CHAPTER 7. MARKUPS FOR EQUIPMENT PRICE DETERMINATION 

TABLE OF CONTENTS 

7.1 INTRODUCTION ........................................................................................................... 7-1 

7.2 DISTRIBUTION CHANNELS ....................................................................................... 7-1 

7.3 MARKUP CALCULATION PROCEDURE .................................................................. 7-2 

7.3.1 Approach for Manufacturer Markups .............................................................................. 7-3 

7.3.2 Approach for Distributor Markups .................................................................................. 7-3 

7.3.3 Overall Markup................................................................................................................ 7-5 

7.4 MANUFACTURER MARKUPS .................................................................................... 7-6 

7.5 DISTRIBUTOR MARKUPS........................................................................................... 7-7 

7.6 SALES TAXES ............................................................................................................... 7-9 

7.7 SUMMARY OF MARKUPS ........................................................................................ 7-10 

LIST OF TABLES 

Table 7.4.1 Major Appliance Manufacturer Gross Margins and Markups............................. 7-7 

Table 7.5.1 Data Used to Calculate Distributor Markups....................................................... 7-8 

Table 7.5.2 Distributor (Mac-Gray) Baseline Markup ........................................................... 7-9 

Table 7.6.1 Average Sales Tax Rates by Census Division and Large State ......................... 7-10 

Table 7.6.2 Average Sales Tax Rates ................................................................................... 7-10 

Table 7.7.1 Summary of Markups ........................................................................................ 7-10 

LIST OF FIGURES 

Figure 7.2.1 Distribution Channel for Commercial Clothes Washers ..................................... 7-2 

7-i 

EERE-2006-STD-0127 COMMENT 69.1
 

CHAPTER 7. MARKUPS FOR EQUIPMENT PRICE DETERMINATION 

7.1 INTRODUCTION 

To carry out the engineering and life-cycle cost (LCC) analyses, DOE needed to 

determine the cost to the customer of a baseline product and the cost of more-efficient units. By 

applying a multiplier called a “markup” to the manufacturers’ equipment costs estimated in the 

engineering analysis, DOE estimated the consumer prices for baseline models and more-efficient 

equipment. 

This chapter presents information and results pertaining solely to CCWs. As described in 

section 1.3 of chapter 1 of this technical support document (TSD), DOE is continuing the 

rulemaking for energy conservation standards for microwave oven standby power, and analyses 

related to these products will be published in a separate TSD. In addition, DOE issued a final 

rule1

 adopting energy conservation standards for conventional cooking products (i.e., cooktops 

and ovens) and microwave oven energy factor (EF), and details of the analyses for these products 

are contained in the corresponding final rule TSD.2 

7.2 DISTRIBUTION CHANNELS 

The appropriate markups for determining the consumer equipment price depend on the 

type of distribution channels through which products move from manufacturers to purchasers. 

At each point in the distribution channel, companies mark up the price of the equipment to cover 

their business costs and profit margin. 

For commercial clothes washers, DOE based the distribution channels (see Figure 7.2.1) 

on data developed by the Consortium for Energy Efficiency (CEE).3 The CEE states that the 

relevant portions of the commercial, family-sized clothes washer market can be divided into 

three areas: laundromats; private multi-family housing; and large institutions. Included as part of 

large institutions are military barracks, universities, housing authorities, lodging establishments, 

and health care facilities. For these three market areas, the CEE data indicate that an 

overwhelming majority of commercial clothes washers are sold through either distributors or 

route operators. Laundromats generally purchase their equipment through distributors while 

multi-family housing and large institutions generally lease their equipment from route operators. 

For purposes of developing the markups for commercial clothes washers, DOE based its 

calculations on the distribution channel that involves only distributors. DOE assumed that the 

markups and the resulting consumer equipment prices determined for the distribution channel 

involving distributors would be representative of the prices paid by consumers acquiring their 

equipment from route operators. 

7-1 

EERE-2006-STD-0127 COMMENT 69.1
Source: CEE, 1998 

Figure 7.2.1 Distribution Channel for Commercial Clothes Washers 

7.3 MARKUP CALCULATION PROCEDURE 

As just discussed, at each point in the distribution channel, companies mark up the price 

of the equipment to cover their business costs and profit margin. In financial statements, gross 

margin is the difference between the company revenue and the company cost of sales or cost of 

goods sold (CGS). Inputs for calculating the gross margin are all corporate costs—including 

overhead costs (sales, general, and administration); research and development (R&D) and 

interest expenses; depreciation, and taxes—and profits. In order for sales of a product to 

contribute positively to company cash flow, the product’s markup must be greater than the 

corporate gross margin. Individual products may command a lower or higher markup, 

depending on their perceived added value and the competition they face from similar products in 

the market. 

In developing markups for manufacturers and distributors, DOE obtained data about the 

revenue, CGS, and expenses of firms that produce and sell the products of interest. DOE’s 

7-2 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

approach categorizes the expenses into two categories: labor-scaling costs (LSC), which are fixed 

labor and occupancy expenses that increase in proportion to the amount of labor required to 

produce or sell the product, and non-labor-scaling costs (NLSC), which are variable operating 

costs that do not scale with labor and vary in proportion to CGS. Together, LSC and NLSC 

represent the gross margin. 

7.3.1 Approach for Manufacturer Markups 

DOE uses manufacturer markups to transform a manufacturer’s equipment costs into a 

manufacturer sales price. Using the CGS and gross margin, DOE calculated the manufacturer 

markup (MUMFG) with the following equation: 

CGS MFG + GMMFG MU MFG = CGS MFG

where: 

MUMFG = Manufacturer markup, 

CGSMFG = Manufacturer’s cost of goods sold, and 

GMMFG = Manufacturer’s gross margin. 

7.3.2 Approach for Distributor Markups 

DOE based the distributor markups for commercial clothes washers on financial data 

from the U.S. Census Business Expenditure Survey. DOE organized the financial data into 

balance sheets that break down cost components incurred by firms that sell the products.a The 

key assumptions that DOE used to estimate the distributor markups using these financial data 

were: 

1.	 The balance sheets faithfully represent the various average costs incurred by firms selling 

home appliances and commercial clothes washers. 

2.	 These costs can be divided into two categories: 

a.	 Costs that vary in proportion to the manufacturer sales price (variable costs); and 

b.	 Costs that do not vary with the manufacturer sales price (fixed costs). 

3.	 Distributor sales prices vary in proportion to distributor costs that are included in the 

balance sheets. 

In support of the first assumption, the balance sheets itemize firm costs into a number of 

expense categories, including CGS, operating labor and occupancy costs, and other operating 

costs and profit. Although distributors tend to handle multiple commodity lines, the data provide 

the most accurate available indication of commercial clothes washer expenses. 

a

 The retailers and distributors to whom these financial data refer handle multiple commodity lines. 

7-3 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

Information obtained from the trade literature pertaining to the heating, ventilation, and 

air-conditioning (HVAC) contracting industry tends to support the second assumption. This 

information indicates that distributor markups should vary according to the quantity of labor and 

materials used to sell or distribute the equipment, with markups on labor tending to be much 

larger than markups on materials.4

 This information also describes markups as varying much 

more in relation to sales volume than in relation to other factors, including appliance efficiency. 

This last finding strongly suggests that labor inputs vary more with sales volume than with 

appliance cost or efficiency. In the discussion that follows in section 7.5, DOE assumes a 

division of costs between those that do not scale with the manufacturer sales price (fixed costs— 

labor and occupancy expenses referred to above as LSC), and those that do (variable costs— 

operating expenses and profit referred to above as NLSC). This division of costs led to the 

estimate of distributor markups described below in section 7.5. 

In support of the third assumption, the distributor industries are relatively competitive, 

and consumer demand for commercial clothes washers is relatively inelastic, i.e. the demand is 

not expected to decrease significantly with a relatively small increase in price. The large number 

of merchant wholesalers of service equipment (i.e., distributors of products including 

commercial clothes washers) listed by the U.S. Census Bureau in its Statistics of U.S. Businesses 

indicates the competitive nature of the market.5

 For example, there are over 5000 merchant 

wholesaler establishments of service equipment in the U.S.b

 Following standard economic 

theory, competitive firms facing inelastic demand either set prices in line with costs or quickly 

go out of business.6 

Using the above assumptions, DOE developed baseline and incremental markups to 

transform the manufacturer sales price into a consumer equipment price. DOE used the baseline 

markups, which cover all of a distributor’s costs (i.e., both LSC and NLSC), to determine the 

sales price of baseline models. The baseline markup relates the manufacturer sales price to the 

distributor sales price. DOE considers baseline models to be equipment sold under existing 

market conditions (i.e., without new energy efficiency standards). DOE calculated the baseline 

markup (MUBASE) for distributors using the following equation: 

CGS + GM CGS + (LSC + NLSC ) MU DIST DIST DIST DIST DIST

BASE = = CGS DIST CGS DIST

where: 

MUBASE = Baseline distributor markup, 

b

 DOE determined the number of establishments for household appliance stores based on the following North 

American Industry Classification System (NAICS) code and description: 443111, Household Appliance Stores. 

DOE determined the number of establishments for distributors of commercial clothes washers based on the 

following NAICS code and description: 42385, Service Establishment Equipment and Supplies Merchant 

Wholesalers. 

7-4 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

 

 

CGSDIST = Distributor’s cost of goods sold, 

GMDIST = Distributor’s gross margin, 

LSCDIST = Distributor’s labor-scaling costs, and 

NLSCDIST = Distributor’s non-labor-scaling costs. 

Incremental markups cover only those costs that scale with a change in the 

manufacturer’s sales price (i.e., NLSC). Incremental markups are coefficients that relate the 

change in the manufacturer sales price of higher-efficiency models to the change in the 

distributor sales price. DOE considers higher-efficiency models to be equipment sold under 

market conditions with new efficiency standards. It calculated the incremental markup (MUINCR) 

for distributors using the following equation: 

MU CGS DIST + NLSC DIST

INCR = CGS DIST

where: 

MUINCR = Incremental distributor markup, 

CGSDIST = Distributor’s cost of goods sold, and 

NLSCDIST = Distributor’s non-labor-scaling costs. 

7.3.3 Overall Markup 

The overall markup is the product of the manufacturer and distributor markups, as well as 

sales taxes. 

DOE used the overall baseline markup to estimate the consumer equipment price of 

baseline models, given the manufacturer cost of the baseline models. As stated above, DOE 

considers baseline models to be equipment sold under existing market conditions (i.e., without 

new energy efficiency standards). The following equation shows how DOE used the overall 

baseline markup to determine the equipment price for baseline models. 

EQPBASE = COSTMFG × (MU MFG × MUBASE ×TaxSALES ) = COSTMFG × MUOVERALL _BASE

where: 

EQPBASE = Consumer equipment price for baseline models, 

COSTMFG = Manufacturer cost for baseline models, 

MUMFG = Manufacturer markup, 

MUBASE = Baseline distributor markup, 

TaxSALES = Sales tax, and 

MUOVERALL_BASE = Baseline overall markup (product of manufacturer markup, baseline 

distributor markup, and sales tax). 

7-5 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

 

Similarly, DOE used the overall incremental markup to estimate changes in the consumer 

equipment price, given changes in the manufacturer cost above the baseline model cost resulting 

from a standard to raise equipment efficiency. The total consumer equipment price for higherefficiency models is composed of two components: the consumer equipment price of the baseline 

model and the change in consumer equipment price associated with the increase in manufacturer 

cost to meet the new efficiency standard. The following equation shows how DOE used the 

overall incremental markup to determine the consumer equipment price for higher-efficiency 

models (i.e., models meeting new efficiency standards). 

EQP = COST × MU + ΔCOST × (MU × MU ×Tax ) STD MFG OVERALL _BASE MFG MFG INCR SALES

= EQPBASE + ΔCOSTMFG × MUOVERALL _ INCR

where: 

EQPSTD = Consumer equipment price for models meeting new efficiency 

standards, 

EQPBASE = Consumer equipment price for baseline models, 

COSTMFG = Manufacturer cost for baseline models, 

ΔCOSTMFG = Change in manufacturer cost for higher-efficiency models, 

MUMFG = Manufacturer markup, 

MUINCR = Incremental distributor markup, 

TaxSALES = Sales tax, 

MUOVERALL_BASE = Baseline overall markup (product of manufacturer markup, baseline 

distributor markup, and sales tax), and 

MUOVERALL_INCR = Incremental overall markup (product of manufacturer markup, 

incremental distributor markup, and sales tax). 

7.4 MANUFACTURER MARKUPS 

DOE developed an average manufacturer markup by examining the annual Securities and 

Exchange Commission (SEC) 10-K reports filed by four publicly-traded manufacturers primarily 

engaged in appliance manufacturing and whose combined product range includes residential 

cooking products and commercial clothes washers.7

 The four manufacturers represent a nearly 

50 percent market share fore core appliances. Because these companies are typically diversified, 

producing a range of different appliances, an industry average markup was assumed by DOE to 

be representative for the manufacture of each type of appliance. DOE evaluated markups for the 

years between 2002 and 2005, inclusive. 

Table 7.4.1 lists the average corporate gross margin during the years from 2002 to 2005, 

and corresponding markups, for each of the four manufacturers. 

7-6 

EERE-2006-STD-0127 COMMENT 69.1
 

 

Table 7.4.1 Major Appliance Manufacturer Gross Margins and Markups 

Mfr A Mfr B Mfr C Mfr D 

Average Net Revenues (Million) $372 $280 $4770 $12,682 

Corporate Gross Margin 15% 28% 16% 22% 

Markup 1.18 1.39 1.19 1.28 

Source: SEC 10-K reports (2002-2005) 

The average markup value based on these four companies is 1.26. 

7.5 DISTRIBUTOR MARKUPS 

DOE used financial data from the BES for the category “Machinery, Equipment, and 

Supplies Merchant Wholesalers” to calculate markups used by distributors for commercial 

clothes washers.c 8 Table 7.5.1 shows the data from the BES and the distributor markups DOE 

estimated using the procedures described above. 

c

 DOE used the 1997 BES was used because the 2002 BES did not contain sufficient data for the calculation of gross 

margin or cost of goods sold. Also, because complete financial data were not available for the category Service 

Establishment Equipment and Supplies Merchant Wholesalers, DOE used data from the classification of Machinery, 

Equipment, and Supplies Merchant Wholesalers which encompasses a broader set of merchant wholesalers. 

7-7 

EERE-2006-STD-0127 COMMENT 69.1
 

Table 7.5.1 Data Used to Calculate Distributor Markups 

Item Million Dollars 

Sales (revenue) 225425 

Cost of Goods Sold (CGS) 158097 

Gross Margin 67328 

Labor-Scaling Costs (LCS):

 Payroll 25904 

 Fringe Benefits 3233 

Contract Labor 954 

Taxes and License Fees 823 

 Lease and Rental Payments 2932 

 Telephone and Communications 1185 

Utilities 705 

 Commissions Paid 963 

Contract Work 958 

Repair and Maintenance 826 

 LCS Subtotal: 38483 

Non-Labor-Scaling Costs (NLCS):

 Depreciation and Amortization 2650 

Office Supplies 885 

 Packaging and Other Materials 346 

Advertising Services 959 

Legal Services 277 

Accounting, Auditing, and Bookkeeping 346 

 Computer Related Services 403 

 Other Operating Expenses 8149 

 Net Profit Before Taxes 14830 

NCLS Subtotal: 28845 

Baseline Markup (MUBASE) = (CGS+GM)/CGS 1.43 

Incremental Markup (MUINCR) = (CGS+NLSC)/CGS 1.18 

As a check on the above markup values for distributors, DOE calculated markups based 

on the annual report of one distributor company (Mac-Gray) within this sector.d 9 The report 

includes data regarding revenue and CGS for this company, but not a breakdown of other 

expenses. As a result, it was only possible to estimate a baseline markup. Table 7.5.2 below 

shows the data for the commercial clothes washer distributor from the annual report as well as 

the baseline distributor markup DOE estimated for the sector as a whole using the procedures 

described above. The average value of 1.27 over the 2000–2004 time period for one company is 

d

 Mac-Gray also serves the multi-family sector and can also be considered a route operator. 

7-8 

EERE-2006-STD-0127 COMMENT 69.1
 

lower than the value of 1.43 developed from the Census data. Although this one company has a 

lower baseline markup than that determined with the Census data, DOE decided to base its 

distributor markups on the Census data because this data is supposed to be representative of all 

distributors of commercial clothes washers. 

Table 7.5.2 Distributor (Mac-Gray) Baseline Markup 

Firm Year Revenue Cost of goods sold Baseline Markup 

Mac-Gray Services 

Inc. 

2000 154268 119120 1.30 

2001 152069 121127 1.26 

2002 150368 117956 1.27 

2003 149656 118349 1.26 

2004 182694 145080 1.26 

Average Baseline Markup 1.27 

Source: Mac-Gray Services Inc. 2004 annual report. 

7.6 SALES TAXES 

The sales tax represents state and local sales taxes that are applied to the consumer 

equipment price of the equipment. The sales tax is a multiplicative factor that increases the 

consumer equipment price. 

DOE derived state and local taxes from data provided by the Sales Tax Clearinghouse.10 

These data represent weighted averages that include county and city rates. DOE then derived 

population-weighted average tax values for each Census division and large state, as shown in 

Table 7.6.1 below. 

7-9 

EERE-2006-STD-0127 COMMENT 69.1
Table 7.6.1 Average Sales Tax Rates by Census Division and Large State 

Census Division/State Tax Rate 

New England 4.98% 

Mid Atlantic 6.07% 

East North Central 6.56% 

West North Central 6.65% 

South Atlantic 5.95% 

East South Central 7.85% 

West South Central 8.30% 

Mountain 6.46% 

Pacific 4.97% 

New York State 8.25% 

California 7.95% 

Texas 7.95% 

Florida 6.70% 

DOE then derived U.S. average tax values for each product (as shown in Table 7.6.2 

below) based on the product’s saturation within each Census division and large state. It 

determined the saturations from the DOE Energy Information Administration (EIA)’s 2001 

Residential Energy Consumption Survey.11 Note that the range of tax rates is relatively 

narrow—ranging from a low of 6.83 percent for microwave ovens to a high of 7.07 percent for 

gas non-self-cleaning ovens. 

Table 7.6.2 Average Sales Tax Rates 

Product Tax Rate 

Commercial clothes washers 6.84% 

7.7 SUMMARY OF MARKUPS 

Table 7.7.1 summarizes the markups at each stage in the distribution channel and the 

overall baseline and incremental markups, as well as sales taxes, for each product. 

Table 7.7.1 Summary of Markups 

Markup Baseline Incr. 

Manufacturer 1.26 

Distributor 1.43 1.18 

Sales Tax 1.069 

Overall 1.93 1.59 

7-10 

EERE-2006-STD-0127 COMMENT 69.1
The example provided below illustrates how DOE used the baseline and incremental 

markups to derive a consumer equipment price. Assuming the baseline manufacturer cost is 

$300 and the change in manufacturer cost to meet a given energy efficiency standard is $50, the 

resulting baseline consumer equipment price (EQPBASE) and higher-efficiency equipment price 

(EQPSTD) are: 

EQP = COST × (MU × MU ×Tax ) BASE MFG MFG BASE SALES

= $300 ×1.26 × 1.43 ×1.069 = $579 

EQP = EQP + ΔCOST × (MU × MU ×Tax ) STD BASE MFG MFG INCR SALES

= $576 + $50 ×1.26 ×1.18 × 1.069 = $579 + $79 = $658 

7-11 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

 

 

 

 

 

 

 

 

 

REFERENCES
 

1	 U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy, Energy 

Conservation Standards for Certain Consumer Products (Dishwashers, Dehumidifiers, 

Microwave Ovens, and Electric and Gas Kitchen Ranges and Ovens) and for Certain 

Commercial and Industrial Equipment (Commercial Clothes Washers); Final Rule. Federal 

Register, 2009. 74(66): pp. 16040-16096. 

2	 U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy. Technical 

Support Document: Energy Efficiency Program for Consumer Products and Commercial and 

Industrial Equipment: Residential Dishwashers, Dehumidifiers, Cooking Products, and 

Commercial Clothes Washers, March, 2009. Washington, DC. 

<http://www1.eere.energy.gov/buildings/appliance_standards/residential/cooking_products_final_rul 

e_tsd.html> 

3	 Consortium for Energy Efficiency, Commercial Family-Sized Washers: An Initiative 

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

<http://www.cee1.org/com/cwsh/cwsh-main.php3> 

4	 Skaer, M. What should you charge? Try these Tested Formulas. The Air Conditioning, 

Heating, and Refrigeration News, 2001. 

<http://www.achrnews.com/CDA/ArticleInformation/features/BNP_Features_Item/0,1338,23113,00.html> 

5	 U.S. Census Bureau. Statistics of U.S. Businesses, 2004. Washington, DC. 

<http://www.census.gov/csd/susb/susb04.htm> 

6	 Pindyck, R.S. and D.L. Rubinfeld, Microeconomics, 5th ed., 2000. New Jersey: Prentice Hall. 

7	 Security Exchange Commission, SEC 10-K Reports, Various dates, 2002-2005, Security 

Exchange Commission. <http://www.sec.gov/> 

8	 U.S. Census Bureau. 1997 Economic Census, Business Expenses Survey Merchant 

Wholesalers, Machinery, Equipment, and Supplies, 1997. Washington, DC. 

<http://www.census.gov/csd/bes/bes97.htm> 

9	 Mac-Gray Corporation. 2004 Annual Report, 2004. Waltham, MA. 

10	 Sales Tax Clearinghouse, Inc. State sales tax rates along with combined average city and 

county rates, 2006. <http://thestc.com/STrates.stm> 

11	 U.S. Department of Energy-Energy Information Administration. Residential Energy 

Consumption Survey, 2001 Public Use Data Files, 2001. Washington, DC. 

<http://www.eia.doe.gov/emeu/recs/recs2001/publicuse2001.html> 

7-12 

EERE-2006-STD-0127 COMMENT 69.1