TEST REPORT:

ENERGY CONSERVATION PROGRAM

FOR CONSUMER PRODUCTS AND 

COMMERCIAL AND INDUSTRIAL EQUIPMENT

CLOTHES WASHER TEST PROCEDURE

July 2015

U.S. Department of Energy

Assistant Secretary

Office of Energy Efficiency and Renewable Energy

Building Technologies Office

Appliances and Commercial Equipment Standards

Washington, DC 20585
2

This document was prepared for the Department of Energy

by staff members of

Navigant Consulting, Inc.
3

TABLE OF CONTENTS

1. INTRODUCTION..................................................................................................................... 4

2. TEST CLOTH LOADING METHODS ................................................................................. 4

2.1 Current Appendix J2 Method...............................................................................................4

2.2 NOPR Method .....................................................................................................................5

2.3 Discussion of Results...........................................................................................................6

3. TEMPERATURE INDICATOR LABELS ............................................................................ 9

3.1 Temperature Accuracy.........................................................................................................9

3.2 Consistency and Durability................................................................................................12

3.3 Summary............................................................................................................................14

LIST OF TABLES

Table 2.1.1. Baseline Unit Test Results – Current Appendix J2 Method........................................5

Table 2.1.2. Max-Tech Unit Test Results – Current Appendix J2 Method.....................................5

Table 2.2.1. Baseline Unit Test Results – NOPR Method...............................................................6

Table 2.2.2. Max-Tech Unit Test Results – NOPR Method............................................................6

Table 2.3.1. Comparison of Total Water Consumption, Machine Electrical Energy, and 

RMC for Each Loading Method ..............................................................................6

Table 2.3.2. Comparison of Loading Times and Cycle Times for Each Loading Method..............7

Table 3.1.1. Results from Temperature Label Accuracy Test .......................................................11

Table 3.2.1. Wash Cycles Tested to Confirm Consistency and Durability of Labels ...................12

LIST OF FIGURES

Figure 2.3.1: Machine Electrical Energy Results for Baseline and Max-Tech Units......................7

Figure 2.3.2: Water Consumption Results for Baseline and Max-Tech Units ................................8

Figure 2.3.3: RMC Results for Baseline and Max-Tech Units........................................................8

Figure 3.1.1. Schematic of Temperature Label Accuracy Test .....................................................10

Figure 3.1.2. Photo of Temperature Label and Thermocouples....................................................10

Figure 3.1.3. Measured Temperature versus Indicated Temperature ............................................11

Figure 3.2.1. Placement of Three Labels in Front-Loading Unit, Test #1.....................................12

Figure 3.2.2. Labels from Front-Loading Hot, Whites Wash Cycle..............................................13

Figure 3.2.3. Labels from Front-Loading Extra Hot, Sanitize Cycle ............................................13

Figure 3.2.4. Placement of Labels in Top-Loading Unit ...............................................................14

Figure 3.2.5. Labels from Top-Loading Hot, Normal Cycle .........................................................14
4

1. INTRODUCTION

 This test report accompanies the clothes washer test procedure final rule. Section 2 of this 

report describes the results of the comparison of two test cloth loading methods for front-loading 

clothes washers. Section 3 describes the results from testing the accuracy, consistency and 

durability of adhesive temperature indicator labels.

2. TEST CLOTH LOADING METHODS

Section 2.8.3 of both the appendix J1 and appendix J2 test procedures instruct the testing 

party to load the energy test cloths into the clothes washer by grasping them in the center, 

shaking them to hang loosely, and then “put them into the clothes container” prior to activating 

the clothes washer. In the April 25, 2014 notice of proposed rulemaking for the clothes washer 

test procedure (“April 2014 NOPR”, 79 FR 23062, 23065) DOE proposed providing additional 

specificity for the test cloth handling and loading instructions to improve the overall clarity and 

consistency of test cloth loading procedures.

DOE proposed using a modified version of the loading instructions for towels and 

pillowcases provided in the Association of Home Appliance Manufacturers (AHAM) HLW-1-

2010 test method, Performance Evaluation Procedures for Household Appliances.

1 Like DOE’s 

current test cloth loading instructions, the AHAM procedure involves grasping the 

towel/pillowcase in the center and shaking it so that it hangs loosely. The AHAM procedure 

further describes placing the towels/pillowcases into the drum with alternating orientations.

In response to comments received by DOE on its proposal, as discussed in the final rule 

that this test report accompanies, DOE conducted investigations into the proposed changes to the 

test cloth loading instructions for front-loading clothes washers. DOE performed comparative 

testing on two front-loading clothes washers: one with baseline efficiency and one with max-tech 

efficiency. On each clothes washer, DOE conducted 10 wash cycles using the current test 

procedure (hereafter referred to as the “current appendix J2 method”), and 10 wash cycles using 

the revised procedure described in the proposed amendments (hereafter referred to as the “NOPR 

method”). DOE used the cold wash/cold rinse temperature selection for all cycles.

2.1 Current Appendix J2 Method

For the current appendix J2 method, DOE loaded each cloth individually according to 

instructions provided in section 2.8.3 of appendix J1 and appendix J2: “Load the energy test 

cloths by grasping them in the center, shaking them to hang loosely, and then put them into the 

clothes container prior to activating the clothes washer.” Each cloth was loaded loosely into the 

drum without being placed in any particular orientation, resulting in a random arrangement of 

cloths inside the drum. For each cycle, DOE measured the following:

 

1 AHAM has since published an updated version of this test method, AHAM HLW-1-2013, which is available at 

http://www.aham.org/ht/d/Store/name/MAJOR/pid/5132. The test cloth loading instructions are the same in both the 

2010 and 2013 versions of this test method.
5

 Time required to load all the cloths into the drum (minutes (min):seconds (sec))

 Total cycle time, excluding cloth loading time (min)

 Total water consumption (gallons (gal))

 Machine electrical energy consumption (kilowatt-hours (kWh))

 Remaining moisture content (RMC) (%)

Table 2.1.1 shows the results of the test runs conducted on the baseline unit using the 

current appendix J2 method. Table 2.1.2 shows the results performed on the max-tech unit using 

the current appendix J2 method.

Table 2.1.1. Baseline Unit Test Results – Current Appendix J2 Method

Test Run Number

1 2 3 4 5 6 7 8 9 10

Time to Load (min:sec) 5:15 3:56 4:01 3:38 3:59 3:46 4:03 4:30 4:15 3:57

Cycle Time (min) 59 65 62 61 66 60 60 75 65 60

Water Consumed (gal) 16.83 16.60 16.50 16.10 17.31 16.43 16.69 16.67 16.89 15.37

Machine Energy (kWh) 0.13 0.15 0.14 0.14 0.14 0.13 0.14 0.15 0.14 0.13

RMC (%) 46.4 47.1 47.1 46.4 47.8 47.1 46.4 46.4 47.8 44.0

Table 2.1.2. Max-Tech Unit Test Results – Current Appendix J2 Method

Cycle Number

1 2 3 4 5 6 7 8 9 10

Time to Load (min:sec) 4:39 5:15 5:10 4:58 5:10 5:08 4:59 4:56 5:20 5:14

Cycle Time (min) 53 56 52 53 55 56 48 55 50 49

Water Consumed (gal) 11.91 12.23 12.11 12.31 12.51 12.53 12.72 12.91 11.88 12.27

Machine Energy (kWh) 0.13 0.13 0.13 0.13 0.14 0.14 0.13 0.13 0.12 0.12

RMC (%) 35.5 33.9 34.4 35.5 35.0 35.0 34.0 35.0 35.5 35.5

2.2 NOPR Method

For the NOPR method, DOE loaded each cloth lengthwise, from front to back, using 

alternating orientations for adjacent pieces of cloth. The clothes were loaded evenly across the 

width of the clothes container, completing each cloth layer across its horizontal plane before 

adding a new layer. DOE measured the same parameters for each test run as described above. 

Table 2.2.1 and Table 2.2.2 show the results for test runs performed on the baseline and maxtech units, respectively, using the NOPR method.

 
6

Table 2.2.1. Baseline Unit Test Results – NOPR Method

Test Run Number

1 2 3 4 5 6 7 8 9 10

Time to Load (min:sec) 5:12 4:59 4:37 4:39 4:58 4:48 4:31 5:10 4:33 4:47

Cycle Time (min) 66 62 61 60 59 64 58 62 57 72

Water Consumed (gal) 16.06 17.24 16.79 16.11 16.82 16.89 16.62 15.89 15.82 17.09

Machine Energy (kWh) 0.14 0.14 0.14 0.14 0.13 0.14 0.13 0.14 0.13 0.15

RMC (%) 47.8 47.1 47.8 46.4 47.1 47.8 47.1 47.1 47.1 46.1

Table 2.2.2. Max-Tech Unit Test Results – NOPR Method

Test Run Number

1 2 3 4 5 6 7 8 9 10

Time to Load (min:sec) 5:55 5:40 5:50 6:00 5:59 6:05 6:10 6:15 6:00 6:10

Cycle Time (min) 50 52 53 54 55 56 54 53 54 48

Water Consumed (gal) 9.39 12.51 12.69 12.48 13.28 12.66 10.96 11.80 12.36 11.01

Machine Energy (kWh) 0.12 0.13 0.14 0.13 0.13 0.13 0.14 0.13 0.13 0.12

RMC (%) 35.0 33.9 35.0 35.5 34.4 32.5 39.3 31.4 35.0 39.9

2.3 Discussion of Results

Table 2.3.1 summarizes the results of the current appendix J2 method and the NOPR 

method tests by providing the range, average, and standard deviation for total water 

consumption, machine electrical energy, and RMC. Table 2.3.2 summarizes the measured 

loading times and cycles times associated with each method.

Table 2.3.1. Comparison of Total Water Consumption, Machine Electrical Energy, and 

RMC for Each Loading Method

Washer 

Type Loading Method

Total Water Consumption 

(gal)

Machine Electrical Energy 

(kWh)

Remaining Moisture 

Content (%)

Range Avg; SD (%) Range Avg; SD (%) Range Avg; SD (%)

Baseline

Current Appendix 

J2 Method 15.4 – 17.3 16.5; 3.0% 0.13 – 0.15 0.14; 4.4% 44 – 48 47; 2.2%

NOPR Method 15.8 – 17.2 16.5; 3.0% 0.13 – 0.15 0.14; 3.9% 46 – 48 47; 1.2%

Max-Tech

Current Appendix 

J2 Method 11.9 – 12.9 12.3; 2.6% 0.12 – 0.14 0.13; 3.3% 34 – 36 35; 1.6%

NOPR Method 9.4 – 13.3 11.9; 9.2% 0.12 – 0.14 0.13; 4.6% 31 – 40 35; 7.1%
7

Table 2.3.2. Comparison of Loading Times and Cycle Times for Each Loading Method

Washer 

Type Loading Method

Loading Time

(min:sec)

Wash Cycle Time (min)

Average 

Total 

Time 

Range Avg Range Avg (min)

Baseline

Current Appendix 

J2 Method 3:38 – 4:15 4:08 59 – 75 63 67

NOPR Method 4:31 – 5:12 4:49 57 – 72 62 66

Max-Tech

Current Appendix 

J2 Method 4:39 – 5:20 5:04 48 – 56 53 58

NOPR Method 5:40 – 6:15 6:00 48 – 56 53 59

The results for machine energy, water consumption and RMC shown in Table 2.3.1 are 

graphically represented in Figure 2.3.1, Figure 2.3.2, and Figure 2.3.3, respectively. In each plot, 

the center points represent the averages, and the bars represent the observed ranges.

Figure 2.3.1: Machine Electrical Energy Results for Baseline and Max-Tech Units

0.11

0.12

0.13

0.14

0.15

0.16

Current

Appendix J2

Method

NOPR

 Method

Machine Electrical Energy (kWh)

Baseline Model

0.11

0.12

0.13

0.14

0.15

0.16

Current

Appendix J2

Method

NOPR

Method

Max-Tech Model
8

Figure 2.3.2: Water Consumption Results for Baseline and Max-Tech Units

Figure 2.3.3: RMC Results for Baseline and Max-Tech Units

9

10

11

12

13

14

15

16

17

18

Current

Appendix J2

Method

NOPR

 Method

Water Consumption (gal)

Baseline Model

9

10

11

12

13

14

15

16

17

18

Current

Appendix J2

Method

NOPR

Method

Max-Tech Model

30%

32%

34%

36%

38%

40%

42%

44%

46%

48%

50%

Current

Appendix J2

Method

NOPR

 Method

Remaining Moisture Content (%)

Baseline Model

30%

32%

34%

36%

38%

40%

42%

44%

46%

48%

50%

Current

Appendix J2

Method

NOPR

Method

Max-Tech Model
9

3. TEMPERATURE INDICATOR LABELS

Determining the maximum wash temperature achieved during a wash cycle requires 

measuring the water temperature during the cycle. In the April 2014 NOPR, DOE proposed to 

amend the test procedure to authorize the use of waterproof, non-reversible temperature indicator 

labels, adhered to the inside of the clothing container, to determine the maximum temperature 

threshold achieved during an extra-hot wash cycle. If testing a front-loading clothes washer, the 

label would be adhered along the inner circumference of the clothes container drum, midway

between the front and the back of the clothes container. For a top-loading clothes washer, the 

label would be adhered along the inner circumference of the clothes container drum, as close to 

the bottom of the container as possible.

In response to comments received by DOE on its proposal, as discussed in the final rule 

that this test report accompanies, DOE conducted investigations of non-reversible temperature 

labels. For this report, DOE investigated two non-reversible temperature labels from Omega 

Engineering Inc.

2

:

 Model TL-E-105, which provides temperature indicators in 5-degree Fahrenheit (°F) 

increments between 105 and 120 °F, and 10 °F increments between 120 and 160 °F.

 Model TL-E-170, which provides temperature indicators in 10 °F increments between 

170 and 240 °F.

DOE is also aware of waterproof adhesive temperature labels from the Paper 

Thermometer Company, Inc.,3including temperature labels designed to indicate the maximum 

temperature threshold achieved during dishwasher testing. At the time of this testing, however, 

the particular temperature labels of interest were not available from the manufacturer. DOE is 

not aware of any temperature labels from any manufacturer offering a temperature indicator of 

135°F, which corresponds to the hot water supply temperature specified in the clothes washer 

test procedure and the threshold that defines an extra hot wash.

To determine the accuracy, consistency, and durability of the Omega labels, DOE tested

both top-loading and front-loading clothes washers using the methodology proposed in the April 

2014 NOPR. The results of this testing are described in the following sections of this report.

3.1 Temperature Accuracy

Omega does not provide a temperature accuracy for the TL-E product line, so DOE

performed testing to investigate the accuracy of the temperature indicators. The testing consisted 

of suspending a label in a pot of water, heating the water using an electric coil cooktop, and 

using calibrated thermocouples to measure the water temperatures at which the individual 

thermal indicators on the label became activated (i.e., changed color).

The test setup included one temperature label sandwiched between two thermocouples and

suspended in the middle of the pot by a wooden support structure. The bottom thermocouple was 

adhered to the label using waterproof adhesive tape to ensure that it was firmly secured. The top

 

2 Omega labels available at http://www.omega.com/pptst/TL-E_LABELS.html

3 Paper Thermometer Company: www.paperthermometer.com
10

thermocouple was situated directly above the label. Figure 3.1.1 shows a schematic of the test 

setup, and Figure 3.1.2 shows a photo of the temperature label and thermocouples.

Figure 3.1.1. Schematic of Temperature Label Accuracy Test

Figure 3.1.2. Photo of Temperature Label and Thermocouples

During the test, DOE recorded the temperature reading of both thermocouples at the time 

each temperature threshold indicator on the label became activated. DOE averaged both

thermocouple readings to determine the calibrated temperature at which each threshold was 

achieved on the temperature label. DOE performed this test on three Omega labels. Table 3.1.1

presents the results of the three tests conducted.
11

Table 3.1.1. Results from Temperature Label Accuracy Test

Temperature 

Threshold on 

Label (°F)

Calibrated Temperature Recorded by 

Thermocouples at Each Label Threshold (°F)

Test 1 Test 2 Test 3

105 104.6 103.9 104.3

110 110.2 109.9 110.5

115 114.1 113.9 113.9

120 123.0 122.6 122.3

130 129.6 127.0 127.4

140 138.2 140.2 136.2

150 148.1 147.8 146.2

160 159.3 157.8 155.4

The results in the Table 3.1.1 are represented in a scatter plot in Figure 3.1.3, which 

shows the label temperature thresholds on the x-axis and the calibrated measured temperature on 

the y-axis. The straight line in the plot indicates a theoretical perfect match between the 

temperature threshold indicated on the label and the actual measured temperature.

Figure 3.1.3. Measured Temperature versus Indicated Temperature

These test results demonstrate that the Omega TL-E-105 labels provide an average 

accuracy within ±1°F for temperatures less than 120 °F, and an average accuracy within ±3 °F 

for temperatures 120 °F and greater. The calibrated temperatures recorded at the 140 °F indicator 

threshold ranged from 136.2°F to 140.2°F.
12

3.2 Consistency and Durability

DOE performed additional testing to investigate the consistency and durability of the 

Omega temperature indicators. For these tests, multiple labels were installed in one top-loading 

and two front-loading clothes washers. Table 3.2.1 shows the three different wash cycles tested.

Table 3.2.1. Wash Cycles Tested to Confirm Consistency and Durability of Labels

Test Parameter Test #1 Test #2 Test #3

Clothes Washer Type Front-Loading Front-Loading Top-Loading

Cycle Selection Whites Sanitize Normal

Wash/Rinse Temperature Selection Hot/Cold Extra Hot/Cold Hot/Cold

Figure 3.2.1 shows the placement of the three temperature labels for Test #1, which was 

performed in a front-loading clothes washer using the Whites cycle and the Hot/Cold wash/rinse 

temperature setting. The first label was placed directly on the side of one of the baffles; the 

second label was placed on the wash drum adjacent to one of the baffles; and the third label was 

placed in the center of the wash drum midway between two baffles.

 

Figure 3.2.1. Placement of Three Labels in Front-Loading Unit, Test #1

Figure 3.2.2 shows photographs of the labels after testing. The dark gray circles indicate

the temperature thresholds that were achieved during the wash cycle. All three labels indicate a 

consistent maximum temperature threshold of 110 °F. With regards to durability, label (c) shown 

in Figure 3.2.2, which was placed in the middle of the drum halfway between two baffles, was 

the most worn after the test. Labels (a) and (b), which were placed on a baffle and adjacent to a 

baffle, respectively, were noticeably less worn than label (c). In no case, however, did the wear 

interfere with the activation or observation of the temperature indicators.
13

(a) Baffle (b) Next to baffle (c) Between baffles

Figure 3.2.2. Labels from Front-Loading Hot, Whites Wash Cycle

Test #2 was performed in a front-loading clothes washer using the Sanitize cycle and the 

Extra Hot/Cold wash/rinse temperature setting. For this test, DOE used four labels: two provided 

a temperature range of 105-160 °F, while the other two provided a range of 170-240 °F. The 

170-240 °F labels were used to verify that the labels would not register a false high temperature 

reading during an extra-hot clothes washer cycle. One of each label type was placed next to a

baffle, while the other two were placed in the center of the drum midway between two baffles. 

Figure 3.2.3 displays the four labels after the test.

. (a) Next to baffles (b) Between baffles

Figure 3.2.3. Labels from Front-Loading Extra Hot, Sanitize Cycle

Both pairs of labels in Figure 3.2.3 indicate a maximum temperature threshold of 150 °F. 

Note that the lighting in Figure 3.2.3 (b) results in the 150 °F indicator appearing lighter than the 

140 °F indicator; however, on the actual label the 150 °F indicator is clearly activated. The labels 

with a range of 170-240 °F did not show any temperature thresholds achieved, as expected. With 

regards to durability, the labels placed midway between the baffles were noticeably more worn

than the labels placed next to the baffles. Again, in neither case did the wear interfere with the 

activation or observation of the temperature indicators.
14

Test #3 was performed in a top-loading clothes washer using the Normal cycle and the 

Hot/Cold wash/rinse temperature setting. Two labels were placed near the bottom of the clothes 

container, as proposed in the April 2014 NOPR. Figure 3.2.4 shows the placement of the 

temperature labels for Test #3.

(a) Vertical portion of sidewall (b) Curved portion near bottom of drum

Figure 3.2.4. Placement of Labels in Top-Loading Unit

Both labels indicated a maximum temperature threshold of 130 °F, as shown in Figure 

3.2.5. With regards to durability, the label located on the vertical portion of the sidewall of the 

drum showed less wear than the label placed along the curved portion near the bottom of the 

drum.

(a) Vertical sidewall (b) Curved portion near bottom of drum

Figure 3.2.5. Labels from Top-Loading Hot, Normal Cycle

3.3 Summary

The results from these tests demonstrate that the Omega labels provided consistent results

and remained intact and adhered to the side of the wash drum. The results show that placement 

within the wash drum affects the amount of wear experienced by the label during the wash cycle.

For the front-loading clothes washers, the labels placed next to the baffles experienced the least 

amount of wear. For the top-loading clothes washer, the label placed along the vertical portion of 

the sidewall of the clothing container experienced the least amount of wear. In no case, however, 

did the wear prevent the activation or observation of the appropriate temperature indicator.