1 | Test Procedure for Residential Clothes Washers eere.energy.gov

The Parker Ranch installation in Hawaii

Test Procedure for Residential Clothes Washers

Notice of Proposed Rulemaking 

Public Meeting

Stephen Witkowski

Department of Energy

Energy Efficiency & Renewable Energy

Email:

stephen.witkowski@ee.doe.gov October 28, 2010
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• NOPR issued by DOE on September 21, 2010

• NOPR public meeting today, October 28, 2010

• Comments on NOPR from interested parties

– Transcript records oral comments from today’s public meeting

– Written comments: DOE will accept comments, data, and information 

regarding the NOPR no later than December 6, 2010

• DOE reviews and considers all comments

• Final Rule Publication

Steps in the Residential Clothes Washer Test Procedure Rulemaking

Introduction

Final

Rule NOPR
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1. Products Covered by This Test Procedure Change

2. Compliance Date of Proposed Test Procedure

3. Standby, Off Mode, and Additional Active Mode Test Procedures

a) Incorporating by Reference of IEC Standard 62301 for 

Measuring Standby Mode and Off Mode Power Consumption

b) Determination of Modes to Be Incorporated

c) Adding Specifications for the Test Methods and Measurements 

for Standby Mode, Off Mode, and Additional Active Mode 

Testing

d) Calculation of Energy Use Associated with Each Operating 

Mode

e) Measures of Energy Efficiency

Test Procedure Overview and Issues

Introduction
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4. Clothes Washer Active Mode Test Procedure

a) Technologies Not Covered by the Current Clothes Washer 

Test Procedure

b) Changes to Reflect Current Usage Patterns and Capabilities

c) Test Cloth

d) Other Revisions and Clarifications

e) Test Procedure Performance Specifications

5. Compliance with Other EPCA Requirements

6. Impact of the Proposed Amendments on EnergyGuide and 

ENERGY STAR

7. Elimination of the Obsolete Clothes Washer Test Procedure

Test Procedure Overview and Issues

Introduction
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• A Test Procedure Final Rule on August 27, 1997 (62 FR 45508) 

established the current test procedure in Appendix J1.

– Since 1997, DOE has amended the Appendix J1 test procedure three 

times, twice substantively and once to correct the introductory note. 

• The Energy Independence and Security Act of 2007 (EISA 2007) 

Amendments to EPCA direct DOE to integrate measures of standby 

and off mode energy consumption into the overall energy efficiency, 

energy consumption, or other energy descriptor.

• On August 28, 2009, DOE published an announcement in the Federal 

Register on the availability of a framework document to initiate a 

energy conservation standards rulemaking for residential clothes 

washers. (August 2009 framework document, 74 FR 44306)

– DOE received multiple comments stating it should consider changes 

to the active mode test procedure, in addition to accounting for 

energy consumption in standby and off modes.

Regulatory History

Introduction
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Test Procedure Overview and Issues

1. Products Covered by This Test Procedure Change

2. Compliance Date of Proposed Test Procedure

3. Standby, Off Mode, and Additional Active Mode Test Procedures

a) Incorporating by Reference of IEC Standard 62301 for Measuring 

Standby Mode and Off Mode Power Consumption

b) Determination of Modes to Be Incorporated

c) Adding Specifications for the Test Methods and Measurements for 

Standby Mode, Off Mode, and Additional Active Mode Testing

d) Calculation of Energy Use Associated with Each Operating Mode

e) Measures of Energy Efficiency
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• 10 CFR part 430.2 defines a clothes washer as “a consumer product 

designed to clean clothes using a water solution of soap and/or 

detergent and mechanical agitation or other movement, and must be 

one of the following classes: automatic clothes washers, semiautomatic clothes washers, and other clothes washers.”

– DOE is not proposing any amendments to this definition, or to the 

definitions of automatic, semi-automatic, or other clothes washers 

provided in 10 CFR part 430.2.

• The clothes washers covered by these definitions, and by today’s 

proposed test procedure, include top-loading compact (less than 1.6 

ft3 capacity); top-loading standard size (1.6 ft3 or greater capacity); 

top-loading semi-automatic; front-loading; and suds-saving clothes 

washers.

Products Covered by this Test Procedure Rulemaking

Covered Products
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Test Procedure Overview and Issues

1. Products Covered by This Test Procedure Change

2. Compliance Date of Proposed Test Procedure

3. Standby, Off Mode, and Additional Active Mode Test Procedures

a) Incorporating by Reference of IEC Standard 62301 for Measuring 

Standby Mode and Off Mode Power Consumption

b) Determination of Modes to Be Incorporated

c) Adding Specifications for the Test Methods and Measurements for 

Standby Mode, Off Mode, and Additional Active Mode Testing

d) Calculation of Energy Use Associated with Each Operating Mode

e) Measures of Energy Efficiency
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• The effective date of the proposed new clothes washer test 

procedure would be 30 days after publication in the Federal Register 

of a final rule in this test procedure rulemaking.

– DOE’s test procedure regulations codified in the CFR would clarify 

that the current clothes washer test procedure in Appendix J1 would 

be used to determine compliance with energy conservation standards 

until the effective date of new standards that account for the new 

methods and measurements in the proposed Appendix J2 test 

procedure.

Compliance Date for the Test Procedure

Compliance Date
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Test Procedure Overview and Issues

1. Products Covered by This Test Procedure Change

2. Compliance Date of Proposed Test Procedure

3. Standby, Off Mode, and Additional Active Mode Test Procedures

a) Incorporating by Reference of IEC Standard 62301 for Measuring 

Standby Mode and Off Mode Power Consumption

b) Determination of Modes to Be Incorporated

c) Adding Specifications for the Test Methods and Measurements for 

Standby Mode, Off Mode, and Additional Active Mode Testing

d) Calculation of Energy Use Associated with Each Operating Mode

e) Measures of Energy Efficiency
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• EISA 2007 amended EPCA to require test procedure amendments 

regarding standby and off mode power to take into consideration the most 

current versions of IEC Standards 62301 and 62087. 

– IEC Standard 62087 is not applicable to this rulemaking.

• DOE proposes to incorporate into the test procedure all applicable 

provisions from Sections 4 and 5 of IEC Standard 62301 First Edition.

– From section 4, “General conditions for measurements”, which establishes 

conditions for repeatable and precise measurements:

• 4.2 – “Test room”

• 4.4 – “Supply voltage waveform”

• 4.5 – “Power measurement accuracy”

– From section 5, “Measurements”, which provides methods for when the 

power measurement is either stable or unstable:

• 5.1 – “General”, Note 1 

• 5.3 – “Procedure”

IEC Standard 62301 and IEC Standard 62087

Incorporating IEC Standard 62301
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• DOE originally delayed this rulemaking beyond the EISA 2007 

deadline of June 30, 2009 to consider a revised IEC Standard 

62301 (Second Edition), expected to be released July 2009.

• This updated Standard has since been delayed, with an expected 

publication date of April 2011. 

– DOE proposes referencing the current IEC Standard 62301 for test 

procedures to expedite the process of incorporating standby and off 

mode power consumption into the clothes washer test procedure.

– DOE expects the provisions it proposes to include from the current 

IEC Standard 62301 to remain valid after the publishing of the 

Second Edition, based on review of a draft version of the updated 

standard, IEC Standard 62301 Committee Draft for Vote (CDV) as 

well as the Final Draft International Standard (FDIS) version.

Updated IEC Standard 62301 Ed. 2.0

Incorporating IEC Standard 62301
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Request for Comment on Incorporating IEC Standard 62301

Incorporating IEC Standard 62301

Item 1 DOE seeks comment on the adequacy of IEC Standard 62301 

to measure standby and off mode power consumption for clothes 

washers in general, and on the suitability of incorporating the specified 

provisions into DOE regulations.
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Test Procedure Overview and Issues

1. Products Covered by This Test Procedure Change

2. Compliance Date of Proposed Test Procedure

3. Standby, Off Mode, and Additional Active Mode Test Procedures

a) Incorporating by Reference of IEC Standard 62301 for Measuring 

Standby Mode and Off Mode Power Consumption

b) Determination of Modes to Be Incorporated

c) Adding Specifications for the Test Methods and Measurements for 

Standby Mode, Off Mode, and Additional Active Mode Testing

d) Calculation of Energy Use Associated with Each Operating Mode

e) Measures of Energy Efficiency
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• The mode definitions provided in EPCA and in IEC Standard 62301 

(First Edition) could lead to multiple interpretations.

– These definitions were developed to be broadly applicable for 

many energy-using products.

• EPCA authorizes DOE to amend mode definitions, considering 

the most current versions of IEC Standards 62301 and 62087.

• DOE expects the definitions provided in IEC Standard 62301 FDIS 

will remain relatively unchanged in the final revised IEC Standard 

62301, Second Edition, and therefore considered these definitions 

as the most current when determining the mode definitions for the 

amended test procedure.

– DOE is proposing mode definitions based on the definitions 

provided in IEC Standard 62301 FDIS, with added clarifications 

specific to clothes washers.

Mode Definitions

Modes to Be Incorporated
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• DOE is proposing to define active mode as “a mode in which the clothes 

washer is connected to a mains power source; has been activated; and is 

performing one of the main functions of washing, soaking, tumbling, 

agitating, rinsing, and/or removing water from the clothing, or is involved 

in functions necessary for these main functions, such as admitting water 

into the washer or pumping water out of the washer.

• DOE is proposing to refer to the typical clothes washing operation (i.e., a 

complete wash cycle intended for washing a clothing load, including 

washing, rinsing, and spinning) as the active washing mode.

• DOE is proposing to define delay start mode as an active mode in which 

activation of the active washing mode is facilitated by a timer.

– Because delay start mode may not persist for an indefinite time, it would not 

be considered as part of standby mode based on the proposed definition 

(discussed later).

– Delay start mode also only occurs prior to operation in the active washing 

mode, and therefore should be considered a part of active mode.

Modes to Be Incorporated

Active Mode – Active Washing and Delay Start
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• DOE is proposing to define cycle finished mode as an active mode that 

provides continuous status display following operation in the active washing 

mode.

– Operation in cycle finished mode occurs only after operation in the active 

washing mode, and therefore should be considered a part of active mode.

• Some clothes washers currently available offer more features in cycle finished 

mode than a continuous status display, such as a low-power fan to circulate 

air or periodic tumbling.

– These functions would use more energy than the continuous display normally 

associated with cycle finished mode.

– DOE is not proposing to account for these additional cycle finished functions.

• DOE believes the shipment-weighted percentage of clothes washers 

offering these additional functions is less than 5 percent.

• DOE believes measuring the energy use associated with these functions 

would significantly increase the test cycle duration to capture an negligible 

contributor to annual energy consumption.

Modes to Be Incorporated

Active Mode – Cycle Finished
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• DOE is proposing to define self-clean mode as an active clothes 

washer operating mode that is:

– Dedicated to cleaning, deodorizing, or sanitizing the clothes washer 

by eliminating sources of odor, bacteria, mold, and mildew;

– Recommended to be run intermittently by the manufacturer; and

– Separate from clothes washing cycles.

• DOE is proposing to consider self-clean mode as a part of the 

active mode because it is a function necessary for the main 

functions associated with washing clothes.

– A clothes washer with excessive bacteria, mildew, or odor cannot 

effectively wash clothes.

Modes to Be Incorporated

Active Mode – Self-Clean
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• DOE is proposing to define standby mode as “any mode in which the clothes washer is 

connected to a mains power source and offers one or more of the following user-oriented 

or protective functions which may persist for an indefinite time:

– To facilitate the activation of other modes (including activation or deactivation of active 

mode) by remote switch (including remote control), internal sensor, or timer;

– Continuous function: information or status displays (including clocks); or sensor-based 

functions.”

• The proposed amendments would clarify timer is a continuous clock function (which may 

or may not be associated with a display) that provides regular scheduled tasks (e.g., 

switching) and that operates on a continuous basis.

• DOE identified only one standby mode, inactive mode, that facilitates the activation of 

active mode by remote switch (including remote control), internal sensor, or timer, or that 

provides continuous status display.

• If any energy is consumed by the appliance in the presence of a one-way remote control, 

the unit would be operating in standby mode under the proposed definition.

• DOE is proposing to amend the test procedure for clothes washers to include provisions 

for measuring energy use in inactive mode as the measurement of standby energy use, 

but remains open to consideration of additional standby modes.

Standby Mode

Modes to Be Incorporated
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• DOE is proposing to define off mode as “any mode in which the 

clothes washer is connected to a mains power source and is not 

providing any standby mode or active mode function, and where 

the mode may persist for an indefinite time. An indicator that only 

shows the user that the product is in the off position is included 

within the classification of an off mode.”

• A clothes washer equipped with a mechanical on/off switch that 

can disconnect power to the display and/or control components 

would be considered as operating in the off mode when the switch 

is in the “off” position, provided that no other standby or active 

mode functions are energized.

Off Mode

Modes to Be Incorporated
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• IEC Standard 62301 FDIS defines network mode as:

– “any product modes where the energy using product is connected to 

a mains power source and at least one network function is activated 

(such as reactivation via network command or network integrity 

communication) but where the primary function is not active.”

• IEC Standard 62301 FDIS also defines disconnected mode as:

– “the status in which all connections to mains power sources of the 

energy using product are removed or interrupted.”

• DOE is not proposing to incorporate either of these modes into the 

clothes washer test procedure.

– DOE is unaware of any clothes washers currently incorporating a 

networking function (discussed further in section 4.a).

– DOE believes that there would be no energy use in a disconnected 

mode, therefore testing in this mode would be irrelevant.

Modes not Included – Network & Disconnected

Modes to Be Incorporated
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Request for Comment on the Proposed Mode Definitions

Modes to Be Incorporated

Item 2 DOE invites comment on the proposed establishment of inactive 

mode as the only standby mode for clothes washers and the 

determination that “delay start mode,” “cycle finished mode,” and “selfclean mode” would be considered active modes. DOE further invites 

comment on the proposed mode definitions, including the definition of 

“self-clean” mode, and on the question of whether there are any modes 

consistent with the “active mode,” “standby mode,” or “off mode” 

definitions that have not been identified in this NOPR that represent 

significant energy use.
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Test Procedure Overview and Issues

1. Products Covered by This Test Procedure Change

2. Compliance Date of Proposed Test Procedure

3. Standby, Off Mode, and Additional Active Mode Test Procedures

a) Incorporating by Reference of IEC Standard 62301 for Measuring 

Standby Mode and Off Mode Power Consumption

b) Determination of Modes to Be Incorporated

c) Adding Specifications for the Test Methods and Measurements for 

Standby Mode, Off Mode, and Additional Active Mode Testing

d) Calculation of Energy Use Associated with Each Operating Mode

e) Measures of Energy Efficiency
24 | Test Procedure for Residential Clothes Washers eere.energy.gov

• Paragraph 5.3.1 of IEC Standard 62301 provides:

– If power is stable (varies by not more than 5% during a 5 minute period), wait 5 

minutes for the product to stabilize, then measure the power at the end of an 

additional time period of at least 5 minutes.

– If power is unstable (varies by more than 5% during a 5 minute period), the power 

measurement shall be at least 5 minutes, or one or more complete operating cycles 

of several minutes or hours.

• Manufacturers may choose a longer stabilization period, or a longer measurement 

period.

• For clothes washers with displays that reduce power consumption by dimming 

after a certain period of user inactivity, DOE proposes that the standby, off, and 

cycle finished mode tests be conducted after the power level has dropped to its 

lowest level (IEC Standard 62301, paragraph 5.1, note 1.)

– DOE testing suggested that the typical higher-power state persists for less than 10 

minutes of inactivity.

– It is possible that some clothes washers may remain in the higher-power state for 

the duration of the 5-minute stabilization and 5-minute test period.

Power Measurement Period

Test Methods and Measurements
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• IEC Standard 62301 CDV specifies a 30-minute stabilization period and 10-minute 

measurement.

– DOE believes this clarification would allow sufficient time for displays that automatically dim or power 

down to reach the lower-power state prior to measurement, so is proposing a 30-minute stabilization 

period, then a power measurement of not less than 10 minutes for inactive, off, and cycle finished 

modes.

– Even if certain clothes washers allow for altering the display settings to increase the time period in the 

high-power state, DOE believes the typical consumer will maintain the default settings, and therefore 

is not proposing additional provisions to address the possibility of adjusting the default settings.

• IEC Standard 62301 FDIS specifies:

– An overall test period not less than 15 minutes if the power consumption is not cyclic.

• The first 5 minutes of data are discarded, and the remaining 10 minutes are used to determine 

whether the power is stable.

• If stability is not achieved, the total period is extended until the stability criteria are met, up to 3 

hours.

• Modes with known varying power consumption must be tested for not less than 60 minutes.

– For cyclic power consumption, the stabilization period is10 minutes, and must be over 4 complete 

cycles, followed by a measurement period of at least 20 minutes.

• DOE believes the specifications in IEC Standard 62301 FDIS would not produce power 

consumption measurements as accurate, repeatable, and enforceable as those 

provided in IEC Standard 62301 CDV.

Test Methods and Measurements

Power Measurement Period
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Request for Comment on Default Settings

Test Methods and Measurements

Item 3 DOE welcomes comment on the suitability of using the default 

settings in testing standby energy consumption, and on any 

methodologies that can account for consumer actions that might 

increase energy use and data on the repeatability of such testing 

procedures.
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• DOE recognizes that power consumption from delay start mode 

may vary depending on the delay time, the time displayed, and/or 

display indication of mode status.

• To ensure comparable and valid results, DOE proposes that the 

delay start time be set at 5 hours, and for power to be monitored 

for 60 minutes after waiting at least 5 minutes for power input to 

stabilize.

– In determining this specification, DOE concluded that the average 

number of LEDs lit for the range of all possible delay times would 

be best approximated by a 60 minute test if the delay time set at 5 

hours.

Delay Start

Test Methods and Measurements
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Request for Comment on Delay Start Mode

Test Methods and Measurements

Item 4 DOE seeks comment on the methodology proposed for 

measuring energy consumption in delay start mode.
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• The current DOE test procedure specifies ambient air temperature 

only for water-heating clothes washers, 75 ± 5oF, which is within the 

range specified by IEC Standard 62301 (73.4 ± 9°F).

• DOE proposes that test room ambient temperature for standby, off, 

delay start and cycle finished mode testing be specified for all 

clothes washers according to section 4, paragraph 4.2 of IEC 

Standard 62301.

– The proposed specification would allow manufacturers more latitude 

in maintaining ambient conditions if the tests for standby, off, delay 

start and cycle finished modes are conducted separately from active 

washing mode tests.

Test Room Ambient Temperature

Test Methods and Measurements
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Clothes Washers – Test Room Ambient Temperature

Test Methods and Measurements

Item 5 DOE seeks comment on the appropriateness of the proposed 

modified test room ambient temperature range, which would allow 

manufacturers to conduct standby, off, delay start and cycle finished 

mode testing separately from active washing mode testing, under the 

less stringent ambient conditions specified in the IEC Standard 62301 

(73.4 ± 9oF)
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Test Procedure Overview and Issues

1. Products Covered by This Test Procedure Change

2. Compliance Date of Proposed Test Procedure

3. Standby, Off Mode, and Additional Active Mode Test Procedures

a) Incorporating by Reference of IEC Standard 62301 for Measuring 

Standby Mode and Off Mode Power Consumption

b) Determination of Modes to Be Incorporated

c) Adding Specifications for the Test Methods and Measurements for 

Standby Mode, Off Mode, and Additional Active Mode Testing

d) Calculation of Energy Use Associated with Each Operating Mode

e) Measures of Energy Efficiency
32 | Test Procedure for Residential Clothes Washers eere.energy.gov

• Modified Energy Factor (MEF) [ft3 of capacity per total energy 

consumption per wash cycle includes:

1. machine energy consumption directly measured during the test 

cycles

2. nominal energy used by a water heater to heat the water supplied 

to the clothes washer

3. energy used by a dryer to remove the remaining moisture after a 

cycle. 

• DOE proposes that the calculation of energy consumption in the 

modes other than active washing mode be expressed on a per 

cycle basis as well to maintain consistency.

• The total energy consumption in standby, off, delay start, and 

cycle finished modes depends on both the power level of the 

mode and the time spent in the mode.

Calculation of Energy Use Associated 

with Each Operating Mode

Calculation of Energy Use
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• DOE proposes to allocate 1 hour per cycle for a typical active 

washing mode, based on four available studies.

– Average cycle times can vary based on the axis of basket rotation 

and type of load; however DOE is proposing one overall cycle time 

to simplify calculations, and because this value has a small effect 

on results.

• For example, using 45 minutes per cycle for top-loaders and 75 

minutes per cycle for front-loaders changes the final number of hours 

allocated to the other modes by less than 1 percent.

• DOE is proposing to revise the representative number of active 

wash cycles per year from 392 to 295, resulting in 295 active 

washing mode hours per year.

Active Washing Mode Hours Per Year

Calculation of Energy Use
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• DOE believes clothes washers use energy in five modes other 

than active washing modes in which residential clothes washers 

use energy: (1) inactive mode, (2) cycle finished mode, (3) delay 

start mode, (4) off mode, and (5) self-clean mode.

• Based on limited studies of the time clothes washers spend in 

each of these non-active washing modes, DOE testing, and 

manufacturer recommendations, DOE estimates the following 

usage for each of these modes:

Hours Per Year Associated with Non-Active Washing Modes

Calculation of Energy Use

Mode Annual Duration Estimate Basis

Delay Start 25 hours 5 min per active washing cycle

Cycle Finished 15 hours 3 min per active washing cycle

Self-Clean 16 hours 1.3 hours per cycle, 12 cycles per year

Off/Inactive 8,409 hours Remainder
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• Power ranges for the different non-active washing modes are based on internal 

DOE testing of clothes washers. The highest and lowest average powers are 

listed for both top- and front-loading clothes washers.

* Per-cycle energy use determined from a 2006 study that referenced data provided in 2005 by the 

Association of Home Appliance Manufacturers and Whirlpool Corporation.

** Remaining time = 8,760 – 295 − 16 − 25 − 15 = 8,409.

† Includes energy consumption for water heating and moisture removal in the dryer as well as machine 

electrical energy consumption.

† † Based on DOE testing of seven units with self-clean cycles, and 12 cycles per year. Values include 

energy consumption for water heating and machine electrical energy consumption.

Calculation of Energy Use

Mode Hours Typical Average 

Power (W)

Annual Energy Use 

(kWh)

Active Washing 295* 2,230 657.9†

Self-Clean 16 75 to 2,081 1.2 to 33.3††

Delay Start 25 1.4 to 8.9 0.04 to 0.2

Cycle Finished 15 0 to 5.2 0 to 0.08

Off and Inactive 8,409** 0 to 1.7 0 to 14.3

Estimated Annual Energy Use Associated 

with Each Operating Mode
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• Not all residential clothes washers will utilize all possible modes.

• The table below shows the proposed allocation of annual hours 

for clothes washers offering different combinations of modes.

Calculation of Energy Use

Hours Per Year Associated with All Operating Modes

Mode

All Modes 

Possible

No Delay 

Start Mode

No Cycle 

Finished Mode

No Delay Start or 

Cycle Finished Modes

No Self-Clean Available

Active Washing 295 295 295 295

Delay Start 25 0 25 0

Cycle Finished 15 15 0 0

Off and Inactive 8,425 8,450 8,440 8,465

Self-Clean Available

Active Washing 295 295 295 295

Self-Clean 16 16 16 16

Delay Start 25 0 25 0

Cycle Finished 15 15 0 0

Off and Inactive 8,409 8,434 8,424 8,449
37 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE believes that the proposed definition of off mode refers to 

units with mechanical rather than electronic controls, or units with 

electronic controls equipped with a mechanical switch to deenergize the electronic controls.

– Reactivation of the clothes washer with a pushbutton sensor would 

be considered to be part of standby mode.

• DOE expects there are few clothes washers with electronic 

controls and an additional mechanical off switch.

– Therefore, the combined inactive/off mode hours would most likely 

be allocated fully either to inactive or off mode, depending on the 

controls present on the clothes washer.

– For clothes washers with both electronic controls and a mechanical 

off switch, DOE is proposing to allocate half of the non-active hours 

each to inactive and off modes.

Hours Per Year Associated with Inactive and Off Modes

Calculation of Energy Use
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• In conclusion, DOE is proposing to calculate residential clothes 

washer energy use per cycle associated with the inactive, off, 

delay start and cycle finished modes by:

1. Calculating the product of wattage and allocated hours for all 

possible inactive, off, delay start and cycle finished modes;

2. Summing the results;

3. Dividing the sum by 1,000 to convert from Wh to kWh; and

4. Dividing by the proposed 295 use cycles per year.

• DOE is also proposing to calculate energy use per cycle 

associated with self-clean mode, if available, by:

1. Multiplying the energy use per self-clean cycle in kWh by 12; and

2. Dividing by the proposed 295 use cycles per year.

Calculation of Energy Use

Calculation of Energy Use Associated 

with Each Operating Mode
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• The comparison of annual energy use for the different clothes 

washer modes indicates that delay start and cycle finished modes 

represent a relatively small number of hours per year at low power 

consumption levels.

– The power consumptions observed in cycle finished mode and 

delay start mode are distinct from but comparable to those for 

inactive mode and off mode.

• As a result, DOE could adopt an approach that would allocate all 

hours not associated with active washing mode or self-clean 

mode (8,449 or 8,465 for models with and without a self-clean 

cycle respectively) to the off and inactive modes.

Calculation of Energy Use

Alternative Calculation of Energy Use Associated 

with Each Operating Mode
40 | Test Procedure for Residential Clothes Washers eere.energy.gov

Request for Comment on the Energy Use 

Calculation for Each Operating Mode

Calculation of Energy Use

Item 6 DOE seeks comment on the approach for calculating energy 

use for the different operating modes observed in clothes washers. 

DOE also invites comment and requests data on the estimates for 

annual hours associated with each mode, including active mode. DOE 

also welcomes comment on whether the alternative energy use 

calculation would be representative of the standby and off mode power 

consumption of clothes washers currently on the market.
41 | Test Procedure for Residential Clothes Washers eere.energy.gov

Test Procedure Overview and Issues

1. Products Covered by This Test Procedure Change

2. Compliance Date of Proposed Test Procedure

3. Standby, Off Mode, and Additional Active Mode Test Procedures

a) Incorporating by Reference of IEC Standard 62301 for Measuring 

Standby Mode and Off Mode Power Consumption

b) Determination of Modes to Be Incorporated

c) Adding Specifications for the Test Methods and Measurements for 

Standby Mode, Off Mode, and Additional Active Mode Testing

d) Calculation of Energy Use Associated with Each Operating Mode

e) Measures of Energy Efficiency
42 | Test Procedure for Residential Clothes Washers eere.energy.gov

• The test procedure provides a calculation for MEF, which 

determines compliance with the current Federal energy 

conservation standards.

– Equal to the clothes container capacity in ft3 divided by the sum, 

expressed in kWh, of: 

• the weighted per-cycle hot water energy consumption; 

• the weighted per-cycle machine electrical energy consumption; and

• the per-cycle energy consumption for removing the remaining moisture 

from a test load in a dryer.

• EPCA directs that test procedures shall be amended to include 

standby and off mode energy consumption in the overall energy 

efficiency descriptor for each covered product. 42 U.S.C. 

6295(gg)(2)(A) 

– DOE examined integrating standby and off mode energy 

consumption on a per-cycle basis.

Measures of Energy Efficiency

Measures of Energy Efficiency
43 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE proposes to establish the following measures of energy 

consumption for clothes washers:

– “per-cycle standby, off, delay start and cycle finished mode energy 

consumption,” expressed in kWh;

– “per-cycle self-clean mode energy consumption,” as applicable, 

expressed in kWh; and

– “integrated modified energy factor” (IMEF) as the clothes container 

capacity in ft3 divided by the sum, in kWh, of:

• the total weighted per-cycle hot water energy consumption;

• the total weighted per-cycle machine electrical energy consumption;

• the per-cycle energy consumption for removing moisture from a test 

load; 

• the per-cycle standby, off, delay start and cycle finished mode energy 

consumption; 

• and the per-cycle self-clean mode energy consumption, as applicable.

Proposed New Measures of Energy Efficiency

Measures of Energy Efficiency
44 | Test Procedure for Residential Clothes Washers eere.energy.gov

Request for Comment on the Proposed

Measures of Energy Efficiency

Measures of Energy Efficiency

Item 7 DOE seeks comment on the proposed plan to establish new 

measures of energy consumption for clothes washers: “per-cycle 

standby, off, delay start and cycle finished mode energy consumption” 

expressed in kWh, and “per-cycle self-clean mode energy 

consumption” expressed in kWh; as well as a new integrated measure 

of energy efficiency : “integrated modified energy factor” expressed in 

ft3 per kWh per cycle.
45 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE does not propose to amend the estimated annual operating 

cost calculation in 10 CFR 430.23 to include the cost of energy 

consumed by modes other than active washing mode because:

– DOE believes that the cost of energy consumed in self-clean, 

standby, off, delay start and cycle finished modes would make little 

difference in the estimated annual operating cost calculation; and

– The Federal Trade Commission’s (FTC’s) EnergyGuide Label for 

clothes washers compares the estimated annual operating cost to 

a range of annual operating costs of similar products. (Appendix 

F1 to 16 CFR part 305) An annual operating cost incorporating 

self-clean, standby, off, delay start and cycle finished mode energy 

would no longer be directly comparable to the minimum and 

maximum operating costs prescribed for the EnergyGuide Label.

Annual Energy Cost Calculation

Measures of Energy Efficiency
46 | Test Procedure for Residential Clothes Washers eere.energy.gov

Request for Comment on the Proposed Approach 

to Not Amend Annual Energy Cost

Measures of Energy Efficiency

Item 8 DOE seeks comment on the tentative decision to maintain the 

existing annual energy cost calculation set forth in 10 CFR 430.23, 

which does not include self-clean, standby, off, delay start or cycle 

finished mode energy consumption. One alternative way of 

incorporating energy consumption in self-clean, standby, off, delay 

start, or cycle finished mode into the annual energy cost calculation 

would be to add the per-cycle energy consumption from these mode to 

the total per-cycle energy consumption in the annual operating cost 

calculations in 10 CFR 430.23 (j)(1)(i) and (ii).
47 | Test Procedure for Residential Clothes Washers eere.energy.gov

4. Clothes Washer Active Mode Test Procedure

a) Technologies Not Covered by the Current Clothes Washer Test 

Procedure

b) Changes to Reflect Current Usage Patterns and Capabilities

c) Test Cloth

d) Other Revisions and Clarifications

e) Test Procedure Performance Specifications

5. Compliance with Other EPCA Requirements

6. Impact of the Proposed Amendments on EnergyGuide and 

ENERGY STAR

7. Elimination of the Obsolete Clothes Washer Test Procedure

Test Procedure Overview
48 | Test Procedure for Residential Clothes Washers eere.energy.gov

• Many clothes washers available on the market offer a steam wash 

cycle, which is claimed to offer enhanced cleaning performance.

– The current test procedure contains no provisions for measuring 

energy and water consumption during a steam wash cycle.

• In response to comments received on the August 2009 framework 

document, DOE is proposing to include specifications for 

measuring energy and water consumption during a steam wash 

cycle.

• DOE is proposing to include a test section for steam wash cycles, 

and to include the energy and water consumption from steam 

wash cycles in the final calculations for the energy and water use 

metrics.

Steam Wash Cycles

Technologies Not Currently Covered
49 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE is proposing to measure energy and water consumption of a 

steam wash cycle with the hottest wash temperature.

– DOE, therefore, is proposing to also update the temperature use 

factors provided in Table 4.1.1 of the test procedure to include a 

steam wash use factor for clothes washers offering this feature.

• DOE lacks data on consumer usage of steam wash cycles, but 

believes the inclusion of a steam wash cycle would decrease the 

number of extra hot cycles a consumer would run, and would 

leave the hot, warm, and cold temperature use factors unchanged.

– DOE believes extra hot and steam cycles would be reserved for the 

most heavily soiled loads, with steam cycles selected somewhat 

less frequently.

– DOE is proposing 0.02 as the use factor for steam wash cycles, 

and to decrease the extra hot use factors by 0.02 (from 0.05 to 0.03 

or 0.14 to 0.12).

Steam Wash Cycles

Technologies Not Currently Covered
50 | Test Procedure for Residential Clothes Washers eere.energy.gov

Request for Comment on Steam Wash Cycles

Technologies Not Currently Covered

Item 9 DOE requests comment on the proposed inclusion of the energy 

and water consumption of a steam wash cycle to the clothes washer 

test procedure, including the associated use factor. DOE also requests 

any data available regarding consumer use of steam wash cycles.
51 | Test Procedure for Residential Clothes Washers eere.energy.gov

• Many clothes washers currently on the market offer a self-clean 

cycle.

– Self-clean cycles may require high water temperatures and greater 

volumes of water than a normal cycle, potentially consuming a 

substantial amount of energy.

• DOE is proposing to define a self-clean mode as an active clothes 

washer operating mode that is: 

– Dedicated to cleaning, deodorizing, or sanitizing the clothes washer 

by eliminating sources of odor, bacteria, mold, and mildew;

– Recommended to be run intermittently by the manufacturer; and

– Separate from clothes washing cycles.

• DOE is proposing to include energy and water consumption 

during self-clean cycles into the overall efficiency metrics.

– This would also benefit clothes washer designs that address mold 

and odor issues without the need for periodic self-clean cycles.

Self-Clean Cycles

Technologies Not Currently Covered
52 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE is proposing to calculate the per-cycle energy and water 

consumption from self-clean cycles by:

– measuring the hot and cold water consumption and the electrical energy 

consumption for a self clean cycle;

– calculating the total energy consumption (water heating plus electrical 

energy consumption) and water consumption during a self clean cycle;

– multiplying the self-clean cycle energy and water consumption by the 

number of self-clean cycles per year (12)*; and

– dividing by the proposed 295 active washing cycles per year.*

• This approach apportions the annual energy and water use in self-clean 

mode to each annual active washing mode cycle.

• If a clothes washer is designed to address mold and odor problems 

without the need for periodic self-clean cycles, the per-cycle self-clean 

energy and water consumption will be zero.

* The last two steps of this calculation for the water consumption were inadvertently not included 

in the NOPR. DOE intends to correct this omission in the final rule.

Self-Clean Cycles

Technologies Not Currently Covered
53 | Test Procedure for Residential Clothes Washers eere.energy.gov

Request for Comment on Self-Clean Cycles

Technologies Not Currently Covered

Item 10 DOE requests comment on self-clean cycles for clothes 

washers, including the proposed definition, inclusion of self-clean cycle 

energy and water use into the IMEF and IWF calculations, and on 

whether any relevant data are available regarding availability and 

consumer use of self-clean cycles.
54 | Test Procedure for Residential Clothes Washers eere.energy.gov

• Adaptive control technologies can adjust wash parameters based 

on the size, fabric mix, and soil level of a wash load.

– The current test procedure accounts for adaptive fill control, but no 

other adaptive controls.

• DOE received multiple comments in response to the August 2009 

framework document stating that adaptive controls are already 

widely used in residential clothes washers.

– DOE is not aware of any residential clothes washers that currently 

incorporate soil sensing systems.

– DOE is only aware of clothes washers that currently use adaptive 

controls to adjust to measured or inferred load size and fabric mix.

• DOE lacks data on the distribution of load sizes and fabric mixes that 

are representative of typical consumer usage.

• DOE is not proposing to account for adaptive controls, other than 

adaptive fill control, in the test procedure.

Adaptive Control Technologies

Technologies Not Currently Covered
55 | Test Procedure for Residential Clothes Washers eere.energy.gov

• Demand response technology enables an appliance to shift its 

activity based on interaction with the electric grid, utilities, or user 

programming. 

– Appliances that can communicate though any network would be 

considered to have a network mode according to IEC Standard 

62301 CDV.

• At this time, DOE is unaware of any clothes washers currently 

available on the market that incorporate a networking function.

• Therefore, DOE is not proposing to amend the clothes washer test 

procedure to include energy consumption in a network mode, or 

to quantify any benefits that may arise from peak load shedding 

through communication with a “smart grid.”

– Once clothes washers offering these features and the appropriate 

data and testing methodologies become available, these provisions 

could be incorporated through amendments to the test procedure.

Demand Response Technology

Technologies Not Currently Covered
56 | Test Procedure for Residential Clothes Washers eere.energy.gov

Request for Comment on Adaptive Controls 

and Demand Response Technology

Technologies Not Currently Covered

Item 11 DOE requests comment on whether any clothes washers are 

currently available on the market offering soil-sensing adaptive controls 

or demand response features. DOE also requests information on load 

size and fabric content, the possible use of a soiled test load to 

determine energy and water use in the presence of soil-sensing 

adaptive controls, appropriate methodologies for measuring energy 

consumption in a network mode, and on the repeatability of such 

testing.
57 | Test Procedure for Residential Clothes Washers eere.energy.gov

4. Clothes Washer Active Mode Test Procedure

a) Technologies Not Covered by the Current Clothes Washer Test 

Procedure

b) Changes to Reflect Current Usage Patterns and Capabilities

c) Test Cloth

d) Other Revisions and Clarifications

e) Test Procedure Performance Specifications

5. Compliance with Other EPCA Requirements

6. Impact of the Proposed Amendments on EnergyGuide and 

ENERGY STAR

7. Elimination of the Obsolete Clothes Washer Test Procedure

Test Procedure Overview
58 | Test Procedure for Residential Clothes Washers eere.energy.gov

• In the January 2001 Final Rule, 66 FR 3315, DOE estimated the 

representative number of annual wash cycles per clothes washer as 

392.

– Comments were received in response to the August 2009 framework 

document in support of updating this value.

– This value is not used in the current test procedure calculations for 

MEF or WF.

• DOE considered three data sources when determining if an updated 

representative number of annual wash cycles is warranted:

– the EIA’s 2005 Residential Energy Consumption Survey (2005 RECS);

– the California Energy Commission’s 2004 California Residential 

Appliance Saturation Survey (California RASS); and 

– a data submittal from Procter and Gamble (P&G).

• DOE estimated the following average annual use cycles from each of 

these data sources:

– 295 cycles per year from the 2005 RECS data;

– 283 cycles per year from the California RASS; and

– 308 cycles per year from the P&G data submittal.

Annual Cycles

Current Usage Patterns and 

Capabilities
59 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE is proposing to update the representative number of annual 

use cycles to 295, based on the 2005 RECS data.

– DOE believes the 2005 RECS data are most representative of 

consumer use throughout the country.

– The California RASS only reflects the usage patterns of consumers 

in one state.

– Analysis of the P&G submittal showed that the data set contained 

fewer single-person households and more multiple-person 

households than indicated in the latest sampling by the U.S. 

Census Bureau and the American Housing Survey.

– Overall, the relatively small variation among the three data sources 

supports DOE’s conclusion that 295 cycles per year is a reasonable 

estimate of actual consumer use.

Representative Annual Cycles

Current Usage Patterns and 

Capabilities
60 | Test Procedure for Residential Clothes Washers eere.energy.gov

Request for Comment on Annual Cycles

Current Usage Patterns and 

Capabilities

Item 12 DOE welcomes comment on the appropriateness of the 

proposed 295 clothes washer cycles per year, and on the validity of 

using the 2005 RECS to establish this estimate. DOE also seeks any 

additional data available on this issue.
61 | Test Procedure for Residential Clothes Washers eere.energy.gov

• Table 5.1 of the current test procedure (Test Load Sizes) specifies 

test load sizes for clothes washer container volumes up to 3.8 ft3.

– DOE is aware that multiple clothes washers available on the market 

have container volumes exceeding 3.8 ft3.

– Multiple stakeholders commented in response to the August 2009 

framework document in support of expanding Table 5.1 to include 

larger capacities.

• On August 22, 2006, DOE granted an interim test procedure waiver 

to Whirlpool for three clothes washer models with container 

capacities greater than 3.8 cubic feet. 71 FR 48913.

– The alternate test procedure extended the linear relationship 

between maximum test load size and container volume in Table 5.1 

to include container volumes of 3.8 to 3.9 ft3.

• DOE is aware of only limited data regarding typical clothes washer 

load sizes.

Test Load Size Specifications

Current Usage Patterns and 

Capabilities
62 | Test Procedure for Residential Clothes Washers eere.energy.gov

• One 2003 P&G study showed an average load size of 7.2 lbs for 

top-loading, and 8.4 lbs for front-loading clothes washers.

– These load sizes correspond to the average test loads for the 2.7 to 

2.8 ft3 and 3.3 to 3.4 ft3 capacity bins. 

– These capacities are consistent with the shipment-weighted 

average capacity of 3.05 ft3 from the 2005 AHAM Factbook.

• From 1993 to 2005, AHAM data show tub capacities have 

increased by 14 percent, while RECS data show the number of 

cycles per year has decreased by 17 percent.

– Assuming that households continue to wash the same volume of 

clothes each year, the average load size increases with capacity.

• The limited data suggest that the current values in the test load 

size table are appropriate, and extending the linear relationship 

between test load size and container capacity is valid.

– DOE proposes to extend Table 5.1 to include volumes up to 6.0 ft3.

Test Load Size Specifications

Current Usage Patterns and 

Capabilities
63 | Test Procedure for Residential Clothes Washers eere.energy.gov

Request for Comment on Test Load Size Specifications

Current Usage Patterns and 

Capabilities

Item 13 DOE welcomes comment on the proposed test load sizes, and 

on whether the linear relationship between test load size and clothes 

washer container volume is representative of actual consumer use. 

DOE invites any relevant data on this topic.
64 | Test Procedure for Residential Clothes Washers eere.energy.gov

• Load size use factors specify the fraction of all cycles run with 

minimum, average, and maximum load sizes.

• DOE received comments in response to the August 2009 

Framework Document stating that DOE should validate the use 

factors for minimum, average, and maximum loads based on more 

recent consumer use data.

• DOE is not aware of recent data characterizing such usage 

patterns.

• Therefore, DOE is not proposing to update the load size use 

factors currently in the test procedure.

– DOE welcomes input and data on consumer selection of load sizes.

Load Size Use Factors

Current Usage Patterns and 

Capabilities
65 | Test Procedure for Residential Clothes Washers eere.energy.gov

• As previously stated, DOE is proposing to amend the TUFs in the 

clothes washer test procedure to account for steam wash cycles.

• DOE also investigated whether the other TUFs in the test 

procedure are valid.

– The 2005 RECS and California RASS both provide some data for 

hot, warm, and cold settings, but no information on extra hot or 

steam wash cycles.

– The 2005 RECS questionnaire also asks respondents only for the 

water temperature selections usually used for the wash and rinse 

cycles, which may not account for the less-frequent use of the hot 

wash cycle.

– The California RASS questionnaire asks for the number of wash 

loads per week at each temperature, and therefore likely captures 

hot washes, but only represents consumer use in one state.

Temperature Use Factors

Current Usage Patterns and 

Capabilities
66 | Test Procedure for Residential Clothes Washers eere.energy.gov

• The following table shows the TUFs as determined from the two 

surveys in addition to the current test procedure values:

*This value equals the sum of warm and hot rinse temperatures shown by the 2005 RECS data

• DOE believes the comparison of these TUFs shows that the values 

currently in the test procedure are a reasonable estimate of 

current consumer use.

– DOE is therefore not proposing to amend the existing wash setting 

TUFs for clothes washers that are not equipped with steam wash 

cycles.

Temperature Use Factors

Current Usage Patterns and 

Capabilities

Temperature 

Setting

TUF, Current 

Test Procedure

TUF, 2005 

RECS

TUF, 2004 

California RASS

Hot Wash 0.14 0.062 0.20

Warm Wash 0.49 0.54 0.41

Cold Wash 0.37 0.40 0.39

Warm Rinse 0.27 0.20* N/A
67 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE notes that it has recently received consumer usage survey 

data from a manufacturer for a clothes washer model with no 

warm rinse option on the cycle recommended for cotton clothes 

and a default cold rinse on all other cycles.

– The data indicate that users participating in the survey used warm 

rinse for 1.6 percent of all cycles.

• DOE does not believe that this conclusion necessarily applies to 

all consumers and residential clothes washer models, and is not 

proposing a revision to the warm rinse TUF at this time.

– DOE remains open to considering a revision to the warm rinse TUF 

and welcomes further data regarding consumer usage of warm 

rinse.

• DOE is, however, proposing to amend the methods for measuring 

warm rinse energy and water consumption.

Temperature Use Factors – Warm Rinse

Current Usage Patterns and 

Capabilities
68 | Test Procedure for Residential Clothes Washers eere.energy.gov

• The current test procedure accounts for warm rinses by 

determining the water heating energy consumption of a warm 

rinse, and applying a use factor of 0.27.

– The measurements occur only for the rinse portion of the cycle.

– For some clothes washers, it is not entirely clear when the wash 

cycle ends and the rinse begins due to multiple fill and drain events 

occurring in various sequences.

• To simplify the warm rinse measurements, DOE is proposing to 

account for energy and water consumption over an entire warm 

wash/warm rinse cycle.

– DOE believes that measuring energy and water consumption over 

a complete warm wash/warm rinse cycle is appropriate because 

most clothes washers currently available allow users to select a 

warm rinse only with a warm wash cycle.

Warm Rinse Methodology

Current Usage Patterns and 

Capabilities
69 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE is therefore proposing to eliminate the incremental use factor 

currently attributed to warm rinse.

– DOE believes that the warm rinse TUF of 0.27 would still apply as 

the TUF for a warm wash/warm rinse cycle.

• For clothes washers offering a warm rinse, DOE is proposing to 

reduce the warm wash/cold rinse TUF from 0.49 to 0.22.

– DOE would specify that clothes washers not offering a warm rinse 

would have a warm wash/cold rinse TUF of 0.49.

• DOE believes this revised methodology for incorporating warm 

rinse cycles would not change the intent of the test procedure.

– DOE is not proposing to amend the TUFs for temperature 

selections other than warm wash.

– Overall, the warm wash and warm rinse temperature selections 

would receive the same weight in the final calculations.

Warm Rinse Methodology

Current Usage Patterns and 

Capabilities
70 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE recognizes that not all clothes washers offer a warm rinse 

selection under the cycle setting recommended for washing 

cotton or linen clothes (typically the “Normal” setting).

– If a warm wash/warm rinse cycle is available in any other wash 

cycle setting that uses agitation/tumble operation, spin speed(s), 

wash times and rinse times that are largely similar to the “Normal” 

cycle, the warm wash/warm rinse cycle would be tested using the 

wash cycle setting that would best reflect typical consumer use.

• As a result, the calculated MEFs for these types of clothes 

washers could differ under the proposed method.

– The proposed method would account for the entire warm 

wash/warm rinse outside of the “Normal” cycle setting.

• DOE expects to analyze potential effects of the proposed 

methodology on MEF, and to incorporate any such effects, as 

appropriate, into any amended standards.

Warm Rinse Methodology

Current Usage Patterns and 

Capabilities
71 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE investigated whether the dryer use factor (DUF) of 0.84 in the 

clothes washer test procedure reflects current consumer usage.

– The DUF is used to calculate clothes drying energy consumption.

• The 2005 RECS and 2004 California RASS include data on both 

clothes washer and clothes dryer use.

– Analysis of the RECS data showed that for households with both a 

clothes washer and dryer, the DUF was 0.95; for all households 

with a clothes washer, the DUF was 0.91.

– Analysis of the California RASS showed for households with both a 

washer and dryer, the DUF was 0.86; for all households with a 

clothes washer, the DUF was 0.76. 

• DOE is proposing a DUF of 0.91, based on the 2005 RECS data.

– DOE is proposing to use the 2005 RECS data to maintain 

consistency with the data source for the number of annual cycles.

Clothes Dryer Use Factor

Current Usage Patterns and 

Capabilities
72 | Test Procedure for Residential Clothes Washers eere.energy.gov

• The load adjustment factor (LAF) represents the ratio of typical 

consumer load size to maximum test load size.

• LAF is used in the calculation of the energy required to remove 

moisture from the test load.

– The RMC value in the calculation is only based on tests using the 

maximum test load, so the LAF is used to scale the calculated 

energy consumption for actual consumer usage.

• DOE lacks information warranting adjusting this value or 

changing it from a fixed value to one that varies as a function of 

average load size.

– Therefore, DOE is not proposing to amend the LAF currently in the 

clothes washer test procedure.

Load Adjustment Factor

Current Usage Patterns and 

Capabilities
73 | Test Procedure for Residential Clothes Washers eere.energy.gov

Request for Comment on Use Factors

Current Usage Patterns and 

Capabilities

Item 14 DOE requests comment on the validity of the proposed use 

factors for temperature, load size, and dryer use, and of the data 

sources used to estimate these values. Additionally, DOE seeks 

comment on the proposed revision to the warm rinse measurements, 

including the validity of the proposed warm wash/warm rinse TUF of 

0.27. DOE also welcomes comment regarding the proposed load 

adjustment factor to be used in the RMC calculation. Stakeholders may 

submit any additional relevant data regarding these use factors.
74 | Test Procedure for Residential Clothes Washers eere.energy.gov

4. Clothes Washer Active Mode Test Procedure

a) Technologies Not Covered by the Current Clothes Washer Test 

Procedure

b) Changes to Reflect Current Usage Patterns and Capabilities

c) Test Cloth

d) Other Revisions and Clarifications

e) Test Procedure Performance Specifications

5. Compliance with Other EPCA Requirements

6. Impact of the Proposed Amendments on EnergyGuide and 

ENERGY STAR

7. Elimination of the Obsolete Clothes Washer Test Procedure

Test Procedure Overview
75 | Test Procedure for Residential Clothes Washers eere.energy.gov

• RMC is the ratio of the weight of water absorbed by the test cloth 

after an energy test cycle to the initial weight of the bone dry test 

cloth, multiplied by 100 percent.

– Characteristics of the test cloth can affect absorbency, so the test 

procedure aims to account for differences between test cloth 

production lots. 

• AHAM submitted comments in response to the August 2009 

framework document, which included revised tolerances for the 

size and weight of the test cloth. 

– These proposed tightened tolerances could only improve 

consistency in the RMC results from lot-to-lot of test cloth.

• DOE believes that the AHAM proposal represents the industry’s 

consensus on limiting uncertainty in the test procedure due to 

variations in test cloth properties, and is proposing to include 

these changes in the test procedure.

Test Cloth Issues

Test Cloth
76 | Test Procedure for Residential Clothes Washers eere.energy.gov

• The current test procedure uses extractor tests with g-forces up to 

500 g in determining the RMC correlation curve for test cloth lots.

– However, DOE is aware of clothes washers on the market that 

achieve g-forces higher than 500 g.

• DOE is therefore proposing to include an additional set of 

extraction tests at 650 g, and to require the 500 g extraction for all 

clothes washers.

• The proposed standard RMC values for the proposed extractor 

tests are shown below, based on AHAM-submitted data.

Test Cloth Issues

Test Cloth

g-Force RMC percentage

Warm soak Cold soak

15 min. spin 4 min. spin 15 min. spin 4 min. spin

100 45.9 49.9 49.7 52.8

200 35.7 40.4 37.9 43.1

350 29.6 33.1 30.7 35.8

500 24.2 28.7 25.5 30.0

650 23.0 26.4 24.1 28.0
77 | Test Procedure for Residential Clothes Washers eere.energy.gov

• Based on additional comments, DOE is proposing:

– To specify a test cloth handling procedure to ensure consistent 

results from the extractor testing;

– To update the extractor manufacturer from Bock Engineered 

Products to North Star Engineered Products, Inc; and

– To require a bone dryer capable of heating the test cloth to over 

210 oF (99 oC).

• The current test procedure also contains redundant sections 

regarding test cloth specifications and preconditioning. 

– DOE is proposing to remove these redundant sections, and to 

move any relevant non-redundant information from these sections 

to the appropriate sections. 

Test Cloth Issues

Test Cloth
78 | Test Procedure for Residential Clothes Washers eere.energy.gov

Request for Comment on Test Cloth Issues

Item 15 DOE requests comment and data regarding the proposed 

updated test cloth specifications and correlation procedure.

Test Cloth
79 | Test Procedure for Residential Clothes Washers eere.energy.gov

4. Clothes Washer Active Mode Test Procedure

a) Technologies Not Covered by the Current Clothes Washer Test 

Procedure

b) Changes to Reflect Current Usage Patterns and Capabilities

c) Test Cloth

d) Other Revisions and Clarifications

e) Test Procedure Performance Specifications

5. Compliance with Other EPCA Requirements

6. Impact of the Proposed Amendments on EnergyGuide and 

ENERGY STAR

7. Elimination of the Obsolete Clothes Washer Test Procedure

Test Procedure Overview
80 | Test Procedure for Residential Clothes Washers eere.energy.gov

• The current clothes washer test procedure requires measuring 

“the entire volume which a dry clothes load could occupy within 

the clothes container during washer operation.”

– This is done by filling the clothes container with water “to its 

uppermost edge,” and determining the volume based on the added 

weight of water.

• The “uppermost edge” is not well-defined, and may not always 

represent a volume which a dry clothes load could occupy.

– DOE believes the remainder of the method provides for an accurate 

measurement of capacity. 

• DOE received multiple comments in support of revising the 

capacity measurement method.

– DOE considered other measurement methods, such as IEC 

Standard 60456, but believes these would create unnecessary test 

burden on manufacturers.

Clothes Washer Capacity Measurement Method

Other Revisions and Clarifications
81 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE conducted capacity tests on a small sample of clothes 

washers, and found that most rated capacities varied from DOE’s 

test measurements, by as much as 0.5 ft3.

– This suggests that the ratings are based on multiple interpretations 

of the uppermost edge of the clothes container.

– DOE seeks to provide an accurate, representative, and repeatable 

definition of the uppermost edge of the clothes container.

• The current definition of the clothes container is “the 

compartment within the clothes washer that holds the clothes 

during the operation of the machine.”

– DOE believes this should include the requirement that the clothing 

remain within the clothes container for an entire operating cycle.

– Additionally, the clothes washer should maintain basic functionality.

• Dry clothing could fit in certain fill volumes which would lead to poor 

washing performance and machine operation during a cycle.

Clothes Washer Capacity Measurement Method

Other Revisions and Clarifications
82 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE believes the top of the rotating portion of the clothes 

container for a vertical-axis clothes washer would be the highest 

horizontal plane that a clothes load could occupy.

– This would include a balance ring as part of the clothes container.

– Clothes could be loaded in the space above the tub cover, but this 

volume is excluded because these clothes would likely wash poorly.

• DOE believes the door seal in contact with the door during 

operation would determine the highest horizontal plane that a 

clothes load could occupy for a horizontal-axis clothes washer.

– DOE also considered the inner surface of the clothes door as the 

uppermost edge, but determined this method was not repeatable.

• For both vertical- and horizontal-axis clothes washers, any volume 

within the clothes container that a clothing load could not occupy 

during operation should be excluded from the measurement.

Clothes Washer Capacity Measurement Method

Other Revisions and Clarifications
83 | Test Procedure for Residential Clothes Washers eere.energy.gov

• The following diagram shows the proposed fill level clarification 

for vertical-axis clothes washers.

• DOE notes that the proposed fill level differs from the draft 

guidance for the current test procedure, which is posted on the 

residential clothes washers rulemaking website.

– The draft guidance sets the tub cover as the maximum fill level.

Clothes Washer Capacity Measurement Method

Other Revisions and Clarifications
84 | Test Procedure for Residential Clothes Washers eere.energy.gov

• The following diagrams show the proposed fill volumes for front 

and top-loading horizontal-axis clothes washers.

Clothes Washer Capacity Measurement Method

Other Revisions and Clarifications
85 | Test Procedure for Residential Clothes Washers eere.energy.gov

Request for Comment on the Capacity Measurement Method

Other Revisions and Clarifications

Item 16 DOE welcomes comment on whether the proposed method for 

measuring clothes container capacity provides for a representative 

measurement of the volume that a dry clothes load could occupy within 

the clothes container during washer operation, and on whether any 

other valid measurement method is available.
86 | Test Procedure for Residential Clothes Washers eere.energy.gov

• The calculation of WF currently in the test procedure is derived 

from only the water consumed during the cold wash/cold rinse 

cycle.

– Hot water consumption is measured for all cycles, but only used to 

determine water heating energy consumption.

– This presents an opportunity to bias the test procedure results by 

setting cold wash water consumption very low, while using more 

water during the higher temperature wash cycles.

• To produce more representative values of water consumption, 

DOE is proposing a new integrated water consumption factor 

(IWF).

– DOE is proposing to include water consumption from all energy test 

cycles, including self-clean cycles, into the calculation of IWF.

New Measure of Water Consumption

Other Revisions and Clarifications
87 | Test Procedure for Residential Clothes Washers eere.energy.gov

• The total weighted per-cycle water consumption would equal:

– The total water consumption for each active mode energy test cycle 

multiplied by its TUF and load usage factor.

– Plus the self-clean cycle water consumption, multiplied by 12 selfclean cycles per year, divided by 295 annual use cycles;

• IWF would then equal the total weighted per-cycle water 

consumption divided by the clothes container volume.

• DOE believes the proposed IWF metric will not substantially 

increase manufacturers’ test burden. 

– Doe believes that in practice, manufacturers likely record the data 

for cold water consumption at all wash temperatures even though it 

is not required by the current test procedure.

New Measure of Water Consumption

Other Revisions and Clarifications
88 | Test Procedure for Residential Clothes Washers eere.energy.gov

Request for Comment on the 

Integrated Water Consumption Factor

Other Revisions and Clarifications

Item 17 DOE welcomes comment on the proposal to establish a new 

integrated measure of water consumption for clothes washers, 

“integrated water consumption factor,” expressed in gallons per cubic 

foot. DOE requests comment on the validity of including water 

consumption from all test cycles, including self-clean cycles, into the 

proposed calculation of IWF. DOE also requests comment on whether 

the IWF calculation would result in a significant test burden.
89 | Test Procedure for Residential Clothes Washers eere.energy.gov

• The energy test cycle is currently defined as:

– “(A) the cycle recommended by the manufacturer for washing 

cotton or linen clothes, and includes all wash/rinse temperature 

selections and water levels offered in that cycle, and 

– (B) for each other wash/rinse temperature selection or water level 

available on that basic model, the portion(s) of other cycle(s) with 

that temperature selection or water level that, when tested pursuant 

to these test procedures, will contribute to an accurate 

representation of the energy consumption of the basic model as 

used by consumers.

– Any cycles under (A) or (B) shall include the agitation/tumble 

operation, spin speed(s), wash times, and rinse times applicable to 

that cycle, including water heating time for water heating clothes 

washers.”

Energy Test Cycle

Other Revisions and Clarifications
90 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE believes that some manufacturers may use only part A of this 

definition to determine the energy test cycle and the 

corresponding temperature and fill levels to be tested.

– Many machines provide a “normal” cycle setting, or some 

equivalent, to be used for washing cotton or linen items, satisfying 

part A of the energy cycle definition.

– However, many normal cycles limit the wash and rinse temperature 

selections; for example, they may offer cold and warm wash 

temperatures, but not hot, extra hot or a warm rinse.

– Certain manufacturers may only test the temperature settings 

available to the normal wash cycle, despite being able to access 

other wash temperature selections by switching out of the normal 

cycle.

– Doing so may neglect part B of the energy test cycle definition.

Energy Test Cycle

Other Revisions and Clarifications
91 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE notes that the requirement to test different cycle settings “if 

such testing contributes to an accurate representation of energy 

consumption as used by consumers” has led to some confusion, 

and is therefore proposing to add clarification to part B of the 

energy test cycle definition as follows:

– “...(B) if the cycle described in (A) does not include all wash/rinse 

temperature settings available on the clothes washer, and required 

for testing as described in this test procedure, the energy test shall 

also include the portions of a cycle setting offering these wash/rinse 

temperature settings with agitation/tumble operation, spin speed(s), 

wash times, and rinse times that are largely comparable to those 

for the cycle recommended by the manufacturer for washing cotton 

or linen clothes. Any cycle under (A) or (B) shall include the default 

agitation/tumble operation, soil level, spin speed(s), wash times, 

and rinse times applicable to that cycle, including water heating 

time for water heating clothes washers.”

Energy Test Cycle

Other Revisions and Clarifications
92 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE notes that it has issued draft guidance available on the 

residential clothes washers rulemaking website to interpret the 

current definition of the energy test cycle.

– The proposed definition is consistent with the draft guidance.

– This guidance states that the energy test cycle should include the 

temperature options on the cycle most comparable to the cycle 

recommended for washing cotton or linen clothes if these 

temperature selections are not available on the cotton or linen 

cycle.

• DOE also notes that it has received data from a manufacturer 

indicating that cycles may vary from the cotton or linen cycle by 

means of lower spin speed and resulting in a higher RMC, and 

therefore would not be largely comparable to the cotton or linen 

cycle.

Energy Test Cycle

Other Revisions and Clarifications
93 | Test Procedure for Residential Clothes Washers eere.energy.gov

Request for Comment on the Energy Test Cycle Definition

Other Revisions and Clarifications

Item 18 DOE requests comment on the proposed definition of the 

energy test cycle, and on how manufacturers currently address wash 

and rinse temperature selection under the current definition. DOE also 

requests comment on the selection cycles to be included in the energy 

test cycle under section 1.7(B) of the test procedure to definitively 

account for temperature options available only outside the normal 

cycle.
94 | Test Procedure for Residential Clothes Washers eere.energy.gov

• The current test procedure specifies test cloth preconditioning 

using AHAM Standard detergent IIA, which is no longer available.

• DOE conducted tests using AHAM standard test detergent 

Formula 3, and found the current dosage requirements (6.0 grams 

per gallon of water) may no longer be appropriate.

– Undissolved detergent was found in the preconditioned test load.

• One supplier of standard test materials, SDL Atlas, provides 

dosing instructions of 27.0 g + 4.0 g per pound of cloth load with 

AHAM standard test detergent Formula 3.

– In addition, AHAM’s clothes dryer test standard, AHAM HLD-1-

2009, specifies this dosage for test cloth pre-treatment.

• DOE is therefore proposing to amend the test cloth 

preconditioning procedure to use AHAM standard test detergent 

Formula 3 with dosing of 27.0 g + 4.0 g per pound of cloth load.

Detergent Specifications for Test Cloth Preconditioning

Other Revisions and Clarifications
95 | Test Procedure for Residential Clothes Washers eere.energy.gov

Request for Comment on Preconditioning Detergent

Other Revisions and Clarifications

Item 19 DOE welcomes comment on the proposed updated detergent 

formulation and associated dosage for test cloth preconditioning.
96 | Test Procedure for Residential Clothes Washers eere.energy.gov

• Section 2.6.3.1 of the test procedure requires that test cloth be 

preconditioned using a clothes washer for which:

– a maximum water level can be set;

– the load can be washed for 10 minutes; and 

– the wash temperature can be controlled to 135 oF ± 5 oF (57.2 oC ±

2.8 oC).

• Multiple manufacturers expressed concern that there are currently 

few clothes washers commercially available capable of meeting 

these requirements.

– Additionally, more stringent energy conservation standards may 

eliminate such clothes washer models from the market entirely.

• DOE seeks information regarding an alternative specification for 

the clothes washer to be used for preconditioning that would 

allow for the use of more recent models.

Clothes Washer for Test Cloth Preconditioning

Other Revisions and Clarifications
97 | Test Procedure for Residential Clothes Washers eere.energy.gov

Request for Comment on Preconditioning Clothes Washer 

Other Revisions and Clarifications

Item 20 DOE requests comment on the clothes washer used in test 

cloth preconditioning, including whether clothes washers currently 

meeting the specifications may be rendered obsolete by potential new 

residential clothes washer energy conservation standards.
98 | Test Procedure for Residential Clothes Washers eere.energy.gov

• Section 2.4 of the test procedure states “[t]he static water 

pressure at the hot and cold water inlet connection of the clothes 

washer shall be maintained at 35 pounds per square inch gauge 

(psig) ... during the test.”

– DOE believes this description is ambiguous as to whether the 

nominal 35 psig pressure is to be set under non-flow conditions and 

allowed to drop during flow, or whether it is to be maintained 

continuously under all flow conditions.

– Additionally, there is no specification for where the measurement is 

to be taken.

• DOE conducted tests on a small sample of front- and top-loading 

clothes washers to determine the effects of different water supply 

pressures on the test results.

Test Procedure Water Supply Pressure

Other Revisions and Clarifications
99 | Test Procedure for Residential Clothes Washers eere.energy.gov

• Tests at 10, 20, and 35 psig water supply pressure under flow 

conditions resulted in total water consumption values varying by 

10 to 30 percent.

– The test data suggest that a water supply pressure of 20 psig under 

flow conditions results in the most consistent results.

– DOE also believes that 20 psig may represent typical static 

pressure under flow conditions that would result from 35 psig 

supply pressure at non-flow conditions, and that these conditions 

may be more representative of water supply conditions that would 

be found in typical residential settings.

• However, other DOE test procedures more closely specify the 35 

psig requirement applying under flow conditions (dishwashers).

• Therefore, DOE is not proposing to amend the water supply 

pressure requirements at this time, but seeks more information on 

the topic.

Test Procedure Water Supply Pressure

Other Revisions and Clarifications
100 | Test Procedure for Residential Clothes Washers eere.energy.gov

Request for Comment on the Water Supply Pressure

Other Revisions and Clarifications

Item 21 DOE seeks information about the conditions under which 

clothes washers are currently tested, and invites comment on the 

appropriate specification of the water supply pressure.
101 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE is proposing the following revisions that will not 

substantively change the test procedure:

– To include the oil repellency test and dimensional change test 

references in 10 CFR 430.3, “Materials Incorporated by Reference;”

– To clarify the RMC calculations in section 3.8.4 for clothes washers 

with options that result in different RMC values;

– To correct an error in the equation in section 4.1.4 for calculating 

the total per-cycle hot water energy consumption for gas- or oilheated water; and

– To remove the current section 4.5, which provides for the 

calculation of energy factor (EF).

• EF was the energy efficiency metric used to establish energy 

conservation standards for clothes washers manufactured before 

January 1, 2004. It is no longer used.

Additional Revisions and Clarifications

Other Revisions and Clarifications
102 | Test Procedure for Residential Clothes Washers eere.energy.gov

4. Clothes Washer Active Mode Test Procedure

a) Technologies Not Covered by the Current Clothes Washer Test 

Procedure

b) Changes to Reflect Current Usage Patterns and Capabilities

c) Test Cloth

d) Other Revisions and Clarifications

e) Test Procedure Performance Specifications

5. Compliance with Other EPCA Requirements

6. Impact of the Proposed Amendments on EnergyGuide and 

ENERGY STAR

7. Elimination of the Obsolete Clothes Washer Test Procedure

Test Procedure Overview
103 | Test Procedure for Residential Clothes Washers eere.energy.gov

• The current DOE test procedure does not include any provisions 

for evaluating the wash quality of a clothes washer.

– The intent is to determine water and energy consumption, 

regardless of a clothes washer’s wash capabilities.

• DOE received multiple comments in support of adding 

performance measures to the test procedure.

– Multiple commenters stated that increasing energy and water 

efficiency requirements could limit the ability of a clothes washer to 

clean laundry as expected.

– The comments referenced other standards that include a measure 

of wash performance, such as AHAM HLW-1 and IEC Standard 

60456, “Clothes washing machines for household use – Methods 

for measuring the performance.”

Test Procedure Performance Specifications

Performance Specifications
104 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE considered these comments and recognizes the benefits of 

characterizing washer performance, but is not proposing to 

incorporate measures of wash performance into the clothes 

washer test procedure.

– EPCA states “[a]ny test procedures prescribed or amended under 

this section shall be reasonably designed to produce test results 

which measure energy efficiency, energy use . . . or estimated 

annual operation cost . . .” (42 U.S.C. 6293(b)(3))

Test Procedure Performance Specifications

Performance Specifications
105 | Test Procedure for Residential Clothes Washers eere.energy.gov

4. Clothes Washer Active Mode Test Procedure

a) Technologies Not Covered by the Current Clothes Washer Test 

Procedure

b) Changes to Reflect Current Usage Patterns and Capabilities

c) Test Cloth

d) Other Revisions and Clarifications

e) Test Procedure Performance Specifications

5. Compliance with Other EPCA Requirements

6. Impact of the Proposed Amendments on EnergyGuide and 

ENERGY STAR

7. Elimination of the Obsolete Clothes Washer Test Procedure

Test Procedure Overview
106 | Test Procedure for Residential Clothes Washers eere.energy.gov

• EPCA requires that “[a]ny test procedures prescribed or amended 

under this section shall be reasonably designed to produce test 

results which measure energy efficiency, energy use . . . or 

estimated annual operating cost of a covered product during a 

representative average use cycle or period of use . . . and shall not 

be unduly burdensome to conduct.” (42 U.S.C. 6293(b)(3))

• DOE believes the proposed amendments regarding standby, off, 

delay start, and cycle finished mode energy consumption satisfy 

this requirement because:

– IEC Standard 62301 is internationally accepted to measure power in 

standby and off mode, and will produce power consumption 

measurements that are representative of an average use cycle.

– The proposed test methods and associated equipment would not 

require manufacturers to make a major investment in test facilities 

and new equipment.

Test Burden

Compliance with Other EPCA 

Requirements
107 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE believes the amendments to the active washing mode portion 

of the test procedure would also satisfy this EPCA requirement.

– The amendments would require manufacturers to make the same 

measurements as specified by the current test procedure, and 

would likely not require additional investment or equipment 

purchases.

– The proposed additional test cycles would increase the total time 

required to test a clothes washer offering these cycle settings, 

however these cycles would likely increase the total test time only 

by approximately 25 percent.

Test Burden

Compliance with Other EPCA 

Requirements
108 | Test Procedure for Residential Clothes Washers eere.energy.gov

• Section 325(gg)(2)(A) of EPCA requires that standby mode and off 

mode energy consumption be “integrated into the overall energy 

efficiency, energy consumption, or other energy descriptor for 

each covered product” unless the current test procedures already 

fully account for the standby mode and off mode energy 

consumption, or if such an integrated test procedure is technically 

infeasible. (42 U.S.C. 6295(gg)(2)(A))

– As previously discussed, DOE is proposing to incorporate the 

clothes washer standby and off mode energy consumption, in 

addition to delay start and cycle finished mode energy consumption, 

into a “per-cycle standby, off, delay start and cycle finished mode 

energy consumption”, expressed in kWh, and into an integrated 

modified energy factor (IMEF), expressed in ft3 per kWh per cycle, 

which satisfies this EPCA requirement.

Integration of Standby and Off Mode Energy Consumption

Compliance with Other EPCA 

Requirements
109 | Test Procedure for Residential Clothes Washers eere.energy.gov

• EPCA also requires that test procedure amendments 

incorporating standby and off mode energy consumption will not 

determine compliance with previously established standards. (42 

U.S.C. 6295(gg)(2)(C))

– Because DOE is proposing to adopt the amendments as a new 

appendix J2 to 10 CFR part 430 subpart B that manufacturers 

would not be required to use until the compliance date of amended 

energy conservation standards for residential clothes washers, the 

proposed test procedure amendments pertaining to standby mode 

and off mode energy consumption would not apply to, and would 

have no effect on, existing standards.

Impact of Test Procedure Amendments on Existing Standards

Compliance with Other EPCA 

Requirements
110 | Test Procedure for Residential Clothes Washers eere.energy.gov

• The test procedure in appendix J1 of subpart B of 10 CFR 430 is 

also used to test commercial clothes washers.

• If DOE were to apply the proposed new appendix J2 to commercial 

clothes washers, the impacts would be limited to the proposed 

amendments associated with active washing mode because 

commercial clothes washer standards are based on MEF and WF.

– These include the proposed changes to the test load size 

specifications, TUFs, DUF, test cloth, capacity measurement, 

detergent, and water supply pressure.

– These changes would have some affect on the measured energy 

and water efficiencies of commercial clothes washers, mostly from 

the changes to the capacity measurement and use factors.

Impact on Commercial Clothes Washers

Compliance with Other EPCA 

Requirements
111 | Test Procedure for Residential Clothes Washers eere.energy.gov

Request for Comment on Commercial Clothes Washer Impact

Item 22 DOE welcomes inputs on the effects of the proposed 

amendments in appendix J2 on the measured energy and water 

efficiencies of commercial clothes washers.

Compliance with Other EPCA 

Requirements
112 | Test Procedure for Residential Clothes Washers eere.energy.gov

4. Clothes Washer Active Mode Test Procedure

a) Technologies Not Covered by the Current Clothes Washer Test 

Procedure

b) Changes to Reflect Current Usage Patterns and Capabilities

c) Test Cloth

d) Other Revisions and Clarifications

e) Test Procedure Performance Specifications

5. Compliance with Other EPCA Requirements

6. Impact of the Proposed Amendments on EnergyGuide and 

ENERGY STAR

7. Elimination of the Obsolete Clothes Washer Test Procedure

Test Procedure Overview
113 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE considered potential impacts of the proposed test procedure 

amendments to the FTC EnergyGuide requirements, and 

determined that there will be no impact.

– The primary indication of energy use provided in the EnergyGuide 

label for clothes washers is annual energy cost, which would not be 

changed by the proposed amendments.

• The ENERGY STAR program for clothes washers is based on MEF 

and WF.

– The calculations of WF and MEF would be slightly affected by the 

proposed amendments, however, these calculations would not be 

required until the compliance date of any amended energy 

conservation standards.

– DOE would analyze any potential impacts of the proposed test 

procedure as part of the current energy conservation standards 

rulemaking.

Impact on EnergyGuide and ENERGY STAR

Impact of the Proposed Amendments
114 | Test Procedure for Residential Clothes Washers eere.energy.gov

4. Clothes Washer Active Mode Test Procedure

a) Technologies Not Covered by the Current Clothes Washer Test 

Procedure

b) Changes to Reflect Current Usage Patterns and Capabilities

c) Test Cloth

d) Other Revisions and Clarifications

e) Test Procedure Performance Specifications

5. Compliance with Other EPCA Requirements

6. Impact of the Proposed Amendments on EnergyGuide and 

ENERGY STAR

7. Elimination of the Obsolete Clothes Washer Test Procedure

Test Procedure Overview
115 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE proposes to delete appendix J to subpart B of 10 CFR part 

430 along with all references to appendix J in 10 CFR part 430.23.

– Appendix J only applies to clothes washers manufactured before 

January 1, 2004 and is therefore now obsolete.

• Appendix J1 to subpart B of 10 CFR part 430 provides applicable 

test procedures for all clothes washers currently available on the 

market.

• DOE proposes to maintain the current naming of appendix J1, 

rather than renaming it as appendix J, to simplify the changes 

required.

– DOE has previously used this approach to retaining later versions 

of appendices to subpart B of 10 CFR 430 when deleting the 

original version.

Elimination of the Obsolete Clothes Washer Test Procedure

Elimination of Appendix J
116 | Test Procedure for Residential Clothes Washers eere.energy.gov

 Public Meeting – oral comments will be captured in the transcript and 

become part of the public record.

 Written comments – NOPR comment period open until 75 days after 

publication in the Federal Register

Reference docket #: EERE-2010-BT-TP-0021 and/or RIN #: 1904-AC08

Email: RES-CW-2010-TP-0021@ee.doe.gov

Mail: Mrs. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

1000 Independence Avenue, SW, Mailstop EE-2J

Washington, DC 20585-0121

Courier: Mrs. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

950 L'Enfant Plaza, 6th Floor

Washington, DC 20024

Telephone: (202) 586-2945

How to Submit Comments...

Closing
117 | Test Procedure for Residential Clothes Washers eere.energy.gov

Support Slides
118 | Test Procedure for Residential Clothes Washers eere.energy.gov

• One household survey conducted by the National Appliance and 

Equipment Energy Efficiency Committee (NAEEEC) in Australia in 

2000, for example, measured different modes for 61 clothes 

washers with an average age of 9 years. 

– The daily time spent in each mode in this study averaged 1 hour for 

washing (active washing mode), zero time for delay start and 

“active standby” (inactive mode) modes, and the remaining time 

split 20 percent for “end of program” mode (cycle finished mode) 

and 80 percent for off mode. Self-clean mode was not explicitly 

addressed.

Hours Per Year Associated with Non-Active Washing Modes

Calculation of Energy Use
119 | Test Procedure for Residential Clothes Washers eere.energy.gov

• The average age of the clothes washers in the study suggests that 

many had electromechanical rather than electronic controls, and 

thus would not likely have been capable of inactive mode. 

– Hence, DOE does not infer from those results that more modern 

clothes washers spend negligible time in inactive mode.

• DOE believes that because current clothes washer models offer 

both mechanical and electronic controls, the time apportioned to 

off mode in this study would actually be split between off mode 

and inactive mode.

• Implementation of a delayed start feature appears to be marketspecific. 

– Markets with a long history of residential time-of-day electricity 

pricing are more likely to have appliances with delayed start 

features than in markets where household electricity prices are 

constant.

Hours Per Year Associated with Non-Active Washing Modes

Calculation of Energy Use
120 | Test Procedure for Residential Clothes Washers eere.energy.gov

• The clothes washers in the NAEEEC study would have been less 

likely to have a delay start mode because differential power 

pricing is a relatively recent development in the Australian 

residential power market.

– Thus, the findings in the Australian clothes washer study regarding 

delayed start are inconclusive regarding current models of clothes 

washers. 

• To help address this uncertainty, DOE examined an Australian 

study on clothes washers conducted in 2005, which noted a small 

number of hours associated with delay start mode. 

– The study monitored time spent in different modes using 

dataloggers on clothes washers in Australia and New Zealand.

– It showed that the average amount of time spent in delay start 

mode per wash cycle was approximately 5 minutes.

Hours Per Year Associated with Non-Active Washing Modes

Calculation of Energy Use
121 | Test Procedure for Residential Clothes Washers eere.energy.gov

• DOE expects similar low usage patterns of delayed start 

functionality for clothes washers in U.S. households, as noted in 

the 2005 Australian survey.

• DOE research suggests that most U.S. residential electricity 

customers have fixed-rate electricity pricing (i.e., the cost of 

electricity does not change with time of day, day of week, or time 

of year).

– However, the adoption of delayed start functionality could rise in the 

United States as more electric utilities offer variable-rate pricing 

plans to residential customers that encourage shifting electricity 

consumption to off-peak hours.

Hours Per Year Associated with Non-Active Washing Modes

Calculation of Energy Use
122 | Test Procedure for Residential Clothes Washers eere.energy.gov

• Based on these two studies, DOE concludes that a typical modern 

clothes washer spends a small amount of time in delay start 

mode.

• Using an estimated 5 minutes per cycle and the proposed 

representative 295 cycles per year, the total annual amount of time 

spent in delay start mode is 25 hours.

• The NAEEEC study suggests allocating the remaining time as 

follows:

– 20 percent allocated to cycle finished mode; and

– 80 percent allocated to off and/or inactive mode for clothes washers 

that have the capability of operating in both modes. 

Hours Per Year Associated with Non-Active Washing Modes

Calculation of Energy Use
123 | Test Procedure for Residential Clothes Washers eere.energy.gov

• However, internal DOE testing of multiple clothes washers showed 

that the actual time spent in a cycle finished mode is very short.

– Most units with a cycle finished mode spent less than 5 minutes in 

this mode before switching to off/inactive mode.

– Some models even had no cycle finished mode, and immediately 

reverted to off/inactive mode after completion of the active mode.

• Based on these results, DOE is proposing to allocate 3 minutes 

per cycle to cycle finished mode, resulting in an average of 15 

hours per year.

Hours Per Year Associated with Non-Active Washing Modes

Calculation of Energy Use
124 | Test Procedure for Residential Clothes Washers eere.energy.gov

• In addition, DOE is aware that some clothes washers offer self-clean 

cycles that are not accounted for in the proposed 295 per year.

– DOE tested seven machines offering a self-clean cycle, and found an 

average cycle time of 1.3 hours.

– Based on an estimated average manufacturer recommendation of 12 

self-clean cycles per year, DOE is proposing 16 self-clean hours per 

year.

• In summary, DOE is proposing to allocate 295 hours per year to 

active washing mode, 16 hours per year to self-clean mode (if 

applicable), 25 hours per year to delay start mode, 15 hours per year 

to cycle finished mode, and the remainder to off and/or inactive 

mode.

Hours Per Year Associated with Non-Active Washing Modes

Calculation of Energy Use