12A-i

APPENDIX 12A. MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDES

TABLE OF CONTENTS

12A.1 MICROWAVE OVENS (ENERGY FACTOR STANDARDS) ......................... 12A-1

12A.2 MICROWAVE OVENS (STANDBY POWER STANDARDS)......................... 12A-5
12A-1

APPENDIX 12A. MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDES

12A.1 MICROWAVE OVENS (ENERGY FACTOR STANDARDS)

Cooking Products Rulemaking 

Manufacturer Impact Analysis Interview Guide: Microwave Ovens

March 3, 2008
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1 KEY ISSUES 

The U.S. Department of Energy (DOE) is currently reviewing a set of efficiency levels for 

Microwave Ovens (MWOs). The efficiency levels are presented below as they apply to the 

single product class. In responding to this questionnaire, please refer to the energy factor (EF) 

values described below.

Table 1.1 Efficiency Levels (EF %)

Product 

Class Baseline EfficiencyLevel 1

Efficiency 

Level 2

Efficiency 

Level 3

Efficiency 

Level 4

Microwave 

Ovens 55.70 58.60 58.80 59.70 60.20

1.1 What are the key issues for your company regarding MWOs related to energy conservation 

standards and this rulemaking?

1.2 For the issues identified, how significant are they for each efficiency level?

1.3 How can we most effectively incorporate these issues in the Manufacturer Impact Analysis

(MIA)?

2 SHIPMENT PROJECTION AND MARKET SHARE

2.1 Would you expect your market share to change once standards become effective? Does 

your outlook change with higher efficiency levels?

2.2 How would you expect shipments to change for the industry as a whole as a function of 

standards and why?

3 CONVERSION COSTS 

An increase in energy conservation standards may cause your company to incur one-time 

capital and product conversion costs. DOE calls these conversion costs because they are 

the costs of changing your business to comply with new energy conservation standards.

3.1 What level of conversion costs do you anticipate incurring under the different efficiency 

levels? Refer to the tables below to provide your company’s estimates. Please provide 

additional qualitative information to help us understand the nature of your investments.

Table 3.1 MWO Conversion Costs

Standard Level Conversion Capital 

Expenditures

Product Conversion 

Expenses

Stranded Assets

Baseline (55.70)

Level 1 (58.60)

Level 2 (58.80)

Level 3 (59.70)

Level 4 (60.20)
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4 PROFITABILITY AND MANUFACTURING CAPACITY

One of the primary objectives of the MIA is to assess the impact of efficiency levels on industry 

profitability and changes in manufacturing capacity.

4.1 Does your company have any MWO manufacturing facilities located in the United States? 

How would you expect shipments to change for the industry as a whole as a function of 

standards and why? 

4.2 Do you expect any changes in your estimated profitability following the new energy 

conservation standard? If so, please explain why.

4.3 How would the imposition of new energy conservation standards affect your 

manufacturing capacity at your production facilities? Would any facilities be closed, 

downsized, added, or upgraded?

5 CUMULATIVE REGULATORY BURDEN

Cumulative regulatory burden refers to the burden that industry faces from overlapping effects of 

new or revised DOE standards and/or other regulatory actions affecting the same products or 

industry.

5.1 Are there other recent or impending regulations that MWO manufacturers face (from DOE 

or otherwise)? What level of investment are you expecting to incur as a result of these 

regulations?

5.2 Under what circumstances would you be able to coordinate any expenditures related to 

other regulations thereby lessening the cumulative burden?

6 DIRECT EMPLOYMENT IMPACT ASSESSMENT

The impact of new energy conservation standards on employment is an important consideration 

in the rulemaking process. This section of the interview guide seeks to explore current trends in 

MWO production employment and solicit manufacturer views on how domestic employment 

patterns might be affected by new energy conservation standards.

6.1 Would your domestic employment levels change under new energy conservation 

standards? If so, please explain how they would change.

6.2 Would the workforce skills necessary under new energy conservation standards require 

extensive retraining or replacement of employees?

7 CONSOLIDATION

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

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

Department are both interested in any potential reduction in competition that would result from a 

new energy conservation standard.
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7.1 In the absence of new standards, do you expect any industry consolidation? Please 

describe your expectations.

7.2 How would new standards affect your ability to compete?

7.3 Could new standards disproportionately advance or harm the competitive positions of 

some firms (e.g., small businesses)?
12A-5

12A.2 MICROWAVE OVENS (STANDBY POWER STANDARDS)

Cooking Products Rulemaking 

Standby Power Interview Guide: Microwave Ovens

INTRODUCTION:

The U.S. Department of Energy (DOE) is currently reviewing energy efficiency standards for 

cooking products. Of high interest are the standby power requirements of microwave ovens. As a 

result, the Department invites manufacturers to participate in this questionnaire to help the 

Department better understand the issues regarding standby power, as well as any potential 

impacts on consumers that standby power legislation could have. 

The Department tested 32 microwave ovens for sale in the United States within the past year. 

The sample included a wide range of input powers and cavity sizes to investigate cooking 

efficiency and standby power requirements. DOE subsequently published its findings at the 

December 17, 2007 Advance Notice of Proposed Rulemaking (ANOPR) meeting in Washington 

DC. Due to comments submitted to DOE during and after this meeting, the Department would 

like to solicit additional feedback from manufacturers. 

During testing, DOE noted that microwave ovens with cooking sensors tend to consume more 

standby power than those without cooking sensors. DOE also noted how display size and 

technology and the associated controller could influence standby power requirements. At the end 

of the testing cycle, every microwave oven was completely disassembled. DOE noted a wide 

variety of display types and cooking sensors, even if most other aspects of microwave 

construction have been largely standardized. This questionnaire will thus focus on the 

controllers, displays, and power supplies.

Cooking Sensors

DOE would like to understand why manufacturers incorporate cooking sensors into their 

microwave ovens, and factors influencing the choice of a specific sensor type from among the 

range of available technologies.

1.1 On a unit shipment-basis, what percentage of microwave ovens that you sell into the 

United States market feature cooking sensors?

1.2 Do you have any data on the percentage of consumers that use the sensor function? Is 

there any data available quantifying the energy savings associated with the use of a 

cooking sensor?
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1.3 What sensor technologies do you use for microwave ovens sold in the United States? 

What are the standby requirements of these sensors? Are there sensor technologies 

available that require less power in standby that can be applied in microwave ovens?

Displays

DOE also noted a wide range of standby power consumption based on the display technology. 

For example, displays based on vacuum-fluorescent displays tended to consume more power 

than comparable-sized displays based on light emitting diodes. DOE noted three display types in 

its market sample, consisting of light-emitting diodes (LEDs), liquid crystal displays (with or 

without LED backlighting), and vacuum-fluorescent displays.

1.4 What is the consumer utility associated with each type of display? Do consumers demand 

displays with specific technologies?

1.5 What are the power requirements for each type of display assuming a comparable size and 

general capability (complexity of the characters that a display can show)? What are the 

relative costs associated with each type of display?

Controllers and Power Supplies

While cooking sensors and displays consumed the most standby power, DOE also noted that 

controllers and the control boards also consume standby power. The Department recognizes that 

there may be tradeoffs between standby power consumption and the ability of control systems to 

tackle complex tasks.

1.6 What consumer utility is associated with microwave oven controllers? Could controller 

attributes or functionalities be impacted by reducing microwave oven standby 

requirements? If so, how?

1.7 Are lower-power versions of these controllers available? What control board design 

options are available for reducing standby power? At what cost? 

1.8 What is the range of efficiencies for controller power supplies? Can higher efficiency 

power supplies be implemented? At what cost?

Potential Standby Power Standard Levels

DOE surveyed foreign regulatory and non-regulatory programs, identifying Korea’s e-standby 

program, Australia’s standby program, and Japan’s Top Runner Program as pursuing reductions 

in standby power consumption through support for the International Energy Agency’s One-Watt 
12A-7

program to lower standby power consumption below 1 watt (W) for microwave ovensa, among 

others. DOE is also aware of zero-watt-standby microwave ovens in Japan that feature cooking 

sensors.

1.9 What design changes from current US products would be required if the following standby 

standard level were established?

• 4 W/h

• 2 W/h

• 1.5 W/h

• 1 W/h

• 0 W/h

• What would be the manufacturing cost impacts of these changes?

• Are there any impacts on consumer utility as standby power levels are lowered? If 

so, what are they, and at what standby power levels do they occur?

Standby Power Standards Manufacturer Impacts

DOE understands that by establishing standby power standards, manufacturer could potentially 

incur one-time capital and product conversion costs.

b

 DOE calls these conversion costs because 

they are the costs of changing your business to comply with new standby power standards. In 

addition, DOE would like to understand possible effects of new standby power standards on 

industry shipments, profitability, and manufacturing capacity.

What level of conversion costs do you anticipate incurring under different standby power 

standard level? Refer to the tables below to provide your company’s estimates. Please provide 

additional qualitative information to help us understand the nature of your investments.

 

a IEA Energy Information Centre, Standby Power Use and the IEA “1-Watt Plan”

http://www.iea.org/textbase/subjectqueries/standby.asp

b Capital and product conversion costs include capital conversion expenditures, product conversion expenditures and 

stranded assets. Capital Conversion Expenditures – One time investments in plant, property, and equipment (PPE) 

necessitated by an energy conservation standard. These may be completely incremental to existing PPE or they 

could involve replacement of existing PPE. Product Conversion Expenditures – One-time expenses in research, 

product development, testing, and marketing necessitated by an appliance energy conservation standard. Stranded 

Assets – Investments such as equipment or tooling that become obsolete as a result of new regulation.
12A-8

Table 1.1 MWO Conversion Costs

Standard Level Conversion Capital 

Expenditures

Product Conversion 

Expenses

Stranded Assets

4 W/h

2 W/h

1.5 W/h

1 W/h

0 W/h

1.10 How would you expect shipments to change for the industry as a whole as a function of 

standby power standards and why?

1.11 Do you expect any changes in your estimated profitability following new standby power 

standard? If so, please explain why.

1.12 How would the imposition of new standby power standards affect your manufacturing 

capacity at your production facilities? Would any facilities be closed, downsized, added, 

or upgraded?

Standby Test Procedure

As part of the analysis, DOE reviewed the existing DOE cooking efficiency test procedure and 

possible standby test procedures that could be incorporated. For standby testing, DOE is 

considering adopting by reference the IEC 62301 standby test procedurec

. 

1.13 Do you currently conduct microwave oven standby power testing? If so, which test 

procedure do you use?

1.14 How do you feel about the incorporation of IEC 62301 to measure standby with the 

provision that a 12-hour (or possibly 24-hour) test be performed with the clock set to a 

specific starting time?

 

c See http://iec.org for further details