technology is still at the research stage. 

In the past, manufacturers have stated that electrolytic disassociation is not a workable 

approach. Primary concerns are negative effects on garments resulting from the bleaching 

3-87 

EE-2006-STD-0127 COMMENT 39.2
process and poor consumer acceptance due to their inability to control the chemistry and 

temperature in the wash portion of the cycle130. 

Horizontal-axis design 

Front-loading horizontal-axis machines rotate the drum (wash basket) and clothes about a 

horizontal axis. With this design, the drum does not have to be filled with water to cover the top 

of the clothes. Therefore, horizontal-axis machines use much less water than traditional toploading vertical-axis machines. At the beginning of each wash or rinse cycle, the washer is filled 

to a specified level and the drum then rotates a few times. As dry clothes absorb the water, a 

water level sensor and the washer controller add water and keep rotating the drum slowly until 

the water level no longer changes, which signals that all clothes are saturated with water. 

Thus, the water level is matched to the laundry load. Washing performance appears to be 

equal to that of vertical-axis machines. In laboratory testing, horizontal-axis machines used on 

average 40 percent less energy and 25 percent less water than traditional vertical-axis washers 

when normalized to clothes container volume. The horizontal-axis machines also had greater 

soil removal effectiveness131. Although water savings are realized with horizontal-axis 

machines, DOE assumes that detergent use remains unchanged132 133. 

In the previous residential clothes washer rulemaking, AHAM submitted comments in 

which some manufacturers stated that factors limiting performance include: (1) soil removal, (2) 

consumer interface (ergonomics), (3) tangling, (4) cycle time, (5) rinsing and (6) suds 

sensitivity134. Although these performance-limiting factors may exist, every major manufacturer 

of clothes washers offers horizontal-axis machines for sale in the United States. 

Horizontal-axis design with recirculation 

This technology option is a variation on the horizontal-axis technology option, using a 

small pump to recirculate water out of the sump and spray it into the drum. The small amount of 

standing water in a standard horizontal-axis washer is thus further minimized. Less hot water is 

needed per wash cycle, thereby saving energy. 

In the previous residential clothes washer rulemaking, manufacturers commented that 

they have not been able to verify that a savings exists with recirculation135. Limiting factors 

mentioned by these manufacturers include: (1) soil removal, (2) tangling, (3) cycle time, (4) 

rinsing, and (5) suds sensitivity. 

In the past, Electrolux has produced models that sprayed eight liters per minute of 

water/detergent solution into the drum by means of a supply valve above the door.136 

Improved fill control 

This technology option is defined as improving the tolerance on existing wash-water fill 

sensing, which can be accomplished by reducing tolerances of presently-used pressure sensors or 

3-88 

EE-2006-STD-0127 COMMENT 39.2
improving switch design. This technology option relates primarily to top-loading vertical-axis 

design washers, although it is sometimes applicable to front-loading horizontal-axis washers, 

depending on the fill control used on the washer design. 

In a traditional top-loading vertical-axis washer, one end of an air hose is connected to an 

air chamber near the bottom of the washer tub and the other end is connected to a pressure 

switch. As water fills the tub, air in the hose and chamber is forced into a smaller volume, 

thereby increasing the air pressure. The air pressure increases until it activates a pressure switch, 

which in turn shuts off the water inlet valve. A more accurate water-level-setting system would 

avoid overfilling the wash tub, thereby reducing the amount of water and energy used. In the 

past, manufacturers have stated that they were not aware of any opportunity to reduce tolerances 

of presently-used pressure sensors137. 

Improved horizontal-axis-washer drum design 

Manufacturers of horizontal-axis washers continue to research and modify existing drum 

designs to improve wash performance, reduce mass, and increase spin speeds. With each drum 

revision, manufacturers frequently make claims that their drum designs increase consumer utility 

by being gentler on clothes or by reducing the cycle time through better agitation of the clothes 

in the washer. A reduction in cycle time would have a measurable impact on washer power 

consumption, just as drums that can sustain higher spin speeds can reduce the remaining 

moisture content (RMC) (see the Improved water extraction technology option below for the 

definition of RMC) and thus raise the MEF of a washer. Implementation of this technology 

option varies, with drums featuring special paddles, drum-wall textures, or similar 

enhancements. 

Improved water extraction to lower remaining moisture content 

Remaining moisture content (RMC) is defined as: 

(WC −WI ) RMC = WI 

where WC is the weight of the test cloth immediately after completion of the washer spin cycle, 

and WI is the “bone dry” weight of the test cloth. There are several ways to reduce the RMC, 

including: (1) increasing the spin speed of the wash basket for the final spin cycle, (2) changing 

the direction of rotation to more evenly distribute clothes, (3) having a longer spin cycle, and (4) 

increasing the size or number of drainage holes in the washer drum. Since mechanical water 

removal is more energy efficient than using heat to dry, energy consumption for the combined 

wash and dry process is reduced. 

The DOE test procedure assumes that the improved-water-extraction feature will not be 

used for 25 percent of all wash cycles. Since this feature can be consumer selectable, clothes 

subject to wrinkling can be washed with a conventional spin-cycle option to avoid a wrinkling 

3-89 

EE-2006-STD-0127 COMMENT 39.2
problem. Some manufacturers in the past were doubtful that RMCs of 35 percent and 30 percent 

could be practically obtained. 

At the time of the 2001 TSD, laboratory testing was conducted to ascertain RMCs on 

commercially-available front-loading horizontal-axis washers. Measured RMCs ranged from 49 

percent to 36 percent with a 50/50 cotton/polyester cloth load. For the same kind of test load, a 

vertical-axis machine had a 52 percent RMC. The washers for the above testing were loaded at 3 

pounds per cubic foot of basket capacity138. The DOE test procedure, however, specifies the test 

load as being closer to four pounds per cubic foot of basket capacity. Since the amount of cloth 

test load has an effect on the RMC achieved, it is unknown whether the above laboratory-tested 

machines can achieve their stated RMC values under DOE test conditions. As of the 2001 TSD, 

clothes washers with a certified RMC of up to 40 percent were available.139 

RMC data is no longer required to be published, as the current test procedure requires the 

publication of only the MEF and WF for clothes washers. RMC data can be found in the CEC 

commercial clothes washer database but this database does not cover all commercial clothes 

washers on the market, nor is it completely current. Thus, DOE is unable to determine the water 

extraction capabilities of all commercial clothes washers that are currently on the market. 

Supporting the 2001 TSD manufacturer comments indicating skepticism towards achieving 

practical lower RMC values, none of the clothes washers listed in the CEC commercial clothes 

washer database has an RMC below 39 percent. Vertical-axis commercial clothes washers 

typically feature an RMC of about 50 percent, while horizontal-axis clothes washers typically 

feature an RMC of about 40 percent, according to the DOE test procedure. 

Increased motor efficiency 

About 10 percent of the total electrical energy consumed by a typical clothes washer is 

used by the electric motor. The typical washing machine has a 1⁄2 to 2⁄3 horsepower motor. In the 

past, a residential clothes washer manufacturer stated that replacing a split-phase motor with a 

capacitor-start motor may increase the efficiency of the motor by 10 percent140. Permanent 

magnet motors offer even higher efficiencies, though the benefit of a higher-efficiency motor has 

to be balanced with the higher cost and the relatively small contribution to the overall energy 

consumption per wash cycle from the motor itself. 

Low-standby-power design 

Electronic controls may consume power even when the clothes washer is not performing 

its intended function. Depending on the implementation of the controller, standby power is 

required to enable the electronic controls to detect user input without the user first having to turn 

on a mechanical power switch or to enable displays, illuminate switches, etc. Reducing the 

standby power consumption of electronic controls will reduce the annual energy consumption of 

the clothes washer, but will not impact the energy consumption of the clothes washer during 

operation. Low-standby-loss electronic controls can be implemented in a wide variety of ways. 

DOE is unaware of any data demonstrating energy savings associated with low-standby-power 

designs for CCWs. 

3-90 

EE-2006-STD-0127 COMMENT 39.2
Ozonated laundering 

Ozonated laundering systems are available for large-scale commercial or institutional 

use. The ozone, manufactured from ambient air, is injected into the water. There is some debate 

as to how the process of the ozonated cleaning exactly works. Some claim the ozone reacts with 

soluble soils, making them insoluble, after which the mechanical action of the washing separates 

the soils from the fabric. One manufacturer proposed that the energy inherent in ozone reduces 

water tension, making the water a better solvent. Energy is saved with this system because the 

water is not heated for lightly- to moderately-soiled laundry. In fact, colder water retains a 

higher concentration of ozone for a longer time than warmer water. For heavily-soiled laundry, 

temperatures of 100-110 °F are used, which are lower than the temperatures required in a 

conventional washer. Also, since fewer chemicals are used, the rinse time is minimized, thereby 

reducing the total cycle time and water consumption. Economical ozone production is critical to 

the potential energy savings. One manufacturer estimates savings of 25 percent on “utility 

expenses” with installation of its system141. However, in addition to the ozone generator, a new 

or reprogrammed controller would be required, adding to the cost of this technology option. 

Reduced thermal mass 

This technology option uses a plastic tub specially designed to minimize the thermal 

mass that is heated by the water. Tests by manufacturers indicate that very little energy can be 

saved this way because the bulk of the thermal mass is contained in the hot water itself. One 

manufacturer compared the impact of both porcelain-enameled steel and polypropylene outer 

tubs on water temperature. Both machines were filled with 16 gallons of 140 °F water and 

agitated for ten minutes. After ten minutes, there was no significant difference in water 

temperature between the two machines. Calculations show that if there were no heat losses 

through the outer tub, the equilibrium temperature for the tested steel tub described above would 

be 138.9 °F. Therefore, there is little to be gained by decreasing the thermal mass of the outer 

tub142 . 

Plastic outer tubs are commonly used by manufacturers and can be considered as part of 

the baseline model. There is no practicable way to manufacture washing machines with plastic 

tubs with a lower thermal mass beyond the current practice. 

Spray rinse or similar water-reducing rinse technology 

 Traditional vertical-axis clothes washers immerse the clothing completely in water during 

the wash and rinse phases of the cleaning cycle. Spray-rinse systems eliminate the immersion 

requirement by spraying rinse water into the drum while the wash basket is rotating. The 

centrifugal force of the rotating basket pins the clothes against the outer walls and subsequently 

forces the rinse liquid through the clothes. In the process, the rinsing liquid picks up remaining 

suds and transports them into the sump, from which they are drained. Since immersion or partial 

immersion is no longer necessary, less rinse water is required. When using hot rinse water, this 

reduces energy consumption by reducing the amount of hot water required for the rinse cycle. 

3-91 

EE-2006-STD-0127 COMMENT 39.2
DOE is unaware of any commercial vertical-axis clothes washers currently available that utilize 

spray rinse. 

Manufacturers caution that spray-rinse or similar rinse-water-reduction technology 

options are not embraced by all customers. For example, spray-rinse technologies allegedly do 

not function well if a washer is overloaded, requiring a consumer-behavior change which is more 

easily achieved in a residential than a commercial setting. Previously-available vertical-axis 

commercial clothes washers with spray-rinse technologies have already been withdrawn from the 

market. 

AHAM may develop a rinse performance standard for clothes washers that could 

preclude the use of rinse-water-reduction technologies. The current DOE test procedure, though, 

captures the benefit of this technology option, as any reduction in water consumption improves 

WF and any reduction in heated water consumption improves MEF. 

Steam washing 

With steam washing, steam is sprayed on the laundry to help clean and sanitize the 

clothes without requiring the tub to be filled with water that is heated to sanitizing temperatures. 

Since less water must be heated to complete a steam washing cycle compared to a traditional 

washer, which immerses clothes in hot water, steam washing can reduce the energy and water 

consumption of clothes washers.143 

LG began offering two residential clothes washers in the U.S. market that use steam 

washing in 2005144. Both models are Energy Star-rated. 

Suds saving 

A suds-saving feature allows water from one wash cycle to be reused in the next wash 

cycle. After agitation, sudsy wash water is pumped into a separate storage tub, remaining there 

until the next wash cycle. While the water is stored, soil settles to the bottom of the tub. During 

the next wash cycle, all but an inch of the water is pumped back into the washer tub for use 

again145. Manufacturers believe that there is low consumer demand for this option and it would 

therefore not be used often. In addition, this option cannot be used for all loads or soil 

conditions. This option is useful only when there is more than one wash cycle per load of 

laundry, e.g., a pre-wash (which is not typically the case), or if the consumer washes more than 

one load in sequence. Subsequent washes could receive diminishing benefits if they are not 

completed immediately after the previous load, since the water in the holding tub would cool if 

left standing too long. Another limiting performance factor mentioned by more than one 

manufacturer for this technology option was soil removal. In addition, because this option 

requires an adjacent external wash tub to store suds in between wash cycles, consumer utility is 

affected. In a commercial setting, this could limit the number of clothes washers that may be 

installed. 

3-92 

EE-2006-STD-0127 COMMENT 39.2
This technology option is no longer commercially available. Electrolux formerly had a 

residential model that saved water from the final rinse of one load to use again as the prewash of 

the next cycle146. Maytag had also featured this technology as a water saving option on one of its 

washers. However, neither model is still in production. 

Thermostatically-controlled mixing valves 

Thermostatically-controlled water valves (TCWVs) are defined by the DOE test 

procedure as “clothes washer controls that have the ability to sense and adjust the hot and cold 

supply water.” This technology option achieves energy savings by more accurately controlling 

inlet water temperature for hot and warm fills. In a typical non-thermostatically-controlled water 

inlet system, two solenoid valves are used; one valve opens for hot water fills while the other 

opens for cold water fills. Both solenoid valves are opened if a warm water setting is selected. 

In the warm wash mode, fixed fractions of hot and cold water are controlled by flow-control 

devices. For example, a manufacturer may decide to specify warm water as 50 percent hot water 

and 50 percent cold water. To reduce hot water energy use, some manufacturers have reduced 

the warm water temperature by using other ratios such as 40 percent hot and 60 percent cold. 

Energy can be saved with a TCWV by either reducing the hot water temperature and/or 

reducing the warm water temperature. For example, the TCWV could be used to lower the hot 

wash temperature from 135 °F to 130 °F by mixing hot water (at 135 °F test inlet conditions) 

with cold water. Warm water temperature could be similarly reduced. The energy savings can 

vary widely depending on the test standard’s specified inlet hot water temperature and the 

selected temperature of the warm water. 

The TCWV technology option has the potential to overstate the real-world energy 

savings, depending on the proximity of the water heater to the installed clothes washer. When 

tested under laboratory conditions, the clothes washer is typically close to the hot water source, 

whereas this is generally not the case in either a residence or commercial laundry setting. As a 

result of the distance between the hot water source and the clothes washer, there is a temperature 

drop due to line losses. Because of these line losses, a clothes washer with a TCWV may use 

more hot water than predicted on the basis of laboratory testing. Similarly, in a real-world 

application, savings will also vary with the temperature of incoming cold water. The unheated 

water temperature will vary with both geographic location and time of year. More energy would 

likely be saved in cases of warmer “cold” supply water, as a TCWV would then reduce the 

amount of time a hot water valve is open. The amount of savings is also dependent on the set 

point of the TCWV, the water heater set point, the temperature selection of the wash (hot or 

warm cycle), and the location of the sensing thermostat controlling the inlet water valves. A 

limiting performance factor mentioned by more than one manufacturer is soil removal with 

lower wash temperatures. 

Tighter tub tolerance 

This technology option reduces the annular volume between the inner wash basket and 

the outer tub. This annulus fills with water, but does not add to the clothes washer capacity. 

3-93 

EE-2006-STD-0127 COMMENT 39.2
Having less space between the inner wash basket and the outer tub reduces the amount of water 

required for a fill, thereby saving the energy required to heat that water. This option applies 

primarily to traditional top-loading vertical-axis washers. In a high-efficiency top-loading or 

horizontal-axis washer, water only occupies the lower portion of the annulus. Since most of the 

annulus in a high-efficiency top-loading or horizontal-axis washer is filled with air, a smaller 

annulus does not yield significant energy savings. 

Other considerations are also important in determining an appropriate clearance between 

basket and tub. In the past rulemaking, residential clothes washer manufacturers stated that if the 

annulus is too small there may be problems with “suds lock”, where suds from the wash water 

remain between the inner wash basket and outer tub. Clearance is also needed to drain water 

during the spin-dry cycle and to allow for deflection of baskets with out-of-balance loads. 

Increasing the spin speed of the washer basket during the spin dry cycle may also require a larger 

space between tub and basket to allow for greater deflection at higher spin speeds. For this latter 

reason, tighter tub tolerance was not combined with the improved-water-extraction technology 

option. Other limiting performance factors mentioned by residential clothes washer 

manufacturers in the past include: (1) noise, (2) vibration, and (3) sand removal. 

Ultrasonic washing 

The addition of mechanical energy to the wash cycle can reduce the need for hot water 

(or chemical energy) in the cleaning action of clothes washers. One potential method of 

delivering the mechanical energy is through ultrasonic vibrations that loosen and remove some 

of the dirt on the soiled clothes. Such washing machines have been produced by a Japanese firm 

and were to be marketed in the U.S. One U.S. clothes washer manufacturer investigated the 

Japanese product and found that it did not successfully clean clothes. The U.S. firm stated that 

the Japanese company is an excellent manufacturer of ultrasonic transducers, but does not have 

experience with clothes washing. 

One of the problems with ultrasonic washing is that clothes are not uniformly exposed to 

the vibrations generated by the transducers, which means that some areas may remain soiled. 

Additionally, the wash solution and the submerged clothes appear to dissipate much of the 

energy without the clothes being cleaned. A design producing adequate cleaning action does not 

appear to have been developed147. 

3.14.3 Energy Efficiency 

In preparation for the screening and engineering analyses, DOE gathered data on the 

energy efficiency of residential dishwashers, dehumidifiers, and cooking products and 

commercial clothes washers currently available in the marketplace. This data is taken from 

databases maintained by a variety of regulatory agencies. While this section is not intended to 

provide a complete characterization of the energy efficiency of all appliances currently available 

and in use, it does provide an overview of the energy efficiency of each product covered by this 

rulemaking. 

3-94 

EE-2006-STD-0127 COMMENT 39.2
3.14.3.1 Dishwashers 

 The CEC publishes a list of “certified” residential dishwashers. Figure 3.14.2 displays 

the distribution of dishwashers in the CEC database as a function of EF. Number of Models 

100

90

80

70

60

50

40

30

20

10

0 

23 

0 

35 

86 

16 

0 2 0 

19 

3 

Energy Factor 

Figure 3.14.2 Dishwashers in the CEC Directory148 

3.14.3.2 Dehumidifiers 

Although not completely representative of the entire current dehumidifier market, Energy 

Star and AHAM publish lists of “certified” dehumidifiers. To qualify for an Energy Star rating, 

dehumidifiers must meet certain criteria depending on their capacity.s The AHAM Dehumidifier 

Certification Program verifies the water removal capacity and EF of each listed dehumidifier as 

tested by an independent laboratory.t

 These lists differ in the number of units, manufacturers, 

and capacity range. 

The following graphs plot the EF versus the capacity of each certified dehumidifier. The 

first graph presents Energy Star-certified dehumidifiers, while the second presents AHAMcertified units. Also, each graph illustrates the EPACT 2005 standards for dehumidifiers, both 

the 2007 standards and the default 2012 standards. 

>0.46 to 0.50 

>0.50 to 0.54 

>0.54 to 0.58 

>0.58 to 0.62 

>0.62 to 0.66 

>0.66 to 0.70 

>0.70 to 0.74 

>0.74 to 0.78 

>0.78 to 0.82 

>0.82 to 0.86 

s

 For more information, please visit www.energystar.gov. 

t

 For more information, please visit www.aham.org. 

3-95 

EE-2006-STD-0127 COMMENT 39.2
n=61

There are no Energy Star-certified dehumidifiers with EF ratings lower than the EPACT 

2005 standards that will become effective October 2007. In fact, many Energy Star 

dehumidifiers already have EFs that exceed the default 2012 standards. Figure 3.14.3 displays 

Energy Star-certified dehumidifier data. 

0 

0.5 

1 

1.5 

2 

2.5 

3 

Efficiency (litres/kWh) 

0 20 40 60 80 100 120

Capacity (pints/day) 

EPACT 2005-2007 Standards EPACT 2005-2012 Default Standards 

Figure 3.14.3 Energy Star-Qualified Dehumidifiers and the EPACT 2005 

Dehumidifier Standards149

Likewise, many AHAM-certified dehumidifiers have EFs that exceed the default 2012 

standards. Only one AHAM-certified dehumidifier does not meet the EPACT 2005 standards 

that will become effective October 2007. Figure 3.14.4 displays AHAM-certified dehumidifier 

data. 

3-96 

EE-2006-STD-0127 COMMENT 39.2
n=14

0 

0.5 

1 

1.5 

2 

2.5 

3 

Efficiency (litres/kWh) 

0 20 40 60 80 100 120 

Capacity (pints/day) 

EPACT 2005 - 2007 Standards EPACT 2005 - 2012 Default Standards 

Figure 3.14.4 AHAM-Qualified Dehumidifiers and the EPACT 2005 

Dehumidifier Standards150 

3.14.3.3 Cooking Products 

Conventional Cooking Products 

The DOE test procedure for cooktops is based on measuring the amount of energy 

required to raise an aluminum test block from room temperature to a specified temperature above 

room temperature. Of the efficiency data available, many are based on tests measuring the 

amount of energy that is required to boil a specified amount of water. The amount of water and 

length of time to boiling varies, depending on the researcher or manufacturer conducting the test. 

In addition, boil times vary with altitude, as increasing altitude decreases the length of time 

required to boil water. Only efficiency data based on the DOE test are used in the analysis 

because “boiling water” tests being conducted currently do not use a standardized water load or 

boiling time. 

Although not completely representative of the current U.S. cooking products market, 

Natural Resources Canada (NRCan) publishes a database of electric cooking appliance 

performance as measured by the applicable CAN/CSA test procedures. This database covers 

products available in the Canadian market, which overlaps with the U.S. market. Data from the 

NRCan database are presented as the distribution of listed models as a function of EF. 

3-97 

EE-2006-STD-0127 COMMENT 39.2
Figure 3.14.5 displays the EFs of standard open (coil)- and smooth element electric 

ranges listed in the NRCan database. 

0 

7 

15 

41 41 

17 

9 

1 1 0 0 0

5 

22 

7 

3 

20 

3 

0 0 

0 

5 

10 

15 

20 

25 

30 

35 

40 

45 

Number of Models 

Coil Top 

Smooth Top 

34 

.38 

.50

36 

40 

42 

46 

48 

50

<0.

.

.

.

.44

.

.

>0.

0

-0

-0

-0

44

-

-0

-0

-0

-0

34

36

38

40

4

46

48

2 .

0.

0.

0.

0.

0

0.

0.

0.

Energy Factor 

Figure 3.14.5 Standard Electric Ranges in the NRCan Database151 

Figure 3.14.6 displays the EFs of self-cleaning open (coil)- and smooth-element electric 

ranges listed in the NRCan database. 

3-98 

EE-2006-STD-0127 COMMENT 39.2
0 0 0 

31 

41 

17 

9 

1 1 0 0 0

3 

38 38 

19 

0 

2 

0 0 

0 

5 

10 

15 

20 

25 

30 

35 

40 

45 

Number of Models 

Coil Top 

Smooth Top 

34 

.40 

.46

36 

38 

42 

48 

50 

50

<0.

.

.

.

.44

.

.

.

-0

-0

-

-0

-0

-0

-0

>0

0

-0

3

36

38

42

44

46

4

40

48

.

.

0

0.

0.

0

0.

0.

0.

0.

Energy Factor 

Figure 3.14.6 Self-Cleaning Electric Ranges in the NRCan Database152 

Figure 3.14.7 displays the EFs of open (coil)- and smooth-element electric cooktops 

listed in the NRCan database. 

0 0 

2 

4 

5 

0 

8 

7 

0 

1 

3 

6 

2 

9 

5 

13 

12 

14 

17 

0 0 0 

0 

2 

4 

6 

8 

10 

12 

14 

16 

18 

Number of Models 

Coil 

Smooth 

0.70 0.71 0.72 0.73 0.74 0.75 0.76 0.77 0.78 0.79 0.80 

Energy Factor 

Figure 3.14.7 Cooktops in the NRCan Database153 

3-99 

EE-2006-STD-0127 COMMENT 39.2
Figure 3.14.8 displays the EFs of self-cleaning electric ovens listed in the NRCan 

database, while Figure 3.14.9 displays the EFs of non-self-cleaning electric ovens listed in the 

NRCan database. 

39 

51 

76 

14 

4 

8 

2 0 0 

16 

0 

10 

20 

30 

40 

50 

60 

70 

80 

Number of Models 

08 

09 

10 

12 

.13 

.14 

.15 

.16 

16 >0.

.

.

.

.11

.

<0

-0

-0

-0

-0

-0

-0

-0

-0

08

09

10

11

12

13

14

15

.

.

.

.

0.

0.

0.

0.

0

0

0

0

Energy Factor 

Figure 3.14.8 Self-Cleaning Electric Ovens in the NRCan Database154 

3-100 

EE-2006-STD-0127 COMMENT 39.2
Number of Models 

6 

5 

4 

3 

2 

1 

0 

5 

4 

3 

1 1 

0 0 0 0 0 

<0.08 

0.08-0.09 

0.09-0.10 

0.10-0.11 

0.11-0.12 

0.12-0.13 

0.13-0.14 

0.14-0.15 

0.15-0.16 

>0.16 

Energy Factor 

Figure 3.14.9 Non-Self-Cleaning Electric Ovens in the NRCan 

Database155 

While self-cleaning ovens tend to be more efficient than non-self-cleaning ovens, due to 

the thicker insulation required to maintain safe exterior temperatures during oven cleaning 

cycles, some non-self-cleaning ovens exhibit EFs comparable to self-cleaning electric ovens. 

However, no non-self-cleaning electric ovens have EFs above 0.15, while 16 self-cleaning 

electric ovens have EFs exceeding 0.16. 

Microwave Ovens 

For microwave ovens, the DOE test procedure utilizes the test procedures specified in 

IEC 705-1998 and Amendment 2-1993. It should be noted that IEC 705-1998 and Amendment 

2-1993 has been superseded by IEC 60705 Edition 3.2-2006. DOE does not plan to revise the 

test procedure to incorporate IEC 60705 Edition 3.2-2006, to measure the cooking efficiency, 

because DOE is unaware of any efficiency comparison data that would justify such a change. 

Microwave ovens consume energy in cooking mode, when heating food, and in standby 

mode, while powering the clock and electronic controls. AHAM recently provided data on 

microwave oven efficiency and standby power for a sample of microwave ovens available in the 

U.S. market.156 Microwave oven efficiency was tested according to DOE’s test procedure. 

Standby power was tested according to IEC 62301-2005. Although AHAM only tested 21 units 

from 9 manufacturers, the units were selected to represent a broad spectrum of units available in 

the market place, and had varying capacities and features. Figure 3.14.10 through Figure 3.14.11 

display the AHAM microwave oven efficiency data. 

3-101 

EE-2006-STD-0127 COMMENT 39.2
50% 

55% 

60% 

65% 

Efficiency 

600 700 800 900 1000 1100 1200 1300 1400 

Rated Output Power (W) 

Figure 3.14.10 AHAM Microwave Oven Efficiency versus Rated Output 

Power 157 

Figure 3.14.10 illustrates the lack of a correlation between microwave oven rated output 

power and microwave oven efficiency. Efficiency remains nearly linear across the tested output 

power range. Figure 3.14.11 illustrates the relationship between microwave oven volume and 

microwave oven efficiency. Again, microwave oven efficiency remains constant and nearly 

linear regardless of microwave oven volume. 

3-102 

EE-2006-STD-0127 COMMENT 39.2
50% 

55% 

60% 

65% 

Efficiency 

0.0 0.5 1.0 1.5 2.0 2.5 

Microwave Oven Volume (ft^3) 

Figure 3.14.11 AHAM Microwave Oven Efficiency versus Oven Volume158 

Figure 3.14.12 displays AHAM-measured microwave oven standby power consumption 

data as a function of rated output power. Figure 3.14.12 also contains standby energy 

consumption measurements made by the Canadian Building Energy End-Use Data and Analysis 

Center (CBEEDAC) at the University of Alberta. The data show a wide range of standby power 

usage, but there is no correlation between standby power consumption and output power. 

3-103 

EE-2006-STD-0127 COMMENT 39.2
0.0 

1.0 

2.0 

3.0 

4.0 

5.0 

6.0 

7.0 

Standby Power Consumption (W) 

600 800 1000 1200 1400 1600 

Rated Output Power (W) 

AHAM Data CBEEDAC Data 

Figure 3.14.12 AHAM Microwave Oven Standby Power 

160 Consumption159, 

FEMP publishes a database of microwave oven standby power consumption, although 

this database is also not completely representative of microwave ovens available in the U.S. 

market. Figure 3.14.13 displays the number of microwave oven models available with different 

standby power consumption rates as listed in the FEMP standby power consumption database. 

3-104 

EE-2006-STD-0127 COMMENT 39.2
100

90

Number of Models 

80

70

60

50

40

30

20

10

0 

0 to 1 W 1.1 to 2 W >2 W 

1 

28 

90 

Standby Power Consumption 

Figure 3.14.13 Microwave Oven Standby Power Consumption from the 

FEMP Database161 

FEMP does not categorize microwave ovens by rated power. Therefore, it is not possible 

to make a direct comparison between the FEMP microwave oven standby data and the AHAM 

microwave oven test data. However, the distribution of standby power consumption in both the 

FEMP database and the AHAM data is similar. Very few microwave ovens consume less than 

one watt of standby power, some microwave ovens consume less than two watts of standby 

power, but the large majority of microwave ovens consume more than two watts of standby 

power. 

3.14.3.4 Commercial Clothes Washers 

Although not completely representative of the current commercial clothes washer market, 

the CEC publishes a list of “certified” products. Even though the Federal standard only recently 

was raised to an MEF of 1.26, California had previously enacted a minimum standard at that 

level, so the database only contains products with MEFs of 1.26 and higher. Figure 3.14.14 

displays the distribution of commercial clothes washers in the CEC database as a function of 

MEF. 

3-105 

EE-2006-STD-0127 COMMENT 39.2
80 

70 

60 

50 

40 

30 

20 

10 

0 

74 

0 

19 

0 

31 

1 0 

19 

0 0 0 2 0 0 0 0 0 

59 

0 

50 

0 0 

Number of Models 

1.26 to 1.3 

>1.3 to 1.4 

>1.4 to 1.5 

>1.5 to 1.6 

>1.6 to 1.7 

>1.7 to 1.8 

>1.8 to 1.9 

>1.9 to 2.0 

>2.0 to 2.1 

>2.1 to 2.2 

>2.2 to 2.3 

MEF 

Vertical Axis Horizontal Axis 

Figure 3.14.14 MEF of Commercial Clothes Washers in the CEC 

Directory162 

Figure 3.14.14 illustrates the difference in MEF between vertical-axis commercial clothes 

washers and horizontal-axis commercial clothes washers. All of the commercial clothes washers 

with an MEF above 1.5 are horizontal-axis units, whereas all but one of the washers with an 

MEF below 1.5 are vertical-axis washers. No commercial vertical-axis washer has an MEF 

above 1.5, while 67 horizontal-axis commercial washer models have an MEF above 2.0. The 

majority of qualified commercial clothes washers are horizontal-axis units, further indicating the 

higher average MEF of horizontal-axis commercial clothes washers. 

The CEC list of certified products also contains data on WF. The database contains 

products with WF of 13 or lower. Figure 3.14.15 displays the distribution of commercial clothes 

washers in the CEC database as a function of WF. 

3-106 

EE-2006-STD-0127 COMMENT 39.2
0 0 1 

20 

42 

2 4 

34 

10 

50 

60 

8 

13 

2 0 0 0 0 

0 

10 

20 

30 

40 

50 

60 

70 

Number of Models 

5 to 6 

>6 to 7 

>7 to 8 

>8 to 9 

>9 to 10 

>10 to 11 

>11 to 12 

>12 to 13 

>13 to 14 

WF 

Vertical Axis Horizontal Axis 

Figure 3.14.15 WF of Commercial Clothes Washers in the CEC 

Directory163 

Figure 3.14.15 illustrates the difference in WF between vertical-axis commercial clothes 

washers and horizontal-axis commercial clothes washers. All of the commercial clothes washers 

with a WF above 9 are commercial vertical-axis units, whereas all of the washers with WF below 

7 are horizontal-axis commercial units. No vertical-axis washer has a WF below 7, while 68 

horizontal-axis commercial washer models have a WF below 7. The majority of qualified 

commercial clothes washers are horizontal-axis units, further indicating the lower average WF of 

horizontal-axis commercial clothes washers. 

3-107 

EE-2006-STD-0127 COMMENT 39.2
REFERENCES 

1 Consortium for Energy Efficiency (CEE). 1998. Commercial, Family-Sized Washers: 

An Initiative Description of the Consortium for Energy Efficiency. 

2 “The Share-of-Market Picture for 2005”. Appliance Magazine, September 2006. 

3 Ibid. 

4 Ibid. 

5 Ibid. 

6 Ibid. 

7 Ibid. 

8 Maytag. 2005. “Whirlpool Corporation and Maytag Corporation Sign Definitive Merger 

Agreement”. Maytag Press Release, August 22, 2005. 

9 P. Hussmann. 2006. “Justice to Extend Maytag-Whirlpool Merger Review”. Newton 

Daily News Online, February 14, 2006. 

10 W. Ryberg. 2006. “Harkin, Boswell want Maytag sale blocked”. Des Moines Register, 

January 13, 2006. 

11 Ibid. 

12 U.S. Department of Justice (U.S. DOJ). 2006. Department of Justice Antitrust Division 

Statement on the Closing of its Investigation of Whirlpool’s Acquisition of Maytag. 

March 29, 2006. 

13 Ibid. 

14 Association of Home Appliance Manufacturers (AHAM) Fact Book 2005. 

15 AHAM Fact Book 2003. 

16 CEE. 1998. Op. Cit. 

17 Ibid. 

18 Ibid. 

3-108 

EE-2006-STD-0127 COMMENT 39.2
19 DOE Docket No. EE-RM-PET-100, submitted by the California Energy Commission 

January 29, 2007. 

20 U.S.

21

22

23

24

25

26

Census Bureau. 2006. “Table Q1. New Privately Owned Housing Units Started in 

the United States by Purpose and Design.” New Residential Construction, February 

2006. 

Ibid. 

AHAM Fact Book 2005. 

Ibid. 

Northwest Energy Star Partners 2005 Market Share Report. Available online at 

http://www.northwestenergystar.com/index.php?cID=226 

AHAM Fact Book 2005. 

U.S. Census Bureau. 2005. “Table 2 - Statistics for Industry Groups and Industries: 2004 

and Earlier Years.” 2004 Annual Survey of Manufacturers (ASM), December 2005. 

27 AHAM Fact Book 2003. 

28 AHAM Fact Book 2005. 

29 J. Notini. 2006. Personal communications. AHAM. Washington, DC, December 2006. 

30 Ibid. 

31 Ibid. 

32 Ibid. 

33 AHAM Fact Book 2005 

34 Ibid. 

35 AbsoluteHome.com-Home Décor Products, Inc. Appliances—Laundry—Commercial 

Washers. 

<http://www.absolutehome.com/web/catalog/ethumbs.aspx?N=102+2204250+4294954347&Ns=P_Priced 

From|1&Nu=P_UniqueID> (Accessed October 16, 2006.) 

36 Abt Electronics, Inc. Appliances—Laundry Products—Commercial Washers. Glenview, 

IL. <http://www.abtelectronics.com/category/528.html> (Accessed October 16, 2006.) 

3-109 

EE-2006-STD-0127 COMMENT 39.2
37 AJMadison. Laundry—Washers. Glenview, IL. 

<http://www.ajmadison.com/cgi-bin/ajmadison/category/cat00174/Laundry.html> 

(Accessed October 16, 2006.) 

38 J. Cole. 2006. Personal Communications. Commercial & Coin Laundry Equipment 

Company, Gulf Breeze, FL. Telephone call with Lawrence Berkeley National 

Laboratory, September 18, 2006. 

39 E. Grimshaw. 2006. Personal Communications. Commercial Laundry Equipment, 

Arroyo Grande, CA. Telephone call with Lawrence Berkeley National Laboratory, 

September 15, 19, 2006. 

40 D. Hoffman. 2006. Personal Communications. Gold Coin Laundary Equipment, Inc., 

Jamacia, NY. Telephone call with Lawrence Berkeley National Laboratory, September 

15, 25, 2006. 

41 D. Smith. 2006. Personal Communications. Mac-Gray Services, Inc., Albany, GA. 

Telephone call with Lawrence Berkeley National Laboratory, September 25, 2006. 

42 L. Mears. 2006. Personal Communications. Texax Laundry Service Company, 

Pasadena, TX. Telephone call with Lawrence Berkeley National Laboratory, September 

13, 2006. 

43 Laundry Systems. Products. Medina, OH. 

<http://www.laundrysystems.com/index.html> (Accessed September 25, 2006.) 

44 U.S. Census Bureau. 2006. “Table 2 - Statistics for Industry Groups and Industries: 2005 

and Earlier Years.” 2005 Annual Survey of Manufacturers (ASM), December 2006. 

45 Ibid. 

46 Ibid. 

47 U.S. Census Bureau, Survey of Plant Capacity: 2004 to 1994. 

48 “An Intelligent Wash Process Sensor.” Scientific Honeyweller, Sensors Issue, 1996. 

49 ASKO Product literature. Available online at 

http://www.askousa.com/pub/manuals/dishwashers/current/EnglishD3mmm_Installation.pdf 

50 Appliance Magazine, November 2005. 

3-110 

EE-2006-STD-0127 COMMENT 39.2
51 Appliance Magazine, October 2002. 

52 U.S. DOE. 1997. Technical Support Document for Energy Conservation Standards for 

Room Air Conditioners, Washington, DC, September 1997. 

53 Ibid. 

54 Ibid. 

55 Ibid. 

56 Ibid. 

57 K. Heinecke. “Single Phase Electric Motors – Characteristics & Applications.” Available 

online at <http://www.iprocessmart.com/leeson/leeson_singlephase_article.htm>. 

58 P. Simmons. 2003. “The Art of Providing Savings.” Appliance Magazine, October 

2003. 

59 U.S. DOE. 1997. Op. cit. 

60 Simmons. 2003. Op. cit. 

61 Ibid. 

62 Y. Yamada, T. Sobue, M. Oyaizu, 2003. “Glass-Ceramic Top Plate Gas Cooking Hob 

with High Efficiency”, Proceedings of the 22nd World Gas Conference, Tokyo, Japan, 

June 2003. 

63 U.S. DOE. 1980. Engineering Analysis. Washington, DC, DOE/CS-0166, June 1980, pp 

D7-1 to D7-28. 

64 J. Flood and T. Enga. 1983. “Energy Conservation Aspects of Cooking Appliances.” 

1983 International Gas Research Conference, Watson House, British Gas Corporation, pp 

741-754. 

65 M. Shepard, A. Lovins, J. Neymark, D. Houghton, and H. Heede, 1990. The State of the 

Art: Appliances. Rocky Mountain Institute, COMPETITEK Information Service, 

Snowmass, CO. August 1990, pp 132-151. 

66 ADM Associates Inc. (ADM). 1987. Costing Analysis of Design Options for Residential 

Appliances and Space-Conditioning Equipment. Prepared by ADM Associates Inc., 

Sacramento, CA, for Lawrence Berkeley Laboratory, Purchase No. 4541710, December 

1987, pp 9-1 to 9-20. 

3-111 

EE-2006-STD-0127 COMMENT 39.2
67 ORTECH International (ORTECH). 1989. Energy-Efficient Electrical Product 

Knowledge Base. Prepared by ORTECH International, Mississauga, Ontario, Canada, 

for the Canadian Electrical Association, C.E.A., No. 821 U 678, October 1989, pp 25-39. 

68 Arthur D. Little Inc. (ADL). 1994. Electric Oven and Cooktop Data Analysis. Prepared 

by ADL, Cambridge, MA, for AHAM, Reference 47066, submitted as comments No. 001 

to the Notice of Proposed Rulemaking, July 15, 1994. 

69 ORTECH. 1989. Op. cit. 

70 U.S. DOE. 1980. Op. cit. 

71 Shepard et al.. 1990. Op. cit. 

72 L. Andrews. 1978. Proposed Test Procedure for Induction Cooking Tops. National 

Bureau of Standards, Washington, DC, October 1978. 

73 K.C. Datwyler and J.R. McFadden. 1992. “A Comparative Analysis of Performance 

Characteristics of Gas and Electric Cooktops.” Proceedings of the 43rd Annual 

International Appliance Technical Conference, West Lafayette, IN, May, 1992, pp 485­

496. 

74 D. DeWitt and M. Peart. Bi-Radiant Oven: A Low-Energy Oven System. Purdue 

University, West Lafayette, IN. Prepared for Oak Ridge National Laboratory, Oak 

Ridge, TN, ORNL/Sub-80/0082/1, ORNL/Sub-80/0082/2, ORNL/Sub-80/0082/3. 

75 GE Appliances product literature. Available online at 

http://www.geappliances.com/products/introductions/trivection/overview/compare_cook_ 

times.htm 

Viking product literature. Available online at

 http://www.vikingrange.com/consumer/products/product.jsp?id=prod150050 

76 D. McFadden, R. Topping, D. Frizche, and R. Hemphill. 1991. “Advanced Residential 

Gas Oven Development”. Proceedings of the 42nd International Appliance Technical 

Conference, Madison, WI, May 1991, pp 83-94. 

77 Viking product literature. Available online at

 http://www.vikingrange.com/consumer/products/product.jsp?id=prod150050 

78 Wolf Product literature. Available online at

 http://www.subzero.com/wolf/description.asp?category=gas%20ranges&id=18 

79 ORTECH. 1989. Op. cit. 

3-112 

EE-2006-STD-0127 COMMENT 39.2
80 Gas Research Institute (GRI). 1994. Topical Report: Technical Input to NAECA 

Rulemaking for Gas-Fired Ranges. Prepared by Battelle, Columbus, OH, American Gas 

Association Laboratories, Cleveland, OH, and Arthur D. Little, Cambridge, MA for Gas 

Appliance Technology Center, Chicago, IL. Comment No. 001 to NOPR, GRI-94/0195, 

July 1994. 

81 ADL. 1994. Op. cit. 

82 GE Advantium product literature. Available online at 

http://www.geappliances.com/products/introductions/advantium/ 

83 GE Advantium product literature. Available online at 

http://www.geappliances.com/products/introductions/advantium/saving_you_time.htm 

84 ADM. 1987. Op. cit. 

85 ORTECH. 1989. Op. cit. 

86 U.S. DOE. 1980. Op. cit. 

87 Ibid. 

88 GRI. 1994. Op. cit. 

89 ORTECH. 1989. Op. cit. 

90 GRI. 1994. Op. cit. 

91 GRI. 1994. Op. cit. 

92 P. Seibold. 1995. Personal communication. Norton Company. Worcester, MA, March 

1995. 

93 Viking product literature. Available online at

 http://www.vikingrange.com/consumer/products/product.jsp?id=prod150050 

94 ADM. 1987. Op. cit. 

95 ORTECH. 1989. Op. cit. 

96 GRI. 1994. Op. cit. 

97 ADM. 1987. Op. cit. 

3-113 

EE-2006-STD-0127 COMMENT 39.2
98 GRI. 1994. Op. cit. 

99 ADL. 1994. Op. cit. 

100 M. Lowe. 2006. “Cooking Technologies: Overachieving Ovens”. Appliance Design, 

February 1, 2006. 

101 Appliance Magazine, August 2004. 

102 Lowe. Op. cit.. 

103 AHAM. 1990. Comments on the Advanced Notice of Proposed Rulemaking Regarding 

Energy Conservation Standards for Room Air Conditioners and Kitchen Ranges and 

Ovens. FR 55(189), September 28, 1990, Docket Number CE-RM-90-201, Comment 

Number 61, December 12, 1990, p 30. 

104 AHAM. 1990. Op. cit. p 35. 

105 AHAM. 2006. AHAM Test Data on Microwave Ovens. October 23, 2006, Docket 

Number EE-2006-STD-0127, Comment Number 17, November 30, 2006. 

106 T. Ishii, T. Handa, M. Aiga, N. Kuwahara. 2006. “Magnetron”, U.S. Patent Number 

7,023,137, Assigned to Matsushita Electrical Industrial Co., Ltd., Osaka, Japan, April 4, 

2006. 

107 AHAM. 2006. Op. cit. 

108 C.R. Buffler, Efficiency Improvement Techniques for Microwave Ovens. Litton 

Microwave Cooking Products, Minneapolis, MN. 

109 Sharp Electronics Corp. 1994. Comments on the Notice of Proposed Rulemaking for 

Microwave Ovens. FR 59(43), March 4, 1994, Docket Number EE-RM-90-201, 

Comment Number 521, July 18, 1994. 

110 Ibid. 

111 Ibid. 

112 Ibid. 

113 GE Appliances product literature. Available online at 

http://www.geappliances.com/products/introductions/trivection/overview/compare_cook_ 

times.htm 

3-114 

EE-2006-STD-0127 COMMENT 39.2
114 Lowe. 2006. Op. cit. 

115 P. Biermayer et al.. 1996. Design Options for Clothes Washers. Lawrence Berkeley 

National Laboratory (LBNL), Berkeley, CA, LBL-47888, October 1996. 

116 Appliance Magazine, September 2005. 

117 Appliance Manufacturer, April 1995, p 27. 

118 Appliance Manufacturer, February 1995, p E-58. 

119 Science Applications Inc. 1977. Energy Efficiency Program for Clothes Washers, 

Clothes Dryers and Dishwashers, SAI-77-839, La Jolla, CA. pp 4-45. 

120 “Big Plans for Tiny Bubbles”. Appliance Manufacturer, December 1994, p 32. 

121 “Sorting Through Laundry”. Appliance, September 1994, p 35. 

122 Daewoo product literature. Available online at: 

http://www.daewoo-electronics.de/eu/products/living_washing_prod.asp?idprod=235 

123 I. Turiel, et al. 1995. Evaluation of Advanced Technologies for Residential Appliances 

and Residential and Commercial Lighting. Lawrence Berkeley National Laboratory, 

Berkeley, CA, LBL-35982, January 1995. 

124 Sharp product timeline. Available online at: 

 http://sharp-world.com/corporate/info/his/chronology/p10.html

125 S. Kristic et al. 1993. “Direct Comparison: Assessing the Energy Efficiency Impact of a 

Transmissionless Motor/Drive System for Conventional Clothes Washers”. Proceedings 

of the 44th Annual International Appliance Technical Conference, p.101, May 1993. 

126 GE product literature. Available online at 

http://products.geappliances.com/ApplProducts/Dispatcher?REQUEST=RESULTSPAG 

E&CATEGORY=CA0096&CATEGORY=CA0095&SITEID=GEA 

127 Fisher & Paykel product literature. Available online at 

http://usa.fisherpaykel.com/global/laundry-products/clothes-washers/clothes-washer.cfm 

128 LG Electronics product literature. Available online at 

http://us.lge.com/products/model/detail/home%20appliances_laundry_washers_WM2688 

H.jhtml 

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EE-2006-STD-0127 COMMENT 39.2
129 U.S. DOE. 1990. Technical Support Document: Energy Conservation Standards for 

Consumer Products: Dishwashers, Clothes Washers, and Clothes Dryers, p.3-14, 

DOE/CE-0299P, December 1990. 

130 Ibid. 

131 ADL. 1995. Laboratory Testing of Clothes Washers, pp 3-8, December, 1995, EPRI 

Report No. TR-105098. 

132 A. Cahn. 1994. The Laundering Process, handout presented at the Workshop on Home 

Laundry Energy Standards Regulatory Issues, Washington, D.C., November 11, 1994. 

133 Procter & Gamble. 1995. Comments on the Advance Notice of Proposed Rulemaking, 

DOE Docket No. EE RM-94-403, comment #9, January 20, 1995. 

134 AHAM. 1995. Comments on the Advance Notice of Proposed Rulemaking. 

No. EE RM-94-403, comment #27, May 8, 1995. 

135 Ibid. 

136 “New for ‘93”, Electrolux product literature, Domotechnica. 

137 Biermayer et al. 1996. Op. cit. 

138 ADL. 1995. Op. cit. 

139 Biermayer et al. 1996. Op. cit. 

140 AHAM. 1995. Op. cit. 

DOE Docket 

141 Electric Power Research Institute (EPRI). 1996. Ozone Laundering: A Better Wash 

Process for Commercial Laundries, Technical Brief RP2890, March 1996. 

142 U.S. DOE. 1990. Op. cit. 

143 Appliance Magazine, June 2005. 

144 Ibid. 

145 “New Ways of Washing”. Appliance, September 1992, p.75. 

146 Appliance, September 1995, p.51. 

147 Turiel et al. Op. cit. 

3-116 

EE-2006-STD-0127 COMMENT 39.2
148 California Energy Commission (CEC) Appliance efficiency database. Available online 

at http://www.energy.ca.gov/appliances/appliance/excel_based_files/ 

149 Energy Star Dehumidifier database. Available online at

 http://www.energystar.gov/index.cfm?c=dehumid.pr_dehumidifiers 

150 AHAM Dehumidifier database. Available online at 

 http://207.140.180.12/dirsvc/aham.nsf/fraDehum?OpenFrameset&pgm=Dehumidifiers 

151 Natural Resources Canada (NRCan) Database of Major Appliances. Available online at 

 http://oee.nrcan.gc.ca/residential/personal/appliances.cfm?attr=4 

152 Ibid. 

153 Ibid. 

154 Ibid. 

155 Ibid. 

156 AHAM. 2006. Op. cit. 

157 Ibid. 

158 Ibid. 

159 Ibid. 

160 N. Fish, D. White, and D. Ryan. Standby Power Energy Use of Common Household 

Appliances. Canadian Building Energy End-Use Data and Analysis Center. University 

of Alberta, Canada. July, 2006. 

161 FEMP Microwave standby power database. Available online at 

 http://oahu.lbl.gov/cgi-bin/search_data.pl 

162 CEC Appliance efficiency database. Op. cit. 

163 Ibid. 

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EE-2006-STD-0127 COMMENT 39.2